Privacy Policy Statement

A. General

Home Gaming Entertainment Limited, as the Data Controller for the collection and processing of data on its websites www.winfest.de www.winfest.com, is strictly committed to the protection of players' personal data, according to applicable legislation, including the EU - General Data Protection Regulation. This Privacy Policy Statement describes how Home Gaming Entertainment Limited processes personal data and notifies players on their related rights.

Personal data means any information relating to an identified or identifiable natural person.

Processing of data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal data will solely be processed by Home Gaming Entertainment Limited in case the player has given consent to such processing, the processing is necessary for the provision of the offered services, the processing is performed to fulfil mandatory legal requirements applying to Home Gaming Entertainment Limited, or the processing is required for the pursuit of the legitimate interests of Home Gaming Entertainment Limited, third parties or the public, when such legitimate interest is not overridden by the particular player’s fundamental rights.

By accepting this Privacy Policy Statement, the player expresses its consent to the collection and processing of its personal data as described in this Privacy Policy Statement.

B. Inquiries & Data Protection Officer

For any privacy issues, for inquiries and/or for further information on Home Gaming Entertainment Limited’s data processing activities, please contact the Data Protection Officer at:

Home Gaming Entertainment Limited
Data Protection Officer
No.2, Geraldu Farrugia Street
Zebbug ZBG 4351
Malta
dpo@hge.com.mt

C. How Home Gaming Entertainment Limited processes personal data

1. Legitimate Interests

Except for the fulfilment of mandatory legal requirements or when the player has consented in such processing, Home Gaming Entertainment Limited processes personal data solely for the pursuit of its legitimate interests or for the pursuit of the legitimate interests of third parties or the public.

As a general rule and not anticipating the results of a proportionality assessment to be performed when appropriate, Home Gaming Entertainment Limited’s legitimate interests for the collection and processing of personal data may be:

• the enabling, optimization and improvement of the services offered by Home Gaming Entertainment Limited,
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited,
• the identification and solution of dysfunctions on the Websites of Home Gaming Entertainment Limited,
• the enforcement of contractual agreements and/or legal duties, and
• the promotion of the services offered.

The legitimate interest for the processing of data in particular will be declared in the relevant section of this Privacy Policy Statement.

2. Principles for the processing of personal data

Home Gaming Entertainment Limited processes personal data solely according to the principles laid down in art. 5 (1) a. to f. of the EU – General Data Protection. These principles are:

1. Lawfulness, fairness and transparency: personal data will solely be processed in a lawful, fair and transparent manner;
2. Limitation of purpose: personal data will solely be processed for the specified, explicit and legitimate purposes these data was collected and not further, when such processing is incompatible with the purpose of collection;
3. Minimisation: personal data will solely be processed in an adequate, relevant and limited extent in relation to the purpose of processing;
4. Accuracy: personal data will be processed in an accurate manner and kept up-to-date where necessary;
5. Storage Limitation: personal data will not be kept longer than necessary for the purpose for which the data will initially collected; and
6. Integrity and confidentiality: personal data will solely be processed in a reasonably secure manner and utilising appropriate organisational and technical measures, in order to protect these data against accidental or malicious loss, destruction or damage.

3. Collection and processing of data within the offers of Home Gaming Entertainment Limited

1.when visiting the website

During the visit of the websites of Home Gaming Entertainment Limited, the gaming system, by automated means, may collect information generated by the browsers of the visitors of the websites and may store them in logfiles on a temporary basis. This may include, but is not limited to 

• the IP address of the accessing computer,
• date and time of accessing,
• the operating system accessing, and
• the browser deployed by the visitor.
• The logfiles may contain IP addresses allowing to identify a particular player.
• Legitimate interest for such collection are:
  the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited,
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited, and
  the identification and solution of dysfunctions on the Websites of Home Gaming Entertainment Limited.

2.when registering with Home Gaming Entertainment Limited

Home Gaming Entertainment Limited is legally required to collect players’ personal data at registration stage. This may include, but is not limited to

• first name and last name,
• gender,
• residential address,
• date of birth,
• nationality, and
• email address.

Players may be required to submit further documentation for the purposes of identity verification, security assessments and regulatory required checks. Home Gaming Entertainment Limited may also collect information from third party databases for such purpose.

