Privacy policy

Privacy policy

Last updated: 06 July 2022

A. General
B. Inquiries & Data Protection Officer
C. How Megapixel Entertainment Limited processes personal data
D. Data Security
E. Rights of the player regarding its personal data
F. Inquiries
G. Amendments to this Privacy Policy Statement

A. General

Megapixel Entertainment Limited (along with any other company within its Group), as the Data Controller for the collection and processing of data on Wunderino, is strictly committed to the protection of players' personal data, according to applicable legislation, including the EU - General Data Protection Regulation [Regulation (EU) 2916/679]. This Privacy Policy Statement describes how Megapixel Entertainment Limited processes personal data and notifies players on their related rights.

Personal data means any information relating to an identified or identifiable natural person.

Processing of data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal data will solely be processed by Megapixel Entertainment Limited in case the player has given consent to such processing, the processing is necessary for the provision of the offered services, the processing is performed to fulfil mandatory legal requirements applying to Megapixel Entertainment Limited, or the processing is required for the pursuit of the legitimate interests of Megapixel Entertainment Limited, third parties or the public, when such legitimate interest is not overridden by the particular player's fundamental rights.

By accepting this Privacy Policy Statement, the player expresses its consent to the collection and processing of its personal data as described in this Privacy Policy Statement.

B. Inquiries & Data Protection Officer

For any privacy issues, for inquiries and/or for further information on Megapixel Entertainment Limited's data processing activities, please contact the Data Protection Officer at:

Megapixel Entertainment Limited
DPO
122, Andrea Debono Street, Naxxar NXR4030, Malta
dataprotection@megapixelltd.com

C. How Megapixel Entertainment Limited processes personal data

1 Legitimate Interests

Except for the fulfilment of mandatory legal requirements or when the player has consented in such processing, Megapixel Entertainment Limited processes personal data solely for the pursuit of its legitimate interests or for the pursuit of the legitimate interests of third parties or the public.

As a general rule and not anticipating the results of a proportionality assessment to be performed when appropriate, Megapixel Entertainment Limited's legitimate interests for the collection and processing of personal data may be:

the enabling, optimisation and improvement of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
the identification and solution of dysfunctions on the Websites of Megapixel Entertainment Limited,
the enforcement of contractual agreements and/or legal duties, and
the promotion of the services offered.

The legitimate interest for the processing of data in particular will be declared in the relevant section of this Privacy Policy Statement.

2 Principles for the processing of personal data

Megapixel Entertainment Limited processes personal data solely according to the principles laid down in art. 5 (1) a. to f. of the EU -- General Data Protection. These principles are:

a. Lawfulness, fairness and transparency: personal data will solely be processed in a lawful, fair and transparent manner;
b. Limitation of purpose: personal data will solely be processed for the specified, explicit and legitimate purposes these data was collected and not further, when such processing is incompatible with the purpose of collection;
c. Minimisation: personal data will solely be processed in an adequate, relevant and limited extent in relation to the purpose of processing;
d. Accuracy: personal data will be processed in an accurate manner and kept up-to-date where necessary;
e. Storage Limitation: personal data will not be kept longer than necessary for the purpose for which the data was initially collected; and
f. Integrity and confidentiality: personal data will solely be processed in a reasonably secure manner and utilising appropriate organisational and technical measures, in order to protect these data against accidental or malicious loss, destruction or damage.

3 Collection and processing of data within the offers of Megapixel Entertainment Limited

a. when visiting the website
During the visit of the websites of Megapixel Entertainment Limited, the gaming system, by automated means, may collect information generated by the browsers of the visitors of the websites and may store them in logfiles on a temporary basis. This may include, but is not limited to

the IP address of the accessing computer,
date and time of accessing,
the operating system accessing, and
the browser deployed by the visitor.

The logfiles may contain IP addresses allowing to identify a particular player.

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited, and
the identification and solution of dysfunctions on the Websites of Megapixel Entertainment Limited.

b. when registering with Megapixel Entertainment Limited
Megapixel Entertainment Limited is legally required to collect players' personal data at registration stage. This may include, but is not limited to

first name and last name,
gender,
residential address,
date of birth,
nationality, and
email address.

Players may be required to submit further documentation for the purposes of identity verification, security assessments and regulatory required checks. Megapixel Entertainment Limited may also collect information from third party databases for such purpose.

Player are required to keep up-to-date their personal details at any time.

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
the enforcement of contractual agreements and/or legal duties, and
the promotion of the services offered.

c. for the purpose of processing payments
Megapixel Entertainment Limited offers the facility to process payments in favour of the offers provided to its players. Depending on the payment method chosen by particular player, and, if applicable, further criteria, the personal information required may vary.

These data will be transmitted to third party payment providers in order to process a particular payment request.

Legitimate interests for such processing are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited, and
the enforcement of contractual agreements and/or legal duties.

d. for the purpose of creating player profiles
Megapixel Entertainment Limited processes information that is collected by cookies, logfiles, clear gifs, and/or by third parties' support in order to create player profiles. A profile contains information on individual players including preferences concerning the activities of the player Profiles are also used to design the player's experience on the websites individually and to provide specific marketing information.

