Privacy Notice

INTRODUCTION

Welcome to the Recro Limited’s Privacy Policy relating to the provision of our services (games and/or sportsbetting) on casumo.com and and/or any local country-code websites and/or any sub-website and/or associated domains (and/or sub-domains) and any related software applications (“Site”, “Website”), where Personal Data is processed by the same relating to You.

We respect your privacy and we are committed to protecting your personal data. This commitment exists throughout the lifecycle of the personal data which you provide to us, from the design of any Recro service which uses personal data to the deletion of that data. We process your personal data in compliance with the EU General Data Protection Legislation (the “GDPR”), (Regulation 2016/679) and the Maltese Data Protection Act (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the same – the ‘DPA’. 

This Privacy Policy will inform you as to how we use and look after your personal data. This Policy covers, among other topics:

• Information about who we are and how to contact us;
• Transparency about how we collect and use your personal data, including when and how it is shared and the categories of recipients;
• Information on how we protect your personal data;
• Information about your rights, the choices available to you, and how we will facilitate your rights and respond to your questions.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. 

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE MAY COLLECT ABOUT YOU

3. HOW IS YOUR DATA COLLECTED

4. HOW WE USE YOUR PERSONAL INFORMATION

5. SHARING OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFER

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHT

10. AUTOMATED PROCESSING – PROFILING

11. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy (the “Privacy Policy” or the “Policy”) aims to give you information on how Recro Limited collects and processes your personal data, including any data you may provide through this website https://www.casumo.com/en-gb (the “Website” or the “Site”) when you sign up to our registration form, send us an email, make a phone call or use our Live Chat service and any data we may collect on you to provide you with our online gaming and betting services (the “Services”) with respect to our relationship with you as a player.

It is important that you read this Privacy Policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

This Website and our Services are not designed or directed to persons under the age of 18 with respect to the use of the Services (“Legally of Age”). If you are not Legally of Age, you should not use the Services nor provide any personal information to us.

CONTROLLER

This Privacy Policy is issued on behalf of Recro Limited, which is the controller (“Controller”) and responsible for your personal data, is referred to as “Recro”, the “Company”, “we”, “us” or “our” in this Privacy Policy. Recro is a company registered under the laws of Malta and it is licensed and regulated by the UK Gambling Commission under license number 000-061549-R-336718-001, which license issued under Part 5 of the Gambling Act 2005.  

The Controller is part of the Casumo Group (which means those companies having Casumo Holdings PLC, CRN- C 63156 as their ultimate parent company). 

The Casumo Group has established an Intra Group Data Transfer Agreement which governs any transfer of personal data within the companies form part of the Casumo Group. 

The Company has appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions relating to this Privacy Policy, including any requests to exercise your rights, please contact the DPO using the details given below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Recro Limited

Company registration number: C 77858

Email address: hey@casumo.com 

Postal address: The Unicorn Centre, Triq Il-Uqija, Swieqi, SWQ 2335, Malta

Data Protection Officer: dpo@casumo.com 

2. THE DATA WE MAY COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data).

We may collect personal data from you because of a legal reason or because you have consented us to do so for a specific purpose. We may collect, use, store and transfer different categories of personal data about you, which we have grouped together as follows:

• Registration Data includes first and last name, username or similar identifier, date of birth, territory applicable social security number where permitted or required by law, gender, country.
  
  
• Contact Data includes postal address, email address and telephone number(s).
  
  
• Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) includes first and last name, permanent address and proof of address, date of birth, nationality, employment history and information, adverse media report, financial status and information (e.g. bank statement, source of income and source of wealth, tax information), Politically Exposed Person check, Sanction check screening, masked credit card details, proof of e-wallet ownership such as Neteller, Skrill, Paypal, Paysafe, KYC documentation (e.g. ID card, passport, utility bill, any other document as may be specified in sectoral implementing procedures issued by the relevant regulator authorities). 

• Responsible Gambling Data (RG) including name, surname, Zip Code, email, phone number, country, date of birth, territory applicable social security number where permitted or required by law , approved transactions (deposits and withdrawals), denied transactions (deposits and withdrawals), Identification and Verification Data, Self-exclusion Data.
  
  
• Self-exclusion Data includes data pertaining to you and your self-exclusion such as your Registration and Contact Data and your self-exclusion details such as reason, start and date, utilisation of self- exclusion tools such as exclusions, session limit, loss limit, wager limit, deposit limit, reality check.
  
  
• Financial Data includes payment card details and bank account details. 
  
  
• Transaction and Usage Data includes details generated through your use of our Services (e.g. playing Games) and include payments to and from you (deposits, withdrawals, failed deposits and reversed withdrawals) and other details of Services you have purchased from us (such as bets, wagers (real and bonus), wins), date and time of the transactions, account balances (bonus and real), bonuses used (conversion and forfeiture), bonuses turnover, bonuses balance, channels used, transaction games played, language, country, account balances. 

• Log in Data includes internet protocol (IP) address, your logins (first log in last login, last failed login), duration of log ins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
  
  
• Profile Data includes internal notes to your account, interests and preferences.
  
  
• Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out). 

