Confidentiality

Casino Davos strives to protect personal data. We therefore take all the necessary action to protect the privacy of those who visit and use (hereinafter referred to as the "Users") the online gaming site Casino777.ch (hereinafter referred to as "the Site").

Users will find below the provisions regarding the processing of personal data which apply during any visit to or use of the Site by the Users (hereinafter referred to as the "Privacy policy").

1. Background

Casino Davos processes personal data belonging to Users of the Site for the purposes and within the limits of the Privacy policy, during any visit to or use of the Site.

When processing personal data, Casino Davos takes care to comply with current laws and regulations, namely the Federal Act on Data Protection (CH) on the protection of natural persons with regard to the processing of personal data (hereinafter "the Regulation").

In this respect, and pursuant to this Regulation, Casino Davos:

  • is legally bound to process the personal data of Users. This processing is explained in Article 2.1 of the Privacy policy;

  • also processes personal data to enable Users to use the Site and for the necessary and legitimate purposes set out in Article 2.2 of the Privacy policy;

  • processes the personal data set out and for the purposes given in Article 3, further to the prior, free and express consent of Users.

By accessing and using the Site, Users are deemed to have read and accepted the Privacy policy. Furthermore, they guarantee that the data and information provided on Casino777.ch is accurate.

2. Processing of personal data that does not require the consent of Users

2.1. Legal obligations of Casino Davos and data processing required for use of Casino777.ch

Casino Davos is bound by the legal and regulatory obligations to which all online gaming operators are subject to, on the one hand, and for the purposes of authenticating Users and enabling them to use the Site, on the other hand, to process the following personal data for the reasons set out below. This processing of personal data carried out by Casino Davos on Casino777.ch does not require the consent of Users under Article 4 of the Regulation. Personal data provided by the User is held in a record which is controlled by and remains the responsibility of Casino Davos at all times, as set out in Article 7.

a. What personal data is processed?

The following personal data is processed:

  • surnames, first name/s, date of birth, nationality, language, sex, domicile/address, email address, landline or mobile telephone number;

  • bank details when transactions are made on the Site to deposit sums and withdraw winnings;

  • copies of personal documents enabling User authentication, such as their identity card, passport, driving licence, a statement of account, bank account and/or delivery note or any other document proving the domicile and/or address of the User;

  • the User's browsing history and activities on Casino777.ch, including betting history their transactions (wins and losses, deposits, withdrawals, bonus and/or promotions), visits (browser data, IP address), particularly through the use of cookies;

  • any other information that may be exchanged between Casino Davos and the User, namely by email or live chat, during the User's registration or use of online gaming offered on the Site.

b. What data processing does Casino Davos carry out on Casino777.ch?

The data processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing or any other transaction that becomes necessary or useful under the legal and regulatory provisions set out in Article 2.1.c). Processing may also consist of transferring personal data:

  • to judicial and administrative authorities, including, namely, Swiss Federal Gaming Board or the FINMA;

  • to Casino Davos's suppliers, whose services are required for use of Casino777.ch and who are cited on a list that may be requested from the contact person detailed in Article 7.3.

c. What are the purposes of this data processing?

1) Casino Davos is required to process personal data as per Articles 2.1.a) and b) in order to comply with the legal and regulatory obligations by which it is bound, namely the following legal provisions:

  • the law of 10 October 1997 on the prevention of money laundering and terrorist financing and the Order of the FDJP of 7 November 2018 on the due diligence obligations of gaming operators in the fight against money laundering and the financing of terrorism (FDJP Ordinance on money laundering, MLO-FDJP);

  • the law of 7 November 2018 on gaming houses and the law of 7 November 2018 on games of chance, bets, gaming establishments and the protection of players, in particular the obligations it places on operators in terms of management and administration, and its implementing orders.

2) Casino Davos also processes personal data set out in Article 2.1.a) to authenticate Users and allow them to access and use the Site. This processing is then carried out in order to:

  • manage User registrations and accounts;

  • manage User deposits and winnings and more generally supply online gaming and betting services;

  • keep Users informed about services offered on Casino777.ch;

  • manage customer services, including the support service and risk and fraud.

2.2. Other data processing that does not require the consent of Users

Casino Davos also processes the following personal data for the legitimate purposes set out below. This processing of personal data carried out on Casino777.ch does not require the consent of Users under Article 4 of the Regulation. Personal data provided by the User is held in a record which is controlled by and remains the responsibility of Casino Davos at all times, as set out in Article 7.1.

a. What personal data is processed on Casino777.ch?

The following personal data is processed:

  • surnames, first name/s, date of birth, nationality, sex, domicile/address, language, email address, landline or mobile telephone number;

  • the User's browsing history and activities on the Site, including betting history, their transactions (wins and losses, deposits, withdrawals, bonus and/or promotions), visits (browser data, IP address), particularly through the use of cookies;

  • any other information that may be exchanged between Casino Davos and the User on Casino777.ch, namely by email or live chat, during the User's registration or use of online gaming offered on the Site.

b. What data processing does Casino Davos carry out on Casino777.ch?

