Emperia Casino May Order a Credit Report on a Player at Any Time and Lists No Right to Erasure

Emperia Casino's privacy policy is issued for EmperiaCasino.com, operated by Fortuna Games N.V. of Curaçao, with Deltaprime Limited of Cyprus as EEA representative. It has 17 numbered sections and the captured text shows no date.

• A credit report is one of the checks. Section 9 reads: "We reserve the right to conduct a security review at any time to validate the registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms and Conditions and of applicable law". It continues that reviews "may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third-party databases", and that the player agrees "to provide such information or documentation as we may request". A review can come at any time, no event that starts one is named, and no limit on what is requested is stated.
• The rights listed are confirm, update, complain and opt out. Section 6 lets the player opt out of promotional communications in account settings, in an email or in writing, and lets the player ask to confirm the accuracy of the data, update it, or complain. The casino will update information "in case you prove the necessity for such changes". Section 15 adds: "as per Article 77 of the GDPR, you have the right to lodge a complaint related to your data processing to a supervisory authority". The policy lists no right to erasure, to a copy of the data or to portability, and no right to object beyond marketing, where on request the casino "will" "mark any information to prohibit future use for marketing purposes". The only mention of retention is that nothing prevents the casino "from retaining your Personal Information where we are required to do so by law". No period is given.
• Data goes to partners, and to other casinos and banks on a fraud finding or suspicion. Section 4 says the casino may share personal information "with our carefully selected partners (including any other parties that have data sharing arrangements with the latter)", and, unless the player has elected otherwise, may use email address and phone number to promote its products and those of third parties. Section 5 reserves the right to share information together with the player's identity with other online gaming sites, banks, credit card companies and authorities if, "in our sole determination, you are found to have cheated or attempted to defraud us", or if the casino suspects "fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment)". A chargeback is listed as fraudulent activity, so a disputed card payment can bring the player's identity to other casinos and banks.
• Accepting winnings is consent to advertising. Section 4 reads: "By accepting any contest prize or winnings from us, you consent to use of your name for advertising and promotional purposes without additional compensation, except where prohibited by law." The consent is given by taking the payout.
• Transfers abroad are consented to by use. Section 12 reads: "By using our services, you expressly consent to any transfer of information outside of your country (including to countries that may not be assessed as having adequate privacy laws)". Section 3 adds that personal information can come from "customer lists lawfully acquired from third-party vendors".
• Changes by posting, and no liability for release. Section 15 says changes are notified by posting the modified terms and that continued use constitutes acceptance. Section 14 says the casino cannot guarantee error-free performance regarding the privacy of personal information and "will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said Personal Information".
• Restricted countries for Netgame slots. Section 17, headed "When you play casino slots developed by Netgame", says a resident of the USA, Netherlands, France, United Kingdom, Australia, Spain, Dutch West Indies, Aruba, Bonaire, Saba, Statia, Dutch St Martin or Curaçao is not allowed to play the Games on the Website.

The policy collects and shares widely and names few limits. The one safeguard it cites by name is the right to complain to a supervisory authority.