Official Legal Document · English Only
Privacy Policy
01. Introduction
This privacy policy (hereinafter “Policy”) applies to the NEO Hold'em sites, accessible via the URL neoholdem.com.
This Policy explains how we collect, share, and use personal data, and how you can exercise your privacy rights. We recommend that you read this Policy in full to ensure you are fully informed.
02. Who is the Data Controller?
NEO Hold'em (neoholdem.com) / Nolimit City Stockholm AB
Kungsgatan 49
111 22 Stockholm, Sweden
03. How do we collect your personal data?
When you are using the NEO Hold'em (neoholdem.com) sites, we collect personal data from you either actively or passively.
Depending on your preferences and/or choices we might collect data from cookies and similar technologies. Said data might contain certain information about you, for example, IP address or online activity, some of which will constitute your personal data. You can find more information about how we use cookies in our Cookie Policy.
04. What personal data do we collect and for what purpose?
The personal data that we collect, and process might differ from the choices you make in the privacy settings while visiting NEO Hold'em (neoholdem.com) sites. It also depends upon what services, functionalities, or experiences you use, your location and applicable law.
We will only process your personal data when we have a lawful basis for doing so. The lawful basis might be:
- you have agreed to data processing by giving your consent;
- it is necessary to provide services to you under the performance of the contract we have with you;
- we are required to do so in accordance with legal or regulatory obligations; or it is in our legitimate interests to process your personal data, if none of these interests prejudice your own rights, freedoms, and interests.
In the table below we indicate the business purposes where we may use your personal data:
| Purpose | Personal data | Legal basis |
|---|---|---|
| To communicate with you and handle your inquiries, requests, comments, and feedback etc. | First name, Last name, E-mail address, Feedback and comments made by you | Legitimate interests to handle, adequately and in a timely manner, your inquiries, complaints, and suggestions regarding the services we provide in our sites. |
| To inform you about our newly released products, events, or other promotional purposes. | First name, Last name, E-mail address | Your freely given consent. |
| To establish, exercise and defend legal claims. | First name, Last name, E-mail address, Telephone number, Other information as necessary for the purpose. | Legitimate interests to defend ourselves in legal claims. |
| To permit you to participate in social sharing, including live social media feeds. | Social networks including your profile information, User ID associated with your social media account, and any other information you allow the social network to share with third parties. | Legitimate interests to provide you better services and permit you to participate in social sharing. |
| To allow participation in polls, lotteries, promotions, contests and to administer these activities. | First name, Last name, E-mail address, Telephone number, Other information as necessary for the purpose. | Your freely given consent. |
| To detect, prevent, or investigate potential security incidents or fraud. | IP address, Log data, Other data that is necessary for the purpose. | Legitimate interests to ensure security for our systems and services provided. |
| To perform analytics, quality control, market research, and determine the effectiveness of NEO Hold'em (neoholdem.com) sites, promotional campaigns, and develop new products and services. | IP Address, Location, Device information, User activity | Legitimate interests to perform marketing and research activities in order to develop our products and provide you better service. |
| To comply with our obligations under applicable laws (including social gaming legislation, and regulatory and licensing requirements). | First name, Last name, Company name, Other information as necessary for the purpose. | Necessary to comply with a legal or regulatory obligations. |
| To share your personal data with other members of NEO Hold'em / Evolution Group entities who assist in providing the services to customers. | First name, Last name, E-mail address, Company name, Other information as necessary for the purpose. | Legitimate interests to allow us to provide services and perform our contractual obligations. |
| To register as a user on the NEO Hold'em (neoholdem.com) site and play Games. | E-mail address, Data provided by your social network account depending which registration form you have chosen. | Your freely given consent. |
Please note that the processes and lawful basis set above are those that primarily apply and are not intended to be exhaustive. They may also change and/or be supplemented over time due to business needs, and in order to comply with current legal requirements.
05. Where may we disclose and/or transfer your personal data?
Since NEO Hold'em (neoholdem.com) operates worldwide your personal data might be shared within our group entities, and/or contracted third parties for various business purposes.
The personal data might be transferred based on legal grounds such as legitimate interests to fulfil the services agreed or based on mutually concluded contractual obligations.
Additionally, there might be situations where personal data is transferred to group entities or external parties located outside the EU/EEA. In such a case, we will ensure that the Standard Contractual Clauses or other legally required documentation is concluded, to ensure an adequate level of protection before transferring personal data outside EU/EEA. For all personal data transfers, an adequate security level is ensured, and all legal requirements are met.
