At zowello.com we value your privacy as much as you do and we have created this Privacy Policy that ensures your peace of mind. This privacy policy (the “Privacy Policy”), together with the General Terms and Conditions of the Site, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Site you are accepting and consenting to the practices described in this Privacy Policy.
You may contact the data controller for any questions in relation to the manner in which we use your Personal Data at https://zowello.com/contact.
1. What data we collect about you?
Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- “Identity Data” includes first name, last name, or similar identifier.
- “Contact Data” includes email address and telephone numbers.
- “Profile Data” includes your username and password (encrypted), login and logout times.
- “Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties, your communication preferences and any correspondence we had with you. This category also includes content you submit, such as, posts, comments, personal preferences, opinions, complaints, chats.
- “Technical Data” includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, your internet service provider (ISP), your device, your location, your operating system and platform, header of your requests and other online identifiers.
- “Usage Data” includes information about how you use our Website, including the full Uniform Resource Locators (URL) and page interaction information.
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
We do not collect any information 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.
2. 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 Data, Contact Data and Profile data while
a) you register to our website
b) subscribe to our newsletter
c) you contact us
d) when you participate in any of our promotions
e) you submit a content such as, posts, comments, personal preferences, opinions, complaints, chats
Automated technologies or interactions: as you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. The Site runs targeted advertisements based on your personal information. This means that the Site provides you with advertisements specifically based on your interests that we would have recorded through your interactions with the Site or else through information collected by analytics platforms that we use or through cookies. To learn more about these functionalities please visit our Cookie policy.
Third parties or publicly available sources: We may partner with third parties (like content providers and analytics companies eg. Google Analytics) to help us improve the services of the Website and better understand how you interact with the Website, as well as support our initiatives. These companies may collect information from you automatically in connection with your visit. To learn more about the cookies we use please visit our Cookie policy.
3. How is your personal information used?
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.
Please note that we may process your personal data without your knowledge in the limited situations where this is required or permitted by law.
| Purpose/Activity | Category of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new user | (a) Identity (b) Contact (c) Profile Data | (a)Necessary for our legitimate interests (to keep our records updated) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our Terms of Use or Privacy Policy (b) Maintain a User Account with us. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated) |
| To send you promotional information and newsletters | (a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing and Communications | (a) Consent (if we contact you by means of direct marketing) |
| To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | (a) Necessary for our legitimate interests (to deliver relevant interests to you through the Site based on your past activity and preferences) |
| To use data analytics to improve our website, products, marketing, customer relationships and experiences | (a) Technical (b) Usage | (a) Necessary for our legitimate interests (to define types of users, to keep our Site updated and relevant and to develop our business) |
| To make suggestions and recommendations to you about products that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Data | (a) Consent (b) Performance of a contract with you |
| To allow you to participate in any free games, tournaments, sweepstakes, and contests available on the Site (“Free Events”). To communicate with you details of any Free Events taking place, or details of any upcoming draws or results from past Free Events. In the event that you are the winner of a Free Event, to publish basic personal information on the Site informing that you are the winner. | (a) Identity (b) Contact (c) Profile (d)Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated) |
| To allow you to post your review, opinion about the casinos supporting the community | (a) Marketing and Communications | (a) Performance of a contract (enable the sites` functioning fulfilling its business purpose) |
Please remember that you can always revoke your consent in your user account, following the unsubscribe link in the newsletters or contacting us.
4. Who we share your personal data with?
We do not trade, share, transfer or disclose any of your personal information, except as is otherwise provided in this Privacy Policy or as otherwise required by and in accordance with applicable law.
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.
We may provide your personal data to its affiliates or related companies for legitimate business purposes.
We do seek to partner with companies who provide services, solutions and promotions we feel will be of value to our customers, and in such instances, we will provide you with any such services, solutions and promotions of such other companies.
We may release your information should we be required to do so by law in order to comply with any legal processes.
In the event of a merge, reorganisation or sale of the Site we may transfer all recorded personal and non-personal information to all relevant third parties. In this case, the Site will inform users before personal information becomes subject to a different privacy policy.
