Privacy Policy

 

Purpose of privacy Policy

This privacy policy (the “Privacy Policy” or the “Policy”) aims to give you information on how Starscream Limited collects and processes the information and personal data that have been provided by You to Us and that We will use in order to manage the relationship that We have with You as a Player on Scatters .

               

All the data processing performed by Starscream Limited will be in line with regulation EU (2016/679) of the European Parliament and of the council of 27 April 2016 on the protection of natural persons with regard to the processing of the personal data and on free movement of such data, and directive 95/46/EC (General Data Protection Regulation). The company has appointed a Data Protection Officer (DPO). If you have any questions about this Privacy Policy, including any requests to exercise your rights as a data subject, please contact the DPO on: [email protected].

Only Adults (18+) Are Allowed to Use the website

It is prohibited for individuals under the age of 18 to use, play or utilise in any manner our Website. We will use the data provided to us to verify your age.

 

Definitions

This Policy is issued on behalf of Starscream Limited. The terms “Company”, “we”, “us” or “our” in this Privacy Policy refer to Starscream Limited/or the relevant company in the group responsible for processing your data., having it’s registered office in Saint Lucia, with registration number 2023-00007, licensed and regulated in virtue of an interactive games of chance or mixed chance and skill Gaming Services license numbered 00932 issued by the Kahnawake Gaming Commission.

All references to “Player”, “end user”, “you”, “yours” and/or “your”, in this Privacy Policy refers to any user which accesses and plays on Scatters.

Any reference to “Games” or “Game” in this Privacy Policy refers to the gaming products offered on Scatters.

“The data controller” is a person, company, or other body that determines the purpose and means of personal data processing (this can be determined alone, or jointly with another person/company/body).

“Data processor” is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Personal Data” are any information which are related to an identified or identifiable natural person

“GDPR” or “the Regulation” – General Data Protection Regulation (2016/679)

 

The types of information processed by Scatters

 Identity Data: refers to First and Last Name, Date of Birth, Place of Birth, Residential Address (including City, ZIP Code and Country), Nationality, Identity Reference Number or Passport Number, Age

 Contact Data: Username, Phone Number, Postal address and Email Address

 Customer Support Correspondence: When you ask for assistance from our Scatters Customer Support team through Live Chat or the Contact Form, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game play or activity on the Website, and your user ID number.

 Account Limits: You may choose to set limits on your accounts including time, bet and loss limits and daily deposit limits (“Limit Data”).

 Financial Data: You might be required to provide the following “Financial Data” – card number, expiry date, security code.

 Self-Exclusions: You always have this option if you decide to take a break from gambling, whether you just want to restrict your play or if you feel it becomes something other than fun and entertainment. Once you set a Self-Exclusion you will not be able to access it before the chosen time period expires, your account will be subject to your Self-Exclusion restrictions on the brand you have set the Self-exclusion on.

 Take a Break: You can choose to block access to your account for a period between 24 hours, 7 days, or 30 days. Once you set this limit on your account you will not be able to access it before the chosen time period expires.

 Know Your Customer: We collect your information when applying our Know Your Customer procedures in line with our Terms and Conditions. These procedures allow us to verify the identity of our customers in line with our obligations under Anti-Money Laundering and Funding of Terrorism Laws. We generally collect the following information for these purposes, however depending on the circumstances of the relationship, we reserve the right to request and collect additional information. (“KYC Data”):

o   Valid ID (Passport, National ID Card or Driving Licence)

o   Utility Bill or other proof of address document (cannot be older than 3 months)

o   Bank statement (with clear visibility of your name and address, IBAN and BIC) (“Bank Account Data”)

o   Source of Wealth and Source of Funds information, and back-up documentation when necessary.

o   Data relating to your political status (“PEP Data”).

