Privacy policy

The introduction

This Privacy Policy (hereinafter the “Policy”) governs the processing of your personal data (hereinafter shall be also referred to as “data”) when you visit or use the website https://vulkanvegas.com/ (hereinafter the “Website”) or communicate with the Website's administration via available contact details.

Information about us

The Website is owned and operated by two joint controllers (as defined by Article 26 of the Regulation 2016/679 (hereinafter the "GDPR")): a) Invicta Networks (License 8048/JAZ2012-009) N.V., address: Heelsumstraat 51, E-Commerce Park, Curaçao, P.O. Box 422, Registration number: 123787; and b) Brivio Limited, the company incorporated in the Republic of Cyprus, with its registered number HE 315596, with its registered address at Office 102, 12A Lekorpouzier, Limassol, Cyprus. These two joint controllers shall hereinafter be referred to as the "Company", "We", "Us", "Our".
You can contact us for any issue relating to data processing via e-mail [email protected].

What data we process

Contact data. When you communicate with us via the interface of the Website or via available contact details, you provide us with the following data:
• Your contact details: it may be your postal address/email address/phone number;
• Your name;
• All the information you provide us during our communication;
• Additionally, we record the history of your communication with us, which includes the record of audio calls with us (for example, when you communicate via audio with our Support team etc.)

Account data. When you create an account on the Website, you provide us, in addition to your Contact data, with the following:
• Your name;
• Your gender;
• Your birth date;
• The information about coupons you have activated;
• Your username (if applicable);
• Your Skype account;
• Additional data (if applicable).

Additionally, if you have excluded your account from gambling for a specific time period or have blocked your account permanently, we will also have this information recorded.

Newsletter consent data. We collect the data on whether have you consented to receive our Newsletter.

Referral data. We collect the data about your referral (referral user or the referral affiliate).

Bets data. These data include information about bets you have made and on what outcomes, games you have played and the total amount of winnings and losses and similar information.

Verification data. During the Verification process you will be required to provide us with the following data:
• A copy or a photo of your identification document;
• A photo of your payment instrument or other evidence that you are a holder of a payment instrument used or intended to be used for making transactions;
• A photo of you;
• A photo of you bearing your identification document and payment card;
• Your address confirmation. It may be a utility bill, telephone bill or other documents which, in accordance with your jurisdiction's legal and regulatory requirements, shall be enough to confirm your address;
• A confirmation of the source of your wealth and your funds (in some situations);
• The record of your video calls/audio-calls with the Website`s administration (if Verification is made via audio/video call);
• When performing Verification, we check some users of the Website in state registers, databases of politically exposed persons and other reliable sources and collect additional data from them.

Payment data. The Company does not directly process your payments: they are processed by third-party payment providers. This means that we receive your Payment data from these payment providers. These include the following data:
• The information about your payment card or payment instrument (first six and last four digits and a name of the cardholder - first three letters of the name and last three letters of a surname or, in some cases, first three letters of the surname and last three letters of the name);
• Information about your transactions and the data which are necessary to identify transactions.

Loyalty Program data. For the frequenters of the Website, we created our Loyalty Program. It means that we create data about the participation of the user within this Program. These data include:
• Your points earned;
• Your level;
• Cashback amount;
• Other data which may be processed within the Loyalty Program.

Bonus data. We process the data about your use of the bonuses within the Bonus Program. These data include, but not limited to:
• Information about the bonuses you have used;
• Your Bonus balance.

Automatically collected data. When you use the Website some data are collected automatically. These data are received from your web browser and then analysed by us. These data include the following:
• The total time you spend on the Website;
• What internal links were clicked (based on the URL of the next pageview);
• Your IP address and user agent string (which browser is being used, what version, and on which operating system).

Cookies data. Cookies may collect data that fall within the definition of “personal data”. To find more information about the use of cookies, please, follow cookie policy.

Purposes and legal bases for the processing.

