HOLLAND CASINO ONLINE PRIVACY STATEMENT

Holland Casino places great importance on protecting your privacy and ensuring the security of your personal data. We process your personal data responsibly, in accordance with the General Data Protection Regulation (hereinafter: “GDPR”) and other relevant laws and regulations such as the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the Remote Gambling Act (Koa).

This Privacy Statement informs you about how we process and secure your personal data. This Privacy Statement applies to the collection and processing of personal data of (potential) visitors/players of (the website of) Holland Casino Online.

Holland Casino Online is located at Neptunusstraat 71, Hoofddorp and is registered with the Chamber of Commerce under registration number 68662289. Holland Casino N.V. has a license from the Dutch Gambling Authority to offer games under license number 1610/01 247085.

The most recent version of this Privacy Statement is dated October 2024. We recommend that you read this statement carefully and check regularly for changes as we periodically update our Privacy Statement. If we make significant or substantial changes, we will actively inform you.

1. The origin of your data

We collect personal data when you visit our website and/or use one of our online services. In some cases, you have provided us with your data yourself, for example when you register for an account or send us a message. We may also receive data from third parties such as the Gambling Authority or law enforcement agencies.

2. Which data we process and why

I. Onboarding, identification, and verification

Legal basis: based on a legal obligation, based on a contract

When you create an account with us, we are legally required to request your personal data in order to verify your identity. Without providing this information, you are not permitted by law to play at Holland Casino Online. Additionally, we need your personal data to offer you games, process payouts, and inform you about our services. To achieve this, we use the following data:

• Name;
• E-mail address;
• Postal address;
• Telephone or mobile number;
• Date of birth;
• Gender;
• Banking and financial data;
• Proof of identity (incl. BSN);
• Login credentials.

II. Monitoring database

Basis: based on a legal obligation

We are legally required to set up a 'monitoring database'. This control database can be used by governmental organizations such as the Gambling Authority and the Tax and Customs Administration that supervise Holland Casino Online, and contains a unique identifier for each player. The following data is stored in this database:

• The date, time and nature of any change to the Player Profile and any action that exceeds the limits of the Player Profile;
• The reason for, and the date, time and nature of each intervention;
• Any amounts that have not been credited to your current account;
• The date and time of any credit request that we have refused because an incorrect means of payment was used;
• The date, time, amount and nature of each credit and debit to each account and payment method you used;
• The total stake and winnings per game type and the total amount of payment.

III. Improving our services

Legal basis: based on our legitimate interest

We process certain data based on our legitimate interest to continuously enhance the quality of our products and services. This helps us better understand how our users interact with our offerings and allows us to make improvements where necessary. Specifically, we use the following types of data:

• Information about how you use our products and services;
• Information about your online behaviour on the website;
• Information about devices you have used to access our services (such as model, operating system, IP address, browser type, mobile device identifier);
• Information that you have voluntarily shared with us or made public, such as Social Media profiles.

Holland Casino Online also conducts trend analyses within different groups of people. We use this to map out the (gaming) needs within our target group, so that we can improve our services.

IV. Gambling prevention policy

Basis: based on a legal obligation, based on our legitimate interest

When you create an account, we check if you are between 18 and 24 years old, as we are required to take extra protective measures for young adults (18 to 23 years old). For instance, young adults are excluded from participating in promotions. We also verify whether you are registered in the Central Register of Exclusion from Gambling (CRUKS) or the Central Guardianship and Administration Register (CCBR). If you are registered in either of these, you will not be permitted to play with us.

Additionally, we monitor your chats and gaming behavior to assess how you engage with gambling and identify any risk factors for addiction. As part of this process, we classify you into a risk category (profiling). We are legally obligated to protect you from gambling addiction and prevent potential financial or personal harm to you and your loved ones. To achieve this, we use the following data:

• Gaming behaviour;
• Transactions;
• Playtime;
• Number of logins;
• Play limits;
• Measures.

If we reasonably suspect excessive gaming or a gambling addiction, we will address your behavior in a personal conversation. During this conversation, we record the following data:

• Your identity;
• The date, time and reason for the personal interview;
• Information about the content of the personal conversation;
• Your reaction to the personal interview;
• The conclusions you draw from the results of Holland Casino's research into your gaming behaviour;
• Any intervention measures taken prior to or as a result of the personal interview.

