In its everyday business operations, Energy makes use of a variety of data about identifiable individuals, including data about you. By collecting and using this data, Energy is subjected to a variety of regulations controlling how such activities are to be carried out and the safeguards that must be put in place to protect it.
Please note that you should read this notice in conjunction with our Terms and Conditions.
References to ‘us’, ‘we’, ‘our’ and ‘Energy’ refer to Probe Investments Limited (Data Controller).
The controller of your personal data is Probe Investments Limited, which is registered under the laws of the European Union member state of Malta. It has a registration number C51749 with registered address at Level 4, 109, Sir William Reid Street, GZR1033 - Gzira, Malta. You can contact us here. If you need more information or help with your Personal Data, contact our Data Protection Officer at email@example.com.
WHAT WE COLLECT FROM YOU
When you use our services, we may collect personal data including but not limited to:
a. Your first and last name.
b. Your email address.
d. IP address.
e. Phone number.
f. Technical information about any devices you use to access our services or other technical information.
g. Information about your use of Energy services, including information about when, how, and where you use the services.
h. When you register for an account, create, or modify your profile, set preferences, sign up for or make purchases through the services.
i. Information on your use of social networks (if you have linked our services to your social media accounts). The above may potentially include certain information from Facebook and other social networks (including access to your friends' list and other non-personal analytical data), strictly in accordance with the applicable Facebook terms and conditions and other social networking websites – only to the extent necessary to provide you with all the functionalities of the Energy services.
j. Information about your deposits and withdrawals.
k. Any other data that you provide to us through our services.
l. Any other data that you provide to us when you contact our support.
m. As part of the Customer Due Diligence process and in accordance with the law, Energy can ask you for additional information.
WHY DO WE NEED THIS DATA?
Energy processes your data to provide you with the full functionality of the services offered on Energy website and to meet legal obligations imposed on Energy and/or to implement a perfectly legitimate purpose of data processing consistent with your rights. These are the data processing security, fraud and money laundering prevention and marketing services.
Energy is obliged to process data on the basis of various legal provisions and current legislation. These include tax regulations, anti-money laundering regulations and other regulations regarding licensed operators issued by supervisory authorities.
In addition to that, your data may be used by Energy for the following purposes:
a. To provide you with services covered by the operation of the Energy website.
b. To provide personalised marketing information about the services that you order from Energy or that may interest you, e.g. Energy can send you emails or display pop-up messages about Energy services and updates.
c. To communicate with users of Energy services.
d. To enable participation in interactive services, tournaments, and promotions in general.
e. To notify you about changes regarding our services.
f. To improve or modify Energy services and policies.
g. To organise competitions, promotions, and bonuses (including contact with participants, evaluation of entries, distribution of prizes, payment of tax, etc).
h. For tax, legal and billing purposes.
i. For billing purposes as defined by EU law (GDPR).
j. For any purposes provided by law, including counteracting money laundering attempts.
k. To profile and personalise Energy marketing communications, offers and advertisements campaigns that Energy display on its website and third-party websites and/or services based on the combined data we have collected about you.
l. For processing online payments.
m. To verify your age and other personal information as may be necessary.
n. For configuring and managing your user account.
o. To complete compliance procedures imposed on Energy.
p. To monitor transactions to prevent fraud and money laundering.
Energy can profile your personal data, which means that Energy can use the information collected to tailor communications addressed to you.
Energy does not use algorithms on your profiled data to make automated decisions that can affect your individual rights or any rights arising from the contract between Energy and you. I.e. Energy does not place automatic offers based on your behaviour in the games.
However, Energy is obliged by laws and license conditions to monitor its players to identify people who may be experiencing, or are at risk of developing gambling problems. Based on data describing unique players, a special algorithm provides us with an estimated probability of gambling addiction, allowing Energy to interact with such players to offer help or support. Decisions based on predictions are not made automatically without human intervention.
FOR HOW LONG DO WE KEEP YOUR DATA?
These regulations set out that Energy can store your personal data for a certain period after you cease being a customer, due to legal and license provisions imposed to us. After this period, Energy will either safely delete or anonymize your information – If deletion is not possible (because the data has been stored in backup archives) then we will securely store, isolate, and safeguard your information from any further use until deletion can be possible.
Where we have the appropriate consent (subjected to your preferences) and/or lawful basis, some of your personal data can be processed by our third-party marketing partners to allow us to communicate with all our customers by phone, email, push notifications, SMS (by sending platform providers) and to inform about prizes and/or gifts from suppliers, etc.
Consent for this processing can be changed in whole or in part at any time by going to ‘My Account’ settings. If you need more information about this, let us know here.
All our marketing communications will include instructions on how to opt out of receiving this specific type of marketing communications. It can take up to 48 hours for your request be fully carried out. We will not share your personal data with unrelated third parties to market their products to you without your prior consent.
Telephone calls to and from our Customer Contact Centre can be recorded for training and security purposes along with the resolution of any queries arising from the service you receive.
The two-factor authentication adds more security to your Energy account.
Any attempts to log in to your Energy account from a new device or country will be followed up with a 6-digit authentication code (token) sent to your mobile phone number or email address provided upon registration. You will be required to enter the generated code (token) upon your login attempt. To do so, just write the code from your mobile SMS or email into the field “Token”.