Purpose Data Legal basis/bases
Purpose

Administer and protect the Website:

  • To protect the Website from any cyberattacks (including, but not limited to DDoS attacks);
  • To diagnose any problems with the Website or the server which makes the Website available.
Data

a) Automatically collected data;
b) Cookies data.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Administration and protection of the Website and the Server which makes the Website available are the legitimate interests of the Company.

Purpose

To create your account and provide you with the Services available on the Website. Without these data, we are incapable of creating your account on the Website and providing you with our Services.

Data

a) Contact data;
b) Account data;
c) Bets data;
d) Payment data.

Legal basis/bases

Performance of the contract in accordance with Article 6(1)(b) of the GDPR. These data are essential to open your account and without these data, we would not be able to conclude a contract with you and open your account on the Website.

Purpose

To conduct Verification. We conduct Verification for the purposes of a) compliance with applicable anti-money laundering and counter-terrorist financing legislation: from this follows that provision of Verification data is required by the law. Without these data, we would be incapable of complying with our legal obligation under the legislation mentioned above; b) prevention of fraud, cheating and violation of the Terms and Conditions of the Website. In some cases, we conduct additional verification (for example, via video-call) in order to prevent violation of our Terms and Conditions (which are a contract between you and us), cheating and fraud. From this follows that additional verification is the procedure required by the contract between you and us; c) prevention of the use of the Website by children.
Without Verification, we would not be able to create your account (in some cases) or allow the continuation of operation of your account.

Data

Any data concerning you we possess.

Legal basis/bases

a) When Verification is conducted for the purposes of compliance with money laundering and counter-terrorist financing legislation and prevention of the use of the Website by children: compliance with the legal obligation to which the Company is subject under Article 6(1)(c) of the GDPR;
b) When Verification is conducted for the purposes of prevention of fraud and cheating: Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Prevention of fraudulent activity and cheating is the legitimate interests of the Company;
c) When Verification is conducted for the purposes of prevention of violation of the Terms and Conditions of the Website: performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR. Our Terms and Conditions are the contract between you and the Company and your failure to pass the verification will be in breach of this document.

Purpose

To comply with the requests from governmental authorities, courts and other similar bodies.

Data

Any data concerning you we possess.

Legal basis/bases

Compliance with the legal obligation to which the Company is subject under Article 6(1)(c) of the GDPR;

Purpose

To contact you.
We may contact you for various purposes:

a) When you contact us via the interface of the Website or via contact details available on the Website and ask a question about our Website, the Company etc.;
b) When you use the Website, you communicate with the Support Team and other staff of the Company who may be engaged in provision to you our Services, or solving of your problem(s) connected with your use of the Website;
c) Additionally, we can use your contact data to communicate with you about changes in our Website, products, services, and documents/rules which affect you.

Data

Contact data and any other data which we have about you (if required by the purpose of communication).

Legal basis/bases

a) If you do not have an account on the Website and communicate with us about the general issues: Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Communication with the general public is the legitimate interest of the Company;
b) When we communicate with you in the course of your use of the Website, your account or our Services: performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR. Without these communications, we would not be able to provide you with some functions of the Website and/or solve your problems that can arise during your use of the Website.

Purpose

To comply with your data subject`s requests and other legal requests from you.

Data

Any data concerning you we possess.

Legal basis/bases

Compliance with the legal obligation to which the Company is subject under Article 6(1)(c) of the GDPR.

Purpose

To exercise your self-exclusion. If you have decided to conduct self-exclusion (to block or restrict your account for a specific time period or block your account permanently), we will use your data to conduct this self-exclusion.

Data

a) Verification data;
b) Account data;
c) Contact data;
d) Payment data;

Legal basis/bases

Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.

Purpose

To send you our Newsletter.

Data

a) Newsletter consent data;
b) Contact data.

Legal basis/bases

Your consent given in accordance with article 6(1)(a) of the GDPR.

