Privacy Policy

1. INTRODUCTION
   1. This Privacy Policy, last revised on 01/11/2024, describes how ninewin.com processes personal data. At ninewin.com, we aim to keep things straightforward for our customers, including being clear, transparent, and honest about the information we collect and the reasons we use it. For that reason, this page provides detailed information.
   2. This Policy explains how your personal data is used when you visit our site, make a deposit, or play our games. It also covers your privacy rights, the situations in which we receive or disclose information about you, and how we may use that information to tailor marketing communications. Please read each section carefully.
   3. If we make significant changes to this Policy, we will notify you.
   4. Please be aware that all employees receive regular Information Security training and must comply with confidentiality obligations, internal policies, and procedures whenever they handle your information.
   5. We hope this page is useful. If you have any questions or concerns about Data Protection, you may contact our Data Protection Officer at [email protected]. 

1. PRIVACY POLICY PROMISE
   1. Ninewin will always respect and protect the privacy of every customer. Your privacy matters to you and to us, and we make the following commitment:
   2. Ninewin is dedicated to safeguarding your privacy. We believe personal information should be used to make your experience simpler and better. We will keep your personal data secure, explain clearly why we collect it and how it is used, and where you have choices or rights, we will explain and honor them.
   3. To request a withdrawal, a player must wager active deposited funds at least once before withdrawing. This requirement supports anti-money laundering procedures.
   4. The Company may use additional procedures and tools to verify a client’s identity (Know Your Client) when deposits are made to an account. This may include, without limitation, a selfie with an identity document or another form of identification. To verify a player`s account, casino management requires documents (ID, payment systems, utility bills Рµtc) in the Latin or Cyrillic alphabet. If a player cannot provide documents in these alphabets, the Casino may require video verification where the player displays his/her documents.
   5. Players who deposit in CAD may withdraw funds only through EcoPayz, Interac, Instadebit, and iDebit. A minimum deposit using these payment methods is required before they become available for withdrawals.
   6. The Company may call the phone number listed in the client’s account as part of the KYC process. Until the account has been fully verified, no payouts will be made.

1. WHAT PERSONAL INFORMATION IS GATHERED AND WHEN
   1. When you register an account:
      1. personal details such as your name, email address, postal address, telephone or mobile number, gender, or date of birth;
      2. photo identification and proof-of-address documents for due diligence checks
      3. banking and financial information, including details needed to establish the source of funds where transactions are involved
      4. account access details, including your username and password

1. Through your use of our Services:
   1. details about how you use and interact with our products
   2. information about your browsing behavior on the Website – please refer to our Cookies Policy for further details;
   3. information about the devices used to access our Services, such as device model, operating system, IP address, browser type, and mobile device identifier
   4. recorded phone calls – we may monitor or record telephone conversations with you to confirm that your instructions have been followed correctly, resolve questions or issues, meet regulatory obligations, improve service quality, train staff, or detect and prevent fraud or other crimes
   5. information you voluntarily provide to us or make publicly available, such as social media profile information

1. Special categories of data
   1. Personal data collected by ninewin.com may include so-called “special categories of data”, including information related to health in a responsible gambling context (see Section «Why do we collect your Personal Data and on what basis»).
   2. we apply additional safeguards to protect sensitive personal data and maintain its confidentiality (see Section «Security of your data and confidentiality»).

1. WHY DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT BASIS?
   1. We understand the trust our customers place in us as a service provider. In return, Ninewin is transparent about why we collect your data. Most importantly, collecting information is necessary to provide the products and services you request. Your data also helps us personalize and improve your experience and contact you with important information from time to time. In some cases, we must collect and use information to comply with legal obligations. Data protection laws also require us to identify a lawful basis for processing personal information. Different activities rely on different lawful bases.
   2. Under the contract – when processing is required to perform a contract to which you are a party. The T&Cs accepted at registration set out the terms of that contract and the services we provide:

1. To provide our services to you under our contract

1. to provide gaming and betting services, activities, or online content, give you information about them, and handle your requests and inquiries;
2. for ‘service administration purposes’, including password reminders, service messages, website maintenance notices, updates to our Privacy and Cookies Policy or T&Cs, notifications that your Ninewin account has become dormant, and messages asking whether you want to use it again before we close it;
3. to process your transactions;

1. Under legitimate interests – Processing is necessary for the purposes described below, unless those interests are overridden by the interests, rights, or freedoms of affected individuals, including you. To decide whether we can process your data on this basis, we consider factors such as what you were told when you provided the data, your reasonable expectations, the type of data involved, and the effect of the processing on you.
   
