Privacy Policy

Welcome to Snurr. This Privacy Policy describes how Snurr ("we", "us", or "our") collects, uses, processes, and protects your personal data when you use our website, mobile applications, and other online products and services (collectively, the "Services"). We are committed to safeguarding your privacy and the security of your personal information. By accessing or using our Services, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this policy, do not use our Services. We operate under a licence granted by a respected regulatory authority, and our data processing activities comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) where relevant.

We collect various types of information to provide and improve our Services. This includes:

• Personal Identifiable Information (PII): This includes your name, date of birth, gender, home address, email address, telephone number, and national identification numbers (where required for verification). We collect this when you register an account, complete verification processes, or communicate with our customer support.
• Financial Information: Details related to your payment methods, such as bank account numbers, credit or debit card details, and e-wallet information. We do not store full payment card numbers. We use tokenisation provided by our payment processors.
• Transaction Data: Information about your betting and gaming activities, deposits, withdrawals, and other transactions conducted through Snurr.
• Technical Data: This includes your IP address, browser type and version, operating system, device type, unique device identifiers, time zone setting, and other technology on the devices you use to access our Services.
• Usage Data: Information about how you use our website and Services, including pages visited, features used, time spent on pages, and referring URLs.
• Communication Data: Records of your communications with us, including emails, live chat transcripts, and telephone calls. We may monitor and record these interactions for training, quality assurance, and compliance.
• Verification Documents: Copies of identification documents, proof of address, and other documents required to verify your identity and age, and to comply with our regulatory obligations (e.g., Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements).

We use the information we collect for various purposes, including:

• To Provide and Manage Your Account: This includes setting up and maintaining your Snurr account, processing your bets and transactions, and providing you access to our gaming products.
• To Process Payments: Managing your deposits and withdrawals securely and efficiently.
• To Verify Your Identity and Age: Confirming you are of legal gambling age and that your identity is correctly established, as required by law.
• To Comply with Legal and Regulatory Obligations: Including AML, KYC, responsible gambling, and fraud prevention requirements.
• To Improve Our Services: Analysing usage patterns to enhance our website, develop new features, and optimise user experience.
• For Customer Support: Responding to your queries, resolving issues, and providing assistance.
• For Marketing and Promotional Purposes: Sending you information about promotions, bonuses, and new games that may interest you, where you have consented to receive such communications. You can opt out at any time.
• For Security and Fraud Prevention: Detecting, preventing, and investigating fraudulent or illegal activities, and ensuring the integrity of our Services.
• To Personalise Your Experience: Tailoring content and offers based on your preferences and gaming history.

We process your personal data based on one or more of the following legal grounds:

• Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party (e.g., our Terms and Conditions) or to take steps at your request before entering into such a contract.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject (e.g., AML, KYC, responsible gambling regulations).
• Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. Our legitimate interests include improving our Services, preventing fraud, ensuring network and information security, and direct marketing (where permitted).
• Consent: Where you have given explicit consent for us to process your personal data for one or more specific purposes (e.g., for sending marketing communications). You have the right to withdraw your consent at any time.

We may share your personal data with the following categories of recipients:

• Service Providers: Third-party vendors and service providers who perform services on our behalf, such as payment processors, IT support, identity verification services, marketing agencies, and data analytics providers. These providers are contractually obligated to protect your data and use it only for the purposes for which it was disclosed.
• Regulatory and Law Enforcement Authorities: We may disclose your information to government bodies, regulatory authorities, and law enforcement agencies when required by law or in response to a valid legal request (e.g., court order, subpoena). This includes our licensing authority.
• Fraud Prevention Agencies: To prevent fraud, money laundering, and other illegal activities, we may share information with specialist agencies.
• Affiliates and Group Companies: We may share your data with other companies within our corporate group for operational, administrative, and analytical purposes.
• Potential Purchasers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity.

We will never sell your personal data to third parties for their independent marketing purposes.

We protect your personal data. We implement robust technical and organisational measures to ensure the security of your information and to prevent unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: Using SSL/TLS encryption for data transmission over the internet.
• Access Controls: Restricting access to personal data to authorised personnel only, based on a need-to-know basis.
• Firewalls: Employing firewalls and other network security technologies.
• Regular Audits: Conducting regular security audits and penetration testing.
• Data Minimisation: Collecting only the personal data necessary for the specified purposes.
• Staff Training: Providing regular data protection and security awareness training to our employees.

While we protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security. You also play a crucial role in protecting your data by choosing a strong password and keeping your account credentials confidential.

Depending on your jurisdiction, and particularly under GDPR, you have certain rights regarding your personal data. These rights include:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ("Right to Be Forgotten"): You have the right to request the deletion of your personal data under certain circumstances (e.g., if the data is no longer necessary for the purposes for which it was collected).
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain conditions (e.g., if you contest the accuracy of the data).
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to Object: You have the right to object to the processing of your personal data in certain situations, particularly where processing is based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Where we rely on your consent for processing, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

To exercise any of these rights, contact us using the details provided in the "Contact Us" section below. We will respond to your request in accordance with applicable data protection laws.

Snurr uses cookies and similar tracking technologies to enhance your experience, analyse website usage, and for marketing purposes. Cookies are small text files stored on your device when you visit our website.

• Strictly Necessary Cookies: Essential for the operation of our website, enabling core functions like account login and secure transactions.
• Analytical/Performance Cookies: Help us understand how visitors interact with our website, allowing us to improve its functionality and content.
• Functionality Cookies: Remember your preferences (e.g., language, region) to provide a more personalised experience.
• Targeting/Advertising Cookies: Used to deliver relevant advertisements to you and measure the effectiveness of our marketing campaigns.

You can accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, disabling cookies may affect the functionality of our Services. For more detailed information about our use of cookies and how to manage your preferences, refer to our dedicated Cookie Policy.

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements. The specific retention periods vary depending on the type of data and the purpose of processing. For example:

• Account Data: We retain your account data for the duration of your active account with Snurr and for a further period as required by our regulatory obligations (typically 5-7 years after account closure) to comply with AML and fraud prevention laws.
• Transaction Data: Financial transaction records are typically retained for a minimum of 5-7 years as required by financial regulations.
• Marketing Consent: If you have consented to marketing, we retain your contact details for marketing purposes until you withdraw your consent or opt out.

After the retention period, your personal data will be securely deleted or anonymised, unless further retention is required by law or for legitimate business reasons.

Your personal data may be transferred to, and stored at, a destination outside of your country of residence, including countries outside the European Economic Area (EEA) that may not have the same level of data protection laws as your home jurisdiction. When we transfer your data internationally, we take appropriate safeguards to ensure your data is treated securely and in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:

• Transferring data to countries deemed to provide an adequate level of protection by the European Commission.
• Using Standard Contractual Clauses (SCCs) approved by the European Commission.
• Implementing other legally recognised transfer mechanisms.

By using our Services, you acknowledge and agree to such transfers.

Our Services are not intended for individuals under the legal gambling age in their respective jurisdiction, which is typically 18 years or older. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will delete that information as quickly as possible. If you believe we might have any information from or about a child, contact us immediately.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. When we make significant changes, we will notify you by posting the updated policy on our website with a revised "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the Snurr Services after any changes indicates your acceptance of the updated policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, contact our Data Protection Officer (DPO) or our customer support team:

• Email: [email protected]
• Live Chat: Available on our website 24/7
• Postal Address: [Our registered office address, which we do not disclose here for security reasons, but is available upon request and to regulatory bodies.]

We address your inquiries promptly and transparently.