Purpose

To improve the Website and its functionality:
a. Testing new functions and features on the Website;
b. Research and analysis.

Data

a) Automatically collected data;
b) Cookies data.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Improvement and enhancement of the Website and the Services which are provided via the Website are the legitimate interests of the Company.

Purpose

Provide you with the Website
and with the Website tailored for your device and the settings installed on your device.

Without Automatically Collected data and Cookies data, the Website may not work and/or may not work correctly. For example, if you disable cookies you will not be able to log in to the Website and we will not be able to remember your website choices (for example, the language of the Website).

Data

a) Automatically collected data;
b) Cookies data.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Provision of the Website to its users is the legitimate interest of the Company.

Purpose

To prevent violation(s) of our Terms and Conditions, cheating, collusion, use of the Website in bad faith and other similar activity.

Data

Any data concerning you we possess.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Prevention of violation(s) of our Terms and Conditions, cheating, collusion, use of the Website in bad faith and other similar activity are the legitimate interests of the Company.

Purpose

To calculate commission to the referrer who has directed you to the Website.

Data

a) Account data;
b) Contact data;
c) Bets data;
d) Payment data.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. Calculation of the commission to the referrers is the legitimate interest of the Company.

Purpose

To establish, exercise and defence legal claims. We may use your data in order to protect our legal interests in courts disputes, legal disputes etc.

Data

Any data concerning you we possess.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. The establishment, exercise and defence of legal claims is the legitimate interest of the Company.

Purpose

To facilitate your payments via the Website. Without your Payment data we will not be able to process your payment and, subsequently, provide you with the Services of the Website.

Data

Payment data.

Legal basis/bases

Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.

Purpose

To calculate your Website balance (both real and bonus).

Data

a) Payment data;
b) Bonus data;
c) Loyalty program data;
d) Bets data.

Legal basis/bases

Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.

Purpose

To calculate your cashback.

Data

a) Payment data;
b) Bonus data;
c) Loyalty program data;
d) Bets data.

Legal basis/bases

Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.

Purpose

To provide VIP support for some users.

Data

a) Payment data;
b) Bonus data;
c) Loyalty program data;
d) Bets data.

Legal basis/bases

Legitimate interests of the Company in accordance with Article 6(1)(f) of the GDPR. VIP support for some users is the legitimate interest of the Company.

Purpose

To provide you with our Loyalty Program.

Data

a) Payment data;
b) Bonus data;
c) Loyalty program data;
d) Bets data.

Legal basis/bases

Performance of the contract to which you are party in accordance with Article 6(1)(b) of the GDPR.

Recipients of your data

Our subcontractors, affiliated companies and other entities. The Website and Services provided via the Website are maintained and provided by a large number of people who may be employed either by the Company or by any of our affiliated companies, subcontractors, and other establishments. This means that your data may be shared with them. Please note that all these transfers are secured by proper data transfer agreements which oblige these recipients to process your data in accordance with this Policy and with the data protection legislation to which the Company is subject.

Data centre(s) which make the Website available. The Website and the Services provided via the Website are placed on the Server which belongs to the third party. From this follows that your data will be shared with them. Please note that your data are stored only in encrypted form, which makes it impossible to decrypt your data without decryption keys.

Financial institutions: banks, payment services providers, payment systems/gateways and other similar entities. Your transactions for the Services provided via the Website are processed by the third-party financial institution(s). This means that your data will be shared with them to process your transactions and perform their legal and regulatory obligations.

Сourier companies. If you win any physical winning(s) or prize(s), your data will be shared with a courier company that will be engaged in the process of delivery of a winning or a prize to you.

Accreditation bodies, auditors. When the Company passes an independent audit, the data concerning you may be shared with the auditor. All these bodies or auditors are legally obliged to handle your data in accordance with this Policy and applicable legislation.

Analytics. This includes Google Analytics, Yandex Metrika and Hotjar.

