PRIVACY POLICY

1. Introduction and general terms

Convert Stars® is committed to maintaining the confidence and trust of our registered users by protecting and respecting your privacy. We have in place measures to protect your sensitive personal data and its confidentiality. This Privacy Notice is sincerely designed to provide you with plain language about your data and your rights. As such; This Privacy Notice explains how and why your personal information is collected, your rights, and how data is kept secure to act in accordance with the 2018 EU General Protection Data Regulations.

2. About Us / Convert Stars:

Established in 2024, Convert Stars® is the Affiliate and digital marketing arm of Omni Casino, a global leader in Online Casino entertainment committed to providing cutting edge online gaming in a safe and secure environment since 1997.

3. How to contact us.

Please do not hesitate to get in touch with our support team on any general matter:

Email Contact: [email protected]
If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at [email protected].

4. What types of personal information do we collect?

We collect personal information when you interact with us and use our services. This information is provided to us by you when you register for the first time and when you make use of our products or contact us throughout your customer life-cycle. Also, third parties (such as payment processors) or publicly available sources provide us information about you. What types of personal information do we collect? Information you provide to us: When you register/sign up:

Your personal details, such as your name, email address, postal address, telephone or mobile number, gender, occupation or date of birth;
Photographic identification and proof of address documents (to carry out withdrawals due diligence for AML “Anti-Money-Laundering” and KYC “Know-Your-Customer” banking purposes)
Banking and financial details (to establish the source of funds where a transaction is involved to carry out due diligence above for banking purposes)
Your account login details, such as your username and password
This list of personal data types collected by Convert Stars is not exhaustive and further information may be requested from you when Convert Stars considers it fair and necessary to do so.

Through your play/use of our services:

Information about how you promote our Participating Brands, products, games that users play, content that you like to read/click upon, financial product preferences.
Information about your online browsing behavior on Convert Stars’s websites, downloaded content, and other Convert Stars content online.
Recording phone calls – If you use our call service, we may monitor or record phone calls with you. We may do this to confirm that we have performed a request made by you; for regulatory purposes; to resolve queries; to help improve our quality of support services; to help us train our staff; or to help detect or prevent fraud or other crimes.
For security and CRM (“Customer Relation Management”), we collect Information about any devices you have used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier)

Other sources of personal data:

When we provide CRM, we may use third party data about you, for example, your public Twitter or Facebook feeds or, other publicly available sources such as white pages, post code lookup, public search results to get to know you and to provide more dedicated services to you.
Data received from our business partners and from other organizations, such as companies providing verification services, CRM supplier services, credit reference agencies, and fraud prevention agencies.
Personal data collected by Convert Stars directly or through a third party service may include so-called “special categories of data” whereby processing such data is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity. For this specific section, the general scope of data relates to responsible gambling purposes. This data may include descriptive self-exclusions reasons, including statements of health, compulsive (gambling) behavior observation/statements received and/or concerns of mental health based on observation or statements received.

Third party referral information:

If you give us personal information about someone else via our Refer-a-Friend program, then you should not do so without their permission. When information is provided by you about someone else, or someone else discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this Privacy Notice.

5. Why do we collect your Personal Data and on what basis?

Convert Stars is forthcoming about why we collect your data. First and foremost, collecting your information is necessary for providing you the services and products you want. Predominantly, we need to collect and use your information to comply with the laws of various jurisdictions, gaming licenses, software licenses, merchant account licenses and AML rules and KYC banking rules/regulations. Under data protection laws, we also need to identify a specified lawful basis upon which we are processing your personal information. We rely on different bases for different processing activities. Your data is also used to personalize and improve your experience using our services, and to contact you from time to time with important information. Why do we collect your Personal Data and on what basis? To contact you:

Respond to your customer support queries or complaints.
Contact you about our services, promotions, special events, by email, social media, phone, or ground post.
Provide you with important product or terms of service notifications.