We transfer your personal data to our service providers or partners outside the European Economic Area (EEA). We shall only transfer your personal data outside the EEA in the event that the respective countries to which such data is to be transferred provide an adequate level of protection for your personal information.
Determining whether an adequate level of protection of your personal data is provided is based on the existence of one of the following:
- The European Commission has determined that the respective third country, territory or a specified sector within that third country ensures an adequate level of protection for data transfers;
- The service provider or partner to whom your personal data is to be transferred provides appropriate safeguards and data subject rights and adequate legal remedies for data subjects are available. Appropriate safeguards can be provided in various ways including the use of standard contractual clauses approved by the EU Commission. For more information kindly click here.
We also reserve the right to provide statistics about your use of the Site, sales, traffic, and other statistical information relating to the Site to third parties, without, however, identifying your identity.
We do not provide any warranty against the use of your information by third party sites linked to, and from, the Site.
5. General Account Registration Policy
You can register a free account with the Site. Please note it is not obligatory to do so in order to continue using the Site and participating in the promotions on offer unless stated otherwise.
Account registration is not available to children and visitors under the age of 18 years of age (or the equivalent minimum age in the relevant jurisdiction). In accordance with this Privacy Policy, the Site does not knowingly record, store or disclose any personal information related to children and visitors under the age of 18 years of age (or the equivalent minimum age in the relevant jurisdiction).
Once you have registered an account you can at any time request for the account to be de-activated, or deleted. Please note we will retain the registered information in our secure archive for statistical and analysis purposes, as explained better in Clause 7. below.
Protection of Children
The Site is an online gambling information portal and as such none of its marketing content, products, services or promotions are appropriate for, or targeted at, children and visitors under the age of 18 years of age (or the equivalent minimum age in the relevant jurisdiction). The Site does not knowingly solicit or collect personal data from children below the age of 18. If the Site discovers that it has accidentally collected personal data from a child below 18, it will remove that child’s personal data from its records as soon as reasonably possible. The Site bears no responsibility for the actions taken by children or visitors under the age of 18 (or the equivalent minimum age in the relevant jurisdiction) based on the content found on the Site, or any of its sub-domains and pages, nor our outbound marketing campaigns (including but not limited to our email newsletter).
6. What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
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 to continue 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 where we need to abide by applicable laws or where otherwise there is a legitimate interest for us not to comply with such request. Otherwise, you may ask users to delete all your personal data at any point in time, and at which point we will use our best endeavours to adhere to your request. Please note that in the event that you wish for us to delete your data related to a job application, we will not be able to consider you for future job roles which may become available and which may fit your application unless you re-apply and submit the information again.
- 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. In some cases, however, 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.
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.
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 could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
We will retain copies of any communications that you send to us (including copies of any emails, chat communications) in order to maintain accurate records of the information that we have received from you. You can also exercise your rights at any time by contacting us at https://zowello.com/contact.
7. How long we keep your personal data?
You can ask us to delete your data by closing your User Account. In that case, we will immediately delete all information aside from that which we may from time to time be required to retain by law.
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.
8. Is your data secured?
The Site has implemented the necessary and digital and infrastructure security measures at the physical IT and data storage facilities to protect against the loss, misuse and alteration of your information.
Your personal information will only be exposed to staff members of the Site who require access to certain data in order to perform the functions associated with their position in the company.
Your personal information is password-protected in a secure digital encryption environment.
We abide by all regulations for the protection of personal information.
9. Do we change our privacy policy?
Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. In the event that you do not agree with any changes, we recommend that you contact customer support or otherwise close your account.
10. Are we responsible for third party sites?
As soon as you leave the Site or are otherwise redirected to another site (“Third Party Site”) by, for instance, clicking on an advertisement or a banner of third party brands advertised on the Site, the terms and conditions, the privacy policies and data processing practices (and which we have no control over) of the Third Party Site shall apply, and the terms and conditions of the Site and this Privacy Policy shall no longer apply to you and to any use you make on any such Third Party Site.
11. Supervisory Authority
You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
