Privacy Policy

1. INTRODUCTION

Respecting the privacy of individuals is essential for Bragg Gaming Group. We are committed to protecting data and ensuring security and confidentiality.

This privacy policy is intended to provide you with a transparent overview of how Bragg Gaming Group processes your personal data while you are visiting the https://playground.bragg.group website (hereinafter referred to as: “Playground”). Please read it carefully before providing your personal data to understand how your personal data will be processed.

BY ACCESSING THE PLAYGROUND, YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN AND BY USING OUR WEBSITE YOU EXPRESSLY CONSENT TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND GRANT US THE RIGHTS SET FORTH HEREIN.

References to “Bragg Gaming Group”, “we” or “our” shall include Bragg Gaming Group Inc..

2. MINIMUM AGE

We do not accept registrations or orders submitted by and do not knowingly collect or use personal data from anyone under the age of eighteen (18) years, or any other age limit set out by the law of his/her country of residence. By accessing and using the Playground and services, you confirm that you have reached the age of majority in your country of residence.

3. CONTROLLER AND CONTACT DETAILS

The personal data that are processed due to the use of the Playground, including with participation in prize competitions, are controlled by Oryx Sales Distribution Limited, a Cyprus company, having its business address at Menandrou, 4, GALA TOWER, 2nd floor, Flat/Office 201, 1066, Nicosia, Cyprus (hereinafter: “Bragg”).

For any clarification, question or requirement related to your privacy and the processing of your personal data, please contact: [email protected].

4. PERSONAL DATA WE COLLECT ABOUT YOU

The Playground offers the users to test and demo Bragg Gaming Group produced and hosted RGS games. Additionally, the option of creating a personal account is available which will allow you to test and demo Bragg Gaming Group produced and hosted player engagement tools and occasionally partners will be able to partake in tournaments and win small monetary prizes (hereinafter: prize competitions).  We require the following information in order to approve the creation of the account with us: first name, last name, birth date, country of residence, email, job title, company name, nickname and password (hereinafter: registration data). You are under no obligation to provide us with data we need for the provision of requested services, however if you fail to provide these data, we will not be able to execute the services you requested. Additionally, when you create an account, we will process the player ID (uniquely created for each personal account) in combination with game-play data (, last login, last open game, duration, game session, wagers, balance, balance changes, …) and device information.  

When you access the Playground, we will also collect technical information such as your IP address, country of access, information about your device and information collected through cookies. In addition, we also collect and process information about how you are using Playground, including log files containing information about your visit to our website (e.g. the duration of your session, time of visit and page interaction information).

If you are accessing the Playground from the UK, you will need to provide us information about your birth date for the purpose of proving you have reached the age of majority before we allow you access to the Playground.    

If you decide to participate in prize competitions, the following data shall be processed in combination with registration data, player ID and game-play data: amount of prizes won, transaction account number (in case the prize is paid out in real money), tax number (in case needed to report the win to tax authorities), birth date. By joining the tournament, you agree to your username being displayed on the top players’ list.

5. USE OF YOUR PERSONAL DATA

Generally, the technical information that we collect when you visit the Playground, is processed by us to deliver and improve our services, including the Playground itself. Such non-directly identifiable information (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the Site, the device used and other information) shall also be processed for the purpose of optimising and enhancing the technical security of Playground, for statistical purposes and for providing you with a better experience based on data analytics and market research. Furthermore, such browsing data may be used to verify that Playground is functioning properly. From time to time, browsing data are processed anonymously for statistical purposes.

When applicable, e.g., if you're accessing the Playground from the UK, we process your information for the purpose of verifying that you are of minimum age and thus complying with the local regulatory requirements.

If you decide to create a personal account at Playground, we will use the information provided to decide on the approval of account creation and to provide the player engagement toolset functionalities as well as enable you to partake in tournaments and win small monetary prizes.

If you decide to participate in prize competitions, personal data will be processed to determine the winner of the competition, to notify the participants of the competition outcome, to pay out the prize, to publish the name of the winner of the competition and to satisfy any regulatory requirements (such as to report the amount of win to tax authorities (if required in line with the applicable legislation)).

6. RIGHT TO WITHDRAW CONSENT OR OBJECT TO LEGITIMATE INTEREST PROCESSING

Where the legal basis for processing of your personal information is your consent, you have the right to withdraw that consent at any time. You can exercise this right by contacting us at: [email protected], by clicking the “unsubscribe” button in our marketing emails or by choosing a similar opt-out option that we may provide to exercise your right to object to the processing of your personal data.

If you created an account with us and no longer want to use it, please let us know by writing to [email protected] and we will delete your account.

When we use legitimate interest to process personal data we are carefully weighing between our interest and the fundamental rights and freedoms of individuals. The data subjects have the right to object, on grounds relating to each data subject’s particular situation, at any time to processing of personal data concerning the data subject.

7. TRANSFERING YOUR PERSONAL DATA OUTSIDE OF THE EURPOEAN ECONOMIC AREA AND DATA SECURITY

While your personal data is primarily stored and processed on servers inside the European Economic Area (EEA), please note that we are a global company, and we need to transfer the information outside the EEA between companies within Bragg Gaming Group and/or to other third-party service providers around the world.  However, if we do transfer personal data collected within the EEA to third parties outside the EEA, such transfer will be done either to a country where the EU Commission has confirmed an adequate level of protection or where careful handling of personal data has been ensured by means of suitable guarantees such as EU Standard Contractual Clauses.

