Privacy Policy

Version 1.0

Sunflower Limited (“we”, “us”, “our”) trading as iCasino operates the Website made available at icasino.com and all subdomains, including the Games, Content, features, tools, and services offered there and on our associated social media pages, and on our associated mobile app and social media pages.

We take our privacy and security obligations in respect of your Personal Information very seriously and we are committed to complying with all applicable data privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Nevada Privacy of Information Collected on the Internet from Consumers Act and the Virginia Consumer Data Protection Act.

This Privacy Policy sets out the types of Personal Information that we collect about users of our Platform (“Users”, “you”, “your”), how we use it, who we share it with, how we keep it safe, and how you can control it. Please review this Privacy Policy carefully and send us an email to [email protected] if you have any questions.

This Privacy Policy should be read in conjunction with, and forms a part of, the iCasino Terms of Service (“Terms of Service”). Any capitalized term used in this Privacy Policy that is not defined in this Privacy Policy, has the meaning given to that term in our Terms of Service.

In this Privacy Policy, the term “Personal Information” means any information about you, whether true or not, that can reasonably be used to identify you, or otherwise makes you identifiable.

We will publish any updates to this Privacy Policy on our website and those changes shall take effect immediately. If we update this Privacy Policy in a way that impacts your rights or obligations, we will notify you when next you visit our Website and you will need to accept the updated Privacy Policy. If, at any time, you do not accept any updated Privacy Policy, then you must cease using our Website.

1. The categories of Personal Information we collect

  1. We may collect the following categories of Personal Information via the Platform:
    1. Personal Data, like your name, age, gender, email address, residential address, phone numbers and any other information that can be used to directly identify you;
    2. Device Data, being information about the electronic devices that you use to access the Platform, like device identifiers, information about your web browser and operating system, your IP address and device settings;
    3. Usage Data, being information about how you use the Platform, like which pages you visit, how often you visit them, how long you stay on them, and how you navigate around the Platform;
    4. Transaction Data is the information you give us when you make a purchase from us, request a redemption, complete verification, or otherwise use our Platform. This includes information about your financial accounts that you use with us, including the names, phone numbers, addresses and bank statements associated with them. Please note that we don’t keep a record of your full card details; and
    5. Geolocation Data is information about your approximate location provided by an electronic device that you use to access the Platform.
  2. We may also collect aggregated data about you, which is information about all or a limited group of our Users that does not directly or indirectly identify you or any other individual.  
  3. We may also collect anonymous data about you, which is information about you that does not directly or indirectly identify you or any other individual.

2. How we collect your Personal Information

  1. We collect Personal Information about you, like your Personal Data and Transaction Data, directly from you when you give it to us. This usually happens when you:
    1. make a purchase from us or redeem a Prize;
    2. send us a message via email or another form of communication;
    3. join or participate on any of the social media pages we control;
    4. register for a User Account with us;
    5. enter a promotion or participate in a survey that we run;
    6. log in to our Website; and/or
    7. play our Games.
  2. We also collect Personal Information, like your Device Data, Usage Data and Geolocation Data, directly from you when you access and use the Platform (“Automated Data”), including:
    1. your electronic device’s IP address when you access the Platform;
    2. the unique identifiers and characteristics of your electronic device that you use to access the Platform;
    3. the unique identifiers of the internet browser on your device that you use to access the Platform;
    4. the operating system on your device when you access the Platform;
    5. the language settings on your device when you access the Platform;
    6. the URLs you use to access to the Platform;
    7. information about the actions you take on the Platform;
    8. when you visit the Platform; and/or
    9. the pages you access on the Platform.
  3. We also use information from other trusted third-party sources to update, supplement and verify the correctness of the Personal Information we collect.

3. How we collect Automated Data

  1. We want to make your experience on our Website simple and effective. We collect Automated Data while you use our Website. This includes Device Data, Usage Data and Geolocation Data. We and our partners collect this information in a few different ways, including via APIs, cookies, and pixel tags/web beacons.
  2. APIs work by allowing different pieces of software to talk to each other. They provide a better experience for Users and make life a lot easier for programmers.
  3. Cookies are tiny files saved in your web browser that store your preferences on your device. Many web browsers automatically allow cookies. If you don’t want cookies on your device, you can set your web browser to not accept them. Please check the instructions for your web browser on how to set your web browser to not accept cookies. Please note that refusing cookies on our Website may result in certain functionality on our Website that is available to others, being impaired for you.
  4. A pixel tag, also known as a web beacon, is a piece of code that is embedded into our Website, which gathers data about your interactions on that specific web page. Employing pixel tags on our Website allows us to record, for instance, that a User has visited a specific page on our Website or has clicked on a particular advertisement. We may also incorporate web beacons into emails that we send to you in order to ascertain whether emails have been opened, actioned, or forwarded.