Group Entities
In order to fulfil data processing purposes, we may disclose your personal data to affiliated group entities. The data transfers between group entities are governed by an Intra-Group data processing agreement which includes the Standard Contractual Clauses. Additional legal safeguards for data transfer may apply in certain cases. Data transfer purposes may be relevant in order to:
- provide accurate information regarding our provided services (based on necessity to comply with a legal/regulatory requirements);
- better understand our business practices, services, and products across the group entities (based on legitimate interests);
- provide group entities with marketing and promotional materials (based on your provided consent);
- identify fraud and other criminal activities including anti money-laundering (based on necessity to comply with a legal/regulatory requirement);
- provide you with the customer support including the obligation to ensure that information is up-to-date and accurate (based on necessity to comply with a legal/regulatory obligation);
- comply with legal requirements towards identification of responsible gaming measures across the group entities (based on necessity to comply with a legal/regulatory requirement); and/or
- provide you services agreed, ensuring the implementation of security measures (based on necessity to comply with a legal/regulatory requirement).
Data Processors Acting on Our Behalf
NEO Hold'em (neoholdem.com) may disclose personal data to external parties, such as vendors and service providers. Third parties might process personal data on our behalf and under our instructions. The personal data may be transferred only if an adequate security level is ensured, and all legal requirements are met.
We engage with data processors (incl. sub-processors) in order to deliver you the agreed services and to comply with legal and regulatory requirements. The data processors might vary from cloud services for data storage purposes, marketing companies in preparing and delivering marketing related materials, and external advisors and auditors. In the case of engagement of processors, we inform you as far as it is required by legal and regulatory requirements.
06. What security measures are implemented?
We ensure that all necessary appropriate security measures are in place to keep and process your personal data securely. In support of this commitment, we have implemented appropriate technical, physical, and organizational measures to protect your personal data against unauthorized or accidental destruction, alteration or disclosure, misuse, damage, theft or accidental loss, or unauthorized access.
07. What is the data retention period?
Personal data is kept for a period that is either required by law and regulatory requirements or for as long as necessary to fulfil the personal data collection purpose. The storage period might differ from the location and services that you are receiving.
08. What rights do you have?
You have several rights towards your personal data. You have the right to request access, rectify, erase, object, restrict personal data processing, withdraw consent if given and transfer your personal data. In addition, you have the right to contact the Data Protection Supervisory authority in the country where you are located.
We will respond to all individual requests wishing to exercise data protection rights. We may request to verify your identity and/or ask for additional information in order to help us respond efficiently to your request, and to protect personal data from unauthorized disclosure.
If you wish to exercise your data protection rights, please contact our Data Protection Team at [email protected]. If you wish to simply close your account, please get in touch with us at [email protected].
Please be informed that certain rights might not be fulfilled entirely due to legal or regulatory reasons or requirements.
Right to access your personal data
You may request at any time confirmation whether we process your personal data. If we process your personal data, you can request a copy of your personal data. You are only entitled to request access to personal data that relates to you.
Right to rectify your personal data
You have the right at any time to request to correct your personal data that is inaccurate, as well as supplement your personal data that is incomplete.
Right to erase your personal data
You may request to erase your personal data under certain circumstances such as when your personal data is no longer needed for the purposes for which it was collected, unless retention is necessary to comply with a legal or regulatory obligation or to establish, exercise, or defend a legal claim.
Right to object to certain personal data processing
You may object to the processing of your personal data if you have a particular situation, your data is being used for direct marketing purposes and the legal grounds of data processing are legitimate interests.
Right to restrict the processing of personal data
You may ask us to restrict the processing of your personal data under certain circumstances, such as when the processing is unlawful, but you do not wish your personal data erased, or while we verify the accuracy of your data.
Right to withdraw your consent
If you have agreed on data processing based on your consent, you have the right at any time to withdraw your consent. The consent withdrawal will not affect the legality of the previous processing.
Right to transfer your personal data
You may ask NEO Hold'em (neoholdem.com) to provide you with a copy of your personal data and if technically possible you can request to transfer this data to another Data Controller, where processed on the basis of consent or contract necessity.
Right to complain to the supervisory authority
You have the right to lodge complaints regarding your personal data processing to the relevant data protection supervisory authority: https://edpb.europa.eu/about-edpb/board/members_en
Need more information? If you have any additional questions or concerns regarding the processing of your personal data on the NEO Hold'em (neoholdem.com) sites or applications, please contact our Data Protection Team by emailing [email protected].