 Account Data: This will be the information we are collecting and processing when You are using of Your Account on Scatters:

Activity Logs - playing history and activity logs including login session activity: start, end, end reason, start balance, start bonus, end balance, end bonus balance, game sessions, game rounds, total bets, total wins, income and IP address;

Account Balance – total, real and bonus balance, pending withdrawals, pending deposits, reserved bets, income, total deposits, withdrawals, bonuses, average deposit and bonus, and maximum balance;

Game Analytics – recently played, most played, favourite provider, biggest win, most rounds per session, average income per session, average rounds per session, free rounds.

Technical Data including:

your Internet Protocol – IP (address used to connect your computer to the internet) and device, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Information about your visit including the full Uniform Resource Locators (URL), games you played and duration of each game and page, page interaction information (“Usage Data”);

Information received from cookies including details of your visits to this site for traffic overview, games you played, duration on each game and in general your behaviour on the website. This information is collected in line with our Cookie Policy (add link) (“Cookie Data”).

Public Sources Data, that represents all the publicly available information from Third Parties or Publicly Available Sources, usually via Google searches.

Marketing communication data: This will include your preference in receiving marketing materials from   Scatters, as well as updates regarding content and new promotions Choosing to opt out from receiving marketing communication will not affect the rest of your relationship with Scatters. If you consent to receiving this information, we will process your name/surname/email address/phone number.

Other data: As a rule, Scatters does not collect or process any kind of sensitive personal data related to:

o   racial or ethnic origin;

o   Political opinions;

o   Religious or philosophical beliefs;

o   Trade union membership;

o   Health data;

o   Data concerning an individual’s sex life or sexual orientation;

In case you chose to share any information regarding the above categories (via chat, email or call with our customer support for responsible gaming purposes), we will make note of your request and, if so decided, we might close the account for your own safety, as well as erase any sort of documents provided to us regarding any of the above mentioned Other data.

If there will be any changes in the type of information that we are collecting and processing, this Privacy Policy shall be updated and you will be informed.

If you have any questions related to any kind of data that we process, please contact our DPO on: [email protected]

 

Purposes of Collecting and Processing the Information:

The main reasons Scatters needs to collect and process this data is so we can offer you  a safe, smooth, efficient, and customized experience, as well as for legal and regulatory compliance purposes, including as necessary: to respond to governmental or regulatory entities requests; to comply with our legal obligations under current Anti-Money Laundering laws and Regulations and any applicable current local and international Tax laws; to identify misuse of our systems and any fraud or other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations

 The information collected will be used for the following purposes:

 

