AG Privacy and Cookie Policy
Introduction

Aspire Global International LTD (“the Company”) is a company registered in Malta for the purposes of operating online games and mobile application games. We respect your privacy and are committed to protect the privacy of our users (“user” or “you”).

The Company provides online and mobile gaming services to you via our in-house brands (each an "In-House Brand"), via third parties' "white label" brands (each a "White Label Brand") and via mobile gaming platforms. The Company and the White Label Brand owner (if applicable) (collectively "we", "our" or "us") have papered this privacy and cookie policy (collectively: “Privacy Policy”) to outline our practices with respect to collecting, using and disclosing your information through the use of our websites, applications and gaming platforms controlled by us (collectively: “the Services”).

The Privacy Policy is a part of our Terms of Service and is incorporated therein by references.

Please Note: If you play or register an account in the United Kingdom (UK) or Denmark, all references herein to “the Company” shall be deemed also as a reference to AG Communications LTD, which is within the same corporate group as Aspire Global International LTD.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to this Privacy Policy.

In this Privacy Policy you will read about:



  • What type of information we collect

      We collect two types of data and information from our users.

      The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services.

      The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). When you use our Services either via an In-House Brand or a White Label Brand, you will be asked to provide Personal Information to us. The Personal information we collect through our Services includes information which is submitted directly by the user, such as: phone number; full name; e-mail address; home address; date of birth; payment means (e.g. credit card number); and other financial information that we may need in order to provide our Services.

      We may also collect Personal Information from your device (e.g. geolocation data, IP address) and information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).

      If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

    • How we collect information

      There are three main methods we may use to collect information:

      a. We collect information through your use of the Services. In other words, when you are using our Services, we are aware of it and may gather the information relating to such usage, either independently or through the help of third-party services as detailed below.

      b. We collect information which you provide us voluntarily. For example, we collect Personal Information which you provide when you: (i) respond to communications from us; (ii) open an account and use the Services ; and (iii) communicate with us via the chat widget or via email.

      c. We collect information through our white label partners and our trusted third-party services, such as information about your credit history agencies and other financial information which is relevant to our Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.


    • Cookies

      We and our trusted partners use cookies and other technologies in our related services, including when you visit our site or access our Services.

      A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

      Our website uses four types of cookies: (i) 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; (ii) 'persistent cookies' which are read only by our website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; (iii) 'third party cookies' which are set by other websites who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access; and (iv) 'flash cookies' which are saved during game play to allow quicker and better gaming experience.

      You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Service may not operate properly and your online experience may be limited.


    • How we use the information we collect

      We use and share Personal Information in the manners described in this Privacy Policy. The Personal Information will be disclosed to a third party only to the extent required for the specific purpose, as stipulated in this Privacy Policy, and in such case we require the relevant third party to agree to process such information in compliance with our Privacy Policy.

      In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:

      • To set up your account and to provide our Services (e.g. send out cash-out checks, process your payments; etc.)
      • To identify and authenticate your access to certain features of the Services;
      • To communicate with you and to keep you informed of our latest updates;
      • To market our websites and products or those of other entities existing within the same group of companies in which we exist (“the Group”) or those of any of our business partners and affiliates (see below under “marketing”);
      • To serve you advertisements when you use our Services;
      • To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests;
      • To support and troubleshoot our Services and to respond to your queries; and
      • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
      With whom we share the information we collect (“Recipients”)

      We do not rent, sell, or share your Personal Information with third parties except as described in this Privacy Policy.

      We may share Personal Information with the following Recipients: (i) our subsidiaries; (ii) our white label partners; (iii) companies within the Group and other affiliated companies (iv) subcontractors and other third party service providers; (v) auditors or advisers of any of the Group's business processes; and (vi) any potential purchasers or investors in any of the companies within the Group.

