The Company (“Natural8 India”) is concerned with protecting the sensitive personal data or information of any person located within India (“SPDI”).
SPDI is defined as the following kinds of personal information capable of identifying a person: (i) passwords; (ii) financial information such as bank accounts, credit cards, debit cards; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information.
This Policy applies to the Company within the Republic of India.
“You” means the player, the ‘Data Subject’ who provides the SPDI to Natural8 India.
“Visitor” means an individual other than a user, who uses the public area, but has no access to the restricted areas of the Website, Application, or Service. Data Subjects shall have the right to request access to and rectification or erasure of Personal Data, or restriction of Processing, or to object to Processing as well as the right of Data Portability.
2. The Information we collect:
2.1 As part of providing you with the Services, we may collect your information including SPDI on registering an account. Information collected by us includes any information from which you can be personally identified or be identifiable, including but not limited to your name, surname, email address, home address, telephone number, mobile number, date of birth, government ID information, electronic location information and electronic device information – this covers passport/license, MAC address and IP address, and financial information such as bank account details, or credit/debit card details. This may include SPDI.
2.2 As part of providing you with the Services, we also collect information about the transactions you undertake, including details of payment cards used, details of the games you played and underlying gaming transactions.
3. How we will use your Personal Information
3.1 When providing our Services we ensure that we collect, retain, possess, store, deal, handle and process your SPDI in accordance with the applicable law. We will process your SPDI to enable us to:
3.1.1 Set-up, administer and manage your Account and records (including processing deposits and withdrawals);
3.1.2 Provide and personalise the Services (including allowing you to wager and play our games);
3.1.3 Receive and respond to your communications and requests;
3.1.4 Notify you about updates to the Software and/or the Services;
3.1.5 Ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you give us;
3.1.6 Comply with our obligations under Applicable Laws and to Regulators in jurisdictions where we are licensed (Isle of Man);
3.1.7 Investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the Services (including, where appropriate, dealing with requests from authorised entities/Authorities for the sharing of information);
3.1.8 Carry out market research campaigns;
3.1.9 Preparing statistics relating to the use of the Services by you and other customers;
3.1.11 Keep you informed on offers and promotions in relation to our products and services;
3.1.12 Support any other purpose necessary for the performance of our contractual obligations or specifically stated at the time at which you provided your SPDI; and
3.1.13 In order to undertake verification of user identity, age, etc., we will supply some of your personal information to third parties (including financial institutions, age verification, and credit reference agencies). Credit reference agencies provide services for identity verification, credit risk and affordability checking, fraud prevention, anti-money laundering, and tracing.
3.2 Your stored payment details will be used to facilitate future transactions initiated by you within the Natural8 India Cashier or any other equivalent options within the Website and / or Application.
3.3 If at any time you wish for us to stop processing your SPDI for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us by firstname.lastname@example.org.
3.4 To ensure a good quality of service we may monitor any communication you have with us whether in writing or by electronic mail (“recordings”). Any recordings remain the property of Natural8 India and will be used only for the purposes listed above.
4. Disclosing your Personal Information
4.1 Except as described in this Policy, we will not disclose the SPDI that we collect and/or retain on the Service to third parties. We may disclose SPDI to third parties in the following circumstances:
- Any company within our Group (including to its employees and subcontractors) which assists us in providing the Services or which otherwise has a need to know such information;
- Any third party which assists us in providing the Services, including (but not limited to) payment processors and marketing service providers;
- Any third party which can assist us in verifying the accuracy of your SPDI, including financial institutions and credit reference agencies (a record of the search may be retained by such third party. Security use/plan to use will fall under this category for ID and document checks;
- Any third party who assists us in monitoring use of the Services, including the detection and prevention of fraud and collusion;
4.2 We shall keep you informed and ensure that these trusted partners and/or third parties will abide with the mandatory data protection measures. During such data transmission, we shall take all appropriate organizational, technical and legal protection measures.
4.3 The Company gives its customers the possibility to make use of “chat rooms” where players are able to communicate with each other. Whilst we will ensure that the players follow the terms as set in the “chat room policy”, we will not be responsible for any data breaches that might arise from the use of our chat rooms. Therefore, you accept responsibility and under no circumstance shall we be held responsible for any damages that might arise from any breach of data.
4.4 If at any time you wish for us to stop collecting, retaining, possessing, storing, dealing, handling, and processing your SPDI for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us email@example.com.