Type of data	Lawful basis for processing	Purpose for which the data will be processed
Identity Data Contact Data Public Sources Data	Performance of a contract with you   Complying with our legal obligations	Registering you as a user to create your account and allow you to play games in order to provide you with gaming services in line with our contract with you (see Terms and Conditions) and performing our obligations arising from the Terms and Conditions including contacting you where contact is necessary to perform our obligations towards you, e.g. customer support matters Complying with our legal obligations under Anti-Money Laundering and gaming laws
Financial Data Identity Data Contact Data Bank Account Data	Performance of a contract with you	To process your deposit/withdrawal of funds and payouts in relation to Games played on our website and in accordance with the Terms Conditions.
Identity Data Contact Data Technical Data Account Data Usage Data Cookie Data	Legitimate interests	Our legitimate interest for administering, protecting and developing our business and the website, provision of administration and IT services, network security, to prevent fraud, including through troubleshooting, data analysis, testing, system maintenance, and support
Identity Data Contact Data Technical Data Usage Data Account Data Cookie Data	Legitimate interests	Our legitimate interest to see how customers use our products in order to develop them and to grow our business and form our marketing strategy and to deliver relevant website content and advertisements to users
Technical Data Usage Data Cookie Data	Legitimate interests	Our legitimate interests to use data analytics to improve our website, products and services, customer relationships and marketing strategy and to define types of customers for our products, to keep our website updated and relevant, and to develop our business
Identity Data Contact Data Technical Data Usage Data Account Data Cookie Data	Consent	Marketing products or services which might be of interest to you Contacting you with bonuses schemes and promotional offers Contacting you with game updates.
Account Data Usage Data Identity Data	Consent	Collecting information to help improve the use of our website, Games and customer experience through participation in surveys and/or contests
Identity Data Contact Data	Complying with our legal obligations	Notifying you of changes to this Privacy Policy in line with our obligations under GDPR
Account Data Usage Data Identity Data	Legitimate interests	Our legitimate interest to develop our products, grow our business and improve customer relationships by providing game leader boards and promote in-game player achievements
Account Data Usage Data Identity Data	Legitimate interests	Our legitimate interests to solicit input and feedback in order to study how our customers use our products in order to develop and improve our Games and services and customise your user experience and customer relationship
Identity Data Contact Data Technical Data Usage Data Account Data Bank Account Data	Complying with our legal obligations	Complying with our legal obligations under money laundering and gaming laws to prevent money laundering, fraud and collusion by analysing and studying player behaviour, communications, depositing and player patterns
Limit Data Identity Data Contact Data Technical Data Usage Data Account Data	Complying with our legal obligations	Complying with our legal obligations under gaming laws for the allowance of the setting of player limits and processing of data to ensure that player and website do not exceed set limits
Self-Exclusion Data Identity Data Contact Data Technical Data Usage Data Account Data	Complying with our legal obligations	Complying with our legal obligations under gaming laws for the allowance of the setting of self-exclusions and processing of data to ensure that player and website abide by such exclusions
KYC Data Public Sources Data Bank Account Data PEP Data	Complying with our legal obligations	Complying with our legal obligations under anti-money laundering and gaming laws to verify your identity and establish source of wealth, source of funds and politically exposed person status.

 

Scatters has the legal obligation to keep a copy of your gambling history and to employ measures to detect and identify problem gaming using analytical tools and/or behaviour monitoring systems, as well as the legal obligation to take steps to prevent further harm if such an issue was identified. We will also use such data to initiate customer interaction where we have concerns that your behaviour may indicate problem gambling.

 

Scatters will also use and study your Usage Data, Technical Data and Account Data to target marketing activities for persons of the same age as you. This activity includes the processing of your age. We consider this to be in our legitimate interests to develop our products, form our marketing strategy, deliver website content and advertisement to users, to keep our website updated and relevant and overall to provide a better customer experience to our players. You have a right to object to such processing (see section Rights and Data Subject Requests).

Scatters  will further process your IP address in order to confirm your location, in line with our verification requirements under anti-money laundering laws, and to ensure that you do not have multiple accounts on our website in line with our obligations under gaming laws.

Scatters  might sometimes process your data automatically, with the aim of evaluating certain personal aspects (profiling). We use profiling for the purposes of complying with our anti-money laundering and funding of terrorism obligations. As a rule, we do not make decisions based solely on automated processing (as defined in Article 22 of the GDPR) to establish and implement the business relationship, as there is always an element of human involvement in such decisions. If we use these procedures in individual cases, provided this is allowed by law, we will inform you of this separately.

 

Data processing

All the collected data will only be used in accordance to current legislation.

Generally, this would be in the following circumstances:

o   When we need to in order to be able to provide you with gaming services in line with the contract we have with you or are about to enter into with you (please see our Terms Conditions);

o   Where it is necessary for our legitimate interests and your interests do not override those interests;

o   Where we need to comply with an obligation under law including Anti-Money Laundering and Funding of Terrorism Laws, and gaming laws.

We do not generally rely on your consent as a basis for processing your personal data other than in relation to the sending of marketing communications. You are not obliged to give your consent and refusing to give your consent will not lead to any detriment to you. You have the right to withdraw your consent at any time by ticking the opt-out option on your profile. You may also opt-out by contacting our DPO at any time or clicking the ‘unsubscribe’ link in any marketing material sent to you.

 

Credit card information processing:

Scatters does not collect your credit card and financial information, as the payment process is done through our payment gateway providers.

