Data we collect
The lawfull basis for the processing
Confidentiality of personal data
How we use your data
Who we share your data with
Disclosure Of Data
How we store your data
How we protect your personal data
Changes to this policy
1. General information
1.2. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. If we ask for your personal information for a secondary reason, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
2. Contact us
2.1. TOTO VENTURES N.V. is a data controller based in Curacao. Our registered address is Kaya Richard J.Beaujon Z/N Curacao.
2.2. If you have any questions regarding your personal data please contact our Customer Support team on [email protected]
3. Data we collect
3.1. We collect several different types of information for various purposes to provide and improve our Service to you. While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
your first and last name,
date of birth,
address, County, Postal code, City, Country,
scan/photo of yor passport/ID card,
your unique user name and password combination for your account.
3.2. Additional information is processed on an on-going basis. We may also collect:
a record of all internet communications and details of your visits to our Website;
technical information relating to how you use our products, such as the type of device you are using and the browser you are using to access our Website;
payment information and details of transactions you carry out through the site, including your payment, withdrawals and wagers;
communications with us or our employees, for examples, calls, emails, and messages sent through the form;
information regarding your location, including IP address and traffic information;
any additional information you submit through the website;
Sometimes we may also request photo ID, proof of address, and source of funds;
Occasionally we may also access your public records (ege.g.: news articles, social media, forums, official records such as the electoral roll).
3.3. To protect both you and us, we use Services provided by third parties to help us decide whether to accept transactions from you by assessing your method of payment, and the devices you use to visit our Website. These third-party services check whether the device or method of payment has been identified with fraudulent or abusive transactions in the past, such as reported instances of identity theft, promotion abuse or credit card fraud.
4. The lawfull basis for the processing
Processing of personal data is legal if:
the data has been processed in compliance with the requirements of the law and the data subject has given consent to this, with the exception of cases directly provided for by this Law or other laws, or
the data being processed is obtained from publicly available personal data sources.
5. Confidentiality of personal data
5.1. Information relating to personal data that has become known to us is considered as confidential information and is protected by law.
5.2. Our employees and other persons who have access to the processed personal data have signed a non-disclosure agreement, as well as are warned of possible disciplinary, administrative, civil and criminal liability in the event of violation of the norms and requirements of the applicable laws relating to personal data processing.
6. How we use your personal data
We process your personal data for the purposes:
to provide and maintain our Service;
to notify you about changes to our Service;
to ensure you gamble responsibly;
to comply with our legal and regulatory obligations;
to process your online financial and wagering transactions;
to allow you to participate in interactive features of our Service when you choose to do so;
to provide customer support;
to gather analysis or valuable information so that we can improve our Service;
to monitor the usage of our Service;
to detect, prevent and address technical issues;
to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
7. Who we share your personal data with
7.1. Certain trusted third party companies provide services essential to our ability to offer our gambling products to you, for example those that supply the software and games for our Website, banking and payment services, identity verification, fraud prevention and risk management. We may be required to share some of your information with these companies, some of which may be based outside of our country of residence to be able to offer our Services to you. In these instances, we ensure that the third party has appropriate security and privacy arrangements in place, so that your data is protected.
7.3. In the event of the sale of our business, or other business event, which results in us having to transfer your personal data to a third party, you will be notified via email, or notice posted on our website, to explain the identity of the new data controller and your options regarding your personal data.
7.4. Our site may contain links to and from the Websites of third party organisations. Please note that these Websites may have their own privacy policies and that we do not accept any responsibility whatsoever for these policies. Please check these policies carefully before you submit any personal data.
8. Disclosure of data
TOTO VENTURES N.V. may disclose your Personal Data in the good faith belief that such action is necessary to:
to comply with a legal obligation;
to protect and defend the rights or property of TOTO VENTURES N.V.;
to prevent or investigate possible wrongdoing in connection with the Service;
to protect the personal safety of users of the Service or the public;
to protect against legal liability.
9. How we store your personal data
9.1. Our company is incorporated in Curacao and your data is stored within its territory on our servers.
9.2. But where we work with third parties, the data we collect from you may be transferred to, and stored at, a destination outside of the territory of Curacao. It may also be processed by staff operating outside Curacao who work for us or for one of our suppliers. Such staff may be engaged in, among other things, customer services, the processing of your payment details and risk/fraud management.
9.3. We ensure there are appropriate contractual controls over any third party that helps us process your data, which ensuring that your rights are upheld and your data is secure.
9.4. We store your data for as long as you are an active customer. Once you are no longer our customer, we will retain and use your personal data on our systems to the extent necessary to comply with our legal obligations (such those imposed by tax, gambling and AML laws), resolve disputes, and enforce our legal agreements and policies.
10. How we protect your personal data
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. We store all of the personal information we receive directly from you in an encrypted and password-protected database residing within our secure network behind active state-of-the-art firewall software.
11. Your rights
11.1. You are a data subject, your personal data belongs to you, so you have rights over your personal data. Some of these rights only apply in certain circumstances. These are your fundamental rights:
withdrawing your previously granted consent; however, this will not invalidate any previously consented processing;
lodging a complaint with any relevant Data Protection Authority;
access to your Personal Data that we hold or process;
correction of any Personal Data that is incorrect or out of date;
erasure of any Personal Data that we process;
restrict processing of your Personal Data in certain circumstances;
asking us to provide you or another company you nominate with certain aspects of your Personal Data, often referred to as ‘the right to portability’;
the ability to object to any processing data where we are doing it for our legitimate interests;
the ability to contest a decision made entirely by automated processing, to express your point of view and to request that a human review the decision.
11.2. Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations.
11.3. If you want more information you can contact [email protected].
12.1. Cookies are text files containing a small amount of information that are downloaded to your device when you visit a website. They are generally used by most websites to improve your online experience and to ensure that content and functions are delivered and used more effectively.
12.2. Cookies perform various different functions. For example, some cookies are session cookies, which are downloaded to your device temporarily for the period that you browse a particular website; these cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Other cookies are persistent cookies, which can be used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to your specific needs and interests.
12.4. You agree that TOTO VENTURES N.V. may, from time to time, place cookies on your device to save information (such as user name, other personal details, e-mail address, technical device information such as the model and its IP address) to make full use of the functionality and Services on our website and to allow your browser to identify you as a user. This enables you to not have to re-enter this information each time you visit TOTO VENTURES N.V.’s site. These cookies cannot be used to run programs or deliver viruses to your computer, and are uniquely assigned to you. These cookies can only be read by the web server(s) that placed the cookies on your device.
12.5. At any time you can amend your browser settings to block some or all cookies from TOTO VENTURES N.V.. However, if you block cookies from TOTO VENTURES N.V. some or all the website's functions may not perform as intended. For example, you may not actually be able to place any bets.
12.6. Further information about cookies can be found at: www.allaboutcookies.org.
13. Changes to this policy