Player are required to keep up-to-date their personal details at any time.

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited,
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited,
• the enforcement of contractual agreements and/or legal duties, and
• the promotion of the services offered.

3.for the purpose of processing payments

Home Gaming Entertainment Limited offers the facility to process payments in favour of the offers provided to its players. Depending on the payment method chosen by particular player, and, if applicable, further criteria, the personal information required may vary.
These data will be transmitted to third party payment providers in order to process a particular payment request.

Legitimate interests for such processing are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited, and
• the enforcement of contractual agreements and/or legal duties.

4.for the purpose of creating player profiles

Home Gaming Entertainment Limited processes information that is collected by cookies, logfiles, clear gifs, and/or by third parties' support in order to create player profiles. A profile contains information on individual players including preferences concerning the activities of the player. Profiles are also used to design the player's experience on the websites individually and to provide specific marketing information.

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited, and
• the promotion of the services offered.

5.via logfiles

Home Gaming Entertainment Limited uses logfiles on its websites. These may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyse trends for administration of the website, to track a particular players' movements on the website, and to gather comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited, and
• the enforcement of contractual agreements and/or legal duties.

6.player communication

Home Gaming Entertainment Limited may store communication with players with the customer support and further.

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited, and
• the enforcement of contractual agreements and/or legal duties.

7.for the purposes of marketing activities

Depending on the account settings set by a particular player, its personal data may be used for marketing activities across various channels including mail, email, electronic/instant messaging, and further.

The consent in the use of the player’s personal data for marketing activities may be cancelled or restricted by the player at any time. Such request may be submitted to the customer support team of Home Gaming Entertainment Limited via support@winfest.com or via the player account settings.

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited, and
• the promotion of the services offered.

The following marketing software is integrated to the websites of Home Gaming Entertainment Limited:

• Send in Blue | 7 Rue de Madrid, 75008 Paris, France

8.for other purposes

In exceptional cases, it may become necessary for Home Gaming Entertainment Limited to process personal data for other purposes. However, the conditions set out in section A. above apply to any case; no processing will take place unless the said conditions of section A. above are met.

9.third party content and tracking software

Home Gaming Entertainment Limited uses tracking software and website analytics tools on its websites, allows the use of social media plugins and single sign-on technology, and may provide third party content on its websites.

9.1 Tracking software

Home Gaming Entertainment Limited uses tracking software for the purpose of evaluating the user’s preferences and therefore to improve the offers of Home Gaming Entertainment Limited.

Tracking software collects user data such as IP address, accessing website, advertisement preferences and further marketing information.
The following tracking software are integrated to the websites of Home Gaming Entertainment Limited:

• Google Tag Manager
• Facebook Impressions
• Zendesk
• Hotjar

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited.

9.2 Website analytics

Home Gaming Entertainment Limited uses website analytics tools for the purpose of understanding the player’s behaviour on the Home Gaming Entertainment Limited websites and optimise the services provided by Home Gaming Entertainment Limited.

Website analytics tools collect data by using cookies and IP address tracking for that purpose.

The following website analytics tools are integrated to the websites of Home Gaming Entertainment Limited:

• Google Analytics

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited.

9.3 Social media plugins

Home Gaming Entertainment Limited uses social media plugins for the purpose of enabling the player to interact between social media and the Home Gaming Entertainment Limited websites and therefore share the gaming experience with others.

Social media plugins allow the user to login to both social media and Home Gaming Entertainment Limited account and to link content provided by Home Gaming Entertainment Limited to the player’s social media profile.

Social media plugins collect user data such as IP address, login data, accessing website and cookie data.

The following social media plugins are integrated to the websites of Home Gaming Entertainment Limited:

• Facebook Social Plugin

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited.

9.4 Single sign-on

Home Gaming Entertainment Limited uses single sign-on technology for the purpose of facilitating the player’s access to the Home Gaming Entertainment Limited websites and allowing interaction between the player’s chosen service provider or social media profile and the Home Gaming Entertainment Limited websites.
Single sign-on tools collect user data such as IP address, login data and cookie data.

The following single sign-on tools are integrated to the websites of Home Gaming Entertainment Limited:

• Facebook Connect
• Facebook Social Plugin

Legitimate interest for such collection are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited.

