Privacy Policy
1. INTRODUCTION
1.1. At Gamdom (hereinafter referred as “we”; “us”; “our”; “website”), we are committed to protecting the privacy and personal data of our users.
1.2. The Data Controller responsible for the Personal Data described in this Privacy Policy is Moon Revolution Limitada, a limited liability company organized and existing in Costa Rica, registered in the commercial register under number 3-102-903008, having its registered office at n. 400, La Ceiba Street, San Rafael district, County of Escazu, San José, Costa Rica (the “Company”), contactable at support@gamdom.com.
1.3. This Privacy Policy describes how we collect, use, disclose, store and otherwise process personal data when users access and use our Platform and Services. Personal Data is collected, used and retained only to the extent necessary to provide, operate, maintain, improve and secure the Services, comply with legal and regulatory obligations and pursue our legitimate business interests as further described in this Privacy Policy.
1.4. We take appropriate technical and organizational measures to ensure that Personal Data is processed securely and in accordance with Applicable Regulations.
1.5. By accessing or using the Platform and Services, you acknowledge that your Personal Data may be processed in accordance with this Privacy Policy. Depending on the circumstances, we may process Personal Data where necessary to provide the Services, comply with legal or regulatory obligations, pursue legitimate business interests, or where you have provided your consent. Where consent is required, it will be obtained separately and may be withdrawn at any time, subject to applicable legal or operational requirements.
1.6. We may amend this Privacy Policy from time to time to reflect changes in our practices, legal obligations or operational requirements. Where we make a material change, we will notify registered users at least thirty (30) days before the change takes effect, by email and by notice within your Account, and that notice will identify the substance of the change and its likely effect on you. Changes that are not material, including the correction of typographical or stylistic errors, take effect upon publication. Where a change requires your consent, that consent will be requested separately and the change will not apply to you unless and until you provide it. The Date of Last Update will be amended on each revision, and the superseded version will remain available on request.
2. DEFINITIONS
2.1. For the purposes of this Privacy Policy, the following terms shall have the meaning set out below, whether used in singular or plural form:
2.1.1. “Account” means a registered user account created by you on the website, through which you access our Services.
2.1.2. “Applicable Regulations” means all applicable requirements and guidance relating to privacy, data protection and the provision of the services.
2.1.3. “Data Controller” means Gamdom through its entity (Moon Revolution Limitada), which determines the purposes and means of processing your personal data.
2.1.4. “Cookies” means small text files and/or similar technologies stored to enable and improve the functionality, performance and security of the Services.
2.1.5. “Date of Last Update” means the date on which any information contained in this Privacy Policy was last added, modified or deleted.
2.1.6. “KYC” (Know Your Customer) means the identity verification process through which we confirm your identity, age, location and eligibility to use our Services, including the collection of personal documents.
2.1.7. “Payment Processor” means any third-party entity engaged by us to process financial transactions performed on our Platform.
2.1.8. “Personal Data” means any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers, transaction records, and any documentation related and required to facilitate access to our Services.
2.1.9. “Platform” means the Website, mobile applications, software, systems and any other digital interface through which Gamdom makes its Services available to users.
2.1.10. “Processing” means any operational action performed on Personal Data, including but not limited to collection, storage, use, disclosure, transfer or deletion.
2.1.11. “Processor” means any third party that processes Personal Data on behalf of Gamdom under a data processing agreement.
2.1.12. “Regulatory Authorities” means any governmental, statutory, supervisory, regulatory, licensing, tax, or law enforcement authority, agency, body, or court with jurisdiction over the Company or its activities, including data protection and privacy authorities, gaming and gambling regulators, and authorities responsible for anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance.
2.1.13. “Services” means the platform, products, tools, and all associated features offered by Gamdom through the Site.
2.1.14. “Service Provider” means any third party engaged by the Company to perform services on its behalf and in connection with the Services, including payment processing, KYC/AML verification, hosting, fraud prevention, customer support, analytics and marketing.
2.1.15. “Site” means the website accessible at gamdom.com and any associated mobile applications, domains or platforms operated by Gamdom.
2.1.16. “Third Party” means any natural or legal person other than Gamdom and the User, including but not limited to: Service Providers, partners, affiliates, advertisers, analytics providers, and payment providers.
