Royal Ascot BV (hereinafter "PepperMill Casino") and its subsidiaries are committed to respecting and protecting players' personal data confidentiality. The paragraphs below outline the protection and use of data provided by players of PepperMill Casino.
1.1. Identity and contact details of the controller
Royal Ascot BV, with registered office at Europalaan 75, 3600 GENK, a company under Belgian law, with company number 0460.929.746. Royal Ascot BV is the holder of license B3864 under Belgian law for the exploitation of offline games of chance in a class II establishment and an additional license B+3864 under Belgian law for the exploitation of games of chance via information-society instruments.
1.2. Collection of personal data
All personal data provided is stored on the PepperMill Casino platform and remains strictly personal and confidential. Sensitive information is stored in encrypted form.
The categories of personal data stored are:
- Personal identification, such as name, address, date of birth, place of birth, nationality, gender, and telephone number.
- Electronic identification, such as username, email, browser type, and IP-address
- Identity card or passport number/national identification number
- Financial identification and transactions
Almost all of this data is provided by the player, except data received from business partners and other organizations, such as specialized companies that provide verification services, credit reporting agencies, and fraud prevention agencies.
The personal data collected may include so-called "special categories of data," such as data revealing health (related to responsible gambling).
In case of a change of personal data, players are requested to update their account information or contact the PepperMill Casino team with notification of the change in their account information, so that the correct personal data can be accessed by the PepperMill Casino team.
1.3. Purpose of collecting personal data
The processing of the player’s personal data is done in a confidential manner and in compliance with national and international law.
The collection of personal data is essential for the provision of the services and products offered by PepperMill Casino. Various bases are used for processing personal data.
1.3.1. Under the contract
The general terms and conditions that the player must accept when the player register include the terms of the contract.
- To offer game services, activities, or online content, to inform the player about them and to handle the player’s requests and queries;
- For "service administration purposes," such as resetting passwords, service messages, or updates to our policies;
- To process the player’s transactions.
1.3.2. Based on legitimate interests
- To personalize the player's experience. The player’s game history may be used to recommend content. The player may opt-out of personalized marketing offers at any time, which requires the player’s consent;
- To improve our products and services;
- To communicate with the player.
1.3.3. Based on legal obligation s
To comply with mandatory legal obligations to which PepperMill Casino is subject under EU regulations or local law.
- To verify that the player has access in accordance with our license terms;
- Detection, prevention and prosecution of crime;
- To verify the player’s identity and determine the source of funding for a transaction;
- To conduct appropriate anti-fraud checks. However, this will not affect the player’s credit rating;
- To assess and manage potential risks.
1.3.4. With the player’s permission
- For marketing purposes and to provide PepperMill Casino's services, by signing up the player accepts that PepperMill Casino reproduces the player’s username on its website, as well as those of its partners, when the players wins a tournament, win, prize and/or bet.
- We will send the player news about PepperMill Casino's products and services through various channels including email, text, post, social media, targeted advertising, but only if the player has previously agreed to receive these marketing communications. The player can change their marketing choices in their profile at any time.
1.4. Recipients of personal data
The collected personal data will be treated confidentially by PepperMill Casino’s staff. PepperMill Casino may disclose certain personal data to third parties, but only in the following cases:
- We work with service providers, agents and subcontractors to provide support in the internal operation of our website and to help us manage the various features, programs and offers available on the site. These third parties and their employees may also come into contact with the player’s personal data when they provide their services to us. All such third parties are required to apply the same level of security to the player’s personal data at all times as PepperMill Casino and, where appropriate, are bound by an agreement that requires them to maintain the confidentiality and security of the player’s personal data and to process it only in accordance with specific instructions.
- Personal information may be disclosed as part of a fraud investigation or if it is requested by a government agency as a result of legal processes and regulations (such as the Belgian Gaming Commission or the police). The player may not be informed of the disclosure of information, but PepperMill Casino can assure its players that all legal steps will be followed to prevent the leakage of information.
Service providers, representatives and subcontractors with whom we cooperate may be located in third countries. In this case, the transfer is based on an adequacy decision of the Commission of the European Union.
To protect customer information, PepperMill Casino uses the most advanced systems on the market. All information, whether from registration or financial transactions, is transferred to the PepperMill Casino server using secure encryption-technology and firewall. The PepperMill Casino website and its software are equipped with the latest security technology as well as the means to prevent the leakage of information through malicious use.
1.5. Retention of personal data
PepperMill Casino shall ensure an adequate, relevant and non-excessive collection of personal data, taking into account the purpose of the processing as indicated in this statement. The player’s personal data will not be retained for longer than is necessary to achieve the purpose of the processing, unless the retention of data is imposed by a law, decree or order. Typically, this means that we will retain the player’s relevant personal data for a period of ten years after the player is no longer a customer, from the date the player’s account is closed. There are several reasons why we retain the player’s data, these include:
- To comply with legal obligations under EU/local law (e.g. anti-money laundering requirements, or licensing requirements);
- To establish or defend legal claims (e.g., negligence claims) that might be brought against PepperMill Casino.
1.6. Player's rights with respect to personal information
The player has the right to access, modify and delete the personal information held by PepperMill Casino, the right to object to the processing of this data, the right to withdraw consent, and the right to data portability. The player also has the right to lodge a complaint with the supervisory authority if he/she is concerned about the way his/her information is processed. In addition, the player has certain rights regarding automated decision making and "profiling". Further information and advice on the player’s rights can be obtained from the organization responsible for processing the player’s personal data, as mentioned above, or from the data protection supervisor of the player’s country.
