Privacy Policy


Privacy Policy 

Version 1.0

11/12/2024

General

  1. The below is the data protection declaration of Thelivering Ltd. (“the Company”). The Company, acting as the data controller, values your integrity and privacy immensely. The current version of this privacy policy is the valid one.
  2. The purpose behind this policy (the “Privacy Policy”) is to inform you of how the Company protects the privacy of your communications and processes your Personal Data, along with the rights you have with regard to your access to and use of this website as well as other services provided by us.

The Data Controller 

  1. The Controller of your personal data is Thelivering Ltd., registered at Level 4, Pendergardens Business Centre 44, St Andrew’s Road, STJ 9023, St Julians, Malta (email: info@thelivering.com). 
  2. Thelivering Ltd. has appointed a Data Protection Officer that can be contacted via mail at the address dpo@budsino.com.

What personal data do we collect from you?

  1. We collect information that is needed in order to provide you with our services. This information is necessary in so far as creating a “contract” between the customer and the budsino.com website (“the Website”)- only then can we provide you with the services available.
  2. We also collect data which may be necessary to provide a functioning website and, in so far as permissible, to provide you with service offers (such as marketing content).
  3. The above can be summarised in the following types of data:
    1. Personal identification information, such as:
      i. your full name,
      ii. e-mail address,
      iii. a chosen password,
      iv. username,
      v. date of birth
      vi. valid mobile phone number,
      vii. full address,
      viii. country of residence, and
      ix. Any personal data which can be found in the requested identification documents (“Know Your Customer” requirements), including your government issued identification documents (such as an ID card, passport and residence documents

How is this data collected?

  1. The Company receives your data through:
    a. The Website;
    b. The information that you supply during the lifespan of your account with us (including upon registration and other interactions with us);
    c. From payment service providers when necessary;
    d. From publicly accessible sources (for adverse media checks).

What is the legal basis for collecting this information?

  1. The provision of personal data is partly required due to our regulatory obligations or also due to the contractual relationship between the customer and the Company for the provision of services through our Website.
  2. The processing of your personal data is based on at least one of the following legal bases, for the purposes described below:

Legal Basis

What we Process 

Based on your consent

-       Your email address to receive any marketing or advertisement materials that you may opt-in for

To fulfil our contract

-           The personal data received when opening a gaming account with the Website

-           Your transactional data in order to process payments.

To fulfil our Legal Obligations

-           Your date of birth and, in some cases, identity verification, to exclude that you are an underaged player

-           The personal data on your account that you provide when opening the gaming account to verify the account and exclude inaccuracy, incompleteness or multiple accounts;

-           The transactional data or data related to game history in order to fulfil tax obligations as well as reporting and information obligations

Due to Legitimate Interests

-           Your IP address to verify the residence and to prevent misuse

-           Your cookies received from the use of the website for advertising and marketing research (Google Analytics)

 

Use of Cookies 

  1. We may send you a temporary cookie when you visit the Company Websites. A cookie is a text-only string of information that we place in your computer's cookie file so that we can remember who you are when you revisit our Websites. We may use the data that is generated from cookies to compile statistical data on your use of our Websites. You are not obliged to accept cookies from us and you have the ability to accept or decline cookies by modifying the settings in your browser.

Use of Google Analytics

  1. This website uses Google Analytics, a web analysis service provided by Google Inc. Google Analytics uses methods that enable an analysis of your use of the website through cookies. The information generated about your use of this website is usually transmitted to a Google server and stored there.
  2. You can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by Google by downloading the browser plug-in available under the following link and install: http://wbs.is/rom89

Changes and Consent to the Privacy Policy

  1. Changes in the law or changes to our internal processes may make it necessary to adapt this data protection declaration. In the event of such a change, we will inform you of this before it comes into effect.
  2. By opening a gaming account with the Company, you agree to the terms of the Privacy Policy. We may occasionally update the Privacy Policy and encourage you to periodically review it. Your continued use of the Company Websites and their services constitutes your agreement to the Privacy Policy and any updates.

International Operations and Data Transfers

  1. We may be required to transfer your data due to contractual and/or legal obligations to the following entities:
    a. Banks and payment service providers
    b. Service providers
    c. Applicable authorities (if and when necessary)
  2. Your data may also be transferred to, and stored in, countries outside of the European Union. By using this website and submitting your information you are agreeing to this transfer, storing and processing. Should we transfer your information outside of the EU in any way we will take reasonable steps to ensure that appropriate security measures are taken to ensure that your privacy rights are protected as shown in this policy. Should it be that you are accessing this site when outside of the EU your information may then be transferred outside of the EU to provide you with the services you requested.
  3. If we transfer data to trusted third parties outside the EEA, we will rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us.

How long will my data be stored?

  1. We will store your information for as long as we need to fulfil the purposes we collect the information for. We may store your information after we have stopped providing you our services should it be necessary to meet regulatory requirements and comply with data protection laws and or other legal or contractual obligations. Unless required by law, we will keep your player personal data for five years after your account has been closed.
  2. Your personal data (including game data and deposit/withdrawal data) are therefore used from the time your game account is closed for processing and to safeguard your claims or for subsequent verifiability of manipulations until the end of the statutory period and is therefore stored for at least five years. In other cases, the deletion takes place at the earliest. After the respective period has expired, the personal data will be deleted, unless there are legal or factual reasons to the contrary.

What are my data protection rights?

  1. As a data subject, you have a set of rights bestowed by the GDPR, that can be used by you at any time:

Data Subject Right

Description

Right to Information

You can request information as to how the Company processes your personal data, and what personal data is being processed.

Right to Correction

You can request a correction of any incorrect and/or incomplete data.

Right to Deletion

You can request a data deletion, provided that the requirements for this are met and if the purposes for which your data was collected or processed no longer apply.

Right to Restrict Processing

You can request for the processing of your data to be restricted if and when possible.

Right to Data Portability

You can request for your data to be made available to you for further use or transmit it to a recipient to be designated by you.

Right to revoke your consent

You have the right to withdraw any of your consents to the processing of personal data for the above purposes at any time. The revocation of the consent does not affect the legality of the data processed until the revocation. After the revocation, the Company may only process the personal data to the extent that the processing is still necessary for the Company on the basis of legal requirement.

Right to Objection

You have the right to object to the processing of personal data related to you. If you file an objection, your personal data will no longer be processed for the purposes covered by the objection, unless(1) there are compelling reasons worthy of protection that outweigh the interests, rights and freedoms of the person concerned, or(2) the Processing serves to assert, exercise or defend legal claims.

Right to Lodge a Complaint

We invite you to address any concerns of our handling of your data directly with our assigned Data Protection Officer (DPO) available by email dpo@budsino.com.

 

You also have the right to lodge a complaint with the data protection supervisory authorities of the member states of the European Union, particularly with Malta’s Information and Data Protection Commissioner (IDPC”) on https://register.idpc.org.mt/report-breach/complaint/

 

 

  1. We are committed to addressing your queries and ensuring that your data privacy rights are respected and upheld in accordance with applicable laws and regulations. As a data subject, you have the right to contact our Data Protection Officer (DPO) regarding any concerns or questions related to your personal data. To facilitate this process, you may contact the Company’s DPO on dpo@budsino.com.