Privacy Policy

1. Who We Are (Data Controller)

Pirots4Play Ltd. is the data controller responsible for your personal data collected via this website. This means we determine the purposes and means of processing your personal data.

2. Key Definitions

• Personal Data: Any information relating to an identified or identifiable natural person (a "data subject").
• Processing: Any operation performed on personal data, such as collection, storage, use, disclosure, or deletion.
• Data Controller: The entity that determines the purposes and means of processing personal data (that's us, Pirots4Play Ltd.).
• Data Processor: An entity that processes personal data on behalf of the Data Controller.
• UK GDPR: The General Data Protection Regulation as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018.
• YMYL: "Your Money Your Life" – A Google Quality Rater Guideline category for content that can significantly impact a person's health, financial stability, or safety.

3. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you. We have grouped these into categories to help you understand what data is collected.

4. How and Why We Use Your Data (Purposes and Legal Bases)

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 (e.g., managing your account, allowing you to play games).
• 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 (e.g., improving our services, preventing fraud).
• Where we need to comply with a legal or regulatory obligation (e.g., age verification, AML checks, reporting to the UKGC).
• Where you have given your explicit consent (e.g., for certain marketing activities or non-essential cookies).

Specific Uses of Your Data:

a. To Provide and Manage Your Account

• Purpose: To register you as a new customer, verify your identity, manage your account, and provide customer support.
• Data Used: Identity, Contact, Profile, Verification, Correspondence Data.
• Legal Basis: Performance of a contract with you; Legal obligation (for verification); Legitimate interests (for customer support).

b. To Facilitate Gameplay and Payouts

• Purpose: To allow you to play the PIROTS 4 game, track your bets, calculate wins and losses, process deposits and withdrawals, and apply bonuses.
• Data Used: Identity, Financial, Transaction, Gameplay, Profile Data.
• Legal Basis: Performance of a contract with you; Legal obligation (for AML/payment regulations).

c. For Security, Fraud Prevention, and Anti-Money Laundering (AML)

• Purpose: To detect and prevent fraudulent activities, money laundering, terrorist financing, and to protect the integrity of our services. This includes automated monitoring of transaction patterns and gameplay behaviour.
• Data Used: Identity, Contact, Financial, Transaction, Profile, Gameplay, Technical, Verification Data.
• Legal Basis: Legal obligation (AML regulations, UKGC licensing conditions); Legitimate interests (protecting our business and users from fraud).

d. For Responsible Gambling Initiatives

• Purpose: To implement and monitor responsible gambling measures (e.g., deposit limits, self-exclusion, time-outs), identify potential problem gambling behaviours, and provide support. This may involve analysing your gameplay patterns and financial activity. For more details on our commitment to player safety, please visit our Play PIROTS 4 Responsibly page.
• Data Used: Identity, Profile, Transaction, Gameplay, Responsible Gambling Data.
• Legal Basis: Legal obligation (UKGC Licence Conditions and Codes of Practice); Vital interests (protecting vulnerable individuals); Legitimate interests (promoting player well-being).

e. For Legal and Regulatory Compliance

• Purpose: To comply with all applicable laws, regulations, and licensing conditions, including reporting to regulatory bodies like the UKGC and the Information Commissioner's Office (ICO).
• Data Used: All categories of personal data as required by law.
• Legal Basis: Legal obligation.

5. How We Share Your Data

We may share your personal data with the following categories of recipients:

• Service Providers: Third-party companies that perform services on our behalf, such as payment processors (e.g., for PCI DSS compliance), identity verification services, IT and system administration services, customer support platforms, and game providers (ELK Studios). These providers are contractually obliged to protect your data and only use it for the specified purposes.
• Regulatory and Law Enforcement Bodies: The UK Gambling Commission (UKGC), the Information Commissioner's Office (ICO), financial intelligence units, police, and other government agencies, where legally required or necessary to prevent fraud, money laundering, or other illegal activities.
• Affiliate Partners: To track referrals and calculate commissions, we may share anonymised or pseudonymised identifiers (e.g., cookie IDs) with our affiliate partners. We do not share your direct personal data with affiliates for their own marketing purposes without your explicit consent.
• Professional Advisors: Lawyers, bankers, auditors, and insurers who provide legal, financial, or accounting services to us.
• Potential Purchasers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the prospective buyer and their advisors.
• Responsible Gambling Organisations: Where required by law or necessary for player protection, we may share relevant data with organisations dedicated to preventing and treating problem gambling (e.g., GamCare, BeGambleAware).

6. International Data Transfers

Some of our service providers or partners may be located outside the UK and the European Economic Area (EEA), which means your personal data may be transferred to and stored in countries with different data protection laws.

