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Privacy Policy

During everyday business activities, Energy Casino Ireland collects and manages various types of information relating to identifiable persons, including details about you.

This Privacy Policy outlines how we collect, store, manage, process, and share personal information, including sensitive details and other non-personal information that Energy lawfully receives from you when you access or use Energy services.

By accessing Energy services, you agree to allow us to collect, store, manage, process, and share your personal information as described in this Privacy Policy. Should you find any part of this policy unacceptable, we ask that you discontinue use of all Energy services and avoid any interaction with our business operations.

We recommend reading this document thoroughly and carefully, together with our Terms and Conditions.

Throughout this document, 'us', 'we', 'our' and 'Energy' mean Probe Investments Limited (Data Controller).

DATA CONTROLLER

Your personal information is controlled by Probe Investments Limited, a company registered under the legal framework of Malta, an EU member state. Our registration number is C51749 and our registered office is located at No. 2, TRIQ GERALDU FARRUGIA, ZEBBUG, ZBG 4351, Malta. You may reach us here. For matters specifically concerning your Personal Data or if you require further clarification, please contact our Data Protection Officer at [email protected].

WHAT WE COLLECT FROM YOU

While you engage with our services, we may gather personal information, which may include but is not limited to:

  • Your complete name (first and last).
  • Your electronic mail address.
  • Internet Protocol address.
  • Telephone number.
  • Physical address details.
  • Birth date.
  • Gender identity.
  • Technical details regarding devices used to access our services or related technical specifications.
  • Details on how you interact with Energy services, such as timing, methods, and locations of service usage.
  • Information gathered during account registration, profile creation or modification, preference settings, service sign-ups, or transactions made via the services.
  • Details regarding your deposits and withdrawals.
  • Any additional information you submit through our services.
  • Any extra information you choose to share when contacting us (this may include special categories such as racial or ethnic background, religious or philosophical views, intimate life details, sexual orientation, political stance, trade union affiliation, health information, and genetic or biometric data).
  • During Customer Due Diligence procedures and as required by applicable law, Energy may request supplementary information or documentation from you.
  • Information obtained from third party data providers (typically private firms working with public data sources) for purposes of preventing money laundering, combating terrorism financing, and supporting responsible gaming practices.
  • Information gathered through searches of publicly accessible platforms including Facebook, LinkedIn, Twitter, Instagram, Google search, and similar sources.

HOW WILL WE USE THIS DATA?

Energy values your privacy and commits to safeguarding your personal information while processing it according to relevant legal requirements, particularly:

  • The Maltese Data Protection Act (Chapter 586 of the Laws of Malta) together with related subsidiary legislation;
  • The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons regarding the processing of Personal Data and the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) - the 'GDPR';
  • Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 addressing the prevention of using the financial system for money laundering or terrorist financing purposes (4th EU AML Directive);
  • Gaming Act, 2018 (Cap. 583 of the Laws of Malta);
  • Any additional data protection laws or instruments applicable in our operational territory or market, as relevant by virtue of territorial or extra-territorial application.

Supplying information for these purposes is mandatory. Processing data under these legal frameworks serves identification and verification needs (to confirm your age and other personal details as necessary and mandated by law), fulfills responsible gambling duties placed on licensed operators, prevents anti-money laundering activities, and completes compliance procedures required of Energy.

Identity Verification and KYC Procedures

As part of our dedication to maintaining a secure and compliant gaming platform, we may employ sophisticated tools to confirm the legitimacy of identity documents submitted during Know Your Customer (KYC) verification. We examine the identity documents you upload (such as ID cards, passports, utility bills) to authenticate them and identify potential fraud. This may encompass document metadata (such as document type, issuing country), visual content and security elements, and indicators of tampering or manipulation (such as artificially generated or falsified content).

Throughout KYC verification, certain documents may be examined using AI-driven tools to assess their effectiveness in strengthening our KYC procedures. This processing is essential to meet our legal requirements under Anti-Money Laundering legislation and Gaming regulatory standards, which mandate identity verification and fraud detection (Article 6(1)(c) GDPR).

Contractual Performance

Your information may also be processed when needed to deliver services to you as part of fulfilling our contractual agreement with you, specifically:

  • To deliver services provided through the Energy website operation, to facilitate participation in interactive features, tournaments, and promotional activities generally;
  • For setting up and administering your user account;
  • To arrange competitions, promotional offers, and bonuses (including participant communication, entry assessment, prize distribution, tax payment, etc);
  • For handling online payment transactions;
  • To inform you regarding modifications to our services;
  • To maintain communication with you.

Supplying this information is voluntary but essential for using our services. Without it, access to our Website will be unavailable.

