Last update: March 2022
Your privacy is important to Push Gaming Malta Limited and its group companies (hereinafter "we" and/or "us" and/or “Push Gaming”). We recognise the responsibility you entrust us with when providing your personal data. This Privacy Notice explains to our business contacts (“you”) how we handle and treat your personal data when you engage with us for business purposes, including but not limited to via the business client area: https://clientarea.pushgaming.com/games/ or public website: www.pushgaming.com (together the “Website").
The purpose of this Business Contacts Privacy Notice (“Privacy Notice”) is to provide you with a clear explanation of what personal data we collect, when, why and how we collect, use and share your personal data and it explains your statutory rights. Please make sure you fully understand our practices in relation to personal data before you engage with us for business purposes. Where you have read this Privacy Notice but would like further clarification, please contact us at dataprivacy@pushgaming.com.
1. Who are we and what do we do?
Push Gaming Malta Limited, with company number C90728, and registered address at Sonor, Level 1, 66 Cathedral Street, SLM1524 Sliema, Malta, is the controller of your personal data.
2. What personal data do we collect and why do we collect it?
Personal data is information relating to you, such as your name, email address, phone number, etc.
Information you provide to us directly:
- When you create an account in the client area: you provide us with your email address, name, company, job position and password.
- When you contact us, including by email: you can enter in contact with us, including by sending a message at info@pushgaming.com. If you contact us, we will collect your contact details (e.g. email address) as well as any information you decide to share with us.
- When we invite you to receive marketing communications from us: We can propose that you receive electronic marketing communications from us, when you provide us with your contact details during our interactions via Skype/email, telephone during social events, or otherwise.
- When we engage in contractual or business negotiations: you provide us with your business contact information, such as your name, job title, email address, telephone number, etc.
- When we conduct due diligence on our contractual partners: you provide us information about your company, directors, shareholders and ultimate beneficial owners. Furthermore we collect corporate documentation and personal identification documents necessary for due diligence purposes.
- When we administer our agreement with your company: you provide us with your business contact information, such as your name, job title, email address, telephone number, your signature, billing information etc.
- When you use our products and services: we collect any information that you provide to us as part of your use of our products and services. For example, when you access and use the Back Office or raise a ticket via our Support Desk, we collect your email address.
- When you register to a social event that we organise, participate in or sponsor: we and/or our business partner collect your first and last name, phone number; your email address; the name of your company; as well as any information you decide to share with us.
- When we invite you to receive our themed gifts and/or merchandise: we collect your name, postal address, phone number and email address as well as any other information you decide to share with us, to send you gifts or merchandise related to our business relationship with you.
- When it is necessary for us to otherwise process your personal data, you provide us with other data, not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection.
Information collected by automated means from your browser and device through cookies and other tracking technologies:
- When you navigate on our Website: we use cookies, in combination with other tracking technologies to distinguish you from other users of the Website. We will process your personal data in accordance with our Cookie Notice and our Website Privacy Notice.
3. How do we use your personal data and on which legal basis?
| Purposes of processing | Legal bases |
| To conduct due diligence |
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| Manage and administer our agreement with your company (e.g., to provide our products and services, answer your requests and queries, manage your invoices and payments) |
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| To handle general requests or queries |
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| Conduct client satisfaction surveys and studies |
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| To send you themed gifts or merchandise |
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| Send you marketing communications by electronic means (e.g. to send you our newsletters) |
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| Invite you to attend our social events |
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| Comply with any legal or regulatory requirements (e.g. comply with our legal accounting obligations) |
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| If applicable, investigate or settle inquiries or disputes (e.g. management of complaints, after-sales service and guarantees) |
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| If applicable, to disclose your personal data to third party business partners / services providers (as listed in section 4) |
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4. Who do we share your personal data with?
We share your personal data with third parties only where it is necessary, and for purposes described in this Privacy Notice. We may share your personal data with the following categories of third parties:
- Group Companies: We may share your personal data with our corporate parent, subsidiaries, and affiliated companies.
- Business partners / Services providers: We may share your personal data with our business partners / service providers as necessary for them to provide services to us in connection with our fulfilment of the purpose set out above. For example, we may rely on service providers to process payments, conduct marketing activities or background screenings.
- Government Agencies, Regulators and Professional Advisors: Where permitted or required by applicable law, we may also need to share your personal data with government agencies and regulators (e.g., tax authorities, courts, and government authorities) to comply with our legal obligations, and to external professional advisors as necessary to defend our legal interests.
- Organizations Involved in Business Transfers: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, will be transferred to the surviving entity in a merger or the acquiring entity. Such information will be transferred in accordance with applicable law.
5. How Do We Protect Personal data?
We are committed to keeping the personal data provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. We have put in place procedures to deal with any suspected breach of personal data and will notify individuals and any applicable regulator of a breach where we are legally required to do so.
6. How long do we keep your personal data?
We may retain your personal data as long as necessary for the purpose for which it was collected, and beyond such time as necessary to defend us in the context of legal claims, or for compliance and legal protection purposes.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal data, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. If we fully anonymize your personal data (so that it can no longer be associated with you), we may use this information indefinitely.
7. Your Privacy Rights
- Right of access: you can ask us to provide you with information about our processing of your personal data and give you access to your personal data;
- Right to rectification: if the personal data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified;
- Right to erasure: you can ask us to delete or remove personal data where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request;
- Right to restrict processing: you can ask us to suspend the processing of your personal data if, (i) you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Right to object: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms;
- Right to data portability: you have the right, in certain circumstances, to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you; and
- Right to withdraw consent at any time: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal data or where certain exemptions apply.
To exercise any of these rights, please contact us using the contact details provided below.
Although we urge you to contact us first to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.
8. International Data Transfers
We may transfer your personal data to recipients based outside of the European Economic Area (“EEA”) and/or the United Kingdom (“UK”). Some of these recipients are located in countries in respect of which either the European Commission and/or UK Government (as and where applicable) has issued adequacy decisions, in which case, the recipient’s country is recognized as providing an adequate level of data protection under UK and/or European data protection laws (as applicable) and the transfer is therefore permitted.
Some recipients of your personal data may be located in countries outside the EEA and/or the UK for which the European Commission or UK Government (as and where applicable) has not issued adequacy decisions in respect of the level of data protection in such countries (“Restricted Countries”). For example, the United States is a Restricted Country. Where we transfer your personal data to a recipient in a Restricted Country, we will either:
- enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or
- rely on other appropriate means permitted by the EU/UK GDPR, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details below.
9. Contact us
You may contact us using the following details:
- Email address: dataprivacy@pushgaming.com
- Postal address: Push Gaming Malta Ltd, with company number C90728, and registered address at Sonor, Level 1, 66 Cathedral street, SLM1524 Sliema, Malta.
10. Changes to this Privacy Notice
We may make changes to this Privacy Notice from time to time. To ensure that you are always aware of how we use your personal data we will update this Privacy Notice from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Please regularly check these pages for the latest version of this Privacy Notice.