• Other Communication Data provided by you in communication with us (via recorded calls, chats, emails, or SMS) which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes. 

• Analytics Data include various data provided by your observed with respect to your use of our Website and Services such as your player ID, language, location, browser data, campaigns utilised, channels used, device, payment provider, Transaction and Usage data and in case of online acquisition analytics also pages visited, postcards clicked, scroll depth. Certain information is collected using cookies and/or similar tracking technology. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, there may be times when you may voluntarily choose to disclose information like this to us, such as when you are speaking with our Ambassadors or Responsible Gaming Specialists, and these chats and emails are assigned to your account with us. Where you have a health condition that affects your ability to control your gambling behaviour and you choose to provide us with documentation to support this, we will make note that you have a health condition but delete the documentation you provide to us. Where you disclose a health condition which we feel may impact your ability to make rational decisions around your gameplay, we may take the decision to block you from our Services for your own safety.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We collect your personal data through different methods, including:

• Direct interactions - you may give us your Registration, Contact, Identity and Verification, Marketing and Communications and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise when you engage with us to provide you with our Services. 

• Third parties and publicly available sources - We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information and other third parties. Due to regulatory requirements we collect know your customer (KYC) information from specialised third parties. Such information is collected only when it is reasonably necessary for the organisation’s activities.

• Automated technologies or interactions - We and our third-party service providers may collect information automatically from your device in a variety of ways, including:

a. Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your IP, device type, language and the Internet browser type you are using. 

b. Through your use of an app: When you download and use our apps, we may track and collect app usage data, such as the date and time the app on your device accesses our Servers and the information and files that have been downloaded to the app.

 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information related to your query).

4. HOW WE USE YOUR PERSONAL INFORMATION

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:

• To process your registration, set up and look after your account (including checks made to age verify you and to guard against fraud);
• To provide and operate the Services (such as for gaming/betting and payment processing);
• To communicate with you and to keep you informed of our latest updates to our Services and special offers;
• For legal and regulatory reasons, to comply with our legal obligations and license conditions such as Anti-money laundering and responsible gaming; including for the purpose of ascertaining your source of funds or income, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request;
• Providing, maintaining, enhancing and personalizing the Services and analysing how customers use the Services and the Website;
• To know your preferences and to try to ensure that the content on our Website is presented in the most effective manner for you and your computer or mobile device;
• To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
• To communicate with your and to process any of your requests to exercise your Legal Rights;
• To identify and authenticate your access to certain features of the Services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
• To investigate violations of our policies and Terms and Condition as well as enforce our policies and the Terms and Conditions; and
• To investigate and resolve disputes in connection with your use of the Services.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, text message or by post. You have the right to withdraw consent to marketing at any time by either unsubscribing from our mailing list or by contacting our DPO.

PURPOSE FOR PROCESSING YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new player, identify you and verify you when you access your Account to allow you to participate in games.	(a) Registration Data (b) Contact Data  (c) Log-in Data	Performance of a contract with you
To allow you participate in the games.	(a) Transaction and Usage Data	Performance of a contract with you
To process and manage transactions	(a) Financial Data (b)Transaction and Usage Data	Performance of a contract with you
To manage our relationship with you, to provide you with access to our Services.	(a) Registration Data (b) Contact Data  (c) Profile Data (d) Other Communication Data (e) Transaction and Usage Data (f) Self-exclusion Data	(a) Performance of a contract with you (b) Compliance with legal obligations
For AML/CTF and due diligence purposes	(a) Registration Data (b) Contact Data  (c) Identity and Verification Data (e) Transaction and Usage Data	Necessary to comply with legal obligations
To establish and investigate any suspicious behaviour in order to protect our business from any risk and fraud	(a) Registration Data (b) Contact Data  (c) Identity and Verification Data (d) Log-in Data (e) Financial Data (f) Other Communication Data	Legitimate interests (detection and prevention of fraud)
Identification and investigation of gaming activity for responsible gaming purpose	Responsible Gaming Data Self-exclusion Data Other Communication Data	Necessary to comply with legal obligations
Responsible gaming profiling	(a) Responsible Gaming Data (b) Self-exclusion Data (c) Other Communication Data	Necessary to comply with legal obligations
To ensure that self-excluded players with respect to Recro or any other brand/company within Casumo Group are duly self-excluded and do not access our Services.	Self-exclusion Data	Necessary to comply with legal obligations
Direct marketing of our own Services including bonuses, news, and promotions.	Contact Data Marketing and Communication Data	Legitimate Interests (to promote our own Services and to develop our business) Consent
Direct marketing of products and services including promotions of any other brand/company within Casumo Group.	Contact Data Marketing and Communication Data	Consent
Social Media Marketing	Contact Data	Legitimate Interests (to promote our own Services and to develop our business) Consent
Customer segmentation for the purposes of tailored offers and bonuses sent via direct marketing.	Registration Data Transaction and Usage Data	Legitimate Interests (to promote our own Services, to develop our business and enhance our relationship with you by targeted offers)
To administer and protect our business and this portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Registration (b) Contact (c) Analytics data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

MARKETING

We may use your personal data, such as your email address and telephone number, ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials (including news and bonuses), concerning our Services as well as products, services and promotions which relate to other companies within the Casumo Group, which we believe may interest you.

