Privacy notice

Last update: 20-12-2019

Summary

Data Controller Name: Royal Panda Ltd.

Methods of information collection: when you provide it to us through our website such as signing up and subscribing to newsletters, use of our website through cookies, occasionally through third parties.

Information use: in compliance with legal obligations, to improve our website and games, to prevent fraud.

Information sent to third parties: when required by law, to our platform providers, to LeoVegas Mobile Gaming Group (“LeoVegas”) in fulfilling legitimate interest and to payment processors to fulfil their respective service contract.

Information Retention: for a minimum of five years from last player transaction or account closure as per relevant anti-money laundering regulations in the United Kingdom and Malta.

Information sold to third parties: no.

Transfer to countries outside the European Economic Area (EEA): only in specific circumstances we transfer limited personal data outside of the European Economic Area. Royal Panda will ensure appropriate safeguards and contractual measures are in place.

Use of cookies: required, functional (optional) and advertising (optional) cookies.

Information collected on you: name, email, date of birth, phone, gender, address, products of Royal Panda in use, government identity for customer verification as required by applicable law, other data that you have provided while contacting us, especially using the contact, or signup forms on our website, data that you have sent to us through an online chat, phone call and support ticket, self-exclusion data which include data pertaining to you and your self-exclusion such as your registration and contact data and your self-exclusion info such as start and end date. For marketing purposes and to improve our websites and services, we also collect data sent by your web browser, e.g., information about your browser, your IP address, and your operating system.

Your rights: you may request for information on what personal data we store in relation to you, you may have the data rectified, you may object to the processing of your personal data for direct marketing purposes, and withdraw consent, and you may lodge a complaint and request for an export or transfer of your data.

Introduction

As a data controller, Royal Panda Ltd (“Royal Panda”) has a legal obligation under gambling regulations to process personal data from the player for the purposes of allowing him/her access to use its services and in order to allow him/her to participate in games and provide him/her with ancillary services.

The purpose of this notice is to inform you about our policies for the collection, use and disclosure of personal information. Your information will not be shared with anyone except for the named parties in this privacy notice.

We reserve the right to update this privacy notice at any time without prior notice. Royal Panda shall at all times process data in accordance to the privacy notice that you have consented to at the time of your consent. Upon a change in policy, we will alert you with a website banner notice; your continued use of the website and/or its services will constitute your consent to the updated notice. Use the “Last updated” date in this notice to determine when it was last changed.

1. Purposes of the Data Processing

Royal Panda collects and processes your personal data from your first visit on our website using cookies in order to:

• Comply with relevant gambling and anti-money laundering regulations in licensed gaming jurisdictions;
• Participate in games and provide you with ancillary services;
• Provide you with the services that you seek from our website;
• Improve our website and services;
• Ensure the security of our website;
• Better market relevant content generally, using anonymous or pseudonymized personal data;
• And, if you have additionally consented to it, market to you specifically, such as through email, phone, SMS remarketing and web retargeting.
• Beyond these purposes, we process your data only if you have granted consent for its stated purposes including publishing the player’s username and/or first name and/or first letter of last name and/or region for promotional purposes.

None of the above processing includes automated decision taking.

2. Cookies and Tracking Pixels on Visit

When you visit the Royal Panda website, our system automatically collects information about your visit, such as your browser, IP address, and the referring website.

This collection may be done in conjunction with our platform providers and partners (see data recipients list below). We may receive from them general demographic or usage data of our site visitors. We do not use automatically collected information to identify you personally without collecting additional consent.

This information is collected using cookies, embedded hyperlinks, and similar tools. The latest browsers can be set to disable or delete cookies. The list below contains the types of cookies we use and their purposes.

Required Cookies: enable the navigation and basic functionality of the websites, e.g., access to member areas of the websites.

Functional Cookies: allow us to analyze your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalized experience.

Advertising Cookies: allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track site visits and new player signups from advertising. We do not share your personal information (such as name or email) to providers except for site visit data collected directly by such Advertising Cookies. However your site visit data may be linked with other personal information collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers.

See below for descriptions about the cookies used on our websites and how you can opt out from them.

www.royalpanda.com / m.royalpanda.com (Required Cookies)

Cookie name	Value description
device_type	Device type name if known
device	Integer indicating the device type
has_js	Boolean indicating browser has javascript support
currency_to_show	Contains the currency key that should be used on the site for jackpots etc
content_currency	Contains the currency key that should be used for the currency in the content
sessionKey	Session key
rp_login	Player session key
rp_casino_cat	ID of game category last used
rp_casino	List of ID's of all games within the last category or within the last search
aucp13n	Cache invalidation cookie
Random	Session key that is bound the Player session key
btag	Affiliate id
affTracking	Affiliate related tracking codes
hasPendingLimits	Boolean used to determine if a player has to confirm pending Responsible Gambling limits

Opt-out: You can configure your browser to disable the Advertising Cookies. This may reduce site functionality.

Google Analytics (Functional Cookies)

Our website uses Google Analytics, a web analysis service of Google, Inc. (“Google”). Learn more from their Terms of Service and Privacy Policy.

Opt-out: Download the browser plugin “Google Analytics Opt-out Browser Add-on” here.

Adform (Advertising Cookies)

Royal Panda utilises Adform, a web analysis service supplied by Adform A/S, Wildersgade 10B, sal. 1, DK-1408 Copenhagen, Denmark (hereinafter referred to as Adform). Adform's technology enables advertisers to collect and retain non-personal information on internet users and to use it for analysis and online behavioural advertising. Adform uses a cookie mechanism in order to decide which ads to display, e.g. ads for similar products that the visitor has already viewed. Data is collected on an anonymous basis only. The cookie contains a random identification number, an accept or decline option, or information on campaigns / advertising activities on an advertiser's website. This use of random identification numbers in the cookies means that Adform collects and retains anonymous information in cookie-based profiles. This includes: operating system, browser version, geographic location, URLs on which Adform displays advertisements, or facts about interactions with advertisements (such as number of clicks or views). Further information can be found on Adform's Privacy Policy.

