High Roller Takes Accepting Any Contest Prize or Winnings as Consent to Use a Player's Name in Its Advertising

High Roller's Privacy Policy, version 3.0 of 13 April 2026, is issued by Happy Hour Solutions Ltd of Nicosia, Cyprus, as data controller under European data protection legislation. Registering an account counts as consent to the policy, and the data subject rights are set out in full, from access and rectification to erasure, portability and objection.

• Winnings as consent to publicity. "Additionally, note that by accepting any contest prize or winnings from Us, you consent to the use of your name and/or nickname for advertising and promotional purposes without additional compensation, except where prohibited by law." The sentence does not say whether its winnings are only contest winnings or any win the casino pays, and it names no way to decline. A player cannot tell from the document whether an ordinary cash-out carries the consent.
• Five years of retention, and no erasure before then. "You are to note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, We are obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a Player account for a minimum of five (5) years from the last player transaction or account closure." "Therefore, requests for erasure prior to the lapse of this period cannot be entertained." The five years begin only when a player stops transacting, so for an active account the clock has not started.
• Data from online searches and the press. Alongside registration forms, correspondence, transaction history and GeoIP login data, the policy lists "Personal data from publicly accessible sources, including online searches, official company registries, and media publications, where it is reasonable to do so and where such collection does not adversely affect your rights or freedoms." Identity checks include whether a player is a politically exposed person. What a player never gave the casino can still end up in the file.
• Profiling for marketing, with a human on request. The policy may profile location data, age, betting and gameplay activity, interests and behavioural patterns for segmentation and tailored marketing, and gives the example that a player who places most bets on roulette may be sent roulette promotions. "You have the right to challenge any decision made solely through automated processing, to present your perspective, and to request a review of the decision by a human." The human review exists, and it is the player who has to ask for it.
• Marketing until the player opts out, partners included. Unless a player has elected not to receive promotional material, the email address and phone number may be used for marketing, including products and services from business partners such as game providers. Opting out is available in the account settings or through customer support, and an objection to direct marketing needs no justification. The default is in, and the switch is the player's to find.
• Who receives the data. Information may be passed to group companies and business partners: "These companies include Our parent companies, their parent companies and all of the subsidiaries of these respective companies, as well as other companies with whom We carry out business and hold necessary agreements." It may also go to processors outside the European Economic Area, with safeguards in place. Personal data is not sold or rented to third parties, and players will be told by email before their data is transferred in a merger or acquisition. The group the data may travel to is described by its relationships, never by its names.
• Changes with best-effort notice. "While We will do Our best to notify you of such changes, We recommend that you revisit this Privacy Policy regularly." Continued use of the website constitutes consent to the policy. A changed policy binds the player who keeps playing, whether or not the notice arrived.

The rights section follows the European rulebook closely, and a complaint to a data protection supervisory authority can be lodged at any time, even after the company declines a request. The clause that reaches furthest sits in the marketing section: a player who accepts a contest prize or winnings has agreed to appear in its advertising.