3. DATA COLLECTION, PROCESSING AND RETENTION
3.1.1. We collect and process the below mentioned categories of Personal Data and any references to “Art. 6” and “Art. 9” are to the articles of the EU General Data Protection Regulation (GDPR), and references to “Art. 5(3)” are to the ePrivacy Directive (2002/58/EC).
3.2. Account and Identity Information:
We collect your full name, date of birth, nationality, email address, contact details, username and account credentials, government-issued identity documents (such as your passport or national ID), proof of address and source of funds information. We process this information to create and manage your account, to verify your identity as part of our know-your-customer (KYC) checks, and to provide you with access to the Services. We rely on the performance of our contract with you (Art. 6(1)(b)); on compliance with a legal obligation under applicable law, including where relevant Union or Member State law (Art. 6(1)(c)); and otherwise on our legitimate interests, and those of third parties, in
3.3. Financial and Transaction Data:
We collect your deposit and withdrawal history, payment method information, cryptocurrency wallet addresses, bet history, game activity and account balance. We process this information to handle payments, facilitate gameplay and meet our regulatory reporting obligations. We rely on the performance of our contract with you (Art. 6(1)(b)); on compliance with a legal obligation under applicable law, including where relevant Union or Member State law (Art. 6(1)(c)); and otherwise on our legitimate interests in transaction integrity, fraud prevention and satisfying the reporting conditions of our gaming license (Art. 6(1)(f)). We retain this information for a minimum of five years from the end of our business relationship, or for longer where required by applicable law or regulatory obligation.
3.4. Technical and Usage Data:
We collect your gameplay session history, IP address, browser type, operating system, device information, geo-location data, session logs, access times, pages visited, usage analytics and platform interaction data. We process this information for platform security, fraud prevention, improving the Services and analytics. We rely on our legitimate interests in platform security and fraud prevention (Art. 6(1)(f)); and where analytics involve the storage of information on, or access to information stored on, your device, we obtain your consent (Art. 5(3) ePrivacy Directive). We retain this information for up to 24 months from collection, unless a longer period is required for fraud prevention or security purposes.
3.5. Communication Information:
We collect your customer support requests, emails, chat messages, survey responses and other correspondence. We process this information to provide customer support and to maintain accurate records of our communications with you. We rely on the performance of our contract with you (Art. 6(1)(b)) and on our legitimate interests in providing support and keeping accurate records (Art. 6(1)(f)). We retain this information for up to three years from the date of the communication, or for the duration of any unresolved dispute.
3.6. Marketing Data:
We collect your marketing preferences and records of your interactions with our promotional communications. We process this information to send you promotional communications and to personalize the offers we show you. We rely on your consent (Art. 6(1)(a)), which you may withdraw at any time. We retain this information until you withdraw your consent, or for up to two years from the date of your last interaction, whichever occurs earlier.
3.7. Cookies and Similar Technologies:
We collect information through cookies, pixels, web beacons and similar tracking technologies. We use this information for user recognition, functionality, usage analysis, security and marketing. We rely on your consent for all non-essential cookies and similar technologies (Art. 5(3) ePrivacy Directive; Art. 6(1)(a) GDPR); technologies strictly necessary to deliver a Service you have requested are exempt from the consent requirement. Session cookies are deleted when you close your browser, and persistent cookies last for up to 12 months from the date of placement.
3.8. MINORS
The Services are intended solely for individuals aged eighteen (18) years or over, or such higher minimum age as applies in the jurisdiction in which the user is located. We do not knowingly collect Personal Data from minors. Where we become aware that an Account has been opened by a minor, the Account will be closed, the Personal Data collected will be deleted save where retention is required by Applicable Regulations, and any balance will be dealt with in accordance with our Terms and Conditions. If you believe that a minor has provided us with Personal Data, please contact us at support@gamdom.com.
4. DATA PROCESSING PURPOSES
4.1. We may process Personal Data for the following purposes:
4.1.1. Providing, operating, maintaining and improving the Platform and Services.
4.1.2. Complying with applicable legal, regulatory, licensing and compliance requirements, including cooperating with Regulatory Authorities;
4.1.3. To verify identity, age, location and eligibility to use the Services, conduct know-your-customer (KYC) procedures, perform screening and due diligence checks, and satisfy applicable legal, regulatory, licensing and compliance requirements.
