Dazzletag Entertainment Limited Privacy and Cookie Policy

Last Updated 23rd May 2018

PlaySunny is owned and operated by Dazzletag Entertainment Limited.

This is the privacy policy for Dazzletag Entertainment Limited. It sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. It is important that you read this policy in full to understand what information we hold about you, how we may use it and what rights you have in relation to your data.

We are bound by data protection and privacy laws. Under data protection and privacy laws, Dazzletag Entertainment Limited is a data controller of your personal data. Data controller is a legal term used in the General Data Protection Regulation to signify the entity who controls what to do with any given personal data.

By giving us your personal information, directly and/or through use of our services, you are accepting and consenting to our processing of your personal information in accordance with the practices described in this policy.

We may need to update this policy from time to time to reflect business or regulatory changes. If we do, we will contact all our customers pro-actively. However, it is important that you continue to check this policy regularly to ensure you are familiar with its terms.

If you have any requests concerning your personal data or any queries relating to these practices, please contact our Customer Support team on: helpdesk@playsunny.com


1) Who We Are

Dazzletag Entertainment Limited, a limited company incorporated and domiciled in Malta with company number C50978. Our registered address is Villa Seminia, 8, Sir Temi Zammit Avenue, Ta' Xbiex, XBX1011, Malta.

We are licensed to provide remote gambling facilities and software by the Malta Gaming Authority of Malta and The Gambling Commission of Great Britain. Dazzletag Entertainment Limited operates the following brands:

- Bingocams
- ShinyBingo
- TrendieBingo
- PlaySunny
- PlaySunny

In this policy, we refer to ourselves as “we”, “us”, “our” and “Dazzletag Entertainment Ltd”.



2) What We Collect

When you navigate to the website of one of our brands, we collect browser and cookie information. Please read our cookie policy below for further information on the cookies we use and how you can enable/disable them. In addition, we may also collect your IP address and technical information relating to the device from which you are accessing our website(s).

During the registration process and when you subsequently use your account at one of our brands, you may be asked to submit specific personal data including, but not limited to:
- your first and last name
- date of birth
- gender
- credit card or other payment information
- home address
- e-mail address
- phone/mobile number or other contact data
- a unique username and password combination for your account

Once you have created an account at one of our brands, additional information is processed on an on-going basis to ensure that our services can continue to be offered to you in a safe, legal and convenient manner. You must use your username and password to access (log-in) to your account. It is your responsibility to ensure the security of your log-in details and not to reveal this information to others. If you are concerned that a third party is aware of your user name and password, please contact our customer support via Live Chat or email helpdesk@playsunny.com immediately. You can also reset your password using the link in the top right of our homepage.

Much of the personal data we request from you is essential for the provision of the services to you (for example, enabling you to play the games on our website) or is required in order for us to comply with our legal obligations. It will be made clear to you when information we request is mandatory. We will not be able to provide you with our services or allow you to create an account with us if you choose to withhold requested information.

When you are logged into your account, Dazzletag Entertainment Ltd may also collect:

- a record of all internet communications and details of your visits to our website(s)
- a record of all wagers and game play activity
- a record of all promotional activity and bonus code redemption
- technical information relating to the device, such as device identifier, and browser you use to access our website
- details of transactions you carry out through the site, such as payments, withdrawals and wagers
- details of payment methods used; i.e. last four digits and card type
- communications with us or our employees; i.e. calls, emails, and messages sent through the live chat service
- messages or comments sent via our social media pages
- communications (chat logs) between you and other website users; e.g. public and private chat in our bingo rooms
- information regarding your location, including IP address
- any additional information you submit through the website; for example, on forums, chat rooms, comment sections or in response to quizzes and questionnaires
- in certain instances, we may also request that you send us additional information to verify your identity. This may include copies of photographic identification documents, proof of address, and source of funds for your account.

Card information and identification (KYC) documents are not stored directly by us. These are stored by third-parties who we have verified as having necessary PCI-DSS compliance to handle and store such sensitive information. These third parties are namely Pay360 by Capita and Experian. We will only store a “token”, containing the card type and last four digits, relating the card details stored with our payment provider, so that you can make a payment using a previously registered card.


3) How We Use Your Information

We use the information we collect to provide, maintain, protect and improve our services, to develop products and to protect Dazzletag Entertainment Limited and you. We also use this information to offer you tailored content, such as giving you more relevant promotional offers.

