1. General Information
2. Data Controller
The data controller of Interwetten is
Interwetten Gaming Ltd.
2nd Floor, Global Capital Building
Testaferrata Street, TaXbiex XBX 1403,
Registration Number C35736
3. Data Protection Officer
For any privacy issues or for further information on Interwetten’s data processing activities please contact the data protection officer of Interwetten:
Interwetten Gaming Ltd.
2nd Floor, Global Capital Building
Testaferrata Street, TaXbiex XBX 1403
Fax +356 23276-400
4. How Interwetten processes Personal Data
a. General Information
Interwetten only processes personal data
- when the player has given consent with such processing,
- when processing is necessary for the performance of the services provided by Interwetten,
- when processing is necessary for compliance with a legal obligation to which Interwetten is subject, or
- when processing is necessary for the purposes of the legitimate interests pursued by Interwetten or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the player.
Not providing personal data may mean that Interwetten is unable to provide services to the player.
In the following it is described how Interwetten processes personal data and how such processing is justified.
b. Data Collected when visiting the Website
During the visit of the website www.interwetten.com our system automatically collects information which is generated by the browser of the visitor of our website and stores them in logfiles on a temporary basis including but not limited to
- the IP address of the requesting computer,
- the date and the time,
- the operating system,
- the browser used by the player.
The logfiles may contain IP addresses which allow identification of a player.
Such collection is necessary for the performance of the services provided and for the purpose of our legitimate interests in order to enable the use of the site by the visitor, to optimize the website and in order to identify dysfunctions and abuse of Interwetten services.
c. Data Collected upon Registration
Interwetten collects players’ personal data during registration process (and during ongoing KYC monitoring at a later stage in time) including but not limited to
- first name and last name
- complete address
- date and place of birth
- a verifiable email address
- mobile phone number
- username and password
- personal security question and answer
- in certain countries id-card or social security number.
Players will be requested - at any given time and in line with applicable laws and regulations, particularly the current regulations to prevent money laundering and the financing of terrorism - to submit further documents to verify their identity and to enable security identity checks, such as a copy of a valid ID issued by the competent authority, e.g. passport, personal identity card, driver's license, a utility bill (e.g. for gas, electricity or a lease contract).
Following registration, players may change their personal data at any time under "Change account data" (with the exception of the surname, first name, date of birth, country, and user name and nickname). Every player is to update his personal data without delay once information provided to Interwetten is no longer correct or is incomplete.
Interwetten may also collect information from third party databases.
The collection of such data is required for us to provide our services to the player. The verification of the players’ age and identity is necessary for complying with legal obligations. It may also be necessary for enforcing our contractual agreements and is therefore in our legitimate interest.
d. Data collected for Payment Services
If players deposit funds into the Interwetten account by credit card, the processing of particularly the following additional personal data is required:
- first name and last name of cardholder
- name of credit card company
- credit card number
- expiry date of credit card, CVC code and password
For a transfer of winnings into the player's bank account, particularly the following personal data has to be collected:
- name and surname of account holder
- name of bank
- SWIFT code
Such data may be transmitted to payment providers. The collection of this data is necessary for performing payment services.
e. Additional Data collected when using Interwetten Services
Interwetten processes information that is collected by cookies, logfiles, clear gifs, and/or by third parties' support in order to create player profiles. A profile contains information on individual players including preferences concerning the activities of the player. This information is related to the players' personal and identifiable data and used to provide and improve our services to the benefit of the player. Profiles are also used to design each player's experience on the Interwetten website individually and to provide specific marketing information.
Interwetten uses logfiles. These include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyze trends for administration of the site, to track players' movements on the site, and to gather usable comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.
The collection of such data is required for us to provide our services to the player. It is also necessary to protect our customers and ourselves from crime and to comply with legal obligations. It is also in our legitimate interest to improve and promote our services.
f. Communication with Players
Interwetten stores communication with players including requests for information or customer support. This applies to communication via email, the website or other means of communication including telephone. Telephone calls are recorded for training and security purposes.
Interwetten uses the Chatvisor Customer Service Suite (“Chatvisor”), a technology of Chatvisor GmbH (www.chatvisor.com). Chatvisor enables Co-Browsing, Live Chat, Chatbots, Webcalling and similar Functionalities on the website. For more information see sec. 6. B. ff below.