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the promotion of the services offered.

e. via logfiles
Megapixel Entertainment Limited uses logfiles on its websites. These may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyse trends for administration of the website, to track a particular players' movements on the website, and to gather comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited, and
the enforcement of contractual agreements and/or legal duties.

f. player communication
Megapixel Entertainment Limited may store communication with players with the customer support and further.

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited, and
the enforcement of contractual agreements and/or legal duties.

g. for the purposes of marketing activities
Depending on the account settings set by a particular player, its personal data may be used for marketing activities across various channels including mail, email, electronic/instant messaging, and further.

The consent in the use of the player's personal data for marketing activities may be cancelled, withdrawn or restricted by the player at any time.

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited, and
the promotion of the services offered.

h. for other purposes
In exceptional cases, it may become necessary for Megapixel Entertainment Limited to process personal data for other purposes. However, the conditions set out in section A. above apply to any case; no processing will take place unless the said conditions of section A. above are met.

i. third party content and tracking software
Megapixel Entertainment Limited uses tracking software and website analytics tools on its websites, allows the use of social media plugins and single sign-on technology, and may provide third party content on its websites.

(1) Tracking software
Megapixel Entertainment Limited uses tracking software for the purpose of evaluating the user's preferences and therefore to improve the offers of Megapixel Entertainment Limited.

Tracking software collects user data such as IP address, accessing website, advertisement preferences and further marketing information.

The following tracking software are integrated to the websites of Megapixel Entertainment Limited:
• Adform
• Adalyser
• AppsFlyer
• Beeswax
• Bannerflow
• Daisycon
• DNA Fusion
• DoubleClick
• DoubleClick Floodlight
• FreeWheel
• Facebook
• Google Ads
• QuantCast
• MyAffiliates
• Spoteffect
• StickyAds
• Taboola
• TradeDesk

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited.

(2) Website analytics
Megapixel Entertainment Limited uses website analytics tools for the purpose of understanding the player's behaviour on the Megapixel Entertainment Limited websites and optimise the services provided by Megapixel Entertainment Limited.

Website analytics tools collect data by using cookies and IP address tracking for that purpose.

The following website analytics tools are integrated to the websites of Megapixel Entertainment Limited:
• Amazon Web Services
• Beeswax
• Google Analytics
• Google Tag Manager
• HotJar
• Leadlink
• Mixpanel
• Matomo
• Pingdom
• Quantcast
• Scarab Research
• Spoteffect

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited.

(3) Social media plugins
Megapixel Entertainment Limited uses social media plugins for the purpose of enabling the player to interact between social media and the Megapixel Entertainment Limited websites and therefore share the gaming experience with others.

Social media plugins allow the user to login to both social media and Megapixel Entertainment Limited account and to link content provided by Megapixel Entertainment Limited to the player's social media profile.

Social media plugins collect user data such as IP address, login data, accessing website and cookie data.

The following social media plugins are integrated to the websites of Megapixel Entertainment Limited:

Facebook Connect

Legitimate interest for such collection are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited.

(4) Third party games providers
Within the offers of Megapixel Entertainment Limited, games provided by third party game providers may be deployed.
In the event of games being provided via the game provider websites and therefore beyond Megapixel Entertainment Limited's framework of privacy regulations, Megapixel Entertainment Limited cannot acquire warranty for data collected via the third-party websites.

A list of the third-party game providers offering games on the websites of Megapixel Entertainment Limited can be found in subsection 4.e. below.

j. via cookies
Megapixel Entertainment Limited uses cookies. Cookies are small files that are automatically created by the user's browser and are stored locally (on the accessing laptop, tablet, smartphone, etc.) when visiting the websites of Megapixel Entertainment Limited.
For more information about the use of cookies on the websites of Megapixel Entertainment Limited, please refer to our Cookie Policy!

Change or withdraw your consent

4 Sharing and disclosure of personal data
Megapixel Entertainment Limited will, in no event, transfer data to states outside of the European Economic Area provided unless the recipient guaranties a standard of data protection comparable to European standards (e.g. by agreeing to approved contractual clauses, binding corporate rules or further measures applied and accepted to ensure that the recipients of personal data obtain an appropriate level of data protection and privacy at any time).

Megapixel Entertainment Limited shares data within the framework of the EU - General Data Protection Regulation:

a. with services providers
Under the circumstances set out in subsection 4. above, Megapixel Entertainment Limited may make use of third party companies to process players' personal data. In such event, the sharing of personal data collected by Megapixel Entertainment Limited may be necessary.

Megapixel Entertainment Limited requires any service provider to act with a reasonably high level of diligence and care, imposes contractual obligations to treat any data shared accordingly, to any service provider and ensures that data shared will solely be utilised for the purpose of collection and to the extent necessary to fulfil the respective task.

Legitimate interest for such transmission are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
the enforcement of contractual agreements and/or legal duties, and
the promotion of the services offered.

b. for measures of KYC, AML and fraud prevention
For the purpose of a players' identity verification, to carry out security checks, to assess a players' compliance with the applicable Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and the protection of minors, player data may be matched against third party databases.