Marketing and Personalization

You may also provide consent for us to process your information for additional purposes, namely for marketing activities, to deliver customized marketing messages and advertising campaigns that Energy presents on its website and external websites and/or services using the combined information we have gathered about you concerning the services you request from Energy or that might appeal to you. Energy may send you electronic messages or show pop-up notifications regarding Energy services and updates. Whenever your consent for processing is needed, we will explain the extent, character, and objectives of the processing and request your consent. Providing this information is voluntary.

Legitimate Interests

Energy also processes information for its legitimate purposes, assuming these interests do not override your rights, freedoms, and interests. This includes statistical analysis, improving or adjusting Energy services and policies, or protecting the company from claims or disputes.

Profiling and Automated Processing

Energy may profile your personal information, meaning Energy can utilize the gathered data to customize communications directed to you.

Energy does not apply algorithms to your profiled information to reach automated conclusions that could impact your individual rights or any rights stemming from the agreement between Energy and you. For instance, Energy does not generate automatic offers based on your gaming behavior.

Nevertheless, Energy is required by legal and license requirements to observe its players to recognize individuals who may be facing, or are vulnerable to developing gambling difficulties. Using data characterizing individual players, a specialized algorithm supplies us with an estimated likelihood of gambling addiction, enabling Energy's staff to engage with such players to provide assistance or support. Decisions derived from predictions are not executed automatically without human involvement.

FOR HOW LONG DO WE KEEP YOUR DATA?

We will retain your personal information only for the duration reasonably required to fulfill the purposes and legal requirements described in this Privacy Policy.

Energy may retain your personal information for a specified period following the termination of your customer relationship, owing to legal and license requirements placed upon us. Following this period, Energy will either securely delete or anonymize your data. If deletion proves impossible (because the information has been preserved in backup archives) we will securely store, isolate, and protect your data from further use until deletion becomes feasible.

The standards we apply to establish what is 'necessary' depend on the characteristics of the specific personal information in question. Because of AML requirements placed upon us, we will preserve your personal information for up to five years following your account closure, final login, or transaction if your account remains open but inactive, unless otherwise mandated in relevant legislation. Notably, several exceptions exist to this retention timeframe:

  • If you have permanently self-excluded from any of our services, we will preserve this data indefinitely;
  • If you are subject to investigation or where we have detected possible fraudulent or other criminal conduct, we may keep your personal information for extended periods and as necessary to assist relevant authorities;
  • If legal proceedings arise, we will preserve your personal information for at least the complete duration of the proceedings and as may be necessary to defend our interests in any subsequent claim or action stemming from the same matter.

MARKETING PURPOSES

If you have registered for services provided by us, we may deliver direct marketing regarding additional services provided by us or our Group or other casino operators, assuming you have granted your consent to receive such marketing. Certain personal information may be processed by our external marketing partners to enable us to reach you via telephone, electronic mail, push notifications, SMS, and to notify you about prizes and/or gifts from suppliers, etc.

Consent for this processing may be modified entirely or partially at any time through 'My Account' settings. If you require additional details about this, contact us here.

All marketing communications from us will contain guidance on how to decline receiving that particular type of marketing communication. Your request may take up to 72 hours to be completely implemented.

We may also utilize data you supply to us to display relevant advertising and customized content regarding our services on specific third party social media platforms accessible to us through relevant social media websites (such as Facebook, Twitter). If you prefer not to view these advertisements, you may adjust your settings on the social media platforms. If you do not want us to distribute your information with social media platforms, you may contact us directly.

PROCESSING OF THIRD-PARTY PERSONAL DATA (PAYMENT METHOD HOLDERS)

In certain situations, we may process personal information concerning individuals who are not our registered customers but whose payment credentials have been utilized on a player's account (for example, cardholders or account proprietors). This usually happens when a player tries to make a deposit using a payment method registered to another party, which violates our Terms and Conditions.

Categories of Data Collected

We may gather and process the following types of information related to third-party payment method holders:

  • Identification details (such as complete name, birth date, ID document);
  • Payment card information (such as cardholder name, masked card number);
  • Connection to the registered player, if disclosed.

Purpose of Processing

We process this information for the following reasons:

  • To confirm and prevent unauthorized or fraudulent payment method usage;
  • To fulfill legal requirements under anti-money laundering (AML) and responsible gaming regulations;
  • To protect our legitimate interest in preventing fraud and maintaining the integrity of our platform.

Legal Basis

Legal foundations for processing (according to the GDPR) are Article 6(1)(c) – Fulfilling a legal obligation (such as AML regulations) and Article 6(1)(f) – Legitimate interests pursued by the controller (such as fraud prevention, security).

This information is supplied to us by our customers during service usage, typically as part of a payment verification procedure.