Google Analytics. The Website uses Google Analytics, a web analytics service. It is operated by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses previously mentioned "cookies". The information generated by the cookie about your use of the Website is usually transmitted to a Google server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.

Cloudflare, Inc. The Company uses the services, provided by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Сloudflare provides web optimization and security services that the Company uses to improve and protect the Website, including a reverse proxy, pass-through security service. Cloudflare may collect the log data from the visitors of the Website. Additionally, the Company deployed Cloudflare`s cookie file for security purposes (see Cookies Policy to find out more). To find out more about the processing of the data by Cloudflare, please follow https://www.cloudflare.com/privacypolicy.

Hotjar. Hotjar (registered place of business: Hotjar Ltd, Level 2 St Julians Business Centre, 3, Elia Zammit Street St Julians STJ 1000, Malta) is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, etc.) and this enables us to maintain, and improve our Website. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular a device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. If you want to opt-out from the processing of the data concerning you by Hotjar, please, follow Hotjar`s Opt-out Webpage via the link https://www.hotjar.com/legal/compliance/opt-out.

Yandex.Metrica. Yandex.Metrika is a web analytics service offered by Yandex Oy, Moreenikatu 6, 04600 Mantsala, Finland. Yandex.Mertica tracks and reports website traffic. Yandex uses the data collected to track and monitor the use of our Website. This data is shared with other Yandex services. If you want to opt-out from the processing of the data concerning you by Yandex, please, install Yandex.Metrica opt-out add-on from this link https://yandex.com/support/metrica/general/opt-out.html.

How long we will store your data

For the data of our users who possess an account on the Website: 6 (six) years starting from the date you closed your account on the Website and our contract with you is terminated. Please read more about the storage of your personal data in our FAQ on data retention.

Your data subject`s rights

Under applicable data protection legislation, you have the rights which you can exercise either by a) sending a request to us to our registered address; or b) sending a request to our email address [email protected]; or c) via the interface of the Website (for some functions).

Please note, that these rights are applicable with some restrictions:

  • If we are not sure about the identity of the requestor, we will verify the identity of a user/visitor who requests for the implementation of any of the rights before the implementation;
  • We may restrict the rights specified below or deny in implementation of any of the rights if this restriction or denial is grounded on the legislation to which the Company is subject or if we can deny implementation of your request under applicable legislation. In this case, we will specify the reason for the denial in the reply to your request;
  • Information contained in this section is just an informational description of the rights under the GDPR and has no legal effect. If you want to find more about each right, please refer to Articles 15-22 of the GDPR.

Your rights are the following:

The right to withdraw consent. If you previously consented (under Article 6(1)(a) of the GDPR) to the processing of your data, you have the right to withdraw this consent at any time. It means that we will stop the processing of the personal data for the processing of which the consent was required starting from the date of the withdrawal. The withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal.

The right of access. You have the right to obtain from us the confirmation as to whether or not the data concerning you are being processed, and, if we indeed process your personal data, to receive a copy of the personal data undergoing processing.

The right to rectification. You have the right to obtain from us the rectification of inaccurate personal data concerning you.

The right to erasure (or the right "to be forgotten"). You have the right to obtain from us the erasure (removal) of your personal data. Upon your request, your personal data shall be removed. This right shall be applied if:
• your personal data are no longer needed for the purposes for which these data were collected;
• you have withdrawn your consent (if you have provided this consent) and there are no other legal bases for further processing;
• we do not need to keep your personal data for the purposes of compliance with the applicable legislation;
• the data are processed unlawfully;
• there are no any restrictions of this right by the applicable legislation;
• in other cases when the erasure (removal) is required by the applicable law.

The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by the Company or by a third party (Article 6(1)(f) of the GDPR). Additionally, you have the right to object to the processing of your personal data for direct marketing purposes (if applicable).

The right to restriction of the processing. You have the right to obtain from us restriction of processing, in case if one of the following applies:
• you contested to the accuracy of the personal data, for a period enabling the Сompany to verify the accuracy of the personal data;
• processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of the Company.