We process your personal data for the purposes of:

- creating and managing your account
- providing you with our services
- if necessary, contacting you via your registered contact information in connection with the management and operation of your account;
- protecting your personal information
- processing your online financial and wagering transactions
- researching your preferences, to develop new features, functionality, products and services
- providing you with customer support; ensuring our website functions correctly and identifying any technical issues
- complying with our legal and regulatory requirements, such as those relating to the identification of individuals under anti-money laundering legislation and ensuring responsible gambling
- complying with legal requirements for geo-restriction of gambling services;
- preventing fraudulent activity or cheating
- development of player profiles and algorithms to improve sales and marketing performance
- determining what promotions and bonuses to offer you
- analysing website traffic and providing you, unless you have not opted in, or subsequent to that, have opted out, with information by the contact methods you authorise us to use about our services, products, competitions, prizes and offers.
- publishing community content of interest to other players and to showcase our brands, such as via https://blog.bingocams.co.uk/

Dazzletag Entertainment Ltd. may assess your data to determine motivations for opening an account or placing a wager. Should your activity stand out from what Dazzletag Entertainment Ltd considers to be usual and expected behaviour, or fits into certain known patterns that denotes potential exposure and liability concerns, further analysis may be performed. In line with our Terms and Conditions, we may exclude you from certain promotions or from placing certain wagers as a result of this investigation.

Any commercial analysis performed is solely for our benefit and is not transmitted to any third party provided; however, we do reserve the right to transmit any personal data to third parties in a manner consistent with legal and regulatory requirements such as for e.g., fraud, anti-money laundering purposes and the like.


4) Who we share your data with

Certain trusted third-party companies provide services essential to our ability to offer our gambling products to you; for example. those that supply the software and games for our website, payment services, one or more entities in our corporate group, identity verification (such as verification service providers), fraud prevention and risk management. We may be required to share some of your information with these companies to be able to offer our services to you. In these instances, we ensure that the third party has appropriate security and privacy arrangements in place, so that your data is protected.

Dazzletag Entertainment Ltd may also be required to disclose your information to government authorities, such as the police or our regulators, to comply with our legal obligations and the requirements of our gambling licences, including for anti-money laundering purposes.

We will also disclose information as required to enforce our terms of use, in the administration of justice or where we have to defend ourselves or prosecute claims legally.

In the event of the completed sale of our business, or other business event which results in us having to transfer your personal data to a third party, you will be notified via email, and/or notice posted on our website, to explain the identity of the new data controller and your options regarding your personal data.

Our site may contain links to and from the websites of third party organisations. Please note that these websites may have their own privacy policies and that we do not accept any responsibility whatsoever for these policies. Please check these policies carefully before you submit any personal data via those websites.


5) Our Lawful Basis for Processing Your Personal Data

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

- it is necessary for the performance of a contract we have with you (e.g., to provide our services to you)
- you have provided your consent (e.g., for us to send you marketing);
- it is necessary for us to comply with legal obligations (e.g., to enable us to comply with fraud, anti-money laundering and gambling legislation)
- for reasons of substantial public interest
- it is in our (or a third party's) legitimate interests and such interests do not prejudice your rights or freedoms.
- our (or a third party's) legitimate interests include:

• ensuring our services are used fairly and in accordance with our terms and conditions;
• Combating crime (e.g., anti-fraud, anti-money laundering, etc) which could also include our requirement to comply with legal obligations, for instance, under money laundering regulations and legislation
• Detecting and preventing player game fraud and abuse, bonus abuse, in-game abuse
• Financial information (such as credit card or bank account numbers) in connection with a transaction
• Actions that are part and parcel to provision of services; such as account creation, account functionality, access to gambling, payment processing and customer services;
• Commercial purposes, including marketing, personalisation of offers, VIP management, trading decisions, website optimisation, promotions and bonuses, loyalty programmes, value profiling and risk management, such as promotional controls and stake factoring and customer retention;
• Social responsibility (i.e., minimisation of gambling related harm);
• Our enablement to benefit from the services and expertise of third party services providers;
• Regulatory and statutory requirements, such as, as above combating crime, plus specific know-your-customer (KYC) issues; such as location, device used, which might be needed to comply with the Gambling Commission's Licence Conditions and Codes of Practice; and, Transmission of customer data within our corporate group for the purposes of internal administration.
• Where we rely on legitimate interests to process your personal data, you have a right under data protection legislation to object to that processing if you believe that your particular situation means that your rights and freedoms are unduly negatively impacted. You can exercise that right by contacting us at helpdesk@playsunny.com. Please note that we may be able to continue to process your personal data for our legitimate interest reasons, even if you object, where we can show compelling reason(s) for doing so.

6) Marketing, Opting In and Opting Out

Dazzletag Entertainment Ltd reserves the right to process personal data for marketing purposes and in certain limited circumstances to provide this to our third-party partners for the purpose of marketing Dazzletag Entertainment Ltd's services to you.

We request your consent to market to you when you first create an account with us. Thereafter, you can choose not to receive marketing/promotional material at any time by clicking the unsubscribe link from promotional material being received, by changing your preference settings on the “My Account/Details” page or by contacting us at helpdesk@playsunny.com.

If you have opted-in to receive promotional material on the PlaySunny brand, we may occasionally send you similar offers from other brands operated by Dazzletag Entertainment Limited, which will cease if you opt-out.

