1. GENERAL
This Privacy Policy explains what personal data BIG2.WIN (the “Operator”) collects from you, the user of the Operator’s website (the “User”; such website the “Website”), for what reason the Operator collects it and how it is utilized. The User is requested to read this privacy policy (the “Privacy Policy”) carefully prior to using the Website and/or the games on the Websites (the "Services").
Please note that the Privacy Policy constitutes an agreement between the User and the Operator. The Operator may periodically make modifications to this Privacy Policy. While the Operator will do its best to notify the User of such changes, the User is recommended to revisit this Privacy Policy regularly.
2. INFORMATION COLLECTED
The personal information from the User which the Operator may request to use and process shall include, without limitation (the “Personal Information”):
a) any of the information that the User provides the Operator when filling in the forms on the Website’s account registration pages, as well as any other data that the User submits to the Operator via the Website or email (e.g. first and last name, date of birth, physical address, email address, phone number);
b) correspondence made via the Website, email, telephone and web chat or through other means of communication;
c)survey participations or any other customer assessments that the Operator may carry out from time to time;
d) all customer account transaction history, whether this takes place through the Website or via other means of communication; and
e) Website logins and details, including traffic data, GeoIP location data, weblogs, activity logs and other traffic information recorded on the Operator’s system.
3. USE OF INFORMATION COLLECTED
(a) The Operator will use the Personal Information to be able to deliver the Services and for the following purposes:processing the User’s transactions, including the User’s use of online payment systems;
(b) providing the User with customer support service, including assistance with setting up, operating and managing the User’s member account (the “Member Account”);
(c) complying with legal and regulatory responsibilities;
(d) creating personal profiles for the User, which may lead to certain benefits on the Website (e.g. loyalty points and rewards);
(e) undertaking necessary measures for the Member Account’s security and to identify the required verification checks;
(f) analysing customer trends through market study assessments (participation in surveys, if any are sent to the User, is not obligatory and the User always has a choice as to whether he/she would like to partake);
(g) providing the User with information about promotional offers, products and services, or providing promotional information from the Operator’s selected business partners, associates and affiliates, only in case the User has specifically consented to receiving marketing material; and
h) monitoring and investigating transactions for the purposes of preventing fraud, money laundering and other irregular gaming activities.
4. MARKETING COMMUNICATION
4.1 Only if the User has given his/her consent to receive promotional information from the Operator, the Operator may also use the Personal Information, including the User’s email address, for marketing communications regarding products, services and promotions, including information about other gaming products and services from the Operator’s business partners (such as game providers), which would have been carefully selected by the Operator.
4.2 The User may always withdraw his/her consent to receiving marketing communications by contacting the Operator’s customer support service on support@big2.win
4.3 The User, by accepting any contest prize or winnings from the Operator, consents to the use of his/her name and likeness for advertising and promotional purposes without additional compensation, except where prohibited by law.
5. OBTAINING PERSONAL INFORMATION
5.1 The Operator shall not collect any Personal Information without the User’s knowledge. The Operator may however automatically collect certain data and receive Personal Information where the User would have provided such information using the Services and through his/her interactions with the Operator.
5.2 The Operator may also receive Personal Information from online vendors and service providers as well as from customer lists lawfully acquired from third-party vendors. In addition, the Operator retains the right to engage the services of third-party service providers to provide technical support to the User, to process the User’s online transactions and to maintain the Member Account.
5.3 The Operator may be granted access to any information the User may provide to such vendors, service providers and third-party e-commerce services. The Operator will use and safeguard any Personal Information so obtained, as set out in this Privacy Policy. Any information that the User provides will only be disclosed to third parties outside the Operator in accordance with this Privacy Policy and the Operator shall take necessary steps to ensure that all its agreements with third-party service providers and online vendors always protect the Private Information.
6. SHARING OF PERSONAL INFORMATION
6.1 The Operator may pass information that the User has provided the Operator to other entities within its group of companies and to its business partners. These companies may include the Operator’s parent companies, their parent companies and all of the subsidiaries of these respective companies, as well as other companies with whom the Operator carries out business and holds necessary agreements. Data processing of such Personal Information may be undertaken by Sherbrooke or by another company in Sherbrooke’s group of companies, which may use a third party to fulfil such data processing needs.