The collection of the player’s personal data is required for us to provide our services to the player and to comply with legal obligations. It may also be necessary for enforcing our contractual agreements and therefore in our legitimate interest.
g. Marketing activities
Subject to the player’s account settings his personal data may be used by Interwetten for marketing activities across various channels including mail, email, telephone call as well as electronic/instant messaging. The use of the player’s personal data for marketing activities may be cancelled or restricted to certain communication channels at any time. Players may either adjust the respective account settings or contact our service department by email to firstname.lastname@example.org. Due to the nature of the technical workflow involved, updates to the respective account settings may take up to 5 working days before they become effective.
Whenever a player has not consented to the use of his personal data for marketing purposes Interwetten processes personal data for marketing purposes only as necessary for the purpose of our legitimate interests in promoting our services.
h. Cookies, third party Content and Trackers
A cookie is a piece of data saved on the player's computer and linked to specific user information.
For cookies, third party services, social media plugins and the use of trackers see Sec. 6 below.
i. Other Purposes
It may be necessary to process personal data for additional purposes. However, Interwetten will only process personal data if and to the extent that one or more conditions set out in Sec. 4 a. are met.
5. Disclosure of Personal Data
a. General Information
Player’s personal data is treated as strictly confidential.
Personal player data may be disclosed to third parties
- if the player has given consent with such disclosure,
- the disclosure is necessary for compliance with legal obligations to which Interwetten is subject, or
- when the disclosure is necessary for the purposes of the legitimate interests pursued by Interwetten or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the player.
Interwetten only transfers data to states outside of the EU/EEA provided the recipient guaranties a standard of data protection comparable to European standards (e.g. by agreeing to approved contractual clauses, intragroup agreements or other measures designed to ensure that the recipients of personal data protect them).
In the following clauses b. – f. it is described how Interwetten shares personal data. Additional information is laid down in Sec. 6 below:Cookies, Third Party Services, Social Media Plugins and Trackers.
b. Sharing of personal data within the Interwetten Group
Personal data may be transferred or disclosed to any company within the Interwetten Group. Interwetten Group means Interwetten International Ltd., Interwetten Gaming Ltd., Eurotrade International Ltd. and their related companies.
c. Sharing of personal data with Service Providers
Interwetten may share personal data with other third party service providers, when players request a service, which Interwetten offers partly or fully through the third party provider, such as casino games, virtual sports or eSports. For these products provided via the game provider websites’ additional provisions may apply.
Interwetten makes also use of trusted third parties to process players’ personal data including but not limited to payment services, information technology, statistics and reporting, customer support, sales, marketing related services. Pursuant to applicable data protection regulations including the General Data Protection Regulation these third parties are contractually bound to Interwetten and obliged to treat players' data securely and confidentially. Their use of the said data is restricted to the extent required to fulfil the respective task. Interwetten only transfers data to states outside the EU/European Economic Area provided that the recipient guarantees a standard of data protection comparable to that in place in Europe.
d. Sharing of personal data for KYC, the Prevention of Fraud and Money Laundering
In order to complete players' identity verification, to carry out security checks, to assess players’ compliance with our Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and the protection of minors, player data may be matched against third party databases of including but not limited to GB Group plc, Jumio Corporation, Bisnode Austria GmbH.
Upon any indication of transactions and/or activities that may raise suspicions of criminal activities, Interwetten will report to the relevant parties in charge (e.g. police, sporting associations, private associations aiming at the prevention of criminal and fraudulent activities in sports betting and/or games of chance).
In this context, data on players’ activities and personal data may also be transferred in the framework of an early warning system to the European Sports Security Association (ESSA) and the respective sports federations.
Furthermore, Interwetten reserves the right to record telephone calls with players and forward recordings to law enforcement agencies if there is precise evidence of criminal offences.
With the acceptance of the General Terms and Conditions and this Data Protection Policy, the player grants his explicit consent to these procedures including requests for credit information and the matching of data provided against databases of third parties.
The sharing of players’ data also is necessary to protect players and ourselves from crime and to comply with legal obligations.
Within the framework of this contractual relationship, we transmit collected personal data for the purpose of requesting, implementing and terminating this business relationship, as well as data regarding non-contractual conduct or fraudulent conduct to CRIF Bürgel GmbH, Leopoldstr. 244, 80807 Munich.
