Playbey respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
PRIVACY POLICY
This is the (“Privacy Policy”) that governs how we, Playbey. (“Playbey”, “the Company”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about individuals who visit or use Playbey.com (together with its sub-domains, content and services, the “Site”). The Site is not structured to attract individuals under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
Important Notice
Personal Information. We have implemented a Privacy Policy because your privacy, and the privacy of other Site users, is important to us. We provide this Privacy Policy explaining our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site and certain services that we offer through or in connection with the Site. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information. It does not include data where the identity has been removed (anonymous data).
English and Translated Versions. If you are reading a translation of this Privacy Policy in a language other than English, you acknowledge and agree that (i) the English version is the official version; (ii) the non-English version is provided for your convenience only and the translation will not be valid as an agreement; and (iii) in the event of any inconsistency between the English and a non-English version, the English version will prevail and govern.
Consent and Modification. By using the Site, you consent to the terms of this Privacy Policy and to the processing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not use the Site. We reserve the right, at our discretion, to change the Privacy Policy at any time; if we do so we will notify in advance of such changes. The changes will come into effect following your confirmation of acceptance thereof.
Personal Data Changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
CONTROLLER
Playbey, referred to as the Company in this privacy notice, is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
We do not currently require you to provide Personal Information in order to have access to general information available on the Site.
We may however, collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar title and date of birth.

Contact Data includes billing address, email address and telephone numbers.

Verification Data includes a copy of your passport, driver’s license, national identity cards, a utility bill (for proof of address), and/or a copy of the front and back of your credit card that you are using in connection with your Account (we request that you cover and do not send us the credit card code verification (CVV) number; if we receive your CVV number we will use commercially reasonable efforts to delete and not store it and may ask that you resubmit a copy of your credit card without the CVV number being visible).

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including billing information, invoice related information and other data required to process your order. We may also update such data should you grant us permission to bill you or your credit card for recurring charges, such as monthly or other types of periodic payments

Technical Data includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

AGGREGATED DATA
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
SPECIAL CATEGORIES OF PERSONAL DATA
Note that, unless you provide this to us yourselves, we do not request, nor do we collect, any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). In the same manner, we do not collect any information about criminal convictions and offences.
COOKIES
To enable the working of certain functions during your visit to our website, we make use of cookies on various pages. Cookies are small text files that are stored on your device. We use two types of cookies: (i) ‘session cookies’ which are stored temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; (ii) ‘persistent cookies’ which are read only by our website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial Data and Verification Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
create an account on our website;
apply for our services;
receive payments from us (for example, in connection with lottery winnings)
purchase certain products or services from us
verify your account
send us a “contact us” or “chat with us” request;
request marketing to be sent to you;
enter a competition, promotion or survey; or
provide us with feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, logs files and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Facebook Connect. You may engage with our content, such as video, lottery games, applications, and other offerings, through third-party social networking sites, such as Facebook. When you engage with our content on or through third party social networking sites, plug-ins or applications, you may allow us to have access to certain information from your public social media profile to deliver the content or as part of the operation of the application.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, text message or phone. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To set up your account and provide our services
(a) Identity
(b) Contact
(a) Performance of a contract with you
To identify and authenticate your access to the Services
(a) Identity
(b) Contact
(c) Verification
(a) Necessary to comply with a legal obligation
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to u
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To communicate with you and to keep you informed of our latest updates:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(c) Contact you in response to a “contact us” or “chat with us” request
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To support and troubleshoot our Services and to respond to your queries
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests:
• for running our business
• provision of administration and IT services
• network security
• to prevent fraud
• in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To perform a research or to conduct analytics in order to improve and customize our Services to your needs and interests
(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Usage
(f) Marketing and Communications
Necessary for our legitimate interests:
• to study how customers use our products/services
• to develop products/services
• to define types of customers for our products and services
• to keep our website updated and relevant
• to grow our business and to inform our marketing strategy
To market our websites and products
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(a) Necessary for our legitimate interests:
• to develop our products/services
• to grow our business
(b) Consent
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Profile
(g) Usage
(h) Marketing and communications
(a) Necessary to comply with a legal obligation
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can review and make certain decisions about the use of your personal data in the My Account section of the website.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that marketing.
OPTING OUT
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product service experience or other transactions.
CHOICE
At all times, you may choose whether or not to provide or disclose Personal Information. The notices that we provide on the Site in circumstances where we collect Personal Information should help you to make this choice. If you choose not to provide the Personal Information we request, you may still visit parts of the Site, but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We do not rent, sell, or share your Personal Information with third parties except as described in this Privacy Notice.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
GOOD FAITH DISCLOSURE
We may also disclose your Personal Information or any information you submitted via the Site if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, its users, yourself or the public.
MERGER, SALE OR BANKRUPTCY
In the event that the Company is acquired by or merged with a third party entity, we reserve the right to transfer or assign Personal Information that we have collected as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how Personal Information is treated, transferred, or used. In any of the circumstances described in this paragraph, the information will be subject to the privacy notice of the purchaser or assignee.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
We share your personal data within the Company and with third party service providers. This will involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
SECURITY
The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
To the extent that we collect sensitive Personal Information from you (for example, your credit card number or other financial Personal Information), we use SSL encryption to protect that information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. If you have any questions about security on the Site, you can contact us.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us.
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
COMMITMENT
We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Site to meet these demands. If you have any comments or questions regarding our Privacy Notice, please contact us.
GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
EXTERNAL THIRD PARTIES
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Service providers acting as processors based in Israel who provide IT and system administration services.
Service providers such as WalkMe and Hotjar, acting a processors based in Israel and Malta who provide marketing services;
Service providers such as Data Dog and Humio acting a processors based in Israel and Malta who provide logging tools;
Service providers such as Twillio, BriteVerify, SendGrid, Google Cloud Messaging (GCM) and Apple Push Notification service (APNs) acting a processors based in Ireland, UK and TBC who provide communication services;
Service providers acting as processors based in Germany and the UK who provide payment services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based Malta who provide consultancy, banking, legal, insurance and accounting services.
Inland Revenue department, regulators and other authorities acting as processors or joint controllers based in Malta who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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