This procedure will protect your account from unusual activity or potential third-party access by keeping unknown people away, even if they are in possession of your password.
If for any reason you do not receive the verification token, please contact our Customer Support.
Energy and its third-party partners (advertising and analytics partners) use various technologies to collect information, such as cookies and web beacons and other technologies to improve and customise services, websites and your experience; to allow you to access and use the services without re-entering your username or password; to understand usage of services and the interests of our customers; to determine whether an email has been opened and acted upon; and to present you with advertising relevant to your interests.
• Where strictly necessary.
These cookies and similar technologies remember choices you make, such as language, search parameters or remembering you have logged in. Energy uses these cookies to provide you with a tailored experience more appropriate with your selections.
• For performance and analytics.
These cookies and similar technologies collect information on how users interact with the services and enable Energy to improve how these services operate. Energy use Google Analytics cookies to help understand how visitors arrive at and browse our products and website to identify areas for improvement, such as navigation, user experience, and marketing campaigns.
• Targeting Cookies or Advertising Cookies.
These cookies collect information about your browsing habits in order to make advertising relevant to your interests. They remember websites you have visited and that information is shared with other parties such as advertising technology service providers and advertisers.
• Social media cookies.
These cookies are used when you share information using a social media sharing button or ‘like’ button on our websites, link your account or engage with our content through a social media website. The social network will record such data and it may be linked to targeting/advertising activities.
To opt out of our cookies policy, you can instruct your browser by changing its options to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our services. Energy and its third-party partners also collect information using web beacons (also known as tracking pixels). Many browsers include their own management tools for removing HTML5 local storage objects. Please note that you will not be able to opt out of any cookies or other technologies that are strictly necessary for the services.
SHARING AND PROCESSING YOUR PERSONAL DATA
Energy securely shares information with third parties that help Energy operate, provide, improve, integrate, customise, support and market its services. Energy will ensure that all relationships involving the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.
Energy works with its third-party partners and service providers to provide website and application development, games software, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services, which may require them to access or use information about you. These include also software suppliers, payment systems providers, entities dealing with Energy. If a service provider needs to access information about you to perform services on Energy behalf, they do so under close instruction from Energy, including policies and procedures designed to protect your information at all times.
If required by law, Energy may disclose your information to the Police or other public authority – this includes, but is not limited to the IP address and details of any suspected unlawful or dishonest activity, such as abuse of a given form of payment or security risk assessment.
We may share your Personal Data within the Energy Group and with these other organisations:
• Law enforcement agencies, regulators, and other legal authorities.
• Credit reference agencies.
• Fraud prevention agencies.
• Identity verification agencies.
• Sports governing bodies.
• Organisations that introduce you to us.
• Third parties you ask or allow us to share your data with.
• Third parties necessary to provide products or services you have requested.
• Third parties allowing us to comply with the affordability rule (if applicable).
DATA TRANSFERS OUTSIDE THE EEA
By agreeing to the transfer of your data to third parties, you also agree that third parties may be located outside the EEA. The privacy laws in these countries may not provide the same level of protection as in your country or EEA. Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
If Energy shares your data outside of the EEA, Energy will rely on standard EU contractual clauses which allow the transfer of your data and provide the right level of protection.
KNOW YOUR RIGHTS
You have rights under the GDPR. These consist of:
1. The right to withdraw the consent.
However, this will not invalidate any previously consented processing.
2. The right to be informed.
You have the right to be informed about how your personal data is processed and why.
3. The right of access.
You have the right to request a copy of the personal data we hold about you.
4. The right to rectify.
Where personal data is inaccurate, you have the right to request a correction and also complete any incomplete personal data.
5. The right to be forgotten.
You can request us to erase your personal data where there is no lawful basis requiring us to continue processing this personal data. This right only applies in certain circumstances, given that legal obligations include data retention periods.
6. The right to restrict/object processing.
In certain circumstances, you have the right to object or restrict the processing of your personal data, where this processing is based on consent or our legitimate interest. However, despite your objections or wish to restrict processing, where there are compelling legitimate grounds or legal obligations, we would be required to continue said processing.
7. The right to data portability.
You have the right to request that your personal data be provided to you in a structured, commonly-used and machine-readable format (GDPR Article 20) and to transfer that data to another party. This applies to personal data for which processing is based on your consent and the processing is carried out by automated means.
8. Rights in relation to automated decision making and profiling.
You have the right to not be subjected to automated decision-making when the decision has a significant effect on you; you can insist on human intervention where appropriate. You also have the right to express your point of view and contest decisions.
9. The right to withdraw.
You have the general right to withdraw the consent you have given us to process your personal data (in respect of our marketing activities) and where this processing is based on what we deem to be our legitimate interest.
Please note that Energy is subject to several EU/local regulations, therefore, some of these rights outlined above may not apply when the processing is:
• Necessary for entering or performing a legal contract with you.
• It is authorised or enforced by EU/local laws.
• It is based on your explicit consent.
Energy is required by law to keep your personal data for a certain period after you cease to be a customer, this is based on current legal regulations on anti-money laundering. It's very important that you understand that we do everything in our power to comply with your requests but we are ultimately subjected to GDPR and other EU/local laws.