If you have not opted in, or subsequently thereafter have opted out of marketing from us, we will take all reasonable steps to ensure you no longer receive promotional material about Dazzletag Entertainment Limited. Please note that this may mean you no longer receive information about promotional offers and bonuses. Mailings that have been scheduled before your opt-out may still reach you.

7) Access to your Information and your Rights

You have the following rights in relation to your personal information:

- a right of access to a copy of the information comprised in your personal data
- a right to access your personal information in machine-readable format and to request that we transfer this to a third-party data controller
- a right to object to processing that is likely to cause or is causing damage or distress
- a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed, but this right is not absolute, for example specific gambling and/or licensing regulations may require us to retain certain personal data about you)
- a right to object to decisions being taken by automated means
- a right to claim compensation for damages caused by a breach of data protection legislation
- a right to object to us using your personal data for direct marketing purposes, including profiling (for more information about how to unsubscribe from marketing please see section above)
- where we make it clear that we are relying on consent to process your personal data (such as for marketing purposes), you will have the right to withdraw consent at any time. You can exercise this right by emailing helpdesk@playsunny.com or, in relation to marketing material, by unsubscribing
- This will not affect or undo any instances where we have already lawfully used or shared your information prior to you withdrawing your consent
- a right to lodge a complaint to data protection supervisory authorities (for example in the UK this is the Information Commissioner's Office and in Ireland this is the Data Protection Commissioner)
- a right to object to processing based on legitimate interests if you believe that your particular situation means that your rights and freedoms are unduly prejudiced

To exercise such rights, you are required to submit a request, detailing what information you wish to enquire about, together with proof of identity to helpdesk@playsunny.com. If you contact us in relation to your rights, we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute. Sometimes other legal obligations or third-party rights will take precedence.

You can help us to maintain the accuracy of your information by notifying us of any change.

Should you require additional information about how to exercise your rights please write to helpdesk@playsunny.com.


8) Cookie Policy

Cookies are text files containing a small amount of information that are downloaded to your device when you visit the website. They are generally used by most websites to improve your online experience and to ensure that content and functions are delivered and used more effectively.

Cookies perform various different functions. For example, some cookies are session cookies, which are downloaded to your device temporarily for the period that you browse a particular website; these cookies will allow you to navigate between pages more efficiently or enable the website to remember the offers you are eligible to receive. Other cookies are persistent cookies, which can be used to help website remember you as a returning visitor or ensure the online adverts you receive are more relevant to your specific needs and interests.

The primary use of cookies on our brand websites, either directly by ourselves or our chosen partner(s), is to: enable you to save time and facilitate future access to the site; identify how people navigate through our website to improve our service, content and the effectiveness of our communications; performance monitoring of the website; collect and share device data to detect and prevent devices associated with fraud and money laundering; identify account and device irregularities and detect and prevent fraudulent transactions and abuse of our customer accounts and our services.

The cookies we use can be split into two categories; necessary and functional.

Necessary cookies are required for the operation of our website and provision of our services. These include tracking of your location, unique user ID, depositor status and session ID.
Functional cookies are not strictly necessary, but are required to provide you with the best user experience and also to tell us which pages you find most interesting (anonymously). These include cookies from Google Analytics that help us track what pages players are visiting and which features on the website are being used.

You can manage and/or remove cookies via your browser settings. However, as some cookies are essential for the operation of our websites and services, we may not be able to serve you our products unless you choose to accept at least the necessary cookies from us, this is because these are often required for regulatory and anti-fraud obligations.
You can opt-out of Google Analytics cookies on the following link: https://tools.google.com/dlpage/gaoptout
If you have any questions regarding our cookie policy please contact helpdesk@playsunny.com


9) Storage Security and Retention of Personal Data


The data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area (“EEA”) including South Africa and the United States of America. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. These countries may not have equivalent data protection legislation to Europe. However, when we transfer your personal data in this way we will ensure that adequate measures are in place to keep your personal data secure, including via standard contractual clauses.

We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy and the requirements established by the applicable data protection regulations. Once we have received your information, we will use strict procedures and security measures to prevent unauthorised access and ensure the integrity and availability of personal data.

We are required to keep full records of all financial and wagering transactions together with any identification provided. Subject to the clause below, we will hold your personal data on our systems for as long as is necessary under our legal obligations and for the purposes for which it was collected.

We will hold your personal data for so long as you have your account with us, we are providing services to you and for up to six years following the end of the services. We provide to you or your last contact with us. We will delete any personal data sooner where it is no longer necessary for the purposes for which it was collected, but please be aware that this retention period may also be extended if any applicable statutory or regulatory obligation requires us to hold information for a longer period or if there is an active dispute or the possibility of an active dispute between us that extends past the normal retention period.

10) Changes to this Privacy Policy

We may occasionally update this privacy and cookie policy as provided by our Terms and Conditions. When we do, we will take reasonable steps to make you aware of any changes to it. We would further recommend that you revisit this page regularly to keep informed of our current privacy practices