4. How we use the Personal Information we collect

  1. We will use your Personal Information in the following circumstances:
    1. to operate the Platform and provide our offerings and services to you; 
    2. to facilitate the financial transactions you request; 
    3. to respond to your queries and complaints; 
    4. in accordance with your consent or as per your request; 
    5. in order to satisfy a contractual obligation owed to you; 
    6. where it is necessary for our legitimate interests (or those of a third party), provided that your fundamental rights do not override those interests; and 
    7. to comply with our legal or regulatory obligations.
  2. We disclose your Personal Information to third-parties in the following circumstances:
    1. To our affiliates: We may disclose Personal Information to other companies in the Sunflower Group, including any Payment Administration Agent for the purpose of processing payments to/from you on our behalf.
    2. To host our Website: Personal Information may be disclosed to our upstream hosting suppliers that host our Website. Our hosting suppliers host that Personal Information on their computer servers;
    3. To provide the services made available via our Website: We may work with third-parties for database management, direct marketing, fraud prevention, technical and customer support. These services may require us to disclose your Personal Information, however we will always require them to keep all such Personal Information confidential and to only use it to perform their obligations to us;
    4. Claims and Complaints Handling: We may disclose Personal Information to our insurers and lawyers;
    5. Marketing Communications: We may share Personal Information with email, marketing, and newsletter service providers for the purpose of sending newsletters and marketing materials; 
    6. Professional Advice: Providing information to our legal, accounting, and financial advisors for advice, representation and/or debt collection;
    7. Business Sale or Merger: Disclosing Personal Information to the purchaser or merging entity in case of a business asset or share sale, or merger; 
    8. Financial Crime Prevention: We use external service providers for document verification and checks related to financial crime prevention;
    9. Legal Compliance: We will cooperate with law enforcement or regulatory investigations, safeguard the Platform against misuse, and ensure compliance with our legal obligations; and
    10. Publication on the Platform: With your consent, we may publish your name and image on the Platform for promotional purposes.
  3. When we share Personal Information with third parties, we will take reasonable measures to ensure that the Personal Information is protected at a standard comparable to our own. We restrict third parties from using the Personal Information for purposes other than those specified by us or required by law.

5. If you choose not to provide us with your Personal Information

  1. When you register a User Account on the Platform, we need to collect Personal Information from you to establish your identity and create a User Account for you on our Website. We will also collect Personal Information from you when you use the Platform, when you enter the Personal Information into our Website, when you contact us for customer support and assistance with your User Account and for the other purposes set out in this Privacy Policy. 
  2. You have the the option of remaining anonymous or using a pseudonym when making inquiries about our Platform, but not when registering a User Account with us or requesting customer support in respect of your User Account.

6. How long we retain your Personal Information

  1. We will retain your Personal Information for the minimum period necessary to fulfill the purposes outlined in this Privacy Policy (Retention Policy), which will be determined based on:
    1. the time required to achieve the intended purposes for which the information was collected; 
    2. our legal, regulatory, financial, accounting, and reporting obligations related to the information; 
    3. operational requirements related to the information; and 
    4. the need to retain the information for current or anticipated legal claims, investigations, and/or disputes.
  2. We will take reasonable steps to irretrievably delete or irreversibly anonymize Personal Information in accordance with our Retention Policy.

7. Data Security

  1. We take our data privacy obligations very seriously and only process Personal Information in a way that ensures its proper security. This involves safeguarding the Personal Information from unauthorized or unlawful processing and protecting it against accidental loss, destruction, or damage by putting in place appropriate technical and organizational measures.
  2. Unfortunately, even despite our best efforts, sometimes it is not possible to absolutely secure data transmissions over the Internet. While we implement appropriate measures to keep Personal Information that you transmit via the Platform secure, any transmission of Personal Information is at your own risk. We cannot guarantee that such information will not be intercepted by third parties, and we bear no liability for security breaches in respect of your Personal Information that are beyond our reasonable control.

8. Links to Third Parties

  1. The Platform may contain links to websites, plug-ins, and applications operated by third parties (Third-Party Links). Clicking on Third-Party Links may enable these third parties to collect or share data about you. We neither control nor endorse these Third-Party Links, and we bear no responsibility for their privacy practices.
  2. We recommend reviewing the privacy policies of such third parties to understand how they may collect and process your Personal Information. These privacy policies may differ significantly from ours, and we do not control the operations of those websites or apps or how they collect, store, or process data.
  3. If you use a third-party website or application (e.g., Facebook or Google) to access the Platform, your activities on such third-party websites or apps are subject to the privacy policies of those sites or apps.