4.1.4. Processing financial operations carried out through the Platform: to process deposits, withdrawals and other account transactions, maintain transaction records, administer account balances, and facilitate the operation of payment and cryptocurrency services made available through the Platform.
4.1.5. Responsible Gambling and Player Protection: to implement responsible gambling measures, monitor account activity where appropriate, apply player protection controls, and fulfil obligations relating to safer gambling and user welfare.
4.1.6. Service Improvement and Business Operations: to analyse, develop, maintain and improve the Platform and Services, conduct testing, research, auditing and quality assurance activities, troubleshoot technical issues, and support our internal business operations.
4.1.7. Marketing and Promotional Activities: to administer promotions, bonuses, loyalty campaigns, competitions and other promotional activities, and to send marketing communications when permitted by applicable laws and in accordance with user preferences.
4.1.8. Legal and Regulatory Matters: to establish, exercise or defend legal rights, manage disputes, complaints and investigations, comply with legal and regulatory obligations, and cooperate with competent authorities where required or permitted by law.
4.2. We will only process Personal Data where there is an appropriate legal or operational basis for doing so, including where processing is necessary to provide the Services, comply with legal and regulatory obligations, protect the security and integrity of the Platform and Services, pursue legitimate business interests, or where a user has provided consent for a specific processing activity.
4.3. Provision of the Account and Identity Information described above is a requirement both of entering and maintaining a contract with us and of the regulatory conditions under which we are licensed. If it is not provided, we will be unable to open or maintain your Account, process withdrawals, or continue to make the Services available to you. Provision of Marketing Data is optional and refusing it has no effect on your access to the Services.
4.4. We use automated systems to support fraud detection, anti-money laundering and sanctions screening, bonus abuse detection, responsible gambling monitoring and risk scoring. Where a decision producing legal effects concerning you, or similarly significantly affecting you, is based solely on automated processing, you have the right to obtain human intervention, to express your point of view, and to contest that decision by contacting us at support@gamdom.com.
5. DISCLOSURE OF INFORMATION
5.1. We may disclose Personal Data where necessary for the purposes described in this Privacy Policy, including to:
5.1.1. Regulatory Authorities or any other competent authority where disclosure is required by Applicable Regulations or legal process, or otherwise necessary to protect our rights, interests, users or the integrity of the Platform and Services;
5.1.2. Third-Party Service Providers supporting the operational status of the Platform and its Services;
5.1.3. Payment Service Providers, Financial Institutions, Cryptocurrency providers, including wallet infrastructure providers or any other entities involved in the processing, routing or settlement of transactions carried out through the platform;
5.1.4. Identity verification, screening and compliance service provider;
5.1.5. Analytics, technology, hosting, customer support, marketing and other operational Service Providers;
5.1.6. Professional advisers, auditors, consultants and other professional service providers engaged in connection with the operations of the Platform, provision of the Services, business activities or protection of our rights and interests;
5.1.7. Any other third-party where the user has provided consent, requested or authorized such disclosure, or where disclosure is otherwise required, permitted or reasonably necessary to support the Platform’s operations.
5.2. The Services may contain links to third-party websites, platforms or applications. Gamdom is not responsible for the privacy practices or content of third-party services, and users should review the applicable privacy policies of those third parties separately.
6. INTERNATIONAL DATA TRANSFERS
6.1. By the nature of our operations and the Third-Party Service Providers engaged to support them, Personal Data collected through the Platform may be transferred to, stored in, or otherwise processed in jurisdictions outside the European Economic Area (EEA).
6.2. We take reasonable steps to ensure that appropriate safeguards are in place in accordance with applicable data protection law and regulations, including, where relevant, Standard Contractual Clauses approved by the European Commission or other legally recognised transfer mechanism. For further information about the safeguards applicable to international transfers of your Personal data, please contact us at: support@gamdom.com
7. DATA RETENTION
7.1. We retain personal data only for as long as reasonably necessary for operational, legal, compliance and fraud prevention purposes. Retention periods may vary depending on applicable regulations, the nature of such data, account activity, and dispute resolution requirements.