   1. To personalize your experience

1. to deliver a more relevant and tailored service; for example, we may use your playing history to suggest personalized products and recommendations;
2. If you are logged in or subscribed to marketing offers, you may receive a personalized service. If you do not want this, you can unsubscribe from marketing offers or disable personalization by contacting Customer Service or emailing our Data Protection Officer.

1. To improve our services and products

1. to give you a smoother and more user-friendly online navigation experience;
2. for analysis and research so that Ninewin can improve the services it offers;
3. to test new systems and review upgrades to existing systems;
4. to measure marketing effectiveness and support market research and training;
5. for customer modeling, statistical review, and trend analysis, with the goal of developing and improving products and services.

1. To contact and interact with you

1. to contact you about our services, for example by phone, email, post, or social media;
2. to manage promotions and competitions that you choose to enter;
3. to invite you to participate in, and to manage, customer surveys, questionnaires, and other market research activities conducted by Ninewin or by other organizations acting on our behalf. We use market research to improve our services; however, if we contact you about this, participation is optional. If you tell us that you do not want to be contacted for market research, we will respect that choice and it will not affect your ability to use our services;
4. to respond to your questions and complaints.

1. To make your gaming experience safer and more enjoyable

1. to discourage, prevent, or detect the use of third-party software in peer-to-peer gambling;
2. to discourage, prevent, or detect activities that breach our T&Cs;
3. to carry out affordability checks and confirm that you have sufficient funds to use our Services.

1. Special categories of data
   1. We will process such data only if:

1. you have provided explicit consent;
2. the information concerns personal data that you have made public;
3. processing is required to establish, exercise, or defend legal claims;
4. processing is necessary for reasons of substantial public interest under European Union or Member State law.

1. WHEN DO WE SHARE YOUR PERSONAL INFORMATION?
   1. In general, we do not share your personal information with third parties outside the Company/s group for marketing purposes. However, we may share personal data with other companies, with third parties that provide services to you on our behalf, and with other parties where this is required to meet legal obligations. 
   2. We may disclose personal data to third parties in the following circumstances:
      1. when required by any regulatory authority and/or by any legal provision under the applicable governing law;
      2. we may instruct and authorize the Financial Institution holding an Account Holder’s account to disclose information requested by the Regulator in relation to that account;
      3. to establish, exercise, or defend our legal rights;
      4. for verification, affordability checks, and fraud detection purposes, we may transfer your personal data to third parties);
      5. with service providers that help us deliver our services, including companies supporting technology services, data storage and combination, payment processing, or relevant online advertising for our products and services;
      6. with external auditors who may perform independent checks as part of our accreditations;
      7. to an organization to which we sell or transfer, or negotiate to sell or transfer, any part of our business or any rights or obligations under an agreement we may have with you. If the sale or transfer proceeds, the receiving organization may use your personal data in the same way we do;
      8. to any other successor in title to our business; or
      9. with the relevant regulator regarding self-exclusion matters.
      10. when we enter into any merger or business sale, because customer personal information is likely to be included in the sale or transfer. We would notify you before such a transfer of personal data takes effect. Even when information is shared, we ensure it is used only for the purposes described in this Privacy Policy.

1. HOW LONG WILL NINEWIN.COM KEEP MY DATA?
   1. We keep your information only for as long as necessary to fulfill the purposes for which it was collected.
   2. While you remain a customer, we must retain your information to meet legal and contractual requirements. After you stop using Ninewin Services, we may still keep your personal information for a period of time. Reasons for retaining information include:
      1. to comply with legal obligations under EU/local laws, such as anti-money laundering rules or licensing requirements;
      2. to establish or defend legal claims, including negligence claims, that may be brought against us;
      3. to comply with contractual obligations and rights relating to the information concerned;
      4. to pursue legitimate interests where we have completed balancing assessments;
      5. to comply with guidance issued by relevant data protection authorities.