We place great importance on the security of all personal data associated with our users. Consequently, we have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. To further ensure the best possible protection of your personal data outside the limits of our control, we strongly advise you to protect your device (e.g. by updated antivirus systems) and ensure that your internet service provider has taken appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).

Regardless of the steps we take to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur. Respectively, by using the Playground you accept the inherent security implications of dealing online over the internet and will not hold Bragg Gaming Group or their processors responsible for any data breach unless it is due to our negligence.

Should you require further information with regards to transfers of personal data, you can contact us at: [email protected].

8. DATA RETENTION

We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

If you created an account with us, we will keep the data for as long as the account is open and delete it in 3 years after you decide to close the account.

If you participate in prize competitions, your data will be kept for 2 years (or longer if required under applicable legislation, such as to satisfy and tax or accounting rules).

In some circumstances, certain personal data can be erased upon receiving your request.

9. HOW WE SHARE THE INFORMATION WE COLLECT

We disclose your personal data to our affiliate companies and to our third-party service providers who assist us in providing the services, fulfilling requests for information, receiving and sending communications, providing support services or in performing other tasks.

Playground also embeds some social media features from Facebook, LinkedIn, Twitter, Instagram, YouTube, Vimeo, which require you to set up a cookie in order to function properly and may allow the respective social media provider to collect your IP address and information on which page you are visiting.

In the event of a corporate merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, your personal data may also be shared with the relevant third party.

Access to your personal data will be limited only to authorized personnel of the Bragg Gaming Group and to service providers acting on our behalf on a need-to-know basis. On (rare) occasions, we may also share your personal data with law enforcement, data protection authorities, government officials, and other authorities if:

• compelled to do so by a subpoena, court order, or other valid legal procedure;
• we believe that the disclosure is necessary to prevent physical harm or financial loss;
• disclosure is necessary to report suspected illegal activity;
• disclosure is necessary to investigate violations of this privacy policy or other legal agreements;
• we obtain your consent or at your direction.

10. THIRD PARTY LINKS

Playground may include links to third-party websites, plugins, channels or other applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you use the third-party services, we encourage you to read the privacy notice of every website or application you use.

11. YOUR DATA PROTECTION RIGHTS

Under certain circumstances, you have the following rights under data protection legislation in relation to your personal data:

• Request access to your personal data. You have the right to request that we provide you access to your personal data held by us.
• Request correction of your personal data. You have the right to request the correction of any personal data we hold that is inaccurate, incorrect, or outdated.
• Request erasure of your personal data. You have the right to request deletion of your data when it is no longer necessary, or no longer subject to legal obligations to which we are subject to. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data. You have the right to request that we cease processing some of your personal data, such as personal data processed for direct marketing purposes. Also, you have the right to object to solely automated processing and to profiling activities based on our own legitimate interests.
• Request restriction of processing your personal data. You have the right to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns with this information, or we no longer need your personal data for the purposes of the processing, but they are necessary for the establishment, exercise or defence of legal claims).
• Request transfer of your personal data. You have the right to request an export of your personal data.

Whenever personal data is processed based on your consent (i.e., in case you have chosen to subscribe to our Newsletter), you retain the right to withdraw your consent at any time. You can do so by clicking on the ‘unsubscribe’ link in any email that we send (or a similar opt-out option that we provide) or by contacting us by sending an email to the address stipulated below.

All requests are generally free of charge, and we try to respond to all legitimate requests within one month. However, we may charge a reasonable fee based on administrative costs or/and take more time if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Please address your requests to: [email protected].

12. USE OF COOKIES

When you use the Playground, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “cookies”) on your computer or other access devices.

12.1. What are cookies?

Cookies are small files that are sent from the web server to the user’s computer via the user’s browser. They are then stored in the user’s computer as text files and passed back to the server. Cookies are generally used to identify users and, on occasion, prepare customized web pages for them.

12.2. What cookies do we use?

We use both session and persistent cookies. Session cookies expire when you log out of your account or close your browser. Persistent cookies remain on your computer or other access device until deleted or otherwise expire.

We use the following cookies:

12.3. Consent

Where lawfully required, we will ask you to provide your consent for the use of non necessary statistics and marketing cookies.

12.4. How to manage cookies?

You can control which cookies you want to be stored on your computer through the settings in your web browser. You may refuse cookies by turning them off in your browser. However, you should be aware that choosing to remove or disable our cookies may interfere with your use and functionality of our website and you may not be able to access all or parts of our website.

For more information about cookies and how to block, delete or disable them, please consult your browser’s help pages for instructions on how to do this, or contact us at [email protected].

13. CHANGES TO THIS PRIVACY POLICY

Occasionally we may, in our discretion, make changes to the privacy policy by posting a revised version and updating the ‘Effective Date’ at the end of this privacy policy. The revised version will be effective on the “Effective Date” listed.

14. CONTACT

If you have any questions or concerns regarding our privacy policy or if you believe our privacy policy or applicable laws relating to the protection of your personal information have not been respected, you can file a complaint with us by using the contact details listed below and we will respond to let you know when you can expect a further response. We can request additional details from you regarding your concerns and may need to engage or consult with other parties to investigate and address your issue. We will keep records of your request and any resolution. Our contact information:

Oryx marketing d.o.o.

Litostrojska cesta 52

1000 Ljubljana

Slovenia

Email: [email protected]

You also have the right to lodge a complaint regarding the processing of your personal data by us at any time with your local data protection authority (see https://edpb.europa.eu/about-edpb/about-edpb/members_en). We would, however, appreciate the opportunity to deal with your concerns before you approach the authorities, so please contact us in the first instance.

Effective date: February 2024