When we transfer your data to such countries, we take appropriate safeguards to ensure your personal data remains protected as required by UK GDPR. For Yandex.Metrica, we implement the following measures:

• Consent: We only enable Yandex.Metrica for non-essential analytics when you have provided your explicit consent through our cookie banner.
• Pseudonymisation/Anonymisation: We configure Yandex.Metrica to collect data in a pseudonymised or anonymised form where possible, such as by hashing IP addresses and not collecting directly identifiable personal data.
• Contractual Safeguards: We strive to put in place standard contractual clauses (SCCs) or other appropriate legal transfer mechanisms where feasible, although the effectiveness of these can vary depending on the local laws of the recipient country.
• Transparency and Risk Acknowledgment: By using Yandex.Metrica, we acknowledge that there may be a higher risk that your data could be accessed by public authorities in Russia. We have carefully assessed this risk and determined that, given the pseudonymised nature of the data collected and your explicit consent, the benefits of using this tool for site improvement outweigh the residual risks.

We will not transfer your personal data to any country unless we are satisfied that appropriate safeguards are in place to protect your data as required by UK GDPR.

7. Data Security

We have implemented robust security measures designed to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. These measures include:

• Encryption: Using SSL/TLS encryption for all data transmissions between your browser and our servers.
• Access Controls: Restricting access to your personal data to employees, agents, contractors, and other third parties on a need-to-know basis, who are subject to strict confidentiality obligations.
• Firewalls and Intrusion Detection Systems: To protect against unauthorised access to our networks.
• Regular Audits: Performing regular security assessments and penetration tests.
• Data Minimisation: Collecting only the data necessary for the stated purposes.
• PCI DSS Compliance: Ensuring that all payment processing is handled by third-party providers who are certified as PCI DSS compliant, meaning we never directly store your full payment card details.

We have procedures in place 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.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The typical retention periods are guided by:

• Legal and Regulatory Obligations: For example, UKGC regulations require us to retain customer transaction data, KYC documents, and responsible gambling interactions for a minimum of five years from the date of the last transaction or account closure. AML laws also mandate specific retention periods.
• Contractual Requirements: Data needed to perform our contract with you.
• Legitimate Interests: For example, fraud prevention, dispute resolution, and analytics, where data is anonymised or pseudonymised where possible.

When your personal data is no longer required, we will securely delete or anonymise it.

9. Your Legal Rights

Under UK GDPR, you have the following rights regarding your personal data:

If you wish to exercise any of these rights, please contact us using the details in Section 15. 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.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

10. Responsible Gambling and Player Protection

We are committed to promoting responsible gambling and protecting our players. Our Privacy Policy integrates our obligations under the UKGC Licence Conditions and Codes of Practice related to responsible gambling.

We process your data to:

• Monitor for problem gambling: Our systems analyse gameplay patterns, betting habits, and financial transactions to identify behaviours indicative of potential gambling harm.
• Implement player protection tools: Data is used to enforce deposit limits, reality checks, time-outs, and self-exclusion requests that you may set.
• Communicate responsibly: We use your contact data to provide information about responsible gambling tools and support services (e.g., GamCare, BeGambleAware).

This processing is a fundamental part of our legal and ethical obligations as a licensed gambling operator. If you wish to familiarise yourself with the game mechanics before playing with real money, we recommend trying our free demo version first.

11. Cookies and Similar Technologies

Our website uses cookies and similar technologies (e.g., pixel tags, web beacons) to enhance your user experience, analyse site usage, and support our marketing efforts.

• What are cookies? Cookies are small text files placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

How we use cookies:

• Strictly Necessary Cookies: Essential for the website to function, enabling core features like account login, secure areas, and payment processing. These cannot be switched off.
• Analytical/Performance Cookies: Allow us to recognise and count the number of visitors and see how visitors move around our website. This helps us improve the way our website works (e.g., Yandex.Metrica). We only use these with your consent.
• Functionality Cookies: Used to recognise you when you return to our website, enabling us to personalise our content for you, greet you by name, and remember your preferences (e.g., language or region). We only use these with your consent.
• Targeting/Advertising Cookies: Record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose (e.g., affiliate tracking). We only use these with your consent.

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.

Our cookie consent management platform provides you with granular control over your cookie preferences.

12. Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications, including trusted casino platforms where you can play Pirots 4. 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 policy of every website you visit.

13. Children's Privacy

Our services are strictly for individuals aged 18 or over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete that information as quickly as possible and close the associated account.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, and regulatory landscape (including UKGC and Google Quality Rater Guidelines). Any changes will be posted on this page with an updated "Effective Date." We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. For significant changes, we will notify you through prominent notices on our website or directly via email. All use of our services is also subject to our Terms and Conditions.

15. Contact Us

If you have any questions about this Privacy Policy or our data protection practices, or if you wish to exercise any of your rights, please contact us: