PRIVACY AND COOKIE POLICY
Effective from: 01.09.2026
1. Introduction
1.1 This Privacy and Cookie Policy, last updated on the Effective date above, sets out the data-processing practices of 3-102-968695 S.R.L., with registered number 3-102-968695, having registered address at: PROVINCIA 01 SAN JOSE, CANTON 15 MONTES DE OCA, DISTRITO UNO DE SAN PEDRO, LOS YOSES, AVENIDAS OCHO Y DIEZ, CALLE TREINTA Y NUEVE, LY CENTER, (the "Company") in connection with DonGamble (the "Website"). We aim to be clear and transparent about what personal data we collect, and how and why we use it.
1.2 This Policy explains how we use your personal data whether you are visiting the Website, registering an account, making a deposit, or playing our games. It also explains your data-protection rights, the circumstances in which we share your information, and how we use it, including for marketing purposes where you have consented.
1.3 We will inform you of any material update to this Policy in accordance with Section 10.
1.4 All Company staff undertake regular training on information security and are required to comply with confidentiality obligations and internal data-protection procedures whenever they handle player information.
1.5 If you have any questions or concerns about this Policy or how we handle your data, please contact [email protected].
2. Our Privacy Commitment
2.1 The Company values and respects the privacy of every player. We commit to protecting your privacy, using your personal information to make your experience simpler and better, keeping it safe, and being clear with you about why we collect it and how we use it. Where you have choices or rights, we will explain them and respect your wishes.
2.2 As described in our Terms and Conditions and KYC Policy, the Company applies risk-based Customer Due Diligence and, where a relevant trigger under the KYC Policy is met (including a player's first withdrawal request or aggregate lifetime deposits reaching USD 10,000), Enhanced Due Diligence, in line with the AML/CTF Code of Conduct for Anjouan Internet Gaming Operators. This may include a request for identity documents, proof of address, proof of source of funds, a selfie holding an identification document, or a verification phone call. No payout will be processed until the required verification has been completed.
3. What Personal Information We Collect and When
3.1 When you register an account
personal details such as your name, email address, postal address, telephone number, gender and date of birth;
photographic identification and proof-of-address documents (for KYC/AML due diligence);
banking and financial details, to establish source of funds where relevant;
your account login credentials.
3.2 Through your use of our services
information about how you interact with our products;
information about your online browsing behaviour on the Website — see our Cookie Policy in Section 12 for details;
information about the devices you use to access our services (model, operating system, IP address, browser type, device identifier);
recordings of phone calls, where we monitor or record calls to verify instructions, resolve queries, meet regulatory obligations, improve service quality, train staff, or detect and prevent fraud;
information you share with us voluntarily or that you make public, such as on social media.
3.3 Special categories of data
Personal data we process may include special categories of data, such as data revealing health information relevant to responsible gambling (see Section 4). We apply additional safeguards to protect the confidentiality of such data (see Section 8).
4. Why We Collect Your Personal Data and On What Basis
We collect and use your data primarily to provide the services you request, to personalize and improve your experience, to contact you with important information, and to comply with our legal and regulatory obligations, including under Anjouan Gaming's licensing conditions and the applicable data-protection laws in the jurisdictions where our players reside (including, where applicable, the EU General Data Protection Regulation (GDPR) and other local data-protection legislation). We rely on the following legal bases:
4.1 Performance of a contract
Processing necessary to provide gaming and betting services under our Terms and Conditions, for account and service administration (password resets, service messages, dormant-account notices, policy updates), and to process your transactions.
4.2 Legitimate interests
Processing necessary for our legitimate interests, balanced against your rights and expectations, including: personalizing your experience; improving our services through analysis, testing and research; contacting you about our services and managing promotions or surveys; and protecting the integrity of our platform, including affordability checks and fraud prevention.
4.3 Legal obligation
Processing necessary to comply with our AML/CTF, licensing, tax and other legal obligations, including verification, monitoring, and reporting to Anjouan Gaming as described in our KYC Policy.
4.4 Special categories of data
We process special categories of data only where you have given explicit consent, the data relates to information you have made public, processing is necessary to establish, exercise or defend legal claims, or processing is necessary for reasons of substantial public interest under applicable law.
5. When We Share Your Personal Information
We do not share your personal data with third parties outside the Company's group for marketing purposes. We may, however, share personal data in the following circumstances:
when required to do so by Anjouan Licensing Services Inc. / Anjouan Gaming, the Anjouan Offshore Finance Authority (AOFA), a Financial Intelligence Unit, or any other competent regulatory or law-enforcement body, including in connection with Suspicious Activity Reports and Currency Transaction Reports described in our KYC Policy;
with financial institutions holding an account holder's funds, as required by the regulatory or law-enforcement body ;
to establish, exercise or defend our legal rights;
with third parties engaged for identity verification, affordability checks and fraud detection;
with service providers that support our technology, data storage, payment processing, and marketing services on our behalf;
with external auditors carrying out independent compliance checks, including the annual AML audit required by Anjouan Gaming;
with a purchaser or successor in the event of a sale, merger or transfer of our business, subject to prior notice to you where required;
with the relevant regulator in connection with self-exclusion requests, as described in our Responsible Gaming Policy.
6. How Long We Retain Your Data
We retain your information only for as long as necessary to fulfil the purposes for which it was collected. In accordance with the AML/CTF Code of Conduct for Anjouan Internet Gaming Operators, we retain KYC/AML-related records, including identification documents, transaction records, and Suspicious Activity Reports, for a minimum of five (5) years after your account is closed, or such longer period as may be required by applicable law. We retain other categories of personal data for the periods necessary to comply with our legal obligations, establish or defend legal claims, meet contractual obligations, or satisfy our legitimate interests, whichever is longest.
