Privacy And Security
PAPPAKAYA is managed by PAPPAKAYA Limited (hereinafter referred to as PAPPAKAYA ). PAPPAKAYA is committed to protecting and respecting your privacy and ensuring your security when you use our Services.
PAPPAKAYA is bound by all applicable data protection and privacy laws. PAPPAKAYA Limited is registered as a data controller in Malta.
Information that we collect
We collect personal information about you (“Personal Data”) either because (i) it is required to be able to offer our Services to you or (ii) to improve our Services to you. A full list of why we process your information can be seen below under “How we use your data”. You are under no obligation to provide Personal Data to us, but much of the Personal Data we request is essential for the provision and quality of the Services we offer to you (for example, enabling you to play the games on our Websites). We may not be able to provide you with our Services if you choose to withhold requested information.
When you navigate to websites and mobile applications of brands which are managed by PAPPAKAYA Limited (“Websites”), we collect browser and cookie information. In addition, we may also collect your IP address and technical information relating to the device you are accessing our websites from.
During the registration process and when you subsequently use your PAPPAKAYA account, you are requested to submit specific personal data including, but not limited to, your first and last name, date of birth, credit card or other payment data, home or another physical address, e-mail address, phone/mobile number or other contact data. In addition, you will be asked to create a unique user name and password combination for your account. This information is required to be able to access our Services.
Once you have created an account and have become a PAPPAKAYA customer, additional information is processed on an on-going basis to ensure that our Services are offered to you in the best possible manner. You must use your unique password to access your account.
When you are logged into your account, PAPPAKAYA may collect:
- a record of all internet communications and details of your visits to our Websites.
- technical information relating to the device, such as device identifier, and browser you use to access our Websites.
- details of transactions you carry out through the site, such as payments, withdrawals and wagers.
- communications with us or our employees, for examples calls, emails, and messages sent through the live chat service.
- information regarding your location, including IP address.
- any additional information you submit through the website for example on forums, chat rooms, comment sections or in response to quizzes and questionnaires.
In certain instances, we may also request that you send us additional information to verify your identity. This may include copies of photographic identification documents, proof of address, and source of funds for your account. Your documents are stored and treated in a secure manner at all times.
In some limited instances we may conduct open source checks which access public records and publically available information about you, such as news articles, social media, forums and official records such as the electoral roll.
To protect both you and us, we use services provided by third parties to help us decide whether to accept transactions from you by assessing your method of payment, and the devices you use to visit our Websites. These third-party services check whether the device or method of payment has been identified with fraudulent or abusive transactions in the past, such as reported instances of identity theft, promotion abuse or credit card fraud.
How we use your information
We use the information we collect to provide, maintain, protect and improve our Services, to develop new ones and to protect PAPPAKAYA and You. We also use this information to offer you tailored content – like giving you more relevant promotional offers.
We process your Personal Data for the purposes of:
- creating and managing your account
- providing you with gambling services
- if necessary, contacting you via your registered contact information in connection with the management and operation of your account
- Iprocessing your online financial and wagering transactions
- researching your preferences, to develop new features, functionality, products and services
- ensuring our Websites function correctly and identifying any technical issues
- complying with all our legal and regulatory requirements, such as those relating to the identification of inpiduals under anti-money laundering legislation and ensuring responsible gambling
- preventing fraudulent activity or cheating
- determining what promotions and bonuses to offer you
- providing you, unless you have opted out, with information by the contact methods you authorise us to use about our, and selected third party services, products, competitions, prizes and offers.
We actively manage our financial liabilities and risk on events and markets. Liability and exposure controls can be applied across betting markets and or across inpidual accounts to manage those liabilities. PAPPAKAYA may assess your data to determine motivations for opening an account or placing a bet. Should your activity stand out from what PAPPAKAYA considers to be usual and expected behaviour, or fits into certain known patterns that denotes potential exposure and liability concerns, further analysis is performed. In line with our terms and conditions, we may exclude you from certain promotions or from placing certain bets as a result of this investigation. Examples of unusual betting behaviour can be, though is not limited to:
- larger than expected bets appearing on a very specific outcome, for example a correct set score in an ITF Tennis match;
- a bet being placed by a customer who may be privy to information regarding the potential outcome of an event;
- a customer changing their established betting pattern;
- Ian alert from a sport’s governing body or monitoring agency
- a large number of bets placed in a short time period on one specific outcome.
Any analysis performed is a private business owned commodity and is not transmitted to any third party. PAPPAKAYA reserves the right to apply restrictions to customer accounts where it believes it to be appropriate to their betting activity.
Who we share your data with
PAPPAKAYA takes your privacy very seriously. Wherever possible, for example for the purposes of marketing, we will not share your data with a third party without first asking for your consent. In the case of sensitive personal data (as defined by the Data Protection Act) we will only share it in the case of specific consent from you.
Certain trusted third party companies provide services essential to our ability to offer our gambling products to you, for example those that supply the software and games for our Websites, banking and payment services, identity verification, fraud prevention and risk management. We may be required to share some of your information with these companies to be able to offer our Services to you. In these instances, we ensure that the third party has appropriate security and privacy arrangements in place, so that your data is protected.
In the event of the sale of our business, or other business event, which results in us having to transfer your personal data to a third party, you will be notified via email, or notice posted on our website, to explain the identity of the new data controller and your options regarding your personal data.
Our site may contain links to and from the Websites of third party organisations. Please note that these Websites may have their own privacy policies and that we do not accept any responsibility whatsoever for these policies. Please check these policies carefully before you submit any personal data.
Marketing and Opting Out
PAPPAKAYA reserves the right to process personal data for marketing purposes and in certain limited circumstances to provide this to our third-party partners for the purpose of marketing PAPPAKAYA Services to you.
We request your consent to market to you when you first create an account with us. You can choose not to receive marketing/promotional material at any time by clicking the unsubscribe link from promotional material being received or by contacting us at email@example.com.
If you have opted out of marketing from us, we will take all reasonable steps to ensure you no longer receive promotional material about PAPPAKAYA . This may affect your eligibility for certain promotional bonuses.
Access to your information
You have the right to request information on what data PAPPAKAYA has processed about you and to access your personal data.
You also have the right to correct and/or erase wrong and/or inappropriate data, so long as specific gambling regulations do not require us to retain certain personal information about you.
To exercise such rights, you are required to submit a request, detailing what information you wish to enquire about, together with proof of identity to firstname.lastname@example.org. We may charge a fee for providing certain records of your personal data. We are committed to providing your data within 40 days of receiving a valid request.
Should you require additional information on how to request your information from PAPPAKAYA please write to email@example.com.
Cookies are text files containing a small amount of information that are downloaded to your device when you visit a website. They are generally used by most websites to improve your online experience and to ensure that content and functions are delivered and used more effectively.
Cookies perform various different functions. For example, some cookies are session cookies, which are downloaded to your device temporarily for the period that you browse a particular website; these cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Other cookies are persistent cookies, which can be used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to your specific needs and interests
You agree that PAPPAKAYA may, from time to time, place cookies on your device to save information (such as user name, password, other personal details, e-mail address, technical device information such as the model and its IP address) to make full use of the functionality and Services on our website and to allow your browser to identify you as a user. This enables you to not have to re-enter this information each time you visit the PAPPAKAYA site. These cookies cannot be used to run programs or deliver viruses to your computer, and are uniquely assigned to you. These cookies can only be read by the web server(s) that placed the cookies on your device.
At any time you can amend your browser settings to block some or all cookies from PAPPAKAYA . However, if you block cookies from PAPPAKAYA some or all the website’s functions may not perform as intended. For example, you may not actually be able to place any bets.