Privacy Policy is committed to protecting your personal information. This Privacy Policy lets you know what information we collect when you use our services, why we collect this information and how we use the collected information.

Please note that this Privacy Policy will be agreed between you and Grattiano, hereinafter referred to as the “Website”. This Privacy Policy is an integrated part of Website’s Terms and Conditions.

We recommend that you revisit this Privacy Policy regularly.

Grattiano is operated by 3-102-944465 SRL, a company registered in Costa Rica with company number 3-102-944465 and registered address at Provincia 01 San Jose, Canton 01 San Jose, Distrito Carmen, Barrio Escalante, Avenida Siete, Calle Veintinueve, Edificio Dos Mil Novecientos Diez, Costa Rica, which is licensed and regulated by the Tobique Gaming Commission to offer services under license number 0000175 in accordance with the Tobique Gaming Act 2023. Customer support team is available at [email protected].

This Privacy Policy should be read together with the Terms and Conditions, the Responsible Gaming Policy and the AML/KYC Policy made available on the Website. We process personal data in accordance with applicable data protection law.

We consider information that may be used to identify an individual, including, but not limited to, first and last name, date of birth, home or other physical address, email address, phone number or other relevant information to be Personal Information (“Personal Information”). You may be asked to provide Personal Information when you use the website, register for an account or use our services. The Personal Information that we collect may include information such as: contact information (including telephone number), shipping information, billing information, transaction history, website usage preferences, feedback regarding the Services, and, where required for account verification, security, AML/CFT, fraud prevention, responsible gaming, payment processing or regulatory purposes, identification, verification, payment, transaction, screening and related account review information. When you interact with the services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. This information is essential for the provision and quality of our services. We do not collect Personal Information about you without your knowledge.

We may automatically collect certain data as discussed above and receive Personal Information about you where you provide such information through the services or other communications and interactions on the website. We may also receive Personal Information from online vendors and service providers, and from customer lists lawfully acquired from third-party vendors. In addition, we may engage the services of third-party service providers to provide technical support, process your online transactions and maintain your account. We will have access to any information you provide to such vendors, service providers and third-party e-commerce services, and we will use the Personal Information as set out in this Privacy Policy below. This information will only be disclosed to third parties outside the company in accordance with this Privacy Policy. We take steps to ensure that our arrangements with third-party service providers and online vendors protect your privacy.

We use the Personal Information we collect from you to deliver our Services, to provide customer support, to undertake necessary security and identity verification checks, to process any of your online transactions, to assist your participation in third-party promotions, meet certain business requirements and for any other purpose related to the operation of the Services. As such, we may share your Personal Information with third parties, including but not limited to our group companies, affiliates, agents, service providers, payment and verification partners, professional advisers, competent authorities, regulators and other relevant parties, where necessary or appropriate for the operation of the Services, account verification, payment processing, security, fraud prevention, AML/CFT, responsible gaming, legal/regulatory compliance or other purposes described in this Privacy Policy.

Your Personal Information may also be used by us to provide you with: (1) promotional offers and information regarding our products and services; and (2) promotional offers and information regarding the products and services of our partners, in order to enlarge the range of provided products and improve our customer service. From time-to-time, we may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age). By accepting any contest prize or winnings from us, you consent to use of your name for advertising and promotional purposes without additional compensation, except where prohibited by law. Unless you have elected not to receive promotional information, we may also use your Personal Information (including your email address and phone number) to provide you with information regarding our products, services and promotions, including other gaming products (including online poker, casino, betting, backgammon) and products and services from third parties carefully selected by us.

We may disclose your Personal Information if required or permitted to do so by applicable law, regulation, regulatory instruction or any competent authority, or if we believe in good faith or determine that such disclosure is necessary or appropriate to: (1) comply with any legal, regulatory, supervisory, reporting or similar obligation; (2) protect and defend our rights, property, operations, systems, users or the public; (3) prevent, detect, investigate or respond to fraud, cheating, game manipulation, payment fraud, chargebacks, misuse of the Services, prohibited transactions, money laundering, terrorist financing, proliferation financing, sanctions exposure, responsible-gaming concerns, security incidents or any other unlawful, abusive, suspicious or prohibited activity; or (4) support regulatory, compliance, risk-management, payment, verification, security, responsible-gaming, complaints, dispute-resolution or enforcement purposes.

For these purposes, we may disclose your Personal Information, including your identity, account information, transaction information, payment information, gameplay information, verification information and related records, to third parties including but not limited to the Tobique Gaming Commission, law-enforcement bodies, regulators, supervisory authorities, competent authorities, courts, dispute-resolution bodies, payment providers, banks, card schemes, credit card companies, verification providers, fraud-prevention providers, security providers, responsible-gaming bodies, professional advisers, group companies, affiliates, agents, service providers, other online gaming operators, relevant agencies and any other relevant persons or entities where we consider such disclosure necessary, appropriate, required or permitted for the purposes described in this Privacy Policy, these Terms, applicable law, regulatory instruction or the operation of the Services.

For the purpose of research on the prevention of addiction, data may be anonymised and shared with relevant institutions.

You may opt out of receiving marketing or promotional communications by using the available account settings. This will not affect service, transactional, account, security, responsible-gaming, legal, regulatory or other non-marketing communications.

In addition, You may contact us if you: 1) want to confirm the accuracy of the Personal Information we have collected about you; 2) would like to update your Personal Information; and/or 3) have any complaint regarding our use of your Personal Information. If requested, we will (1) update any information you have provided to us, in case you prove the necessity for such changes or (2) mark any information to prohibit future use for marketing purposes. For the avoidance of doubt, nothing in this Privacy Policy shall prevent us from retaining your Personal Information where we are required to do so by law.