In addition to this, We may retain anonymized data for longer periods for research and statistical purposes. This anonymized data helps Us improve Our services and marketing strategies, ensuring that no personal identifiers are involved in these processes.
When determining the appropriate retention period applicable to your data, we take several factors into consideration, such as the purposes for which we collect and process such data, the applicable laws and/or regulatory requirements imposed on us, the nature and sensitivity of the personal data, and the potential risks surrounding the unauthorised use or disclosure of such data.
7. Your Rights and Choices Over Your Personal Information
Subject to applicable data-protection law and certain conditions, you have the following rights in respect of the personal information we hold about you. To exercise any of these rights, contact us at:
7.1 Right to access and rectify
You may request a copy of the personal information we hold about you, and request correction of any information that is inaccurate or out of date.
7.2 Right to erasure
You may ask us to erase your personal information where it is no longer necessary for the purpose for which it was collected, where you withdraw consent and no other legal basis applies, or where we have no lawful ground to continue processing it. This right is subject to our mandatory AML/CTF retention obligations described in Section 6.
7.3 Right to restrict processing
You may ask us to restrict processing of your information while we verify its accuracy, while you establish a legal claim, or while we assess an objection you have raised.
7.4 Right to data portability
Where processing is based on consent or contract and carried out by automated means, you may request your data in a commonly used, machine-readable format.
7.5 Right to object
You may object to processing based on our legitimate interests, including profiling, and to the use of your data for direct marketing at any time.
7.6 Right to withdraw consent
Where we rely on your consent, you may withdraw it at any time, including via the "unsubscribe" option in any marketing communication.
7.7 Automated decision-making
We use automated processing in limited circumstances, including to detect fraud or money laundering, to assess eligibility to open an account, and to conduct risk assessments connected to your play. You have the right not to be subject to a decision based solely on automated processing that produces a legal or similarly significant effect on you, except where necessary for a contract with you, authorized by law, or based on your explicit consent.
We will respond to requests under this Section without undue delay and, in any event, within one month of receipt (extendable by a further month for complex requests, with notice to you). If your request does not meet applicable legal requirements, we may charge a reasonable administrative fee or decline the request, with reasons provided.
The personal information requested at registration is compulsory unless marked optional; it is required to process your registration, contact you, and comply with applicable gambling and financial-crime laws. If you do not provide it, you will not be able to use our services.
8. Security of Your Data and Confidentiality
We take all reasonable steps to ensure information collected through the Website is treated securely and in line with this Policy and applicable data-protection standards, including robust technical and organizational safeguards against unauthorized access or misuse, consistent with Section 6 (Data Protection and Cybersecurity) of the Code of Conduct for Anjouan Internet Gaming Operators.
Payment card details are encrypted by our payment providers; we do not collect, store or transfer card data ourselves.
Our systems and applications are tested by independent third-party security experts on a regular basis.
We operate an Intrusion Detection System monitoring network traffic on an ongoing basis for signs of attack or intrusion.
We maintain a dedicated fraud-prevention function and advanced systems to detect and prevent suspicious activity.
The Website uses SSL/TLS encryption to protect the confidentiality of data in transit.
We will report any cybersecurity incident affecting player data to Anjouan Gaming within 24 hours of its discovery, and will notify affected players without undue delay where required by applicable law. If you notice any unrecognized transaction or suspicious change to your account, please contact us immediately.
9. Changes to This Policy
We may update this Policy from time to time to reflect changes in how we operate or how our operations are regulated. The date of the most recent revision appears at the top of this page. Where a change is significant, we will provide more prominent notice, which may include email notification, and, where required, ask you to expressly accept the change before continuing to use the Website.
10. Your Obligations
By using the Website and providing personal data, you confirm that the information you provide is true, accurate and complete, and you agree to notify us of any change. If we reasonably suspect the information provided is false, incomplete, or contrary to applicable data-protection law or this Policy, we may reject your registration or suspend or terminate your account without notice and without liability to you.
11. Cookie Policy
This section describes how we use cookies on the Website. The terms "we", "us" and "our" refer to the Company as operator of the Website.
11.1 What is a cookie?
A cookie is a small text file downloaded to your device when you access the Website, allowing us to recognize your device and remember information about your preferences or past actions. Session cookies are erased when you close your browser; persistent cookies remain on your device for a defined period.
11.2 Why we use cookies
Strictly necessary cookies enable the Website to function and provide a usable interface — for example, associating your bets with your account, and ensuring you receive bonuses for which you are eligible. These cookies do not store personally identifiable information and cannot be disabled without affecting core functionality.
Other cookies are used, with your consent, to analyse aggregate usage statistics and conduct marketing research (including via analytics and advertising tools), personalize Website content, serve personalized advertisements, and adapt the Website's language to your preferences.
We retain cookie-related information for up to 6 months after your last visit, save where a given cookie has its own retention period outside our control.
11.3 Managing cookies
Strictly necessary cookies are set by default. For all other cookie categories we obtain your consent via the cookie banner shown on your first visit; you may accept all cookies, decline non-essential cookies, or manage your preferences at any time via the Website's Cookie Settings. Declining non-essential cookies may affect personalization and device recognition but will not prevent you from using core Website functions. You may also control cookies through your browser settings, though disabling all cookies may cause parts of the Website to stop working correctly.