7.1.1. Transaction records are retained for a minimum of five (5) years from the date of the relevant transaction;
7.1.2. Account records are retained for the duration of the account relationship and for five (5) years thereafter;
7.1.3. Marketing data is retained until consent is withdrawn or two (2) years from the date of last interaction, whichever occurs earlier;
7.1.4. Technical and usage data is retained for up to twenty-four (24) months from collection, unless a longer period is necessary for fraud prevention or security purposes;
7.1.5. Communication records are retained for up to three (3) years from the date of the communication, or for the duration of any unresolved dispute.
7.1.6. Notwithstanding the foregoing, certain Personal Data may be retained for longer periods where required by applicable laws, regulations, regulatory authorities or legal proceedings.
7.2. Following account closure, Personal Data may be retained for the periods set out above and for longer where required by applicable laws, regulations or requests from competent authorities.
8. COOKIES AND TRACKING TECHNOLOGIES
8.1. We use cookies and similar technologies, including pixels, web beacons, software development kits, device and browser fingerprinting and local storage, to operate and secure the Platform, analyses traffic and usage, and enhance the user experience. These technologies involve the storage of information on, or access to information already stored on, your device.
8.1.1. Save for technologies strictly necessary to deliver the Service you have requested, we place and read such technologies only with your consent. You may give, refuse and withdraw consent at any time through our cookie preference centre, which is accessible from every page of the Site, and withdrawing consent is no more difficult than giving it. Refusing non-essential technologies does not restrict your access to the Services. Details of each technology, its purpose, provider and duration are set out in our Cookies Policy.
9. SECURITY OF PERSONAL DATA
9.1. We implement appropriate technical and organisational measures designed to protect Personal Data against unauthorised or unlawful processing and against accidental loss, destruction or damage. These include encryption of data in transit and at rest, role-based access controls and authentication requirements, logging and monitoring of access to systems containing Personal Data, contractual confidentiality and security obligations imposed on staff and Service Providers, and periodic review and testing of our security measures.
9.2. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security. Where a personal data breach occurs that is likely to result in a high risk to your rights, we will notify you without undue delay in accordance with Applicable Regulations.
10. DATA SUBJECT RIGHTS
10.1. Subject to Applicable Regulations, you may have some or all of the following rights in relation to your Personal Data:
10.1.1. Right of access: request a copy of the personal data we hold about you;
10.1.2. Right to rectification: request correction of inaccurate, incomplete or outdated Personal Data;
10.1.3. Right to Erasure: request us to delete your Personal Data where there is no overriding legitimate reason to continue holding it. Please note that certain Personal Data may be retained according to Applicable Regulations;
10.1.4. Right to restriction: request restriction of your Personal Data in certain circumstances, where applicable;
10.1.5. Right to object: object to processing carried out on the basis of our legitimate interests;
10.1.6. Right to withdraw consent: where processing is based on your consent, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
10.1.7. Right to Data Portability: where applicable and subject to applicable laws and regulations, request a copy of certain Personal Data in a structured, commonly used and machine-readable format and, where technically feasible, request that such information be transferred to another service provider.
10.1.8. Right to Lodge a Complaint: lodge a complaint with a competent data protection, privacy or other regulatory authority where you consider that your Personal Data has been processed in a manner inconsistent with applicable laws or regulations.
10.1.9. Rights in Relation to Automated Decision-Making: where applicable, request additional information regarding decisions based solely on automated processing that produce legal or similarly significant effects and request review of such decisions when permitted under applicable laws and regulations.
10.2. To exercise any of these rights, please contact us at support@gamdom.com. We may require identity verification before processing your request to protect your data.
10.3. We aim to respond to your request within one (1) month of receipt. Where a request is particularly complex or where a high volume of requests has been received, we reserve the right to extend this period by a further maximum two (2) months. Where an extension is necessary, you will be notified accordingly within the initial one (1) month period.
11. EMAIL AND OTHER COMMUNICATIONS
11.1. Marketing communications will only be sent where you have consented to receive them.
11.2. You may withdraw your consent at any time by updating your account preferences or using the unsubscribe link included in the relevant communication.
12. CONTACT US
12.1. If you have questions or comments about this Privacy Policy, please contact us at: support@gamdom.com