Information placed on your device

When accessing our services, we may store information on your device. This information is referred to as cookies, which are small text files that are stored on your device when you visit online pages and that record your preferences. Cookies help us monitor traffic to the site, keep you signed in, remember your preferences, improve our services and make it easier and/or more relevant for your use. We may also use similar tracking technologies, such as pixels and local storage, for the same purposes.

Strictly necessary cookies

Strictly necessary cookies are essential to allow a user to move around a website and use its features, such as accessing secure areas of the website or making financial transactions. Without these cookies, we would not be able to make the website work efficiently.

During the registration process

These cookies will hold information collected during your registration and will allow us to recognize you as a customer and provide you with the services you require. We may also use this data to better understand your interests while online and to enhance your visits to our platforms.

On website

For visitors to the website, we use cookies to collect information. Our servers use different types of cookies, including:

A ‘session-based’ cookie: This type of cookie is only allocated to your device for the duration of your visit to the website. A session-based cookie helps you move around the website faster and, if you’re a registered customer, it allows us to give you information that is more relevant to you. This cookie automatically expires when you close your browser.

A ‘persistent’ cookie: This type of cookie will remain on your device for a period of time set for each cookie.

An ‘analytical’ cookie: This type of cookie allows us to recognize and count the number of visitors to our site and see how visitors use our services. This helps us improve the way our site works, for example, by ensuring you can find what you are looking for easily.

You have the ability to accept or decline non-essential cookies through the cookie banner available on the Website, or by adjusting your browser settings. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser settings to decline cookies. If you choose to decline non-essential cookies, some interactive features of our site may not be available to you.

In order to play real money games on our services, you will be required to send money to and receive money from us. We may use third-party electronic payment systems to process such financial transactions. By accepting this Privacy Policy, you expressly consent to Personal Information necessary for the processing of transactions including, where necessary, the transfer of information outside of your country. We take steps to ensure that our arrangements with payments systems protect your privacy.

We reserve the right to conduct a security review at any time to validate the registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms and Conditions and of applicable law. By using our services and thereby agreeing to our Terms and Conditions, you authorize us to use your Personal Information and to disclose it to third parties, including but not limited to group companies, affiliates, agents, service providers, payment and verification providers, fraud-prevention and security providers, professional advisers, competent authorities, regulators, law-enforcement bodies and any other relevant persons or entities, for security reviews, account or payment verification, KYC, AML/CFT, sanctions/PEP screening, fraud prevention, responsible-gaming review, regulatory reporting, investigations, enforcement or any other purpose described in this Privacy Policy or the Terms and Conditions, including, where necessary, the transfer of information outside of your country. Security reviews may include, without limitation, verifying the information you provide against third-party databases or other sources and conducting any related compliance, risk-management, operational or account-integrity checks. To facilitate such reviews and checks, you agree to provide such information or documentation as we may request.

We understand the importance of security and the techniques needed to secure information. We apply appropriate technical and organisational measures designed to protect Personal Information, including encryption, access controls and other security measures where appropriate. We store Personal Information we receive directly from you in a password-protected database residing within our secure network. We also take measures to ensure our subsidiaries, agents, affiliates and suppliers employ adequate security measures.

Our Services are not intended for or directed at persons under the age of eighteen (18) (or the lawful age in their respective jurisdiction). Any person who provides their information to us through any part of the services signifies to us that they are eighteen (18) years of age (or the lawful age in their respective jurisdiction) or older. It is our policy to uncover attempts by minors to access our services which may involve having to initiate a security review. If we become aware that a minor has attempted to or has submitted personal information via our services, we will not accept their information and will take steps to purge the information from our records.

Personal Information collected on the services may be stored and processed in any country in which we or our affiliates, suppliers or agents maintain facilities. By using our services, you expressly consent to any transfer of information outside of your country (including to countries that may not be assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.

We cannot ensure the protection of any information that you provide to a third-party online site that links to or from the services or any information collected by any third party administering our affiliate program (if applicable) or any other program, since these third-party online sites are owned and operated independently from us. Any information collected by these third parties is governed by the privacy policy, if any, of such third party.

The Services operate ‘AS-IS’ and ‘AS-AVAILABLE’ without liability of any kind. We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technology and business, we cannot guarantee nor do we claim that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said Personal Information.

Your use of our services constitutes an agreement to our Privacy Policy.

This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy should be read in conjunction with our Terms and Conditions, our Responsible Gaming Policy, our AML/KYC Policy and any additional applicable terms posted on our platforms. We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on our Platforms. Your continued use of our services following any changes to this Privacy Policy constitutes your acceptance of the changes. We recommend that you revisit this Privacy Policy regularly. You may also have the right to lodge a complaint with a competent privacy or data protection authority, where such right is available under applicable law.

Our website may contain links to other websites, which are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We are not responsible. Solely the operators of these websites shall be responsible for their functionality or possible errors on the linked sites.

Participation in the Games may not be available to residents of certain jurisdictions. The current list of Restricted Jurisdictions is set out in the Terms and Conditions, which prevail over any list of countries referenced elsewhere on the Website or in prior versions of our policies.

We may retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including account administration, legal and regulatory compliance, AML/CFT, fraud prevention, responsible gaming, dispute handling, reporting, record-keeping and enforcement, and for any longer period required or permitted by applicable law or regulatory instruction.