Privacy Policy

In its everyday business operations, HotSlots makes use of a variety of data about identifiable individuals, including data about you. By collecting and using this data, HotSlots is subjected to a variety of regulations controlling how such activities are to be carried out and the safeguards that must be put in place to protect it.

This Privacy Policy defines the safe collection, storage, handling, processing, and sharing of personal data, including sensitive data and other non-personal data that HotSlots legally obtains from you in connection with your use of HotSlots services.

If you use HotSlots services, you consent to the collection, storage, handling, processing, and sharing of your personal data under this Privacy Policy. You have the option of using tools to control how we use and share your data. Detailed information about it has been included in this Privacy Policy. If you do not agree with this policy, please refrain from accessing, using, or interacting with any HotSlots services or another aspect of its business.

Please note that you should read this notice in conjunction with our Terms and Conditions.

References to ‘us’, ‘we’, ‘our’ and ‘HotSlots’ refer to Forwell Investments B.V.

DATA CONTROLLER

The controller of your personal data is FORWELL INVESTMENTS B.V. Reg. No 136125 (0) Emancipatie Boulevard Dominico F. “Don” Martina 29, Curacao. You can contact us at https://hotslots.io/en/support/. If you need more information or help with your Personal Data, contact us at privacy@hotslots.io.

WHAT WE COLLECT FROM YOU?

When you use our services, we may collect personal data including but not limited to:

a. Your first and last name.

b. Your email address.

c. Username.

d. IP address.

e. Phone number.

f. Technical information about any devices you use to access our services or other technical information.

g. Information about your use of HotSlots services, including information about when, how, and where you use the services.

h. When you register for an account, create, or modify your profile, set preferences, sign up for or make purchases through the services.

i. Information on your use of social networks (if you have linked our services to your social media accounts). The above may potentially include certain information from Facebook and other social networks (including access to your friends' list and other non-personal analytical data), strictly in accordance with the applicable Facebook terms and conditions and other social networking websites – only to the extent necessary to provide you with all the functionalities of the HotSlots services.

j. Information about your deposits and withdrawals.

k. Any other data that you provide to us through our services.

l. Any other data that you provide to us when you contact our support.

m. As part of the Customer Due Diligence process and in accordance with the law, HotSlots can ask you for additional information.

WHY DO WE NEED THIS DATA?

HotSlots processes your data to provide you with the full functionality of the servces offered on HotSlots website and to meet legal obligations imposed on HotSlots and/or to implement a perfectly legitimate purpose of data processing consistent with your rights. These are the data processing security, fraud and money laundering prevention and marketing services.

HotSlots is obliged to process data on the basis of various legal provisions and current legislation. These include tax regulations, anti-money laundering regulations and other regulations regarding licensed operators issued by supervisory authorities.

In addition to that, your data may be used by HotSlots for the following purposes:

a. To provide you with services covered by the operation of the HotSlots website.

b. To provide personalised marketing information about the services that you order from HotSlots or that may interest you, e.g. HotSlots can send you emails or display pop-up messages about HotSlots services and updates.

c. To communicate with users of HotSlots services.

d. To enable participation in interactive services, tournaments, and promotions in general.

e. To notify you about changes regarding our services.

f. To improve or modify HotSlots services and policies.

g. To organise competitions, promotions, and bonuses (including contact with participants, evaluation of entries, distribution of prizes, payment of tax, etc).

h. For tax, legal and billing purposes.

i. For billing purposes.

j. For any purposes provided by law, including counteracting money laundering attempts.

k. To profile and personalise HotSlots marketing communications, offers and advertisements campaigns that HotSlots display on its website and third-party websites and/or services based on the combined data we have collected about you.

l. For processing online payments.

m. To verify your age and other personal information as may be necessary.

n. For configuring and managing your user account.

o. To complete compliance procedures imposed on HotSlots.

p. To monitor transactions to prevent fraud and money laundering.

HotSlots can profile your personal data, which means that HotSlots can use the information collected to tailor communications addressed to you.

HotSlots does not use algorithms on your profiled data to make automated decisions that can affect your individual rights or any rights arising from the contract between HotSlots and you. I.e. HotSlots does not place automatic offers based on your behaviour in the games.

However, HotSlots is obliged by laws and license conditions to monitor its players to identify people who may be experiencing, or are at risk of developing gambling problems. Based on data describing unique players, a special algorithm provides us with an estimated probability of gambling addiction, allowing HotSlots to interact with such players to offer help or support. Decisions based on predictions are not made automatically without human intervention.

FOR HOW LONG DO WE KEEP YOUR DATA?

We will only keep your personal data stored for as long as is reasonably necessary to carry out the purposes and legal obligations outlined in this Privacy Policy. This is in compliance with HotSlots legitimate interests in providing you with the full functionality of the services while abiding by the current legislation and specific regulations.

These regulations set out that HotSlots can store your personal data for a certain period after you cease being a customer, due to legal and license provisions imposed to us. After this period, HotSlots will either safely delete or anonymize your information – If deletion is not possible (because the data has been stored in backup archives) then we will securely store, isolate, and safeguard your information from any further use until deletion can be possible.

MARKETING PURPOSES

If you have signed up to services offered by us, we may send you direct marketing in relation to other services offered by us or our Group, provided that you have given your consent to receive such marketing. Some of your personal data can be processed by our third-party marketing partners to allow us to communicate with you by phone, email, push notifications, SMS and to inform about prizes and/or gifts from suppliers, etc.