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 2.2.a). It also consists of transferring this personal data to third parties, a list of whom may be accessed on request from the contact person detailed in Article 7.3.

c. What are the legitimate purposes of the data processing?

Casino Davos processes personal data set out in Article 2.2.a) for the following legitimate purposes:

  • to promote, advertise and market its offering of new online gaming and betting services, which includes sending text messages, telephone calls, paper or electronic newsletters;

  • to conduct satisfaction surveys, statistical studies, trend analyses, and market research in order to improve online gaming and betting services or to inform or protect Users and prevent gambling addiction.

3. Processing of personal data that requires the consent of Users

By using the Casino777.ch Site, for any reason whatsoever, the User expresses their free, individual, informed and unambiguous consent to expressly authorise Casino Davos to process personal data pursuant to the Regulation, within the limits of and for the purposes set out below and without prejudice to the data processing stipulated in Article 2.

Personal data provided by the User is held in a record which is controlled by and remains the responsibility of Casino Davos at all times, as set out in Article 7.1. The User shall also have certain rights, including the right to withdraw their consent at any time, according to the terms of Article 3.4.

3.1. Nature of the personal data processed

Casino Davos processes the following personal data:

  • surnames, first name/s, date of birth, nationality, language, sex, domicile/address, email address, landline or mobile telephone number;

  • bank details when transactions are made on the Site to deposit sums and withdraw winnings;

  • copies of personal documents enabling User authentication, such as the identity card, passport, a statement of account, bank account proof and/or delivery note or any other document proving the domicile and/or address of the User;

  • the User's browsing history and activities on the Site, including betting history, their transactions (wins and losses, deposits, withdrawals, bonus and/or promotions), visits (browser data, IP address), particularly through the use of cookies;

  • any other information that may be exchanged between Casino Davos and the User, namely by email or live chat, during the User's registration or use of online gaming and betting offered on the Site.

Personal data provided by the User is held in a record which is controlled by and remains the responsibility of Casino Davos at all times, as set out in Article 7.1.

3.2. The data processing

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 3.1. It also consists of transferring this personal data to third parties, a list of whom may be accessed on request from the contact person detailed in Article 7.3.

3.3. Purposes of the personal data processing

Personal data is collected and processed by Casino Davos for the following purposes:

  • promotion, advertising and marketing activities, including membership and management of loyalty programmes relating to the offering of online gaming and betting services, which includes sending text messages, telephone calls, paper or electronic newsletters that does not fit within the framework of article 2.2.c), such as Casino Davos's offline casino business, games of chance and betting, including the advertising, marketing and management of membership and relevant loyalty programmes;

  • preparing competitions and promotional offers, including communication regarding winners;

  • developing new gaming and betting offerings;

  • conducting satisfaction surveys, statistical studies, trend analyses and market research for management, marketing and reporting purposes, including profiling that does not fit within the framework of the provision described in article 2.2.c).

4. Rights of the User

Without prejudice to Articles 2 and 5, Users may exercise their rights to request that their data be rectified, to object to it being processed and to limit the processing, according to the terms and within the limits set out below.

4.1. Right of access

a. Casino Davos can provide Users with a data file as to whether data concerning them is being processed.

b. Users have the right to request to see the information referred to in this Article and in Article 3.1. at any time via the contact person detailed in Article 7.3. Casino Davos shall respond to such requests for information within one month.

c. Users may obtain a copy of personal data that is processed. Casino Davos reserves the right to claim payment for any expenses incurred in this request. These expenses shall be calculated on the basis of administrative costs incurred in the request and shall not exceed 20 swiss francs.

d. Users shall have the right to access the information or a copy thereof in a structured format, such that the personal data is provided to them in a format that meets technical standards in place when the request for access was made. This format shall therefore allow for automatic readability.

4.2. Right to request rectification

Casino Davos guarantees and compels Users to update and rectify their personal data if this data becomes incorrect or incomplete. The right to rectify data may be exercised by contacting the person detailed in Article 7.3.

4.3. Right to object to the processing of data

Casino Davos allows Users to object to their personal data being processed in full or in part on the following grounds:

  • the data is inaccurate;

  • the processing is no longer required for the purposes for which the data was collected;

  • the User has withdrawn consent;

  • the data has been processed illegally.

The right to object to the processing of data may be exercised by contacting the person detailed in Article 7.3.

4.4. Right to be forgotten

Casino Davos also undertakes to follow up any request to erase personal data at the earliest opportunity (right to be forgotten), when:

  • the processing is no longer required for the purposes for which the data was collected;

  • the User has withdrawn consent;

  • the data has been processed illegally or must be erased pursuant to a legal obligation;

  • the User objects to the automatic processing of their data, such as profiling, and there are no justified grounds requiring Casino Davos to perform this processing;

  • the User objects to the processing of their personal data for marketing purposes, such as profiling, if it is linked to this marketing.