To provide CRM services to you:

To offer you a personal and meaningful products and services, we use your history of actions or inactions to provide you with a specific contact.
Upon sign-up, you had/have the choice to “want mail” or not. If you choose not to opt-out to receive marketing offers, you will receive communications from us in the form of direct emails, system wide emails, newsletters or others. However, if you don’t want to receive these communications, you can unsubscribe from marketing communications by contacting [email protected] or (if available) update these preferences within your account directly.

To execute our responsibilities under the Terms of Use/Contract Under our Terms of Use which you have accepted upon signing up/registration, set out the terms of the service and contract thereof that we shall provide you. Our execution of the Terms of Use includes, but is not limited to:

For “service administration purposes,” such as password reminders, service messages, such as site maintenance, updates to our Privacy and Cookies Policy or Terms of Use, unused funds, dormancy of account reminders
To confirm user data
To provide you with information about our games, services, product offerings
Review of tracking reports
To process your transactions out-bound
To inform you of account transactions

Under legal obligation / Regulations When it is necessary in order to comply with mandatory legal obligations to which we are subject under EU or local laws:

To determine where you are accessing the services from to therefore provide you with the proper country/language/currency site, promotional offer or finance product offering, in accordance with our licenses operating conditions;
To allow and restrict services to eligible persons/country of residence
To track financial crimes / AML adherence activities
To confirm your identity, age and residence
To carry out appropriate anti-fraud checks (using online searches/use of a third party service provider). This is not a “credit check.”
To review, research problem gambling issues with referred users

Under legitimate interests It is necessary to process your data for the purposes set out below, except where our interests are overridden by the interests, rights or freedoms of affected individuals (i.e. you). To determine if we can process your data on this basis, we considered three parts: Purpose, Necessity and Balance to number of dynamics, such as what you were told at the time you provided your data, what your reasonable expectations are about the processing of such data, the nature of the data, and limiting impact of the processing on you. And, our reasonable expectation for marketing /customer intelligence/Know-Your-Customer, security and game protection. In this regard, we considered the following: To provide, improve and protect our service to you

To deter, prevent or detect the use of third party software in an effort to change or alter the outcome of a tracker; for your protection and ours.
To deter, prevent, or detect any activities that constitute a material breach of the Terms if Use; for your protection and ours.
To deter, prevent, or detect any activities that constitute a material breach of a promotional event; for your protection and ours.
To deter, prevent, or detect any activities that constitute financial fraud; for your protection and ours.
To provide you with a technical system that is up to date with security and best practices for an end-user experience; to provide and improve service
To evaluate statistical data and trends that serve a dual purpose a) to provide the user a better products and services; and b) to protect the Convert Stars Participating Brands from fraud and illegal activity
Evaluating the results of marketing, promotional and service event activities; to provide and improve service
Marketing research questions; to provide and improve service

Under your consent Upon sign-up, you’ve read, considered and agreed to the Terms of Use. Furthermore, had/have the choice to “want mail” or not. If you choose not to opt-out to receive marketing offers, you will receive communications from us in the form of direct emails, system wide emails, email newsletters, transactional communications, SMS, phone and ground post or via social media. However, if you don’t want to receive these communications, you can unsubscribe from marketing.

Email Contact: [email protected]
If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at [email protected].

We may use general profile (NOT PERSONAL DATA) information which we hold about you to show you relevant advertising on third party sites such as Facebook, Google, Bing, Instagram, Snapchat, Twitter, Affiliate Partner sites. Example would be “a person that likes casino marketing” would be shown an advert for a casino, while not sharing your personal information. If you don’t want to be shown targeted advertising messages from us, some third party sites allow you to request not to see messages from specific advertisers on that site in the future. Special categories of data Section 9 of the 2018 EU General Protection Data Regulations state: “Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.” Therefore; We will only process such data if:

Your explicit consent is given to us to process such data
It relates to personal data which you have made public
It is necessary for the establishment, exercise or defense of legal claims. In this scope, Personal data collected by Convert Stars directly or through a third party service may include “special categories of data” whereby processing health data is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity. For this specific reason, health data relates to responsible gambling purposes. This data may include descriptive self-exclusions reasons provided by you, including statements of health, compulsive (gambling) behavior observation/statements received and/or concerns of mental health (reasonable judgement) based on observation or statements received by you or a third party.
It is necessary for the purposes of carrying out the obligations and exercising specific rights of Convert Stars of the data subject in the field of employment and social security and social protection law;
Is necessary for reasons of substantial public interest, on the basis of European Union or Member State law.