9.5 Third party games providers

Within the offers of Home Gaming Entertainment Limited, games provided by third party game providers may be deployed.
In the event of games being provided via the game provider websites and therefore beyond Home Gaming Entertainment Limited’s framework of privacy regulations, Home Gaming Entertainment Limited cannot acquire warranty for data collected via the third-party websites.
A list of the third-party games providers can be found in section 4.6. below.

10.via cookies

Home Gaming Entertainment Limited uses cookies. Cookies are small files that are automatically created by the user’s browser and are stored locally (on the accessing laptop, tablet, smartphone, etc.) when visiting the websites of Home Gaming Entertainment Limited.
For more information about the use of cookies on the websites of Home Gaming Entertainment Limited, please refer to our Cookie Policy.

4. Sharing and disclosure of personal data

Home Gaming Entertainment Limited will, in no event, transfer data to states outside of the European Economic Area provided unless the recipient guaranties a standard of data protection comparable to European standards (e.g. by agreeing to approved contractual clauses, binding corporate rules or further measures applied and accepted to ensure that the recipients of personal data obtain an appropriate level of data protection and privacy at any time).

Home Gaming Entertainment Limited shares data within the framework of the EU - General Data Protection Regulation:

1.within the group

Any company belonging to group of companies Home Gaming Entertainment belongs to, are subject to the same regulation and corporate rules applying for Home Gaming Entertainment Limited.

When covered by the legitimate interests declared in this Privacy Policy Statement, Home Gaming Entertainment Limited may share personal data with other companies of the group of companies Home Gaming Entertainment Limited belongs to.

2.with services providers

Under the circumstances set out in subsection 4. above, Home Gaming Entertainment Limited may make use of third party companies to process players’ personal data. In such event, the sharing of personal data collected by Home Gaming Entertainment Limited may be necessary.

Home Gaming Entertainment Limited requires any service provider to act with a reasonably high level of diligence and care, imposes contractual obligations to treat any data shared accordingly, to any service provider and ensures that data shared will solely be utilised for the purpose of collection and to the extent necessary to fulfil the respective task.

Legitimate interest for such transmission are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited,
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited,
• the enforcement of contractual agreements and/or legal duties, and
• the promotion of the services offered.

3.for measures of KYC, AML and fraud prevention

For the purpose of a players' identity verification, to carry out security checks, to assess a players’ compliance with the applicable Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and the protection of minors, player data may be matched against third party databases

Upon any indication of transactions and/or activities that may give rise to suspicions of criminal activities, Home Gaming Entertainment Limited will report to the relevant parties in charge (e.g. police, private associations aiming at the prevention of criminal and fraudulent activities in games of chance).

With the acceptance of the applicable Terms and Conditions and this Privacy Policy Statement, the player grants its explicit consent to these procedures including the matching of data provided against databases of third parties.

The sharing of players’ data may also be necessary to protect the players and the operation of Home Gaming Entertainment Limited from crime and to comply with legal obligations.

Legitimate interest for such transmission are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited,
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited,
• the enforcement of contractual agreements and/or legal duties, and
• the promotion of the services offered.

The following KYC, AML and fraud prevention software is integrated to the websites of Home Gaming Entertainment Limited:

• SCHUFA Holding AG | Kormoranweg 5, 65201 Wiesbaden, Germany
• Sum and Substance Limited | 30 St. Mary Axe, London, England
• TransUnion LLC. 1 Park Ln, Leeds LS3 1EP, United Kingdom
• DevCode Identity AB | Sveavägen 49, 113 59 Stockholm, Sweden
• Trapets AB | Kungsgatan 56, 111 22 Stockholm, Sweden
• Global Data Consortium Inc. | 1101 Haynes Street, Suite 109 Raleigh, United Kingdom
• Cloudflare Inc, 101 Townsend St., San Franciso, CA 94107
  

4.for other purposes

It may be necessary share personal data for additional purposes. However, Home Gaming Entertainment Limited solely discloses personal data in case and to the extent that one or more conditions set out in this Privacy Policy Statement and according to the general rules declared in section A. above are met.

