Privacy Policy

Introduction

Club Liberté (the Company) is dedicated to protecting your personal information and informing you about how we use it. This privacy policy applies to transactions and activities and data gathering throughout the Company. Please review this policy periodically as we may revise it without notice. This policy was last revised 01/05/2021. Each time you use Club Liberté services and gaming products or provide us with information, by doing so you are accepting the practices described in this privacy policy at that time.

Data We Collect from You

In order to run our business and to provide you with information about products or services that may be of interest to you, we may collect "personal information" (i.e. information that could be used to contact you directly such as full name, postal address, phone number or email address) or "demographic information" (i.e. information that you give us or that we collect, that is not personal information; this may include but is not limited to post code, home town, gender, username, age/birth date, browsing history information, your IP address and registration history.

If you join Club Royale", our loyalty program, we will also record your facial image and verify you are who you say you are by requesting some form of identification (ID). This ID information will also be recorded. When you join “Club Royale" you will be given an Club Royale" card, this can then be used at the gaming tables or in our Electronic products and for F&B purchases. A full set of terms and conditions for Club Royale" can be found on our website. Each time you use the Club Royale" card we will record details of your visit to the Casino and we will also record any transaction you perform on our gambling products. When you use your card at the gaming tables the same will apply we will record the details of your gambling activity.

How we Use Personal Information

We use your personal information to enable us to efficiently run our business and to contact you about products and services that may be of interest such as events and promotions.

We also use your Personal Information to ensure we comply with the casino industry Gambling Regulations as specified by our Regulator, The Financial Services Authority of Seychelles (FSA).

In order to uphold and comply with Anti-Money Laundering Legislation and Regulations we may pass on your Personal Information to Law Enforcement authorities who may make such requests in the line of their investigations..

How to Edit or Update Your Information

The accuracy and integrity of your Personal Information is very important to us. If you feel at any time that the information we hold about you is incorrect or requires updating then please contact us by any means possible and we will update or correct our records.

We may periodically contact you or speak to you in person about the accuracy of your Personal Information as our efforts to ensure it is accurate are ongoing.

Information Retention

We do under normal circumstances, and if you have not requested otherwise, retain your Personal Information for a minimum of 7 years, in accordance with prevailing legislation.

If after 7 years you have made 1 or more visits to our Casino, then we may contact you to verify that the information we hold about you is still accurate and that you are still happy for us to hold this information about you.

If after 2 years you have not made a registered visit* to our Casino then we will remove your Personal Information from our databases and systems.

*A ‘registered’ visit is classified as a visit which has been recorded on our internal systems. Examples include via customer use of the Club Royale" card, other recorded transactional activity or via redemption of a promotion (on-site).

Your Rights Regarding Your Personal Information

Under normal General Data Protection Regulation provisions, you have a number of rights regarding your Personal Information and we will outline these below.

• You have the Right to be Informed

You must be informed clearly and concisely regarding the purpose and legal basis of collecting and processing the information, who to contact if you have any issues relating to the information, where the information will be kept, if the information is to transferred to another country, who will access the information, the retention period, the right to withdraw consent or lodge a complaint, whether the provision of the personal information is part of a statutory or contractual requirement, the existence of any automated decision making.

• You have the Right to Access

To obtain confirmation as to whether or not your personal data is being processed and, if so verify the lawfulness of processing, this Information must be provided free of charge and provided with a reasonable timeframe.

• Requests should be made in writing to the Compliance Officer and you will need to provide both of the following:

a. Photo ID

b. Proof of address

• You have the Right to Rectification

You have the Right to Rectification If your personal data is inaccurate or incomplete then you have the right to have this corrected. Or if we have disclosed the personal data to third parties for verification purposes and the information has been updated or corrected then we will inform you of this where possible.

• You have the Right to Erasure - We will remove your information without undue delay if:

a. The Processing is no longer necessary in relation to purpose

b. You withdraw consent.

c. You object to processing (and there are no legitimate overriding grounds for ongoing processing).

d. The Processing is unlawful.

e. Your Personal data has to be erased to comply with legal obligation.

• We may refuse a request if we need to comply with a legal obligation to keep the data.

a. For vital interests or public interest.

b. Archiving in relation to public interest, scientific/historic and statistical research.

c. Exercise of legal claims.

•A decision to refuse any request of Erasure will be made by the Board of Directors under advisement from the designated Compliance Officer. Data Subjects have the right to appeal any decision made.

• You have the Right to Restrict Processing You have the right to restrict the processing of your information if you contest the accuracy of the information, if the processing is unlawful or if we no longer need the information but you require the data to establish, exercise or defend a legal claim.

• Cases in Which We Share Personal Information

Your Personal information may be passed onto a third party in the event of a transfer of ownership or assets, or a bankruptcy. We may also disclose personal information when we determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement or to protect the interests or safety of Club Liberté services. We may also disclose your personal information to our subsidiary companies and other affiliated legal entities and businesses with whom we are under common corporate control. All of our subsidiary and affiliated legal entities and businesses that receive your personal information from us will comply with the terms of this privacy policy with respect to the use and disclosure of such information.

• Our Security Precautions

The Company makes every reasonable effort to ensure that your information is secure on our systems and we periodically review and update this Privacy Policy and other privacy initiatives, our systems and network security.

• The Company has security measures in place to protect against the loss, misuse and alteration of your personal information.

• Changing our Privacy Policy for Previously Gathered Information

If at any point we decide to use your personal information in a manner materially different from that stated at the time it was collected, we will notify you by way of an email or by post. This Privacy Policy is available on all our website and we encourage you to review it periodically. Please note we will continue to have the right to change this policy and any related practices and how we use your personal information without notice as described herein, provided that such changes shall only apply to information gathered on or after the date of change.

• Contacting Club Liberté

a. If you have any questions about this Privacy Policy, would like to submit a Data Subject Access Request or amend your current preferences/personal information, please contact our Compliance Officer via email at [email protected] or in writing a letter to Club Liberté, PO Box 4109, Anse Royale, Mahe, Seychelles.

b. Alternatively, enquiries can be made in person at any of Club Liberté. Please note that in all circumstances, ID verification will be required before any Personal Information is released.