Table of Contents

1. Introduction and general terms
2. Who are we?
3. How can you get in touch?
4. What types of personal information do we collect?
5. Why do we collect your Personal Data and on what basis?
6. Cookies and similar technologies
7. When do we share your personal information?
8. Do we transfer your data outside the EEA?
9. How long will ZWEELER keep my data?
10. Your rights & choices over your personal information
11. Security of your data
12. Zweeler employees
13. Complaints
14. Changes to ZWEELER Privacy Notice

1 Introduction and general terms

At ZWEELER, we are committed to protecting and respecting your privacy and maintaining the confidence and trust of our customers.

This Privacy Notice explains how and why your personal information is collected, why it is collected and how it is kept secure.

2 Who are we?

ZWEELER adds multiple unique aspects to the basics of (Daily) Fantasy Sports gaming, making the games more attractive for everyone with big a sports heart aiming for additional family fun (and a bit of cash). ZWEELER.COM was founded on Malta on the 11^th March 2010 and received a Class 3 license on 28^th of May 2011. After 5 years the license was renewed but due to the nature of our games (more skill then gambling) we were asked to switch to a Controlled Skill Game License. We received our license on the 18^th of April 2017.

3 How can you get in touch?

There are various ways you can contact us.

For general queries do not hesitate to get in touch with our Customer Service team via email: support@zweeler.com.

If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email: dataprotectionofficer@zweeler.com

4 What types of personal information do we collect?

We collect personal information when you interact with us and use our services. Sometimes, this information is provided to us by you – like when you register for the first time and when you make use of our products or get in touch with us. Sometimes third parties or publicly available sources provide us information about you.

Information you provide to us

At registration:

• Your personal details, such as your name, email address, postal address, telephone or mobile number, gender or date of birth;
• Your account login details, such as your username and password.

Through your use of ZWEELER services:

• Information about how you interact with our products
• Information about your online browsing behavior on ZWEELER’s websites, mobile apps, and other ZWEELER content online – please see our Cookies Policy for more details;
• Information about any devices you have used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier)

Other sources of personal data

• Data received from our business partners and from other organizations, such as specialist companies providing verification services, credit reference agencies, and fraud prevention agencies.
• Publicly available sources, like postcode lookup.
• Photographic identification and proof of address documents (to carry out due diligence). This is only mandatory when the cumulative refund amount exceeds the 2,000 euro.
• Banking and financial details (to establish the source of funds where a transaction is involved). Only when you ask for a refund via bank transfer.

Information about third parties

If you give us personal information about someone else (for example via a Refer a Friend scheme) then you should not do so without their permission. Where information is provided by you about someone else, or someone else discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this Privacy Notice. This list of personal data types collected by ZWEELER is not exhaustive and further information may be requested from you when ZWEELER considers it fair and necessary to do so.

Special categories of data

Personal data collected by ZWEELER may include so called “special categories of data”, such as data revealing health (responsible gambling related). 

We have in place additional measures to protect your sensitive personal data and its confidentiality.

5 Why do we collect your Personal Data and on what basis?

We recognize the trust and confidence our customers place in us as a service provider. In return, ZWEELER is open about why we collect your data. First and foremost, collecting your information is essential for providing you the services and products you want. In addition, your data is used to personalize and improve your experience using our services, and to contact you from time to time with important information. In some cases, we need to collect and use your information to comply with the law. Under data protection laws, we also need to identify a specified lawful basis upon which we are processing your personal information. We rely on different bases for different processing activities.

1. A) Under the contract– when it is necessary for the performance of a contract to which you are a party. Our T&Cs, which you have accepted at registration, set out the terms of the contract and the services we will provide:

To make our services available to you as part of our contract

• to provide (skilled) gaming services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
• for "service administration purposes", such as password reminders, service messages, such as site maintenance, updates to our Privacy and Cookies Policy or Terms of Use, to let you know if your ZWEELER account has become dormant and to ask if you would like to use it again before we close it;
• to process your transactions;

1. B) Under legitimate interests- It is necessary to process your data for the purposes set out below, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine if we can process your data on this basis, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.

To personalize your experience

• to offer a more relevant, tailored service; for instance, we could use your playing history to provide personalized recommendations and products;
• If you are signed-in or subscribed to our marketing offers, you will receive a personalized service. If you don’t want to receive these services you can unsubscribe from marketing offers, or disable personalization by contacting support@zweeler.com or sending an email to dataprotectionofficer@zweeler.com

To contact and interact with you

• Contact you about our services, for example by phone, email or post or social media;
• Manage promotions and competitions you choose to enter;
• Respond to your queries and complaints.