The legal basis for these transfers is set out in point (b) of Article 6 (1) and point (f) of Article 6 (1) General Data Protection Regulation (GDPR). Data transfers based on point (f) of Article 6 (1) GDPR may only take place insofar as this is necessary for maintaining the legitimate interests of our company or those of a third party, and is not outweighed by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. The exchange of data with CRIF Bürgel GmbH also serves to comply with statutory duties of conducting creditworthiness assessments of customers (§§ 505a and 506 German Civil Code).
CRIF Bürgel GmbH processes the data received and also uses it for the purpose of creating profiles (scoring) to provide its contractual partners in the European Economic Area and Switzerland, and where applicable, third countries (if there exists for the country an adequacy decision of the European Commission) with information, among other things, for assessing the creditworthiness of natural persons. You may find more detailed information about the operations of CRIF Bürgel GmbH in the CRIF Bürgel GmbH Fact Sheet or online at www.crifbuergel.de/en/privacy.
e. Sharing of data with Regulatory and Enforcement Authorities
In order to comply with its legal obligations, Interwetten may be required to transfer players’ registration details, identification documentation, financial transactions, gaming transactions and general information about player accounts to regulatory and enforcement authorities within the EU/EEA. The said disclosure shall also include any disclosure to the Financial Intelligence Authorities in accordance with our legal obligation in terms of the Anti Money Laundering Directive EU (2015/849).
f. Sharing of anonymized Data
Interwetten's commitment to the protection of personal data notwithstanding, the company reserves the right to publish gaming data (e.g. achieved results), the player's first name, the initial of the surname as well as the player's country of residence on the Interwetten website as long as the player remains, directly and indirectly, unidentifiable.
g. Sharing of personal data for other purposes
It may be necessary to share personal data for additional purposes. However, Interwetten will only disclose personal data if and to the extent that one or more conditions set out in Sec. 5 a. are met.
6. Cookies, Third Party Services, Social Media Plugins and Trackers
The following types of cookies are currently used:
- Session cookies:
These cookies are stored in temporary memory and are deleted after the browser is closed. Session cookies do not collect information from the user’s computer. Session cookies allow players to be recognized within the Interwetten website so any page changes or item or data selection carried out is remembered from page to page during one session.
- Persistant cookies:
These cookies stay on players computer or device after the browser has been closed and last for a time specified in the cookie. Interwetten uses persistent cookies when we need to know who players are for more than one browsing session. For example, Interwetten uses them to remember players preferences (e.g. user name and language) for the next visit. They help improve player experience and allow the player’s experience to be personalised. The information these cookies collect may include personal information. Interwetten also uses these cookies to improve the website navigation and security by analysing anonymised information about the user such as browser type, browser plugins version, operating system. If players do not accept these cookies, it may affect the functionality and access to content on the Interwetten websites.
- Advertising cookies:
These cookies are used to deliver targeted content to players that might be of interest to them. Interwetten may use these cookies to remember websites players have visited and may share them with third parties such as advertisers or advertising agencies.
- Third party cookies:
These are cookies (or plugins and active script contents – for details see 6. b,) set on players’ device by third party service providers to allow them to deliver their services to you. The setting of these cookies is regulated by the cookie policies of the respective third parties.
By enabling cookies a player will receive the optimal experience from the Interwetten offers Nevertheless, it shall be the player´s sole choice to accept their use. Players are duly informed that by blocking all cookies they won't be able to use any service from Interwetten and some part of the website may become inaccessible.
For further information on cookies and how to manage and delete them please visit:
b. Third Party Services
Below Interwetten informs about the data collected by the several categories of third party services deployed with the offers of Interwetten. For such third party services additional privacy provisions of these third party services may apply. The following description of third party services may not be exhaustive and Interwetten reserves the right to use additional third party services at any time provided that appropriate measures to protect personaldata are in place.
aa. Social Media Plugins
Interwetten uses social media plugins for the purpose of enabling the player to interact between social media and the Interwetten websites and therefore share the gaming experience with others. Social media plugins allow the user to login to both social media and Interwetten account and to link content provided by Interwetten to the player’s social media profile. Social media plugins collect user data such as IP address, login data, accessing website and cookie data.