You can opt out from tracking by ticking the opt out button.

3. Categories of Personal Data

Personal data means any information relating to an identified or identifiable natural person. Royal Panda collects, processes, or uses the following personal data:

• Name, email, date of birth, phone, gender, address, products of Royal Panda in use;
• Government identity for customer verification as required by applicable law;
• Other data that you have provided while contacting us, especially using the contact, or signup forms on our website;
• Data that you have sent to us through an online chat, phone call and support ticket;
• Self-exclusion data which include data pertaining to you and your self-exclusion such as your registration and contact data and your self-exclusion info such start and date.

For marketing purposes and to improve our websites and services, we also collect data sent by your web browser, e.g., information about your browser, your IP address, and your operating system.

4. Applicable law

Royal Panda will maintain your personal details and associated transactions; and will retain these records in accordance with all applicable laws and regulations in the jurisdictions in which Royal Panda is licensed, which may not be limited to Malta and the United Kingdom.

5. Data retention

Due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, Royal Panda is obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a player account for a minimum of five years from last player transaction or account closure. Thus, requests for erasure prior to the lapse of this period cannot be entertained.

6. Data recipients

Royal Panda does not sell or rent personal information to third parties. We do not share your personal information, except as provided in this privacy notice. These employees of Royal Panda will have access to personal data:​

• Money laundering officer
• Data protection officer
• Director of operations
• Customer support agents
• Risk and fraud analysts
• Customer retention team members
• VIP player manager(s)
• Other key persons of Royal Panda and LeoVegas approved by the Malta Gaming Authority
• Other personal management license holders for Royal Panda and LeoVegas Mobile Gaming Group

Royal Panda’s employees who have access to or are associated with the processing of the player’s personal information, have signed confidentiality agreements to respect the confidential nature of the player’s information pursuant to applicable gaming, data protection and privacy laws.

Third parties

We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of Royal Panda, LeoVegas, its customers or any third party.

Personal data will only be disclosed to third parties in the following cases:

• Where Royal Panda is required to do so by law;
• If Royal Panda needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies;
• To comply with Royal Panda’s legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;
• When Royal Panda feels that disclosure is necessary to protect Royal Panda’s or the player’s safety, or the safety of others, investigate fraud, or respond to a government request;
• If Royal Panda is involved in a merger, acquisition, changes to its gambling licenses, or sale of all or a portion of its assets, the player will be notified via email and/or a prominent notice on www.royalpanda.com;
• If Royal Panda’s marketing service providers require the data to carry out their tasks;
• If you provide your consent to receiving marketing communications from other companies of our Group;
• Self-exclusion data, for the purpose of compliance with legal obligations, notably obligation under the Gambling Act 2005, Malta Gaming Act 2018 and our license conditions, shared also with other companies within the same group, that operate licensed gambling activity, namely LeoVegas Mobile Gaming Group. Likewise, for the same purposes, LeoVegas shares your self-exclusion data with other brands under which it operates its gambling activities;
• to fulfil a compelling legitimate interest of LeoVegas in a manner that does not outweigh your rights and freedoms;
• To any other third party with the player’s prior consent to do so.

We use third-party data processors to process limited personal data on our behalf. Such service providers support Royal Panda, especially relating to hosting and operating the websites, marketing, analytics, improving the websites, and sending email newsletters. These processors are located outside the European Economic Area. Royal Panda shall ensure that the transfer of the Personal Data to the recipient is compliant with Applicable Data Protection Legislation and that the same obligations are imposed on the processor as is imposed on Royal Panda under the respective Services Agreement.

Our websites may also include social media features (e.g., share or like buttons). Such features are provided by third-party social media platforms such as Facebook. Where data is collected this way, its processing is governed by the privacy policy of the respective social media platforms.

Our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

7. Email communications

An email address collected for purposes of communication or promotion, will be used to contact you and also to send you promotional emails where you have provided your consent to do so. You may revoke your consent to receive emails for promotional purposes any time, by clicking on an unsubscribe link or updating your account preferences on our website. The same applies to third-party (Group) marketing communications.

Further, with your consent, we may make use of email tracking technology to obtain data on if you open an email or if you click on links in an email. This data will be used only to help improve future marketing messaging including prioritizing follow-ups based on perceived communications relevance. Without your consent, we will not make use of personal data unique to you, such as your IP address, your device and browser information, or the time and number of times you open an email or click on a link.

8. Technical and Organizational Data Protection

Royal Panda implements feasible technical and organizational measures to protect your personal data against abuse and loss. We store such data in secure environments that undergo regular inspections and audits as per regulatory requirements in the United Kingdom and in Malta. We provide training to our employees on data protection best practices and require them to enter into a confidentiality agreement.

While we use all reasonable efforts to protect your personal information, we cannot guarantee the absolute security of your data submitted through our websites.

9. Rights and Contact Info

You may request for information on what personal data we store in relation to you. Should your personal data be incorrect, you may have the data rectified. You may object to the processing of your personal data for direct marketing purposes, and to withdraw consent. You may request for an export of your data or transfer to another controller. You may lodge a complaint to a supervisory authority as per Article 77 of the GDPR, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement.

Please feel free to direct such requests, or other questions and comments regarding this privacy notice or the privacy practices of royalpanda.com to our Data Protection Officer:

Data protection officer
Royal Panda Limited, Level 7,
The Plaza Business Centre, Bisazza Street,
Sliema SLM 1640, Malta
Email: dpo@royalpanda.com