To make your game safer and more enjoyable

• to deter, prevent or detect the use of third party software;

• to deter, prevent, or detect any activities conducted in breach of the ZWEELER T&Cs.

1. C) Under the legal obligation– when it is necessary in order to comply with mandatory legal obligations to which we are subject under EU or local laws:

• to determine where you are accessing the services from to redirect you to the correct country site, in accordance with our license conditions;
• to make sure we offer our services to eligible persons;
• crime detection, prevention, and prosecution;
• to verify your identity and establish the source of funding in any transaction;
• to carry out appropriate anti-fraud checks (by conducting online searches using a third party identity provider). Please note that this will not affect your credit rating;
• to assess and manage any potential risks and prevent problem gambling.

1. D) Special categories of data

We will only process such data if:

• you have given us your explicit consent;
• it is necessary for the purposes of carrying out the obligations and exercising specific rights of ZWEELER or of the data subject in the field of employment and social security and social protection law;
• it relates to personal data which you have made public;
• it is necessary for the establishment, exercise or defense of legal claims;
• is necessary for reasons of substantial public interest, on the basis of European Union or Member State law.

6 Cookies and similar technologies

ZWEELER’s websites and Apps use cookies for various purposes.

We use cookies for the following purposes:

1. to identify the Player’s preferred language, so it can be automatically selected when the Player returns to the Website;
2. to ensure that the Player receives any bonuses for which they are eligible, and
3. for analysis of the Website traffic, so as to allow ZWEELER to make suitable improvements.
4. Google analytics
5. Adsense

For more information about cookies and how they work, please visit: www.aboutcookies.org.

Manage your cookies

We recommend you don't change your cookie settings as it may limit your user experience and the performance of the site.

If you do want to change the cookies setting, you can do this through your browser. Different web browser may use different way of controlling cookies, so you'll need to use your browser's help section to find out how to do this or you can visit one of the following browser manufacturers sites directly.

Firefox

Google Chrome

Microsoft Internet Explorer  

Safari

7 When do we share your personal information?

We do not share your personal information to third parties outside ZWEELER.COM for marketing purposes. However, there are circumstances when we share your personal data with with third parties that provide services to you on our behalf, and with other third parties in the course of complying with our legal obligations. Other examples of when we share your personal information include when we enter any kind of merger or business sale. Even when it is shared, we ensure that your personal information will only be used for the purposes outlined in this policy.

With third parties

We may share personal data with third parties in the following circumstances:

• providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
• when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law;
• we may instruct and authorize the Financial Institution with which Players account is held to disclose any information as may be requested by the Regulator in respect of an Player account;
• in order to establish, exercise or defend our legal rights;
• for fraud detection and control purposes, we may transfer your personal data to third parties, including but not limited to so-called Address Verification System service providers, Age verification services, Payment Service Providers and Financial Institutions. Furthermore, we reserve the right to disclose the Players personal data to relevant parties where ZWEELER has reasonable grounds to suspect irregularities involving a ZWEELER Account;
• with service providers to enable us to provide our services, such as companies that help us with technology services, storing and combining data, and processing payments or providing relevant online advertising for our products and services;
• with external auditors who may carry out independent checks as part of our accreditations
• to an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organization receiving your personal data can use your personal data in the same way as us; or
• to any other successors in title to our business.

8 Do we transfer your data outside the EEA?

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. For instance, the computer servers used to host a website could be located outside the EEA – this is not unusual given that the internet is a global environment. Your personal information could be held at a destination which offers a different level of data protection than in the EEA. To ensure your personal information remains safe when transferred like this, we will take all reasonable steps to maintain a suitable level of protection in line with this Policy.

Any transfer of your personal information to a location outside the EEA will be based on:

• the contractual Model Clauses adopted by the European Commission or a relevant data protection authority; or
• an adequacy decision from the European Commission, confirming that the third country provides adequate protection for your personal information; or
• Privacy Shield when transferring to the US (this is a form of certification which ensures that your data is handled in a way that is compatible with the strong EU protections); or
• Your consent, or another legal basis on which we are entitled to make the transfer.

9 How long will ZWEELER keep my data?

We will only retain your information for as long as is reasonably necessary to carry out the purposes outlined above and to satisfy our legal obligations. While you are a customer, we will usually need to retain your information to meet our legal and contractual requirements. However, when you cease using ZWEELER services, we will normally still retain your personal information for a period of time.

Typically, we will store your personal information for a period of ten years after you cease being a customer of ZWEELER, beginning at the date your account is closed. There are several reasons which we retain your information, these include:

• To comply with legal obligations under EU/local laws (for example, anti-money laundering regulations, or licensing regulations);
• To establish or defend legal claims (for example negligence claims) which could be made against us.