Our payment gateway providers use secure server software (SSL - SSL Certificate enables encryption of sensitive information during online transactions), which is the industry standard and among the best software available today for secure commerce transactions.

We do not have access to any information about the card or your bank account, other than the ones you provide for KYC verification purposes, that Scatters will only process in order to comply with legal obligations.

 

Disclosing your Personal Data

Your personal data will be disclosed to certain third parties set out below for the purposes listed in the table above.

Scatters shall only disclose your personal data to third party data processors or consultants where lawful to do so including where we:

• Need to in order to provide you with the service;
• Need to in order to obtain services from third parties in order to provide you with the service;
• Have a legal duty to do so, e.g. assisting with detecting and preventing fraud and crime or regulatory reporting or in relation to problem gaming;
• Have a legitimate interest for the purposes of litigation or asserting and defending our legal rights and interests;
• Have a legitimate business interest to do so for managing risk;
• Have been instructed by you to do so;
• Are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena);
• Believe that Scatters and its content is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud or money-laundering protection;
• Have a reasonable and good faith belief that there is an emergency that poses a threat to the health, life and/or safety of you, another person or the public generally; and
• In order to protect the rights or property of Starscream Limited., including to enforce our Terms and Conditions.

 

Scatters will disclose your personal data to third parties which include:

• Regulators and other authorities as may be required by law or by courts of law;
• Law enforcement, government, courts, dispute resolution bodies, regulators and any party appointed or requested by regulators to carry out investigations or audits of our activities;

We will also disclose your personal data to other group entities as identified above.

Scatters will disclose your personal data to external service providers and third-party vendors, that act as data processors on behalf of Starscream Limited. Your information will always be secure as we obtain guarantees from such third parties to ensure that they process your data in line with the GDPR, to keep your information secure and not to use it for their own purposes. We shall only disclose the personal data which is necessary for such third parties to deliver the required service.

The third party processors include:

• MaxMind (provides IP intelligence to locate visitors and show them relevant content and ads, perform analytics, enforce digital rights and efficiently route internet traffic)
• http://Customer.io (email newsletter platform)
• Payment IQ (payment gateway provider)
• Professional advisors including lawyers, compliance officers, auditors and insurers;

 

Scatters may also disclose your personal data in accordance with and to the extent allowed and/or required by the data privacy current laws & regulations.

In the cases when you are disputing payments or losses charged on your account, Scatters shall disclose your KYC Data, Bank Account Data, Usage and Account Data to your bank to settle the dispute.

 Relevant authorities, employees of Starscream Limited., in particular Customer support agents and other employees with relevant roles shall also have access to your personal data for the purpose of executing their duties and providing you with assistance and the service.

 

Data Transfers

We will only transfer your data to the European Union or to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

In case US processors are used (depending on the services you are using on Scatters), We shall only transfer data to providers based in the US after making sure that all appropriate safeguards have been implemented and that the same protection is afforded / same standards are applied as would be within the EEA. We will only share the data with processors that are registered with Privacy Shield (an agreement between the EU and US allowing for the transfer of personal data from the EU to US, only to providers that are compliant to the European Data Protection standards).

 

 Marketing

Scatters would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, but decide you want to stop receiving the information and withdraw your consent, you have the right to opt out at any time from receiving such marketing material.

You may opt-out at any time as set out below: 

Email [email protected] and say that you would like to opt-out 

Tick the ‘opt-out’ option on your profile; 

Press ‘unsubscribe’ on any marketing material received.

 

Withdrawing your consent will not lead to any detriment to you or the relationship with Scatters.

 

Security of data

Scatters is committed to ensuring that your information is secure. We have implemented measures and procedures to prevent unauthorised access or disclosure of your information. Likewise, we seek to keep confidential all information you send to us.

This site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You should be able to see the padlock symbol in the status bar on the top left-hand corner of the browser window. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any personal data breach and will notify you and the relevant regulator of a breach where we are legally required to do so.

 

Data Retention

Scatters will only retain your personal data for as long as necessary to fulfil the purposes for which they were collected.