The following social media plugins are integrated to the websites of Interwetten:
- Facebook: Facebook Ireland Ltd., Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland or Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA https://www.facebook.com/policy.php
- Google+: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA http://www.google.com/intl/en/policies/privacy/
- Pinterest: Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA) https://policy.pinterest.com/en/privacy-policy
- Twitter: Twitter, Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA) : http://twitter.com/privacy
- Youtube: YouTube LLC, based in 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is a company of Google Inc. http://www.youtube.com/t/privacy
bb. Single Sign-On
Interwetten uses single sign-on technology for the purpose of facilitating the player’s access to the Interwetten websites and allowing interaction between the player’s chosen service provider or social media profile and the Interwetten websites. Single sign-on tools collect user data such as IP address, login data and cookie data. The following single sign-on tools are integrated to the websites of Interwetten:
- Facebook Connect: Facebook Ireland Ltd., Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland or Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA https://termsfeed.com/blog/privacy-policy-login-facebook/
- Google+: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA http://www.google.com/intl/en/policies/privacy/
- PayPal: PayPal (Europe) S.à r.l. et Cie, S.C.A. L-1150 Luxembourg https://www.paypal.com/ie/webapps/mpp/ua/privacy-full?locale.x=en_IE
- Windows Live: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland https://privacy.microsoft.com/de-de/privacystatement
cc. Tracking software
- Adjust: Adjust GmbH and Adjust Inc. is used to provide mobile analytics and attribution services to mobile apps. Inconnection with these services Interwetten may collect, process and use certain data from the users of these apps. However, the processing of personal data happens anonymized and in a way that the data can no longer be assigned to a specific data subject without additional information being provided. The collected data is used for analysing the performance of marketing campaigns and to provide performance reports. The data is not combined with any other data that would enable Adjust to personally identify data subjects (players). For more information please visit: (www.adjust.com/terms/privacy-policy/) For opt-out of Adjust tracking please visit (www.adjust.com/forget-device/)
-Emarsys: Emarsys eMarketing Systems AG, Maerzstrasse 1, 1150 Vienna; Interwetten uses emarsys as provider of cloud marketing software for email communication, combining machine learning and data science with personalization and multichannel delivery to maximize customer experience. For further information click here: https://www.emarsys.com/en/privacy-policy/: to unsubscribe to emarsys please send email to: email@example.com
-Google Ads/Marketing Platform: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as Google) Interwetten uses Google services to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. http://www.google.com/analytics/learn/privacy.html. https://tools.google.com/dlpage/gaoptout/
dd. Tracking software
- Google Analytics/Tag Manager/Firebase . Google Analytics uses various techniques, including cookies to help the website analyse how users use the site. The information obtained by Google Analytics about your use of the website will be transmitted to and stored by Google on servers, which may be operated outside member states of the European Union as well outside states party to the Agreement on the European Economic Area. This website uses a Google Analytics tracking code, to which IP anonymisation is added to enable anonymised collection of IP addresses (so-called IP masking). Google will use this information on behalf of the website operator for evaluating your use of the website, compiling reports on website activity and for providing other services relating to website activity and internet usage to the website operator. Google Analytics will not associate your IP address with any other data held by Google. Google Tag manager is managing all Google and third party tags in one place. Google firebase is monitoring and analysing the performance of Interwettens´mobile applications. Players may refuse the use of Google cookies by selecting the appropriate settings on your browser. However, by doing so players may not be able to use the full functionality of this website. http://www.google.com/analytics/learn/privacy.html. https://tools.google.com/dlpage/gaoptout/
- adjust (go to 6 cc.)
ee. Third Party Games Providers
Within the casino offers of Interwetten, casino games provided by third party game providers may be deployed. For these games provided via the game provider websites additional provisions may apply. More information about these third party providers are provided in the general Terms and Conditions. Interwetten reserves the right to use additional casino game providers at any time.