Upon any indication of transactions and/or activities that may give rise to suspicions of criminal activities, Megapixel Entertainment Limited will report to the relevant parties in charge (e.g. police).

With the acceptance of the applicable Terms and Conditions and this Privacy Policy Statement, the player grants its explicit consent to these procedures including the matching of data provided against databases of third parties.

The sharing of players' data may also be necessary to protect the players and the operation of Megapixel Entertainment Limited from crime and to comply with legal obligations.

Legitimate interest for such transmission are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
the enforcement of contractual agreements and/or legal duties, and
the promotion of the services offered.

c. for other purposes
It may be necessary share personal data for additional purposes. However, Megapixel Entertainment Limited solely discloses personal data in case and to the extent that one or more conditions set out in this Privacy Policy and according to the general rules declared in section A. above are met.

Legitimate interest for such transmission are:

the personalisation and optimisation of the services offered by Megapixel Entertainment Limited,
the detection of abuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
the enforcement of contractual agreements and/or legal duties, and
the promotion of the services offered.

d. of anonymised data
Notwithstanding Megapixel Entertainment Limited's commitment to the protection of personal data, Megapixel Entertainment Limited reserves the right to publish gaming data (e.g. game results), the player's first name, the initial of the surname and the player's country of residence on the websites of Megapixel Entertainment Limited, as long as the player remains, directly and indirectly, unidentifiable by the publication of these information.

Such publication is performed in order to promote the services offered.

e. third party games providers
Within the offers of Megapixel Entertainment Limited, games provided by third party game providers may be deployed.
In the event of games being provided via the game provider websites and therefore not within Megapixel Entertainment Limited's framework of privacy regulations, Megapixel Entertainment Limited cannot acquire warranty for data collected via the third-party websites.

The following third-party game providers offer games on the websites of Megapixel Entertainment Limited:

NetEnt Entertainment
Evolution Gaming
Quickspin
Play N' Go
Gamomat
Oryx Gaming
Merkur Gaming
Microgaming
SG Gaming
Habanero
stakelogic
genii
NYX
Yggdrasil Gaming
Leander
Playson
NoLimit City
Red Rake
Pragmatic Play

f. within the group
Your personal data may be shared with other companies of the Group. Such data may also include information relating to your self-exclusion with us.

5 Retention
Personal data is kept by Megapixel Entertainment Limited for the term of the contractual relationship. Whenever a player closes its player account with Megapixel Entertainment Limited, the personal data stored in the gaming system will remain stored for the minimum length of time required to comply with the purposes set out in this Privacy Policy Statement and relevant legal requirements.

Player profile data will be stored for a period of five years from the end of the calendar year in which the business relationship with the respective player was terminated.
Transaction data is stored for a period of ten years from the end of the calendar year in which the transaction was concluded.

Personal Data may also be stored for a longer term, in case a deletion is not possible for technical and/or legal reasons.

D. Data Security

All data will be processed by automated means. Megapixel Entertainment Limited takes all adequate technical and organisational efforts to protect players' data from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration or damage.

Additionally, payment information will be encrypted when being processed.

Sensitive information is protected online by SSL encryption. Furthermore, Megapixel Entertainment Limited takes any reasonable effort to ensure the protection of players' data in all other areas.

Only authorised personnel of Megapixel Entertainment Limited or of third-party companies contractually bound to Megapixel Entertainment Limited and to the compliance with the principles of data protection and the terms of this Privacy Policy Statement, obtain access to the players' information.

Megapixel Entertainment Limited monitors the trustworthiness and reliability of all personnel and service providers. At regular intervals, any employee will be trained on the applicable security and data protection standards. Relevant servers are located in a secure environment.

Data encryption
In order to protect the players' personal data when communicating with the web browser, Megapixel Entertainment Limited uses encryption technology of its trusted certification partner company. In addition, online transactions are shielded by the security system of a worldwide-accredited partner.
Other technical security measures
In addition, all player data will be protected from unauthorised or damage access by firewall and intrusion prevention systems.

E. Rights of the player regarding its personal data

The player, at any time, has the right to

request access to its personal data,
request correction of its personal data,
withdraw the consent to the processing of its personal data fully or in part (e.g. for marketing activities),
request erasure of its personal data,
receive its persona data upon request in a structured, commonly used and machine-readable format (data portability),
request the restriction of processing its personal data, and
to object to the processing of personal data.

Some of these rights may only apply under certain circumstances as set forth in data protection legislation including the General Data Protection Regulation.

F. Inquiries

For inquiries or complaints regarding the handling and collection of data on the websites of Megapixel Entertainment Limited, please contact dataprotection@megapixelltd.com or the relevant data protection authority.

G. Amendments to this Privacy Policy Statement

This Privacy Policy Statement may be subject to change from time to time, of which players will be informed without undue delay and upon their next login to the player account with Megapixel Entertainment Limited at the latest. Anyhow, Megapixel Entertainment Limited recommends the player to review this Privacy Policy Statement for potential changes and/or amendments in regular terms.