All data will be maintained for the duration of your relationship with us.

Following the termination of the relationship, from the moment the termination took place, the following data will be retained in the following manner:

 

 

Data Type	Retention Period	Retention Basis
Identity Data, Contact Data, Technical Data, Usage Data, Account Data, KYC Data, Public Sources Data, Self-Exclusion Data and Financial Data	Five years	Legal obligation Personal data may be held longer where required for a legal investigation or litigation or where there is a reasonable suspicion that a player has been involved in criminal activity by virtue of his/her gaming activities The five years’ retention period for self-excluded players shall begin to run from the lapse of the self-exclusion period.
Contact Data	Five years	Legitimate interest where needed for the establishment, exercise or defence of legal claims, disputes, and judicial investigations
Account Data	Ten years	As required by the income tax laws to abide with our obligations thereunder
Record of Player Interactions in relation to Problem Gaming	Up to five years unless required further to fulfil other obligations /retention periods	As required by gaming laws
Records of indefinite self-excluded Players confirming Problem gaming	Indefinite	As required by gaming laws

 

Rights & Data Subject Requests

 Scatters, through its employees and collaborators, is committed to help You in every way that it can with understanding your data privacy rights and – if you so choose – help you make use of these rights. They are:

 Right to Transparent Information – you have the right to be informed in a clear manner on any personal data pertaining to you that may be processed by us. Such information is being provided to you in this Privacy Policy. If you have any questions or concerns pertaining to your rights, you are always encouraged to contact our Data Protection Officer on [email protected].

 Right of Access to Information – you have the right to request confirmation from us whether personal data relating to you is being processed, why and how it is processed, as well as request access and clarifications about such personal data.

 Right to lodge a request, contact our DPO/DPR on the details above. If you would only like to receive information on a specific category of data, please indicate such category e.g. ‘Identity Data’ or ‘Contact Data’.

 Right to Rectification – you have the right to request from us the rectification, without delay, of any inaccurate personal data pertaining to you.

You may change your data in the following manner:

• Through your Profile: by accessing the ‘Account Details’ page on the platform;
• By email: by emailing: [email protected]

Please note that your username may not be changed.

 

Right to Be Forgotten – you have the right to request from us the erasure of all personal data pertaining to you without delay, where the data has been processed with your consent as the basis for processing and/or where the processing is no longer lawful.

Scatters will also remove the information that was modified as per your right of rectification (once the new provided data has been verified).

Please know that when you exercise your right to be forgotten, Scatters will still keep the information that We are required to keep by the current legislation (as mentioned at 4. Purposes of Collecting and Processing the Information and 11. Data retention).

 Right to Restrict Processing – you have the right to request from us the restriction of processing if: processing is unlawful; you are contesting the accuracy of data; the data is no longer required by the controller but you require us to keep it in order to establish, exercise, or defend a legal claim; or if you have previously objected to the processing. Once data is restricted, we cannot process it in any way other than to store it unless: we have your consent; or if it is required for the establishment, exercise, or defence of legal claims; or if it is for the protection of the rights of other persons; or if it is for reasons of important public interest.

Please note that this does not extend to personal data which is inferred or derived by us.

 Right to Data Portability – you have the right to receive from us personal data which you have provided to Scatters and to transmit that data to another controller without hindrance from us, in a commonly used format. This right applies where the data is being processed with your consent, or for the performance of a contract, and when processing is carried out by automated means.

 Right to Object – you have the right to object at any time to the processing of personal data pertaining to you where the processing is based: on our legitimate interest; or the performance of a task in the public interest/exercise of official authority; or on direct marketing (including profiling); or on processing for purposes of scientific/historical research and statistics.

You also have the right to object to profiling based on our legitimate interests or on the performance of a task in the public interest/exercise of official authority.

You also have the right to object to automated decision making, including profiling, and therefore to not be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects or significantly affects you.

