3.1 In accordance with the information we gather pertaining to our users:

i. Personal Data – means any information that identifies You as an individual or that relates to an identifiable individual. Whenever it is not possible or feasible for Us to make use of anonymous and/or anonymized data (in a manner that does not identify any Users of the Site or customers of our services), We are nevertheless committed to protecting Your privacy and the security of Your Personal Data at all times.

ii. Data obtained from You – We collect from You, through interaction with You or through Your interaction with Us or our Services different kinds of personal data about you which we have grouped together as follows:

• Registration Data provided by You when you register and/or open your Member Account including first name, last name, username or similar identifier, date of birth, territory applicable social security or similar identification number where permitted or required by law, gender, country.
• Contact Data includes permanent address, email address and telephone numbers.
• Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) that include Your name, surname, permanent address and proof, age, nationality, proof of e-wallet ownership such as PayPal, PaySafe, etc. territory applicable personal identification where required or permitted by law, KYC documentation (e.g. ID card, Power of attorney).
• Payments Data includes bank/payment account details, as well as information pertaining to a transaction such as currency, location, amount/value, client IP, user ID, token.
• Transaction and Usage Data generated through Your use of our Services, including payments to and from You (deposits, withdrawals, failed deposits, and reversed withdrawals) and other details of Services, date and time of the transactions, account balances, language, country, account balances.
• Log in Data includes internet protocol (IP) address, your logins (first log in/last login, last failed login), duration of logins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
• Profile Data encompasses a range of information that contributes to an understanding of individual user preferences and enables personalization strategies. This data includes internal notes, interests, preferences, feedback, and event attendance history. By analyzing this data, insights can be obtained regarding users’ preferences for attending events and their specific event preferences. Furthermore, profile data incorporates data related to bonus and cash back deals that users have availed or benefited from, as well as their preferences in this regard. It also considers whether users have received giveaways and their preferences regarding the types of gifts they prefer to receive. This information aids in tailoring promotional offers and rewards to align with individual user preferences. Additionally, profile data includes contact channel preferences, allowing for targeted communication through users' preferred channels. This ensures that users receive information and updates through channels that are most convenient and engaging for them. Lastly, profile data encompasses information about users’ hobbies and interests, providing insights for creating personalized recommendations and content. By leveraging this information, tailored experiences and offerings can be developed to cater to the specific tastes and preferences of individual users.
• Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out), as well as Your contact and registration data.
• Other Communication Data generated as part of communications with Us (via recorded calls, chats, emails, or SMS) which may include various data such as network communication data, content of the communication including Your intentions, interests, complaints, preferences, as well as internal communication and notes.
• Analytics data include various data generated with respect to your use of our Website and Services such as your user ID, language, location, browser data, campaigns utilized, channels used, device, payment provider, transaction and usage data and in case of online acquisition analytics also pages visited, postcards clicked, scroll depth. certain information is collected using cookies and/or similar tracking technology. 

iii. Data obtained from different sources:  

• For the purpose of Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT), we gather information about the user's background from public sources where such information is available and permitted by the law. Additionally, we may obtain information from third-party providers, who are mostly private companies that work with public sources. This information includes whether the user is a politically exposed person, if any international or financial sanctions have been imposed, and any details regarding corporate or property ownership, court judgements, insolvency and taxation that are legally required or allowed in your region. We use a process called Open-Source Intelligence (OSINT) analysis, which involves collecting publicly available information from sources like Google, social media platforms such as Facebook, Twitter, Pinterest, Instagram, LinkedIn and other sources. This is done to establish the source of funds and wealth during the AML risk monitoring and due diligence process.

• To comply with our legal obligations stemming from applicable laws and (applicable) license conditions.
• Profile data (hobbies, interests) are also gathered by search of publicly available sources such as Facebook, LinkedIn, Twitter and Instagram, Google search.
• To simplify the sign-up procedure a separate process, such as (i) Bank ID or similar, (ii) Facebook connect, (iii) Google sign-In, (iv) Apple Pay  (v) a similar option, may be used as a source for identification and verification. If such a process is used, once the authorization of access and the necessary information is provided by You upon sign up, personal data (registration and contact data) will be automatically fed to the users profile from the third-party source to facilitate your registration.

iv. Special Categories of Personal Data 

In certain circumstances, we may collect special categories of personal data about you. These categories include information related to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, details about your health, as well as genetic and biometric data. 

We recognize that these categories of personal data are sensitive in nature, and we want to assure you that we will handle them with the highest level of care and in accordance with applicable legal requirements. We understand the importance of protecting your privacy and ensuring that your personal data is treated confidentially and securely.

Please be assured that the collection of such special categories of personal data will only occur when necessary and with your explicit consent, or if required by law for specific purposes. We strive to be transparent about the purposes for which we collect and process personal data, and we will always provide you with clear information and obtain your consent when required.

v. If You fail to provide data – In situations where We are required by law or a contractual agreement to collect personal data from You, and You refuse to provide this information upon request, We may be unable to fulfill our obligations under the contract or initiate a contract with You. For instance, we may be unable to provide You with the services We offer.

vi. Username – Please make sure that your username does not contain any personally identifiable information, as the username is shared with certain partners and in the course of the sharing of the username, this is not, separately, considered personal data.