The right to data portability. You have the right to receive from us the data which were collected from you, in a structured, machine-readable format and have the right to transmit those data to another controller (in a plain language, to another company). This right applies only to processing which:
• Was carried out by automated means;
• Is based on Articles 6(1)(a) and 9(2)(a) of the GDPR (consent) or is based on Article 6(1)(b) of the GDPR: processing which was carried out under the contract between you and us.

The right to lodge a complaint with the supervisory authority

You can always contact us for any issue concerning the processing of your data, including complaints. Nevertheless, if you suppose that your rights under applicable data protection legislation have been violated, you can lodge a complaint both:

  • With the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our incorporation). The Website of the Commissioner http://www.dataprotection.gov.cy; or
  • With the data protection authority of the country of your habitual residence or place of work. You can find the list of all EU Data Protection Authorities on the Website of the European Data Protection Board https://edpb.europa.eu/about-edpb/board/members_en.

International data transfers

Our Company does business globally, which means that your data may be transferred to the so-called “third countries” within the meaning of the GDPR. Below you can the information about the following:

Description of the transfer Third country Legal mechanism of the transfer
Description of the transfer

Transfer of the data to Google LLC.

Third country

The United States of America.

The existence or absence of an adequacy decision by the European Commission: absent.

Legal mechanism of the transfer

Standard Contractual Clauses between Yandex Oy and Russian-based parts of Yandex group. Standard Contractual Clauses are adopted by the European Commission subject to article 46(2)(c) of the GDPR (hereinafter " Standard Contractual Clauses"). To find out more about Standard contractual clauses for data transfers between EU and non-EU countries, please, follow this link: https://ec.europa.eu

Description of the transfer

Transfer of the data to Cloudflare, Inc.

Third country

The United States of America.

The existence or absence of an adequacy decision by the European Commission: absent.

Legal mechanism of the transfer

Standard Contractual Clauses.

Description of the transfer

Transfer of the data by Yandex Oy within the Yandex group.

Third country

Russian Federation.

The existence or absence of an adequacy decision by the European Commission: absent.

Legal mechanism of the transfer

Standard Contractual Clauses.

Description of the transfer

Transfer of the data to Invicta Networks N.V.

Third country

Curacao.

The existence or absence of an adequacy decision by the European Commission: absent.

Legal mechanism of the transfer

Standard Contractual Clauses.

Description of the transfer

Other recipients.

Third country

The existence or absence of an adequacy decision by the European Commission: absent.

Legal mechanism of the transfer

For regular transfers: Standard Contractual Clauses. If the transfer is occasional: derogations for specific situations in accordance with article 49(1)(b) of the GDPR (the transfer is necessary for the performance of a contract between you and the Company).

Processing of children`s data

The Website is not intended for users under the age of 18 or under the age required to participate in gambling in the place of the residence (jurisdiction) of the particular user ("Legal Age"). If you are a parent or a legal guardian and have found that your child uses our Website, please contact us via any available means of communication and we will apply appropriate measures.

Third-party websites

This Website may contain links to Websites owned by third parties. For example, links/hyperlinks to third-party websites (hereinafter " third-party websites"). You follow those links/hyperlinks at your own risk. The Company bears no liability for the content of any of those Websites and bears no responsibility for anything that can happen as a result of your visit to those third-party`s websites. The Company recommends you to visit "Privacy Policy" or "Data Policy" or another privacy document on any of these Websites before submitting any data concerning you to the latter.

Changes to this Policy

The Company may change this Policy. In case of any changes, the Company will post a revised Policy before these changes will come into force. The Company will notify registered users about the changes to this Policy by sending an e-mail notification. Continued use of the Website by you shall be interpreted as you have read and understood the revised Policy.

Languages of this Policy

This Policy was made in the English language. Please note that other language versions of this Policy are made for convenience. In case of inconsistency between the language versions of this Policy, the English version shall prevail.