The conversation may result in a decision to (temporarily) exclude you from participating in games or to impose specific playing limits. We will document the measures taken. Additionally, we may store health-related data if required to comply with our legal obligations.

V. Prevention of money laundering, fraud and match-fixing

Basis: based on a legal obligation

During your registration, we verify the information you provide to ensure its accuracy. We do this by cross-checking your data with third parties, such as your bank or mobile provider.

Once your account is created, we monitor and analyze your gaming behavior and transactions. If this information, or external signals, raises concerns, we may initiate an investigation and request additional details to ensure there is no money laundering, fraud, or match-fixing. We are legally required to conduct such investigations. In some cases, we may ask you for documents like proof of income or address. With your permission, we may also obtain this information directly from third parties, such as your bank, the Tax and Customs Administration, UWV, or DUO.

If there is a (suspected) case of money laundering or fraud, we are legally obligated to take action. This could include (temporarily) blocking your account or restricting access to certain games. We will document the actions taken and the reasons behind them.

VI. Scientific research

Legal basis: based on our legitimate interest

To improve our understanding of gaming behavior and contribute to scientific research, we collect certain data based on our legitimate interest. This allows us to analyze patterns, improve player protection, and enhance our services. The data we collect includes:

• Frequency of play;
• Time;
• Playing behaviour;
• Limits on gaming behaviour (maximum duration, deposits, funds) and adjustments thereto;
• Changes in the playing account;
• Bets, Winnings and Losses;
• Use of bonuses;
• Measures.

Where possible, we apply pseudonymisation or anonymisation, in line with our internal policy.

VII. Commercial communications

Legal basis: based on your consent

Holland Casino Online would like to inform you about its products and services through various channels, such as email, post, text message, telephone, or other means of communication. We will only contact you if you provide explicit consent, and you can always choose to unsubscribe from further commercial communications. You can opt-out in the following ways:

• By communicating your preferences under 'Communication preferences' in the settings of your account;
• By clicking on the 'unsubscribe' link at the bottom of the e-mails sent by Holland Casino Online;
• By contacting Customer Service or by using the contact form on hollandcasino.nl.

If you unsubscribe from receiving commercial communications, we will remove you from our mailing list as quickly as possible, typically within 1 to 3 business days.

VIII. Customer Service

Basis: based on a legal obligation, based on our legitimate interest

We record all your contact moments (telephone and chat conversations) with Holland Casino Online to check whether we have carried out your instructions correctly, to resolve questions or problems, to ensure that we comply with the rules, or to detect or prevent fraud or other crimes.

IX. Service Messages

Legal basis: based on our legitimate interest

We may reach out to provide important information regarding our services, such as updates to your account or actions required to continue playing. You can opt out of these notifications by contacting Customer Service.

X. Data Sharing and Optimization in Marketing and Social Media

Legal basis: based on our legitimate interest

Holland Casino Online creates a marketing profile for you to provide more personalized offers and enhance your service experience. To do this, we use your age, gaming behavior, and email address.

Holland Casino may also share this data with social media and marketing partners, such as Meta, to improve our advertising strategies, assess the effectiveness of our campaigns, and protect vulnerable groups from unwanted marketing. This ensures that you receive the most relevant ads. We securely handle this data exchange and apply pseudonymization where necessary to protect your privacy.

We never sell your data to third parties for marketing or sales purposes. However, we may sometimes share information about you with third parties insofar as this is necessary for proper business operations or in connection with the delivery of a service or product.

These third parties include:
Google, you can read the privacy terms here.
Microsoft, you can read the privacy terms here.
Meta, you can read the privacy terms here.

XI. Data Collection Through Online Advertising and Social Media

Legal basis: based on our legitimate interest

When you interact with our online advertisements or social media—such as responding to messages or clicking on ads—we may collect information like your profile name and other publicly available details. This data helps us improve our advertising strategies and assess the effectiveness of our campaigns.

In some cases, we may request personal information for activities such as giveaways, quizzes, or polls. However, we only use the information you provide for these specific purposes. For other actions on these platforms, the privacy statements of the respective providers will apply.

3. Automated decision-making

Holland Casino Online uses advanced technology to detect patterns that may indicate fraud or money laundering. We also monitor gaming behavior to identify potential risks of gambling addiction early on. For instance, our systems track the number and amounts of transactions within specific time frames, as well as login attempts from different locations on the same player account. The primary goal is to flag abnormal or suspicious patterns.