6. When do we share your personal information?

We may share your personal information to third parties for marketing purposes. Although unlikely. We may sell your personal information to third parties; through a merger or sale. Additionally, there are several circumstances when we share your personal data with other companies that provide services to you on our behalf (i.e. banks), and with other third parties in the course of complying with our legal obligations (i.e gaming commissions and platform providers). Other examples of when we share your personal information include when we cross-market our other company casino Participating Brands or enter any kind of merger or business sale. When do we share your personal information? We may share the personal data we collect to Peak Interactive N.V., (Parent company of Omni Casino, Convert Stars and Backweb Services LTD), our banking and processing company, for the following purposes:

Providing you banking and payment services
Providing you promotional offers
Securing transactions
Securing member accounts and cross checking for duplicates/fraud
Statistical and trend analysis related to gaming/AML crime/fraud detection, prevention, and prosecution, as well as complying with regulatory requirements
Responding to your support queries and complaints
Providing you with payment products and services and notifying you about either important changes or developments to the features and operation of those products and services;

With third parties We may share personal data with third parties under the following circumstances:

For security, AML compliance, fraud detection and gaming operational control purposes, we may transfer your personal data to third parties, including, but not limited to, Playtech LTD, Playtech Operational Services, Playtech Technical Services, Mexos Affiliation software, Euro Live dealer, Paragon Support Services LTD, Nuvei Payment Services, Paysafe Payment Services, Address Verification System service providers, Payment Service Providers, Financial Institutions and Game Product Suppliers. Furthermore, we reserve the right to disclose your personal data to relevant parties when the Participating Brand Casino has reasonable grounds to suspect irregularities involving a referred player account or gaming transaction;
With other service providers to enable us to provide our services, such as companies that help us with technology services, storing and combining data, and processing payments or providing relevant online advertising for our products and services (most noted above)
We may instruct and authorize the Financial Institution with which your account is held to disclose any information as may be requested to comply with all security and regulatory matters
When ordered to do so by any regulatory body and/or under any legal provision contained in the governing law. Courts, gaming commissions, banks, legal proceedings
In order to establish, exercise or defend our legal rights
With external auditors who may carry out independent checks as part of our regulatory compliances
To an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale is completed, the organization receiving your personal data can use your personal data in the same way as us; or
To any other successors in title to our business.

7. Security of your data

Convert Stars is committed to protecting the personal information you entrust to us. We take all reasonable steps to ensure that all information collected through our Sites is treated securely and in line with this Policy and strict data protection standards. Accordingly, we have adopted robust procedures and technologies to protect your data from unauthorized access and improper use. After logging in all information sent to and from Convert Stars Affiliate Account site is encrypted using 128-bit Secure Socket Layer (SSL) technology. The SSL certificate used is issued and verified by a carefully selected third party. Your banking details are encrypted and sent only once over the Internet to Convert Stars. It is then stored encrypted in Convert Stars’s secure systems, overseen and managed by Mexos, a Playtech LTD company. Convert Stars is dedicated to protecting end user customers’ confidential information and, as part of doing so, Convert Stars is certified towards the Payment Card Industries Data Security Standard. The security of Convert Stars’s systems and applications are tested several times per year by third-party security experts. Furthermore, Convert Star’s (Mexos supplier) has an Intrusion Detection System that monitors all network traffic 24/7 for signs of attacks or intrusions. All overseen and managed by Playtech LTD. Convert Stars has a dedicated fraud department and advanced systems in place to detect and prevent suspicious activity, to ensure that Convert Stars’s website remains a secure playing-field. Any account involved in suspicious activity will be suspended and investigated to the fullest extent. Should you as registered user have any doubts about the activity on your account, such as unrecognized transactions in the transaction history or surprising changes in the balance, please contact us immediately.