1. YOUR RIGHTS & CHOICES OVER YOUR PERSONAL INFORMATION
   
   1. We recognize that, by law and subject to certain conditions, you have several rights regarding the personal information we hold about you. To exercise these rights, contact our Data Protection Officer at [email protected]. These rights include access, correction, and deletion of your personal information, the right to object to processing, the right to withdraw consent, and the right to data portability. You may also complain to your data protection authority if you are concerned about how we process your information. In addition, you have rights related to automated decision-making and ‘profiling’.
   2. The personal information requested during registration is mandatory unless a form states that a field is optional. We need this information to process your registration, contact you, and comply with gambling and financial laws that apply to you. If you choose not to provide this personal information, you will not be able to use our services.
   3. Right to access and correct the information we hold about you. You may request a copy of the personal information we hold about you, known as a data subject access request. You may also ask us to update or remove information that is inaccurate or has changed since you first provided it. These requests are free of charge and may be sent by email to our Data Protection Officer or by contacting Customer Services at [email protected]. 
   4. Right to delete your data. In certain circumstances, you may ask us to erase personal information we hold about you (‘the right to be forgotten’). This includes where:
      1. the information is no longer needed for the purpose for which it was collected, as explained in our privacy notice;
      2. you previously consented to the use of your information but withdraw that consent, and we have no other lawful basis for using it under data protection law;
      3. we process your information based on legitimate interests and cannot show overriding legitimate grounds to continue processing it;
      4. we do not have a lawful basis under data protection law to process your information;
      5. the data must be erased to comply with a legal obligation;

This right is subject to mandatory retention periods required by EU/local laws.

1. Right to restrict processing. You may ask us to restrict (‘block’ or ‘suppress’) the processing of your personal information. When processing is restricted, we may continue to store your information but will not use it further. We keep records of people who have requested that further use of their information be ‘blocked’ so that the restriction is respected going forward. This right applies where:
   1. you challenge the accuracy of the personal information while we verify it;
   2. the processing is unlawful and you object to erasure, asking us to restrict processing instead;
   3. we no longer need the data, but you need it to establish, exercise, or defend a legal claim; and
   4. we process your information for legitimate business interests, but you object while we verify whether grounds for continued processing exist.

1. Right to Data Portability. You may receive personal information you provided to us in a ‘commonly used machine-readable format’. This allows you to obtain and reuse your information for your own purposes across different services. For example, if you choose another provider, it may help you move, copy, or transfer your information between our IT systems and theirs safely and securely without affecting usability. This is not a general right and applies only where the processing of your information is:
   1. based on your consent or required for performance of a contract, and
   2. carried out solely by automated means

1. Right to object. Depending on your particular circumstances, you may object to the processing of your personal information where it is:
   1. based on our legitimate business interests, including profiling; or
   2. carried out for research and statistical purposes

You also have the right to object to the use of your personal information for direct marketing purposes, including profiling.

1. Right to withdraw consent. Where we rely on your consent to process personal information, such as for sales and marketing communications, you may withdraw that consent at any time. We aim to make withdrawal easy by including an “unsubscribe” option in every communication we send. If this is not available, contact our Data Protection Officer at [email protected], and we will try to resolve the issue as quickly as possible.
2. Rights related to automated decision-making, including profiling. We sometimes use systems that make automated decisions based on your personal information. This helps us make decisions that are quick, fair, efficient, and accurate based on what we know. These decisions may affect the products, services, or features we offer you now or in the future, or your ability to use our services.

We may use automated decision-making in the following situations:

1. tailoring products and services – we may place you in groups of similar customers (segments) to understand preferences and needs and to offer you a more tailored experience;
2. detecting fraud – we use personal information to help decide whether your account may be used for fraud or money laundering. If we believe there is a fraud risk, we may block or suspend the account;
3. opening account – when you open an account with us, we check whether the product or service is appropriate for you based on what we know. We also confirm that you meet the conditions required to open the account, which may include checks of age, residency, nationality, or financial position;
4. risk assessment connected to your bet.