Where we have the appropriate consent (subjected to your preferences) and/or lawful basis, some of your personal data can be processed by our third-party marketing partners to allow us to communicate with all our customers by phone, email, push notifications, SMS (by sending platform providers) and to inform about prizes and/or gifts from suppliers, etc.

Consent for this processing can be changed in whole or in part at any time by going to ‘My Account’ settings. If you need more information about this, let us know.

All our marketing communications will include instructions on how to opt out of receiving this specific type of marketing communications. It can take up to 48 hours for your request be fully carried out. We will not share your personal data with unrelated third parties to market their products to you without your prior consent.

TELEPHONE CALLS

Telephone calls to and from our Customer Contact Centre can be recorded for training and security purposes along with the resolution of any queries arising from the service you receive.

TWO-FACTOR AUTHENTICATION

The two-factor authentication adds more security to your HotSlots account.

Any attempts to log in to your HotSlots account from a new device or country will be followed up with a 6-digit authentication code (token) sent to your mobile phone number or email address provided upon registration. You will be required to enter the generated code (token) upon your login attempt. To do so, just write the code from your mobile SMS or email into the field “Token”.

This procedure will protect your account from unusual activity or potential third-party access by keeping unknown people away, even if they are in possession of your password.

If for any reason you do not receive the verification token, please contact our Customer Support.

COOKIES

HotSlots and its third-party partners (advertising and analytics partners) use various technologies to collect information, such as cookies and web beacons and other technologies to improve and customise services, websites and your experience; to allow you to access and use the services without re-entering your Login or password; to understand usage of services and the interests of our customers; to determine whether an email has been opened and acted upon; and to present you with advertising relevant to your interests.

● Where strictly necessary.

These cookies and similar technologies remember choices you make, such as language, search parameters or remembering you have logged in. HotSlots uses these cookies to provide you with a tailored experience more appropriate with your selections.

● For performance and analytics.

These cookies and similar technologies collect information on how users interact with the services and enable HotSlots to improve how these services operate. HotSlots use Google Analytics cookies to help understand how visitors arrive at and browse our products and website to identify areas for improvement, such as navigation, user experience, and marketing campaigns.

● Targeting Cookies or Advertising Cookies.

These cookies collect information about your browsing habits in order to make advertising relevant to your interests. They remember websites you have visited and that information is shared with other parties such as advertising technology service providers and advertisers.

● Social media cookies.

These cookies are used when you share information using a social media sharing button or ‘like’ button on our websites, link your account or engage with our content through a social media website. The social network will record such data and it may be linked to targeting/advertising activities.

To opt out of our cookies policy, you can instruct your browser by changing its options to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our services. HotSlots and its third-party partners also collect information using web beacons (also known as tracking pixels). Many browsers include their own management tools for removing HTML5 local storage objects. Please note that you will not be able to opt out of any cookies or other technologies that are strictly necessary for the services.

SHARING AND PROCESSING YOUR PERSONAL DATA

HotSlots securely shares information with third parties that help HotSlots operate, provide, improve, integrate, customise, support and market its services. HotSlots will ensure that all relationships involving the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.

HotSlots works with its third-party partners and service providers to provide website and application development, games software, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services, which may require them to access or use information about you. These include also software suppliers, payment systems providers, entities dealing with HotSlots. If a service provider needs to access information about you to perform services on HotSlots behalf, they do so under close instruction from HotSlots, including policies and procedures designed to protect your information at all times.

If required by law, HotSlots may disclose your information to the Police or other public authority – this includes, but is not limited to the IP address and details of any suspected unlawful or dishonest activity, such as abuse of a given form of payment or security risk assessment.

KNOW YOUR RIGHTS

You have rights under the GDPR. These consist of:

1. The right to withdraw the consent.

However, this will not invalidate any previously consented processing.

2. The right to be informed.

You have the right to be informed about how your personal data is processed and why.

3. The right of access.

You have the right to request a copy of the personal data we hold about you.

4. The right to rectify.

Where personal data is inaccurate, you have the right to request a correction and also complete any incomplete personal data.

5. The right to be forgotten.

You can request us to erase your personal data where there is no lawful basis requiring us to continue processing this personal data. This right only applies in certain circumstances, given that legal obligations include data retention periods.

6. The right to restrict/object processing.

In certain circumstances, you have the right to object or restrict the processing of your personal data, where this processing is based on consent or our legitimate interest. However, despite your objections or wish to restrict processing, where there are compelling legitimate grounds or legal obligations, we would be required to continue said processing.

7. The right to data portability.

You have the right to request that your personal data be provided to you in a structured, commonly-used and machine-readable format (GDPR Article 20) and to transfer that data to another party. This applies to personal data for which processing is based on your consent and the processing is carried out by automated means.

8. Rights in relation to automated decision making and profiling.

You have the right to not be subjected to automated decision-making when the decision has a significant effect on you; you can insist on human intervention where appropriate. You also have the right to express your point of view and contest decisions.

9. The right to withdraw.

You have the general right to withdraw the consent you have given us to process your personal data (in respect of our marketing activities) and where this processing is based on what we deem to be our legitimate interest.

POLICY CHANGES

HotSlots may change this Privacy Policy from time to time. HotSlots will post any Privacy Policy changes on this page and if the changes are significant, HotSlots will provide a more prominent notice by adding a message on the homepages, login screens, or by sending you an email notification. HotSlots will also keep prior versions of this Privacy Policy in an archive for your review. HotSlots encourages you to review the current Privacy Policy whenever you use services to stay informed about our data practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you must refrain from using HotSlots services and deactivate your account(s), as outlined above. If you need more information or help with your Personal Data, contact us at privacy@hotslots.io.