4.5. Right to limit the processing of data

Users also have the right to limit Casino Davos's processing of their personal data when:

  • the User believes the personal data to be inaccurate, whilst Casino Davos checks the accuracy of the information;

  • the processing is illegal and the User does not wish for their data to be erased but requests to limit the processing thereof;

  • the User objects to automatic processing, including profiling or to the processing of their personal data for marketing purposes and it is necessary to verify the legitimacy of Casino Davos's reasons for seeking to continue this processing;

  • Casino777.ch no longer requires the personal data processed but the data subject would like it to be held to establish, exercise or defend legal claims.

4.6. Procedures

The rights recognised by Casino Davos to the User must be exercised in accordance with the procedures defined by article 7.3.

5. Location, retention and retention period of personal data

5.1. Casino Davos retains Users' personal data appropriately and securely in a form which enables it to be identified and made available. The data is retained and hosted in Zürich at the Data Centre. Casino Davos provides all the required or useful security assurances with regard to current technical standards.

5.2. Users' personal data is retained by Casino Davos for the purposes set out in Articles 2 and 3. It is retained for a period of 5 years for all of the purposes governed by Article 2.a); Casino Davos therefore reserves the right to retain Users' personal data for any reasons imposed by law due to the fact that its business is that of online gaming. Users declare that they have been informed of this and agree that, by reference to the Swiss Gambling Ordinance of 7 November 2018, Casino Davos is required to retain a photocopy of the User's identity card or the document used for identification for at least five years from the date of the player's last activity on the Site.

For all of the cases governed by Article 2.2 and 3, personal data is only retained for the period required for the purpose of the processing. The data is then erased from Casino Davos's files on the User's request sent to the contact person referred to in Article 7.3.

6. Liability of Casino Davos - Data processor

6.1. Casino Davos undertakes to ensure that the processing of personal data is carried out in a lawful, loyal and transparent manner with regard to the User concerned. Any data processing operation performed by Casino Davos shall comply with Federal Act on Data Protection of 1 January 2014, and this privacy policy.

Casino Davos shall implement all reasonable and appropriate means to ensure the confidentiality, integrity and availability of the personal data it processes. These namely technical and organisational measures are explained in the data protection manual which may be obtained from the contact person detailed in Article 7.3.

Technical measures include the anonymisation and encryption of personal data, depending on the purpose.

Organisational measures include carrying out internal audits, in addition to audits to which Casino Davos may be subject by the Swiss Federal Gaming Board in particular.

If necessary, Casino Davos shall carry out an impact assessment when the data processing is likely to pose a high risk for Users.

6.2. User's personal data is not sent to any third parties other than suppliers and partners of Casino Davos, except for the purposes set out in Articles 2.1, 2.2 and 3 and, consequently, if:

  • the data transfer is made mandatory by a law or regulation or when ordered by an administrative or judicial authority;

  • the data transfer proves necessary for the supply of online gaming services, or maintenance services;

  • the User has consented to such a transfer.

The partner shall not be deemed a data processor unless they process User's personal data on behalf of Casino Davos. Casino Davos shall not be held liable for the processing of User's personal data by partners who supply their own services in their own name on their own behalf or if it proves that it is not responsible for the event that gave rise to the damage.

It is understood that in the event that Casino Davos acts in the capacity of the processor's partner, Casino Davos shall be liable for damage caused by processing personal data contrary to the Regulation or this Privacy policy only where it has not complied with obligations of the Regulation or this Privacy policy directed to processors, or where it has acted outside or contrary to lawful instructions of the partner. Similarly, Casino Davos shall not be held liable if it proves that it is not responsible for the event that gave rise to the damage.

6.3. Casino Davos shall ensure that when the processing is carried out by a processor on behalf of Casino Davos, the processor shall provide sufficient assurances that appropriate technical and organisational measures have been implemented and, more generally, that the Regulation has been complied with. In particular, the processor is required to comply with the Regulation and, therefore, keep a record of processing activities.

6.4. Casino Davos undertakes to ensure that in the event of a security problem related to data processed which may affect the confidentiality thereof, Casino Davos shall report the incident at the earliest opportunity to the data protection authority stipulated in Article 7.4.

Casino Davos shall also inform the Users concerned, insofar as the personal data breach poses a high risk to the rights and freedoms of the User; the User shall be informed by letter or email using the contact details that they have provided.

7. Miscellaneous

7.1. Entire agreement - modification of the Privacy policy

The Privacy policy contains all of the contractual provisions binding Users, without prejudice to the general provisions in the Terms and Conditions of Use of the Site of which they form an integral part. The Terms and Conditions of Use of the Site shall remain applicable for any matters that do not relate to the protection of personal data. In addition, Casino Davosh reserves the right to modify the Privacy policy. Any updates are enforceable against Users once published on the Site. Casino Davos undertakes to state the date on which the Privacy policy that appears on the Site was placed online.

7.2. Probative value

The User acknowledges that the electronic documents exchanged and electronic data collected during their registration or use of the Site have the same probative value as if these documents and data had been sent or communicated on paper. They therefore undertake to not dispute their force or probative value due to the fact that they are in electronic form.

7.3. Contact

Casino Davos may be contacted for any questions regarding the protection of Users' personal data via the following:

  • Letter: Casino Davos AG, Promenade 63, 7270 Davos

  • Email: customersupport@casino777.ch