9. Behavioural Advertising

  1. You may encounter promotions for our products and services on the Platform as well as other websites and mobile applications. This collaboration with third-party advertisers enables us to conduct remarketing and retargeting campaigns. Through these partnerships, we can tailor advertising to Users based on their interests, demographics, context, and other relevant factors. These third-party advertisers employ automated methods such as third-party cookies, web server logs, and web beacons to monitor your online activities across various websites and mobile apps and use the data to present personalized advertisements aligned with your specific interests.
  2. The information gathered by our advertising partners may include details about your visits to websites and mobile apps participating in relevant advertising networks. This includes the pages or ads you view and your interactions with them. This data collection spans both our Platform and third-party websites and mobile apps involved in the advertising networks.
  3. Certain third-party advertising companies may be part of the Network Advertising Initiative, which provides a central platform for opting out of behavioural advertising from member companies, accessible here.
  4. If you prefer not to receive behavioural advertising, you can opt-out by adjusting the ad tracking settings on your electronic device that you use to access the Platform by activating the “Limit Ad Tracking” feature. Apps such as the Digital Advertising Alliance’s “AppChoices” app offer controls regarding the collection and use of cross-website data for personalized advertising. You can also opt-out of behavioural advertising on your browser here.
  5. When using these opt-out tools, please be aware that: (a) opting-out does not preclude us from collecting some data about your Platform activity for operational reasons (e.g., fraud prevention), but this data will not be used for targeting advertisements to you; and (b) if you use more than one (1) browser or electronic device to access the Platform, you may need to apply the opt-out on each browser and device. These opt-out tools are not provided by us, and we do not endorse them or control them, or the advertisers and others that use them.

10. Control over Your Personal Information and Opting Out

  1. You can control how we use your Personal Information in the following ways:
    1. Tracking: You can configure any browser you use to access the Platform to block some or all cookies, or to notify you when a cookie is sent. Please refer to the “Help” function on each of your browsers to understand how to apply these settings. Opting out of receiving cookies may affect some functionality on the Platform that is available to others.
    2. Promotional Marketing Materials: If you wish to stop receiving promotional marketing materials from us, you can update your marketing communication preferences at any time by clicking on the “Unsubscribe” link in the footer of those communications or by sending an email request to [email protected]. If you opt-out of receiving promotional marketing communications, you will still receive service-related communications from us, such as an email confirming that a Prize redemption has been processed.
    3. Analytics: Our Website utilizes Google Analytics, a web analysis service provided by Google, Inc. (Google Analytics or Google). Google Analytics uses cookies, which are small text files stored on your computer, to analyze your use of our Website. Information generated by these cookies, including the timing, location, and frequency of your site visits, along with your IP address, is sent to Google’s servers in the United States and stored there. Google may share this information with third parties when required by law or when such third parties process the data on Google’s behalf. Google assures that it will not link your IP address with other data in its possession. You can update your browser settings to prevent cookie being sent, but this may limit your access to our Website’s full functionality. Google Analytics offers a deactivation add-on for most current browsers here, which offers you control over the data Google can collect on websites you access. The add-on instructs the JavaScript (ga.js) used by Google Analytics not to transmit information about website visits to Google Analytics, however, the browser deactivation add-on by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage. Google Analytics also utilizes electronic images called web beacons (also referred to as single-pixel gifs) along with cookies to compile aggregated statistics for analyzing how our Website is used.

11. Children

  1. We do not knowingly allow individuals under the age of 18 to use the Platform, and we do not knowingly collect, use, or disclose Personal Information from anyone under 18 years of age.
  2. If you suspect that a minor may have provided Personal Information to us, please contact us at [email protected]. If we become aware that we have unknowingly collected Personal Information about a minor, we will promptly take appropriate measures to erase such information from our systems.

12. Your Rights Concerning Your Personal Information

  1. By law, you may have certain rights regarding the Personal Information that we collect and store. If you wish to exercise any of these rights, please contact us at [email protected].
  2. You have the right to access the Personal Information we hold about you, the right to object to the processing of your Personal Information, and the right to revoke any consent provided via this Privacy Policy.

13. Information for California Residents

  1. As a resident of California, you have the right to: (a) request disclosure of the categories and specific pieces of Personal Information that we collect about you and how it is used; (b) request deletion of that Personal Information; (c) opt-out of the sale or sharing of your Personal Information (if any); (d) correct inaccurate Personal Information that we hold about you; (e) limit the use and disclosure of sensitive Personal Information used to infer characteristics about you (we currently do not use sensitive Personal Information for this purpose); and (f) not be discriminated against for exercising these rights.
  2. You are entitled to know how we respond to “Do Not Track” settings. Although we currently do not respond to “Do Not Track” settings, we adhere to the standards outlined in this Privacy Policy.
  3. To exercise your California privacy rights, please send us a written request to [email protected]. We will take reasonable steps to verify your identity and confirm the request is from you. You also have the right to designate an agent to act on your behalf, and your agent must provide proof of authorization via a signed written statement or a copy of a relevant power of attorney. Exercising these rights will not result in denial of access to the Platform or any other discriminatory treatment.
  4. We may sell or share information that directly identifies you (such as name, phone number, address). You can opt-out of this by sending us a written request to [email protected].
  5. If you are a resident of California and that is under the age of 19, you can view, correct, or delete Personal Information provided by you or publicly posted by you, by sending an email to [email protected] and requesting the deletion of specific content. Our Website is only intended only for individuals who have reached the age of legal majority.

14. Contacting Us

  1. If you have any questions about your Personal Information, how we collect or use it, or you wish to exercise your rights in respect of Personal Information, please contact our Privacy Officer via email at [email protected].

Account Deactivation

If you wish to close or deactivate your Account, you may do so at any time by reaching out to our Customer Support and submit a request.

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