We will use your personal data for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.

When relying on legitimate interest, Recro will give you the opportunity to oppose to such direct marketing when registering on our Site.

When relying on consent, the consent may be granted by you when registering on our Site.

In both cases, if you do not wish to receive direct marketing any longer, you may opt out, easily, at any time, either by:

• activating the relevant link at the end of an electronic message, or
• contacting us, or
• changing your Settings in your profile.

In case of social media marketing, you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third-party platforms (e.g. Facebook).

In addition, if you download our mobile application to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the settings on the device itself.

THIRD PARTY TRACKING TECHNOLOGIES

When you visit or access our Services (for example when you visit our Website), we use (and authorise third parties to use) cookies, pixels other technologies ("Tracking Technologies").

The Tracking Technologies allow us to automatically collect information about you and your online behaviour, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our users and players.

For further information on what Tracking Technologies/cookies are, which cookies we use, how and why we use cookies, and how you can control which cookies are dropped, please read our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. SHARING OF YOUR PERSONAL DATA

We do not rent, sell, or share your personal data with third parties (“Recipients”) except as described in this Privacy Policy. The personal information will be disclosed to Recipients only to the extent required for the specific purpose(s), as stipulated in this Privacy Policy. 

We may have to share your personal data with the following categories of Recipients: 

• Professional advisers including lawyers, bankers, auditors and insurers based in Malta who provide consultancy, banking, legal, insurance and accounting services.
• Any service providers that may have access to your personal data in rendering us with their support services, for example, IT service providers, payment service providers, game providers for the purpose of provision of games, AML providers providing and/or processing certain data for the purposes of compliance with our AML obligations, analytic services providers, service providers that technically enable communication with you (via email, chat, SMS, phone), marketing service providers, data hosting service providers, Website performance and security systems service providers.
• We may disclose personal data processed to other companies within the Casumo Group in accordance with Intra Group Data Transfer Agreement.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties that are acting as processers to Recro to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where required by law, your personal information may be disclosed to an applicable governmental, regulatory, sporting or enforcement authority. Your personal information may also be disclosed to any regulatory or sporting body in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and where the Company considers that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

6. INTERNATIONAL TRANSFERS

Wherever possible, Recro keeps your information within the European Economic Area (“EEA”). However, it may be necessary for the provision of Services and to the extent required for the specific purpose, as stipulated in this Privacy Policy to transfer your personal information to countries outside the EEA. The data protection and other laws of these countries may not be as comprehensive as those in the EEA.

Where your personal data is transferred outside the EEA, we use best efforts to ensure that your personal information is protected through contractual means (such as by using the standard contractual clauses (“SCCs”) approved by the European Commission for data transfer) or other means (such as ensuring that the European Commission decisions determined that such jurisdictions offer adequate level of protection).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures 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

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our Data Retention

Policy which you can request from us by contacting our DPO. 

Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

WHAT WE MAY NEED FROM YOU

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. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

RIGHT TO MAKE A COMPLAINT

You have the right to make a complaint at any time to the Information and Data Protection Commissioner Office (IDPC), the Maltese supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance. The IDPC’s contact details are as follows,

Address: Level 2, Airways House, High Street, Sliema SLM 1549, Malta

Email: idpc.info@idpc.org.mt

Website: https://idpc.org.mt/en-gb/Pages/contact/complaints.aspx

Landline: 2328 7100

10. AUTOMATED PROCESSING – PROFILING

AUTOMATED PROCESSING FOR RESPONSIBLE GAMING PURPOSES

Recro is on the basis of the applicable laws and license conditions legally obliged to monitor its players in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and interact with them to offer help or support. To this end, and to fulfil this obligation, by using historic data describing behaviour of players, in particular certain Responsible Gaming Data, Transaction and Usage Data, and Other Communication Data (in particular notably sentiment used in message). Recro and the Casumo Group has established rules regarding who is likely to suffer from gambling addiction and then take relevant action.

Decisions, on the basis of the prediction, are not taken automatically without human intervention.

AUTOMATED PROCESSING FOR ANTI-MONEY LAUNDERING PURPOSES

Recro is, on the basis of the applicable laws and license conditions, legally obliged to monitor its players in order to identify potentially suspicious activities regarding AML/CFT. Based on data describing the behaviour of players, in particular Transaction and Usage Data, the algorithm suggests a risk profile.

Decisions, on the basis of the prediction, are not taken automatically and require human intervention.

AUTOMATED PROCESSING FOR DIRECT MARKETING SEGMENTS 

By making use of Your Transaction and Usage data, certain Registration Data such as gender, country, date of birth and Your overall interaction with our services, we analyse and establish various segments of the customers/players. These segments are then processed manually, in order to ensure that we provide the most appropriate offers and bonuses to our players. These decisions are not taken automatically without human intervention. The process is based on legitimate interest of Recro and the Casumo Group regarding providing customised and quality experience for the players. You can object to such processing by contacting us or changing your preferences in your account.

11. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on October 20, 2023 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Version: 0.6
Updated: October 30, 2023