Legitimate interest for such transmission are:

• the enabling, optimisation and improvement of the services offered by Home Gaming Entertainment Limited,
• the detection of abuse of the websites operated and/or the services provided by Home Gaming Entertainment Limited,
• the enforcement of contractual agreements and/or legal duties, and
• the promotion of the services offered.
  

5.of anonymised data

Notwithstanding Home Gaming Entertainment Limited's commitment to the protection of personal data, Home Gaming Entertainment Limited reserves the right to publish gaming data (e.g. game results), the player's first name, the initial of the surname and the player's country of residence on the websites of Home Gaming Entertainment Limited, as long as the player remains, directly and indirectly, unidentifiable by the publication of these information. Such publication is performed in order to promote the services offered.

6.third party games providers

Within the offers of Home Gaming Entertainment Limited, games provided by third party game providers may be deployed. In the event of games being provided via the game provider websites and therefore not within Home Gaming Entertainment Limited’s framework of privacy regulations, Home Gaming Entertainment Limited cannot acquire warranty for data collected via the third-party websites. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit. This is inclusive of event of the games on our website being provided via the game provider websites and therefore not within our framework of privacy regulations. The third party games offered on our website are provided by:

• Danguad Ltd.
• Amatic
• Bally Wulff
• Barcrest
• Big Time Gaming
• Blueprint Gaming
• Endorphina
• Evolution Gaming
• Gamomat
• Givme Games
• Golden Hero
• Isoftbet
• Kajot
• Kalamba Games
• Lionline Entertainment
• Merkur Gaming
• Microgaming
• NetEnt
• NextGen Gaming
• Oryx Gaming
• Pariplay
• Play’n GO
• Playson
• Pragmatic Play
• Red Tiger
• Redrake
• Shuffle Master
• Thunderkick
• Tom Horn Gaming
• United Remote
• Wazdan
• WMS
  

5. Retention

Personal data is kept by Home Gaming Entertainment Limited for the term of the contractual relationship. Whenever a player closes its player account with Home Gaming Entertainment Limited, the personal data stored in the gaming system will remain stored for the minimum length of time required to comply with the purposes set out in this Privacy Policy Statement and relevant legal requirements.

Personal Data may also be stored for a longer term, in case a deletion is not possible for technical and/or legal reasons.

D. Data Security

All data will be processed by automated means. Home Gaming Entertainment Limited takes all adequate technical and organisational efforts to protect players' data from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration or damage.

Additionally, payment information will be encrypted when being processed.

Sensitive information is protected online by SSL encryption. Furthermore, Home Gaming Entertainment Limited takes any reasonable effort to ensure the protection of players' data in all other areas.

Only authorised personnel of Home Gaming Entertainment Limited or of third-party companies contractually bound to Home Gaming Entertainment Limited and to the compliance with the principles of data protection and the terms of this Privacy Policy Statement, obtain access to the players' information.

Home Gaming Entertainment Limited monitors the trustworthiness and reliability of all personnel and service providers. At regular intervals, any employee will be trained on the applicable security and data protection standards. Relevant servers are located in a secure environment.

1. Data encryption

In order to protect the players' personal data when communicating with the web browser, Home Gaming Entertainment Limited uses encryption technology of its trusted certification partner company. In addition, online transactions are shielded by the security system of a worldwide-accredited partner.

2. Other technical security measures

In addition, all player data will be protected from unauthorised or damage access by firewall and intrusion prevention systems.

E. Rights of the player regarding its personal data

The player, at any time, has the right to

• request access to its personal data,
• request correction of its personal data,
• withdraw the consent to the processing of its personal data (e.g. for marketing activities),
• request erasure of its personal data,
• receive its persona data upon request in a structured, commonly used and machine-readable format (data portability),
• request the restriction of processing its personal data, and
• to object to the processing of personal data.

Some of these rights may only apply under certain circumstances as set forth in data protection legislation including the General Data Protection Regulation.

F. Inquiries

For inquiries or complaints regarding the handling and collection of data on the websites of Home Gaming Entertainment Limited, please contact dpo@hge.com.mt or the relevant data protection authority.

G. Changes and amendments to this Privacy Policy Statements

This Privacy Policy Statement may be subject to change from time to time, of which players will be informed without undue delay and upon their next login to the player account with Home Gaming Entertainment Limited at the latest.

Version: v1.5
Version date: 17-03-2022