 Right to withdraw consent – you have the right to request Scatters to stop processing your information for all purposes based on consent (as shown in 4. Purposes of Collecting and Processing the Information).

You may withdraw your consent at any time, and the methods you ca do that are:

Email [email protected]  and say that you would like to opt-out

Tick the ‘opt-out’ option on your profile;

Press ‘unsubscribe’ on any marketing material received.

Withdrawing your consent will not lead to any detriment to you or the relationship with Scatters

 

Data subjects requirements

 When making a request pertaining to your Data Protection rights, Scatters  might need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Scatters has a legal obligation to keep your data updated, and for this reason you may be asked about changes to your personal data at various intervals. You may help us in this process by informing us whenever your data has changed (and use your right to rectification). You are entitled to ask us to modify your personal data if you ascertain that the personal data which we hold is not accurate or updated.

Since Scatters requires your data for the purposes of accepting and carrying out a relationship with you and fulfilling our contractual and legal obligations, should you choose not to provide us with such data, we might not be in a position to enter into a business relationship with you and fulfil the Terms and Conditions applicable between us and our obligations thereunder.

Anti-money laundering obligations require us to verify your identity at certain intervals, for example, by means of your passport and to record your personal details. In order for us to be able to comply with this statutory obligation, we will ask you to provide us with the necessary information and documents and notify us without undue delay of any changes that may arise during the course of the business relationship.

Should you choose not to provide us with such data, we might not be able to enter into or continue our business relationship and fulfil the Terms and Conditions applicable between us and our obligations thereunder as we would be in breach of our anti-money laundering and funding of terrorism obligations.

Reference is made to the Terms and Conditions whereby you have undertaken to provide us with certain personal data, including documentation, and to inform us of any changes to such data. In these circumstances, the provision of personal data is a contractual requirement.

You are never obliged to provide us with any kind of data that will have no other processing legal basis other than your consent (as shown in 4. Purposes of Collecting and Processing the Information).

 

Processing Data Through Consent

The processing of data highlighted above, with the exception of processing for marketing purposes does not require your consent as it relies on legal basis.

We may however also request to process additional personal data on the basis of your consent. You are not obliged to give us your consent. Once you have granted us consent to the processing of personal data for an identified specific purpose, the processing becomes lawful on the basis of such consent. You can withdraw your consent at any time. Withdrawal of consent does not affect the legality of data processed prior to withdrawal.

You can withdraw your consent at any time by: [email protected]

At the time of withdrawal of consent, we may determine that there is another legal ground allowing us to process your data and we shall inform you accordingly.

 

Privacy Policies of Linked Website and Advertisers

Scatters may contain reference and linked third party Website and advertisers. We are not responsible for the privacy practices or the content of such Websites. By clicking on those links you may be directed to those Websites which are not under the control of Starscream Limited and will need to comply with those respective third party privacy policies.

If you have any questions about how these other Websites use your information, you should review their policies and contact them directly.

 

Surveys/Contests

From time-to-time, we collect information via surveys or for participation of any contests organised by us on Scatters. Participation in these surveys and/or contests is completely voluntary, and any information provided to us will be provided on the basis of your consent. You may choose whether or not to participate and thereby disclose any information about you. There will be no detriment towards you for not participating in such surveys and contests. You may wish, and if so have the right to revoke such consent at any time.

By agreeing to participate in the survey, you agree to provide us with any such required information.

Survey information will be used only for purposes of improving the use and customer satisfaction of Scatters.

 

Changes to Privacy Policy

This policy was updated on 13.10.2023.

We retain the right to change our Privacy Policy at any time in case update is needed. Any new change shall apply from the date we publish them.

Any further updates will be listed on this web page, so please check back periodically.

 

Contact Us

If you are unhappy with the way in which we have processed your personal data, or have any questions regarding anything related to this privacy policy, you may contact our Data Protection Officer on [email protected]

You also have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner, or other supervisory authority of your habitual residence, place of work or place of alleged infringement, and the right to seek an effective judicial remedy before courts.

 Starscream Limited.