Data protection law is intended to protect individuals from harm that may result from decision-making, including profiling, carried out without human involvement. You have the right not to be subject to a decision, including profiling, when it is based on automated processing of your personal information and has a legal or similarly significant effect on you.

Please note that this right does not apply where the processing is:

• necessary to enter into or perform a contract with you; or

• authorized by law; or

• based on your explicit consent.

Any requests related to this Section must be sent to our Data Protection Officer at [email protected]. 

We will respond to requests related to this Section without delay and within one month of receiving the request. After prior notice, this period may be extended by one (1) additional month if necessary, considering the complexity of the request and the number of other pending requests. If we reject your request, we will provide the relevant reasons.

If your request does not satisfy the requirements of data protection law, we reserve the right either to: (a) charge a reasonable fee, taking into account the administrative cost of providing the information, communication, or requested action; or (b) reject your request.

1. SECURITY OF YOUR DATA AND CONFIDENTIALITY
   1. We are committed to protecting the personal information you provide to us. We take reasonable steps to ensure that all information collected through Ninewin is handled securely and in accordance with this Privacy Policy and strict data protection standards. We have adopted strong procedures and technologies to protect your data against unauthorized access and improper use.
   2. Our payment providers encrypt your credit card details. We are committed to protecting customers’ confidential information and work only with leading payment providers as part of that commitment.
   3. Third-party security specialists test the security of our systems and applications several times each year. We also operate an Intrusion Detection System that monitors network traffic 24/7 for signs of attacks or intrusions.
   4. We maintain a dedicated fraud department and advanced systems to identify and prevent suspicious activity, helping Ninewin remain a secure gaming environment. 
   5. Any account connected with suspicious activity will be suspended and investigated fully. If you have concerns about activity on your account, such as unfamiliar transactions in your transaction history or unexpected balance changes, please contact us immediately.
   6. ninewin.com uses SSL encryption to protect the confidentiality of information during transmission. We do not collect, store, or transfer card data. Payment operations are handled entirely through the payment gateway’s secure server.  

1. COMPLAINTS
   1. If you want to complain about how we have handled your personal data, you may contact us so the matter can be investigated by emailing our Data Protection Officer at [email protected]. 
   2. If you are not satisfied with our response or believe we process your personal data unlawfully, you may complain to your national data protection regulator.

1. CHANGES TO THE PRIVACY POLICY
   1. This Privacy Policy may be updated from time to time to reflect changes in how we operate or how our work is regulated. You may wish to review it whenever you submit personal information to us. The date of the latest revision will appear on this page. If you do not agree with the changes, please stop submitting personal information to ninewin.com and stop using our Services. Otherwise, continued submission of information or use of the Services will be considered acceptance of the updated Privacy Policy. You may also delete your Ninewin account at any time. If significant changes are made to the Privacy Policy, for example changes affecting how we want to use your personal information, we will provide a more prominent notice, including email notification for certain services. You may be required to expressly accept such a change to continue using the Services, and the change will apply immediately after your acceptance.

1. YOUR OBLIGATIONS
   1. By using ninewin.com and providing personal data, you acknowledge that you must provide real, accurate, and complete information as requested by Ninewin. You must also inform us of any changes to your information so it remains current and accurate.
   2. If you breach these obligations, or if we reasonably suspect that the information you provide is false, incomplete, or otherwise contrary to Data Protection Law or this Privacy Policy, we may reject your registration application or suspend or terminate your account immediately without notice. In such cases, you are not entitled to compensation for the rejection of your application or the suspension or termination of your account.

The operator of this website is Salattino SRL, with platform services provided by Pointissimo B.V., registered and licensed in the jurisdiction of Curaçao by the relevant regulatory authority (Gaming Control Board Curaçao / Curaçao eGaming). Registered address: Schottegatweg Oost 10, Unit 1-9, Bon Bini Business Center, Curaçao.