Retention and Sharing

Personal information of third-party payment method holders is kept only for the duration necessary to accomplish the purposes described above, and no longer than mandated under applicable legislation, particularly AML regulations (typically up to 5 years from the conclusion of the customer relationship).

The third party's personal information may be disclosed to regulatory bodies, financial institutions, or payment service providers if mandated by law or as part of our fraud prevention and AML requirements.

Third Party Rights

As a data subject, you as a third party possess certain rights under the GDPR, including the right to access your personal information, request correction or deletion, object to or restrict processing, and to lodge a complaint with a supervisory authority. To exercise any of these rights, or to receive additional information about how your information is processed, you may contact us at [email protected].

CHATBOT USAGE

Energy may deploy an automated chatbot to improve user experience by helping with common questions and issues.

During initial engagements, the chatbot may gather non-personal data such as the category of question posed and general usage information. This data is utilized to enhance the functionality and effectiveness of the chatbot.

The chatbot may ask for personal details like your electronic mail address to deliver more customized support and follow-up on particular inquiries. Personal details are only gathered when expressly provided by the user and with the user's consent.

Prior to gathering any personal details, the chatbot will notify you of the particular information it plans to collect and the reason for its collection. You will be requested to grant explicit consent by affirmatively opting in.

You have the right to revoke your consent at any moment. To revoke consent, please contact us via [email protected] or follow the guidance provided by the chatbot.

Gathered personal details will be utilized exclusively to provide assistance and support as requested by the user. Your electronic mail address will be used to follow up on your inquiry and ensure you receive the necessary support.

Personal information gathered by the chatbot will be kept only as long as required to accomplish the purpose for which it was gathered or as mandated by law.

TELEPHONE CALLS

Telephone communications to and from our Customer Contact Centre may be recorded for training and security reasons, together with the resolution of any inquiries arising from the service you receive.

SECURITY MEASURES

We employ various security measures to guarantee the confidentiality of your personal details, and to safeguard your personal details from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

  • Password-secured directories and databases;
  • Secure Sockets Layer (SSL) technology to guarantee that your details are fully encrypted and transmitted across the Internet securely;
  • PCI Scanning to actively shield our servers from hackers and other vulnerabilities;
  • All financially sensitive and/or credit details are transmitted via SSL technology and encrypted in our database;
  • Only authorized staff are granted access to your personal details, and these personnel are obligated to treat the data as highly confidential;
  • The security measures will be reviewed periodically in consideration of new and relevant legal and technical developments.

TWO-FACTOR AUTHENTICATION

The two-factor authentication provides additional security to your Energy account.

Any login attempts to your Energy account from a new country will be accompanied by a 6-digit authentication code (token) delivered to your mobile telephone number or electronic mail address supplied upon registration.

You will be obligated to enter the generated code (token) during your login attempt. To do so, simply input the code from your mobile SMS or electronic mail into the field "Token". This procedure will safeguard your account from unusual activity or potential third-party access by preventing unknown individuals from gaining access, even if they possess your password. If for any reason you do not receive the verification token, please contact our Customer Support.

COOKIES

Energy and its third-party partners (advertising and analytics partners) employ various technologies to gather information, such as cookies and web beacons and other technologies to enhance and customize services, websites and your experience; to permit you to access and use the services without re-entering your password; to understand usage of services and the interests of our customers; to establish whether an electronic mail has been opened and acted upon; and to present you with advertising relevant to your interests.

Strictly Necessary Cookies

These cookies and similar technologies remember selections you make, such as language, search parameters or remembering you have logged in. Energy uses these cookies to deliver you a tailored experience more suitable with your selections.

Performance and Analytics Cookies

These cookies and similar technologies gather data on how users engage with the services and enable Energy to enhance how these services function. Energy uses Google Analytics cookies to help understand how visitors arrive at and navigate our products and website to identify areas for enhancement, such as navigation, user experience, and marketing campaigns.

Targeting or Advertising Cookies

These cookies gather data about your browsing patterns in order to make advertising relevant to your interests. They remember websites you have visited, and that data is shared with other parties such as advertising technology service providers and advertisers.

Social Media Cookies

These cookies are employed when you share data using a social media sharing button or 'like' button on our websites, link your account or engage with our content through a social media website. The social network will record such information, and it may be linked to targeting/advertising activities.

Managing Cookies

To opt out of our cookies policy, you may instruct your browser by modifying its options to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our services. Energy and its third-party partners also gather data using web beacons (also referred to as tracking pixels). Many browsers include their own management tools for removing HTML5 local storage objects. Please note that you will not be able to opt out of any cookies or other technologies that are strictly necessary for the services.