When suspicious activity is detected, the system may send an alert, which could lead to automatic actions, such as blocking or temporarily suspending your account. In some cases, this decision is made automatically without employee involvement. However, you have the right to request a manual review by a Holland Casino Online employee, unless the automatic decision is required to fulfill the agreement, is legally permitted, or you have explicitly consented to it. Holland Casino Online regularly tests its detection systems to ensure they function fairly, effectively, and without bias.

4. Minors or incapacitated persons

In accordance with laws and regulations, we are prohibited from offering games to minors. As a result, our online gambling services are not accessible to individuals under the age of 18. This restriction also applies to individuals who have been declared legally incapacitated.

5. How long we keep your data

We retain your personal data only for as long as necessary for the purposes of processing. In some cases, we may store certain data in an anonymous form. For each processing activity, we have defined retention periods outlined in our retention policy. Many of these periods are legally mandated, such as tax regulations that require data to be stored for seven years. Additionally, we may retain your data for archiving purposes, in the event of legal proceedings, or for scientific research.

6. How we protect your personal data

We take all necessary measures to prevent the misuse, loss, unauthorized access, disclosure, or modification of your personal data. This includes using secure network connections, firewalls, and encryption. Access to your data is restricted to individuals who require it, all of whom are legally obligated to maintain confidentiality. We also extend this obligation to third parties who perform services on our behalf through contractual agreements.

7. Your rights as a data subject

You have several rights regarding the processing of your personal data. If you would like more information or wish to exercise any of these rights, please contact our Privacy Team at privacyverzoek@hollandcasino.nl. We are happy to assist you.

Your rights are listed below:

• Access: you have the right to check which of your data we process. Most of the data is visible in your account, but you can always request an overview. Please indicate specifically what you are looking for.
• Correction: you have the right to have your details changed, for example because you have moved house or because your bank account number has changed.
• Deletion: you have the right to have data deleted because it is no longer relevant, you no longer give consent, you object to the processing of personal data or the processing of personal data is unlawful.
• Restriction: You have the right to have the processing of your personal data restricted if you believe that the personal data we use about you is inaccurate, that its processing is unlawful, if you need it to exercise a legal claim, or if you have objected to its processing.
• Data portability: you have the right to have your personal data transferred to you or to a third party if the processing is based on consent or when it is necessary for the performance of a contract, and when the data is processed by automated means.
• Objection: if we process your personal data based on our legitimate interest, you have the right to object to further use of your personal data by us.
• Withdrawal of consent: you have the right to withdraw the consent given to us to process your personal data.

8. Transfer of personal data to other parties

Holland Casino Online engages external companies, subcontractors, and suppliers to process your data. We establish data processing agreements with these parties to ensure that the rights and freedoms of data subjects are protected. We adhere to GDPR as our guiding framework and require all external parties to fully comply with its standards.

Additionally, we may share your personal data with third parties to comply with legal obligations, during legal proceedings, at the request of law enforcement or the judiciary, or in response to a court order or subpoena. Where possible and legally permitted, we will anonymize or encrypt your data.

We are also legally required to prepare reports on various matters, including gambling behavior, consumer protection, the prevention of gambling addiction, and complaints received. These reports may contain your personal data and are securely shared with authorized parties, such as the Gaming Authority and the Dutch Central Bank.

9. Protection of your data in countries outside the EEA

When some of our suppliers or data processors are located outside the European Economic Area (EEA), we take all necessary measures to ensure your data is well protected. Our contracts with these parties require them to guarantee privacy protection at a level equivalent to the standards within the EEA. This means that your data will be safeguarded according to EEA regulations.

Data transfers to countries outside the EEA may be based on an adequacy decision by the European Commission, confirming that the country offers sufficient protection. If no adequacy decision applies, we use the European Commission’s Standard Contractual Clauses. In certain cases, we may also rely on one of the exceptions under Article 49 of the GDPR for specific processing operations.

10. Contact

If you have any questions and/or complaints about the processing of your personal data, you can contact the Privacy Officer via privacyoffice@hollandcasino.nl or our Data Protection Officer via FG@hollandcasino.nl.

If you are not satisfied with the way in which we have handled your question or personal data, you have the right to file a complaint with the Dutch Data Protection Authority.