Autorité de Protection des Données
Data Protection Authority
Rue de la Presse 35 / Drukpersstraat 35
1000 Bruxelles / 1000 Brussels
Tel . +32 2 274 48 00
Fax +32 2 274 48 35
1.6.1. Right to access and rectify personal data
The player has the right to request a copy of the stored personal data, a so-called "data subject access request". The player also has the right to update incorrect data. These requests are free of charge. To exercise this right, the player must send a written, signed and dated request to the organization responsible for the above-mentioned processing, attaching proof of the player’s identity in the form of a copy of the player’s identity card. A copy of the player’s personal data will be sent to the player no later than 45 days after receipt of the player’s request, if relevant by electronic means.
1.6.2. Right to erase personal data
In certain circumstances, players may ask PepperMill Casino to delete their personal data ("the right to be forgotten"). This includes when:
- the information is no longer needed in relationship with the purpose for which it was collected;
- if the player previously authorized the use of the data, but decides to withdraw that authorization and PepperMill Casino cannot justify any other legal basis for its use;
- the information is processed based on the legitimate interests of PepperMill Casino and cannot demonstrate that there are compelling legitimate grounds to continue processing the information;
- PepperMill Casino has no lawful ground under data protection law to process the player’s information;
- the data must be deleted to comply with a legal obligation.
This right is subject to mandatory retention periods under EU and local law. This right can be exercised by closing the player account.
1.6.3. Right to restrict processing
The player has the right to request PepperMill Casino to restrict ("block" or "suppress") the processing of his personal data. When processing is restricted, PepperMill Casino may still store the information, but will not use it further. PepperMill Casino maintains lists of individuals who have requested to 'block' further use of their information to ensure that the restriction is respected in the future. This right is available to the player when:
- the player disputes the accuracy of the personal information (while PepperMill Casino verifies);
- the processing is unlawful, and the player objects to the erasure of the information and requests PepperMill Casino to restrict the processing instead;
- PepperMill Casino no longer needs the data, but the player needs it to establish, exercise or defend a legal claim; and
- PepperMill Casino processes the player's information for their legitimate business interests, but the player objects and while PepperMill Casino verifies the grounds for further processing.
1.6.4. Right to data portability
The player has the right to receive the personal data he provides in a "commonly used machine-readable format". This allows the player to obtain and reuse his information for his own purposes across different services. For example, if the player decides to switch to another provider, this allows him to easily move, copy or transfer his information between PepperMill Casino's IT systems and theirs, in a secure manner, without affecting its usability. However, this is not a general right, and only arises when the processing of the player’s data:
- Based on the player’s consent or when necessary for the performance of a contract, and
- when the information is processed solely by automated means
1.6.5. Right to object
Based on the player's specific situation, he or she may object to the processing of his or her personal data, i.e:
- Based on our legitimate business interests (including profiling);
- For research and statistical purposes.
The player also has the right to object to the use of his personal data for direct marketing purposes (including profiling).
1.6.6. Right to withdraw consent
Where we rely on the player's consent as the basis for processing their personal information - such as for marketing communications (see section 1.3.4) - the player has the right to withdraw consent at any time. PepperMill Casino always strives to make it easy for the player to withdraw consent by choosing an "unsubscribe" option in each communication. If the player finds that this is not the case, he can contact PepperMill Casino who will try to put things in order as soon as possible.
1.6.7. Rights related to automated decision-making, including profiling
PepperMill Casino uses systems to make automated decisions based on the player’s personal information. This helps to make quick, fair, efficient and accurate decisions based on what PepperMill Casino knows. These automated decisions may affect the products, services or features offered, or the ability to use our services.
Automated decision-making is used in the following situations:
- Tailoring products and services - similar customers are put into groups (segments) to study and learn about preferences and the player’s
- needs, and offer a more tailored experience;
- Fraud Detection - PepperMill Casino uses the player’s personal information to determine and detect whether the player’s account may be used for fraud or money laundering. If there is a risk of fraud, the account may be blocked or suspended;
- Account opening - when the player opens an account, PepperMill Casino checks whether the product or service is relevant to the player, based on what is known. PepperMill Casino also checks that the player meets the conditions required to open the account. This includes checking age, residence or nationality;
Data protection legislation aims to protect individuals from harm that may result from decision-making - including profiling - that takes place without human intervention. The player has the right not to be subject to a decision - including profiling - when it is based on the automated processing of the player’s personal data and it produces legal effects or a similarly far-reaching effect for the player.
It should be noted that the law does not apply when the processing takes place:
- Are necessary for entering into or performing an agreement with the player; or
- when permitted by law; or
- when it is based on the player’s express consent.
- To determine the visitor's preferred language
- to authenticate the player
- for website traffic analysis
Player complaint procedures provide players with the opportunity to make a formal statement regarding their experience at our gaming site. This system allows trust to be established between the site and the player, and strict business practices are established and enforced.
We invite players to contact us if they experience any problems. PepperMill Casino does its best to resolve problems within 14 days.
Once a player has filed a complaint, PepperMill Casino will study the case to try to reach a satisfactory resolution.
The player is aware of the general terms and conditions of use of the site and accepts that any complaint or dispute submitted by him later than 14 days after the initial issue will not be taken into account and will therefore be without object.
For more information on this subject, the player can consult the general terms and conditions of the site.
We will make every effort to conduct our investigation and issue any necessary refunds within 10 business days of the submission of the complaint.
Requirements for the player grievance procedure:
To make a complaint eligible for investigation:
- The player must have used our game site.
- The player must have sent their complaint no later than 14 days after the problem arose.
- The complaint must contain precise details of when the problem occurred (day, date and time).
- The complaint must be in accordance with the Terms and Conditions.
- The Terms and Conditions agreed upon at Registration can be accessed by players through our site.
A complaint may be filed:
- By email at firstname.lastname@example.org;
- Through live chat available on the website;
- By post to the organization responsible for the above processing.