10 Your rights & choices over your personal information

We appreciate that by law and subject to certain conditions, you have a number of rights concerning the personal information we hold about you. If you wish to exercise these rights, you should contact our Data Protection Officer using the details set out above in Section 3. These rights include the right to access, amend and erase the personal information we hold about you, the right to object to the processing of your data, the right to withdraw consent, and the right to data portability. You also have the right to complain to your data protection authority if you are concerned with how we process your information. In addition, you have certain rights relating to automated decision-making and ‘profiling’. Further information and advice about your rights can be obtained from our lead data protection authority, IDPC or from your country’s data protection regulator.

Right to access and rectify the information we hold about you

You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent by email to our Data Protection Officer at dataprotectionofficer@zweeler.com or by contacting Customer Services (see Section 3).

Right to delete your data

In some circumstances, you can ask us to erase personal information we hold about you (‘the right to be forgotten’). This includes when:

• the information is no longer necessary in relation to the purpose for which it was collected (as explained in our privacy notice);
• if you previously gave consent to the use of your information, but decide to withdraw it and we cannot justify another legal ground for using it under data protection law;
• we process your information based on our legitimate interests and we cannot demonstrate overriding legitimate grounds to continue processing the information;
• we don’t have a lawful ground under data protection law to process your information;
• the data has to be erased to comply with a legal requirement;

This right is subject to mandatory retention periods under EU/local laws.

Right to object

Based on your particular situation, you can object to the processing of your personal information, that is:

• based on our legitimate business interests ; or
• done for research and statistical purposes

You also have the right to object to the use of your personal information for direct marketing purposes (including profiling), such as when you receive emails from us notifying you about other ZWEELER services which we think will be of interest to you.

Right to withdraw consent

When we rely on your consent as the basis to process your personal information – such as for sales and marketing communications you have the right to withdraw your consent at any time. We’ll always strive to make it easy for you to withdraw consent by choosing an “unsubscribe” option in every communication you receive from us. If you find this isn’t the case, then just get in touch with our Data Protection Officer in the ways outlined above in Section 3, and we’ll try to fix things ASAP.

Rights related to automated decision making

We sometimes use systems to make automated decisions based on your personal information. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the ability to use our services.

We may use automate decisions making in the following situations:

• tailoring products and services – we may place you in groups with similar customers (segments) to study and learn about preferences and your needs, and offer more tailored experience for you;
• detecting fraud - we use your personal information to help decide and detect if your account may be being used for fraud or money-laundering. If we think there is a risk of fraud, we may block or suspend the account;
• opening account - when you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position;

Data protection law seeks to safeguard individuals against harm that may arise from decision-making that takes place without human intervention. You have the right not to be subject to a decision when it is based on the automated processing of your personal information and it has a legal effect or a similarly significant effect on you.

Please note that the right does not apply when the processing is:

• necessary for entering into or for the performance of a contract with you; or
• when it is authorized by law; or
• when it is based on your explicit consent.

11 Security of your data

ZWEELER is committed to protecting the personal information you entrust to us. We take all reasonable steps to ensure that all information collected through our Sites is treated securely and in line with this Policy and strict data protection standards. Accordingly, we have adopted robust procedures and technologies to protect your data from unauthorized access and improper use.

After logging in all information sent to and from the ZWEELER site is encrypted using 128-bit Secure Socket Layer (SSL) technology. The SSL certificate used is issued and verified by Go Daddy Secure Certificate Authority.

ZWEELER has systems in place to detect and prevent suspicious activity, to ensure that the ZWEELER website remains a secure playing-field. Any account involved in suspicious activity will be suspended and investigated to the fullest extent. Should you as user have any doubts about the activity on your account, such as unrecognized transactions in the transaction history or surprising changes in the balance, please contact us immediately.

12 Zweeler employees

All ZWEELER employees are required to comply with the terms of this Privacy Policy. This Privacy Policy provides that employees are obliged to keep Player information strictly confidential. This obligation continues once an employee is no longer employed with ZWEELER.

13 Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by emailing to: dataprotectionofficer@zweeler.com

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to our lead data protection authority, the Office of the Information and Data Protection Commissioner (IDPC) or your national data protection regulator.

14 Changes to ZWEELER Privacy Notice

This Privacy Notice may be updated from time to time to reflect changes in the way we work or the way our work is regulated - so you may wish to check it each time you submit personal information to us. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to submit personal information to ZWEELER or use ZWEELER services in any way. Otherwise, by continuing to do this, you will be deemed to have accepted the changes to the Privacy Notice. You can also delete your ZWEELER account at any time. If significant changes are made to the Privacy Notice, for instance affecting how we would like to use your personal information, we will provide a more prominent notice (including, for certain services, notification of Privacy Notice changes by email).