6.2 The Operator may also disclose Personal Information that the User has given the Operator or to its business partners, suppliers and sub-contractors for the performance of any contract obligations the Operator may have entered into with them or the User. Details of any third party to whom the User’s financial information may be passed on to for the fulfilment of his/her use of the Services, shall be made available to the User upon the User’s request.
6.3 All Personal Information will always be safeguarded in accordance with legal requirements. 6.4 No Personal Information shall be passed on to third parties, unless such disclosure is deemed suitable for the User’s participation in the Operator’s business and in the business carried out in collaboration with any of the Operator’s business partners. This shall include the processing of the User’s requests in relation to the User’s use of the Services or the Operator’s business associates or unless the law expressly requires it. Relevant authorities, regulators, employees of the Operator, more specifically those forming part of the Operator’s customer support team and the Payments & Anti-Fraud teams as well as other selected employees, shall also have access to the Personal Information for the purpose of executing their duties and providing the User with assistance. The User hereby consents to such disclosures.
7. SELLING OR RELEASING OF PERSONAL INFORMATION
7.1 The Operator shall not sell any Personal Information to third parties, but may release Personal Information for the purpose of acquiring any new businesses.
7.2 In case the Operator’s group structure undergoes any changes as a result of a merger or acquisition by another company or a partial acquisition, and Personal Information will be included within the sale or transfer, the Operator will inform the User by email prior to affecting such transfer of Personal Information.
7.3 The Operator reserves the right to release Personal Information when it believes that release is appropriate in order to comply with the law, or to enforce its terms and conditions (the “Terms and Conditions”), or to protect its rights, property, or safety, and also for the protection of any other companies within its group of companies.
8. LAWS AND REGULATIONS
The Operator hereby acknowledges that in collecting and processing Personal Information for the purposes of managing the Member Account, it is bound by strict legal provisions on the protection of personal data. Consequently, the Operator endeavours to protect the Personal Information and respect the User’s privacy in accordance with best business practices and applicable regulations. In addition, and for the avoidance of doubt, nothing in this Privacy Policy shall prevent the Operator from retaining the Personal Information where it is required to do so by law.
9. RETENTION OF PERSONAL INFORMATION
As stated under the Terms and Conditions, both the User and the Operator may decide to have the Member Account closed at any time. Following closure of the Member Account, the Operator will retain all Personal Information on record for as long as required by law. Such Personal Information shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.
10. CONTACTING THE OPERATOR
The User may always contact the Operator in case he/she should wish to:
a) confirm the accuracy of the Personal Information;
b) enquire about the Operator’s use of Personal Information;
c) prohibit future use of Personal Information for marketing purposes; and/or
d) update any Personal Information provided previously by the User, provided that in such cases the User shall provide any evidence the Oprator may reasonably require to effect such changes.
The User acknowledges that it is illegal to provide the Operator with false information pertaining to him/her and it is his/her responsibility to ensure that the Operator is always updated with the User’s correct data.
11. COOKIES
In case the Users wishes to delete any cookies already stored his/her computer or stop the cookies that keep track of his/her browsing patterns on the Website, he can do so by deleting the existing cookies and managing his/her browser's privacy settings to block them. The Operator recommends not to block or delete cookies as this may restrict the User’s use of the Website.
12. SECURITY OF PERSONAL INFORMATION
12.1 The Operator takes all reasonable precautions to ensure that all the Personal Information remains safe.
12.2 The Operator uses Coinpayments, the technology that allows the Operator to guarantee the safety of all cryptocurrency transactions performed on the Website. The Operator works exclusively with reputable and trusted payment processing providers to make sure that the User’s deposits and withdrawals are handled carefully and according to industry standards.
12.3 The Member Account can only be accessed with the User’s unique ID and password. The User is responsible for keeping his/her login information confidential and making sure it cannot be accessed by another person.
13. APPLICABLE LAW, REGULATION ON DISPUTES
13.1 This Privacy Policy is governed by the laws of Costa Rica.
13.2 Any disputes arising under this Privacy Policy that the User and the Operator cannot settle out of Court, are settled in first instance before the competent court of Costa Rica.
If there are any discrepancies, conflicts or inconsistencies between the original English version and the translated Chinese version of this document, the English shall be the governing and prevailing version.