Interwetten is also using WhatMessage, a publishing platform provided by Burda Direct Interactive GmbH Hauptstraße 130 D-77656 Offenburg, which is using WhatsApp, Facebook Messenger, Insta, Telegram to distribute chat functions, ads and product information to users. Personal data such as mobile number and user profiles may be transferred to
Burda Direct to provide the service. For more information please click: http://whatsmessage.de/datenschutz.html
ff. Customer Service (Co-Browsing, Live Chat, Chatbots, Webcalling)
Interwetten uses the Chatvisor Customer Service Suite (“Chatvisor”), a technology of Chatvisor GmbH (www.chatvisor.com). Chatvisor enables Co-Browsing, Live Chat, Chatbots, Webcalling and similar Functionalities on this website.
We use Chatvisor for the purpose of providing our customers with the best possible consulting and support experience on this website and related services. For reasons arising from your particular situation, you have the right at any time to object to this processing of your personal data based on Art. 6 (1) a) GDPR. If you object to the processing, request a copy of your data, correct or delete it, please contact us first at firstname.lastname@example.org or secondarily Chatvisor, at email@example.com.
Co-Browsing is a web-based, download-free screen sharing technology. If the User consents, Chatvisor allows an authorized and trained employee of our company to connect to the user‘s session on this website. When employees connect, it helps them better understand the user's concern to find more targeted solutions faster. Through co-browsing, the following information is continuously transmitted and processed: Mouse movements, scrolling behavior, clicks, form input (sensitive input is excluded from transmission by default), position on website, subpages visited, time on page, browser, operating system, type of terminal, screen resolution, anonymized IP address, place of access (city/nation). Processing is carried out based on Art. 6 (1) a) GDPR with the user's consent.
Desktop Co-Browsing is a download-free screen sharing technology. If the User consents, Chatvisor allows an authorized and trained employee of our company to connect to the User’s desktop (view only). When employees connect, it helps them better understand the user's concern to find more targeted solutions faster. Through screen sharing an image-by-image stream (video) is established. Processing is carried out based on Art. 6 (1) a) GDPR with the user's consent.
Live Chat takes customer inquiries. such inquiries will also be answered through the live chat. Chatbots also do this automatically. When a customer starts the chat, the affected person's browser transmits the IP address by default, which is immediately discarded and is therefore not saved. Basically, further personal data can be exchanged in a chat conversation between the person concerned and the client - either automatically by a chatbot or manually by an employee of the client. The data of the person concerned can be categorized within Chatvisor and saved together with the chat conversation. The data collected via the chat will be completely deleted by the chatvisor after a reasonable time. The personal data are processed in accordance with Art. 6 Para. 1 b GDPR to fulfill a contract to which the data subject is a party or to carry out pre-contractual measures that are carried out at the request of the data subject.
8. Data Security
All data will be processed in an automated manner. Interwetten takes all adequate technical and organizational measures to protect players' data from access by unauthorized persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration or damage. In particular payment information will always be encrypted when data is being processed.
Whereas sensitive information is protected online by SSL encryption, Interwetten makes any reasonable effort to ensure the protection of players' data in all other areas, too.
Only authorized employees of Interwetten, or employees of third parties contractually bound to compliance with the principles of data protection, have access to players' information. Interwetten monitors the trustworthiness and reliability of all its employees. At regular intervals, all employees are given training on the applicable security and data protection standards. All relevant servers are located in a secure environment.
In order to protect players' personal data during communication with the web browser, Interwetten uses encryption technology of its certification partner Thawte. In addition, online transactions are shielded by the security system of a worldwide-accredited partner.
Other Technical Security Measures
In addition, all player data is protected from unauthorized access by firewall and intrusion prevention systems.
9. Players' Rights
The player has the right to
- request access to personal data
- request correction of personal data
- withdraw the consent to the processing of data (e.g. for marketing activities)
- request erasure of personal data
- receive data in a structured, commonly used and machine-readable format (data portability)
- request the restriction of processing personal data
- to object to the processing of personal data.
Some of these rights may only apply under certain circumstances as set forth in data protection legislation including the General Data Protection Regulation.
All requests related to personal data or any rights mentioned above may be addressed to the contact details mentioned in Sec. 3 above.
10.Filing a Complaint
If the player is not satisfied with how we handle your personal data, the player is entitled to file a complaint to the competent data protection authority.
11. Amendments to this Data Protection Policy
This Data Protection Policy is subject to change from time to time. Although players will always be informed about any changes, it is recommended to review this policy and potential amendments regularly.
Version 2.0 – last update on 03/09/2020