SHARING AND PROCESSING YOUR PERSONAL DATA

Energy securely distributes information with third parties that assist Energy in operating, providing, enhancing, integrating, customizing, supporting and marketing its services. Energy will guarantee that all relationships involving the processing of personal information are governed by a documented contract that includes the specific details and terms mandated by the GDPR.

Energy collaborates with its third-party partners and service providers to deliver website and application development, games software, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services, which may necessitate them to access or utilize information about you. These include software suppliers, payment systems providers, entities dealing with Energy. If a service provider requires access to information about you to perform services on Energy behalf, they do so under close instruction from Energy, including policies and procedures designed to safeguard your data at all times.

If mandated by law, Energy may disclose your data to the Police or other public authority – this includes, but is not limited to, the IP address and details of any suspected unlawful or dishonest activity, such as abuse of a given form of payment or security risk assessment.

Categories of Recipients

We may distribute your Personal Data within the Energy Group and with these other organizations:

  • Law enforcement agencies, regulators, and other legal authorities;
  • Credit reference agencies;
  • Fraud prevention agencies;
  • Identity verification agencies;
  • Organizations that introduce you to us;
  • Third parties you request or permit us to share your information with;
  • Third parties essential to deliver products or services you have requested;
  • Third parties that permit us to comply with the affordability rule (if applicable).

Transfers Within Energy Group

Energy belongs to the group of subsidiaries and affiliated companies engaged in delivering online gambling services. Your information may be transferred by Energy to the subsidiary or affiliated company to facilitate the provision of services to you or to enhance the quality of these services. We assure you that each of the companies from the Energy Group delivers the same level of protection for your information. If Energy becomes involved in a merger, acquisition, or asset sale, we will continue to guarantee the adequate level of security of your personal data.

DATA TRANSFERS OUTSIDE THE EEA

By agreeing to the transfer of your information to third parties, you also agree that third parties may be situated outside the EEA. The privacy legislation in these countries may not deliver the same level of protection as in your country or EEA. Transfers of personal information outside the European Union will be carefully examined prior to the transfer occurring to guarantee that they fall within the limits imposed by the GDPR. This depends partially on the European Commission's assessment as to the adequacy of the safeguards for personal information applicable in the receiving country, and this may change over time.

If Energy distributes your information outside of the EEA, Energy will rely on European Commission adequacy decisions or standard EU contractual clauses which permit the transfer of your information and deliver the right level of protection.

KNOW YOUR RIGHTS

According to the GDPR, you have rights concerning the protection of your information. These rights are as follows:

1. The Right to Withdraw Consent

You have the right to withdraw your consent for the processing of your personal information at any time. However, the withdrawal of consent does not impact the lawfulness of processing based on consent before its withdrawal.

2. The Right to Be Informed

You have the right to be informed about how your personal information is processed and why.

3. The Right of Access

You have the right to request a copy of the personal information we hold about you.

4. The Right to Rectification

Where your personal information is inaccurate, you have the right to request a correction and also to complete any incomplete personal information.

5. The Right to Be Forgotten (The Right to Erasure)

You may request us to erase your personal information where there is no lawful basis requiring us to continue processing this personal information. This right only applies in certain circumstances, given that legal requirements include data retention periods.

6. The Right to Restrict or Object to Processing

In certain circumstances, you have the right to object to or restrict the processing of your personal information, where this processing is based on consent or our legitimate interest. However, despite your objections or wish to restrict processing, where there are compelling legitimate grounds or legal requirements, we would be obligated to continue said processing.

7. The Right to Data Portability

You have the right to request that your personal information be supplied to you in a structured, commonly-used and machine-readable format (GDPR Article 20) and to transfer that information to another party. This applies to personal information for which processing is based on your consent and the processing is carried out by automated means.

8. Rights in Relation to Automated Decision-Making and Profiling

You have the right not to be subjected to automated decision-making when the decision has a significant effect on you; you may insist on human intervention where appropriate. You also have the right to express your point of view and contest decisions.

9. The Right to Complain

You have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner by sending an application to [email protected] or visiting Level 2, Airways House, High Street, Sliema SLM1549, Malta.

How to Exercise Your Rights

To exercise any of the rights listed above, please contact our customer support team via electronic mail at [email protected], describing your request. We will respond to your requests within 30 days of receipt. In cases where, due to the complexity of the request or the number of requests, we need more time to process it, we will inform you accordingly.

We also encourage you to contact our Data Protection Officer (DPO) directly for additional information or assistance with your personal information. You may contact the DPO at: [email protected].

POLICY CHANGES

Energy may modify this Privacy Policy from time to time. Energy encourages you to review the current Privacy Policy whenever you use services to stay informed about our data practices and the ways you can help protect your privacy.

If you disagree with any modifications to this Privacy Policy, you must refrain from using Energy services and deactivate your account(s), as outlined above.