      In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our Recipients for any of the following purposes:
        Providing you with our Services (e.g. via our In-House Brands, via our White Label Brands or via mobile gaming platforms);
      • Storing such information on our behalf;
      • Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations, etc.);
      • Performing research, technical diagnostics or analytics; and
      • Communicating promotional and informational materials, in accordance with our marketing policy.
      We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

      Third party collection of information

      Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.

      It is important to note that such third party services may have their own privacy policies and we advise you to read them carefully. Inclusion of a link to third party website or service is not a recommendation of such a website or service. Third party sites may contain information or service that is illegal, unreasonable or that some people may find inappropriate or offensive. Before using third party sites and services or before making a purchase, we recommend you to read and understand those sites’, service’ or product’s terms and conditions, warranty, and privacy policies and to ensure you agree to their terms. You acknowledge that we are not responsible for the products, services, or descriptions of those products or services that you receive from third party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third party products and services. You are knowingly and voluntarily assuming all risks of using third party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them



    • For how long we retain the information we collect?

      We value your privacy and control over your Personal Information, and therefore you may, at any time, request to change and update it by emailing us at support@Winnings.com. You can also request that we will correct errors or that we will erase your Personal Information (except for your transaction history and other data that we are required to keep under applicable laws) by emailing us at support@Karamba.com. Additionally, if you use the Services of an In-House Brand you may change and update your Personal Information by clicking on the 'Update Account' button on our Website
      Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.

      We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

    • How do we safeguard and transfer your information?

      We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

      Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.

      If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact us directly at support@Winnings.com.

    • Advertisements

      We use a third-party advertising technology to serve advertisements when you visit our websites and use our Services. This technology uses Non-personal Information with regards to your use of our Services to serve advertisements to you (e.g. by placing a third-party cookie on your web-browser). We may also use other third parties to assist us in evaluating the success of our advertising.

      You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI") and the Digital Advertising Alliance (“DAA ”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: Networkadvertising and aboutads.info .

    • Marketing

      We may use your Personal Information, such as your name, email address, telephone numbr, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our Services as well, products, services websites and applichations which related to: (i) other companies within the Group; (ii) White Label Brands; or (iii) our business partners’ and affiliates’; (collectively "Marketing Affiliates") which we believe may interest you.

      We may also share and disclose Personal Information with our Marketing, Affiliates for the purpose of providing you different marketing offers we or our Marketing Affiliates believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, SMS and telephone marketing purposis.

      Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us or from our Marketing Affiliates. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by contacting by sending a blank message with the word "remove" to support@Winnings.com.

      If you unsubscribe we will remove your email address from our marketing distribution lists and from any future lists we may share with our Marketing Affiliates. However, you may need to separately unsubscribe from marketing offers sent by our Marketing Affiliates. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

      You hereby acknowledge and agree that by downloading, installing or accessing to our Services, we may share your Personal Information with our trusted partners and Marketing Affiliates for the purpose of direct marketing.

    • Corporate transaction

      We may share Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company or of any other company within the Group or in the event of a corporate transaction of the White Lable Brand (if applicable). In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.



    • Minors

      The Services are not designated to users under the age of 18. If you are under 18, you should not download or use the Services nor provide any Personal Information to us.

      We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at support@Winnings.com.

    • Updates or amendments to the Privacy Policy

      We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website (as reflected in the "Last Revised" heading). We encourage you to review this Privacy Policy regularly for any changes. In case of material changes we will notify you through our Services or by email.

      Your continued use of the Services, following the notification of such amendments on our website, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

    • How to contact us

      If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us at support@Winnings.com.

    • Information about us

      The details of the Company are as follows:
      Aspire Global International LTD>- 135, High street, Sliema SLM 1549, Malta
      Aspire Global LTD- Suites 7b & 8b, 50 Town Range, Gibraltar
      AG Communications LTD- 135, High street, Sliema SLM 1549, Malta
      AG Software LTD- 135, High street, Sliema SLM 1549, Malta

      the White Label Brand owner (if applicable) details are as follows:


      This page has been updated on November 2016.

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