5. Data Subject Rights
5.1 We respect your privacy rights and provide you with reasonable access to the SPDI that you may have provided through your use of the Services. Your principal rights are:
- the right for information in relation to the SPDI being collected; the purpose for which SPDI is being collected; the intended recipients of the SPDI; and the name and address of the agency collecting and/or retaining the SPDI;
- the right to review the SPDI provided by you to us;
- the right to rectification or amendment of SPDI found to be inaccurate or deficient; and
- the right to withdraw consent previously provided.
5.2 If you wish to review or amend any other SPDI we hold about you, you may contact us by email: firstname.lastname@example.org. Natural8 India will respond to these requests in a timely manner, and redress the grievances within a month. We will retain your information for as long as your account is active, as needed to provide you services, or to comply with our legal obligations, resolve disputes and enforce our agreements.
5.3 You may update or correct your account information and preferences at any time by accessing your account settings page on the ‘My Account’ tab in the Cashier. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
5.4 You may decline to share certain SPDI with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service.
5.5 In accordance with applicable law, we reserve the right to withhold disclosing SPDI if such disclosing would adversely affect the rights and freedoms of others.
6. Contacting us
The name and contact details of Our Grievance Officer are provided below for reference.
7.1 Cookies are pieces of information that a website transfers to your computer’s hard disc for record keeping purposes. Cookies can make the web more useful by storing information about your preferences on particular sites, thus enabling website owners to provide more useful features for their users. They contain no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies or inform you when they are set.
7.3 Our Online poker service uses session cookies to establish and maintain your session with us. With cookies enabled, you shouldn’t notice any difference to the service. Natural8 India requires your web browser to accept a session cookie before you can log on or register for the service. Session cookies only exist until you close down your web browser, as opposed to permanent cookies which your browser stores until they expire. If you browser is set to disable cookies, you may restrict your access to Natural8 India.
7.4 Natural8 India web pages may contain electronic images, known as web beacons or spotlight tags. These enable Natural8 India to count users who have visited certain pages on our website. Web beacons and spotlight tags are not used by us to access your personal information, they are simply a tool we use to analyse which web pages customers view, in an aggregated manner.”
7.5 If you object to cookies or want to delete any cookies that are already stored on your computer, you should follow the instructions for deleting existing cookies and disabling future cookies on your web browser or equivalent software. Further information is available at www.aboutcookies.org. Please note that by deleting or disabling cookies you may not be able to access certain areas or features of the Website.
7.6 As part of the Website’s operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do not log any email address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.
7.7 While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.
8. Minors and Children’s Privacy
8.1 Protecting the privacy of minors is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect SPDI from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that SPDI has been collected on the Service from persons under 18 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an account on the Service, then you may alert us at email@example.com and request that we delete your child’s SPDI from our systems.
9.1 We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. Natural8 India has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing SPDI, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.
9.2 Your winnings and cash-outs are kept strictly confidential, and winnings information is stored in secure operating environments. We do not provide winnings information to any third party unless such information is required to be disclosed by law, regulation or a similar governmental authority.
9.3 No method of transmission over the internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, however, we shall ensure that adequate security mechanisms designed to protect SPDI will be used to prevent SPDI from being stolen, misused or abused, and to prevent SPDI breaches. If you believe your SPDI has been compromised, please contact us firstname.lastname@example.org.
10. Data Breach
10.1 We may disclose SPDI to government agencies mandated under applicable law to obtain information for the purpose of prevention, detection, and investigation including cyber incidents, prosecution, and punishment of offences. This shall only be in pursuance of a written request by the government agency or body to us, stating the purpose of seeking such information.
11. Privacy Settings
11.1 Although we may allow you to adjust your privacy settings to limit access to certain SPDI, please be aware that no security measure is perfect or impenetrable. Additionally, we cannot control the actions of other users with whom you may choose to share your information. We cannot and do not guarantee that information you post on or transmit to the Website and/or Application will not be viewed by unauthorized persons. We have taken the necessary steps to protect as much as possible your SPDI in transit by utilising HTTPS on our Website and TLS 1.2 (a strong protocol), ECDHE_RSA with P-256 (a strong key exchange), and AES_256_GCM (a strong cipher).
12. Data Retention
12.1 SPDI that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
12.2 We only retain the SPDI collected from you for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we have initially collected it, unless otherwise required by law.