8. Cookies and similar technologies

Some of our web pages utilize “cookies” and other tracking technologies. By using Convert Stars’s website and mobile products, you are consenting to our use of cookies for the purposes described in this section. A “cookie” is a small text file that is stored on your computer and may be used, for example, to collect information about website activity and is used to ensure that private information associated with your registered account stays private and viewable only to you. Our use of cookies and other tracking technologies allows us to improve our website and your overall experience. We may analyze information that does not contain Personal Information for trends and statistics. We set a persistent cookie to store your passwords so you do not have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our site. You may set most browsers to notify you if you receive a cookie, or you may choose to block /manage cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter the original user ID and password to gain access to certain parts of the website. However, some cookies are necessary, for more information about cookies expand the below. What types of cookies do you use and why? Functional /Necessary cookies These cookies are required to enable core site functionality, ensuring our service performs how you would expect. Functional /Necessary cookies will:

Identify you as being logged into the casino services
Ensure that you are directed to the proper country/language/currency website
Help keep your browsing and gaming sessions secure

Functional /Necessary cookies will NOT:

Send any information to third parties.

Persistent cookies These cookies are used to support your experience on the site and as the name says, are a persistent presence unless you do not want them to be. Persistent cookies will:

Remember if we’ve already asked you if you want to participate in a survey
Show you personalized information when you’re logged into the affiliate service
Remember your username to let you log in quickly when you return to the site

Performance and targeting cookies We may work with external advertising networks (i.e. marketing networks) whom also use cookies to collect information on your preferences, meaning that we can show ads and promotional offers that are appealing to you. You can manage your cookies It’s recommended you allow to keep your cookie settings as it may somewhat reduce your user experience and the performance of the site experience. But, changes will not prevent you from using the site or make your experience too unpleasant as to “force” you to use cookies. If you wish to change your cookies settings, you can do this through your browser. Different web browsers may use different ways of controlling cookies, so you’ll need to use your browser’s help section to find out how to do this.

9. Do we transfer your data outside the EEA?

As a global company, the personal data that we collect from you may be collected at, transferred to, and/or stored, at a destination outside the European Economic Area (“EEA”). It may also be processed by companies operating outside the EEA that provide services to Convert Stars or for one of our service or banking providers. Some of your personal information could be held at a destination which offers a different level of data protection than in the EEA, including the United Kingdom, United States of America, Curacao, Tribal Territory of Kahnawake, Ukraine, and Estonia. To ensure your personal information remains safe when transferred in such a global network, we will take all reasonable steps to adhere to an appropriate level of protection. Any transfer of your personal information to a location outside the EEA will be based on:

The contractual Model Clauses adopted by the European Commission or a relevant data protection authority; or
An adequacy decision from the European Commission, confirming that the third country provides adequate protection for your personal information; or
Privacy Shield when transferring to the US (this is a form of certification which ensures that your data is handled in a way that is compatible with the strong EU protections); or
Your consent, or another legal basis on which we are entitled to make the transfer.

10. How long will Convert Stars keep my data?

We will store your data for as long as is reasonably required to fulfill our legal obligations to our financial institutions, gaming commissions and suppliers. To meet our legal and contractual requirements, we will retain your data for a period of not less than five (5) years after you stop being an active registered user of Convert Stars, starting at the date your account is closed. There are several reasons which we retain your information, these include:

To comply with all legal obligations under EU/local laws
To comply with all legal obligations under a gaming authorities regulations/laws
To establish or defend legal claims
To comply with AML and KYC laws and regulations
To have stored history of gaming outcomes and transactional history related to your account

11. Your rights and choices over your personal information

By EU law, and subject to certain conditions, you have a number of rights concerning the personal information we hold about you. If you wish to exercise these rights, you should contact our Data Protection Officer using the details set out above in Section 3. These free-of-charge rights include:

The right to access, amend and erase the personal information we hold about you
The right to object to the processing of your data
The right to be informed
The right to withdraw consent, and the right to data portability.
The right to have inaccurate personal data rectified, or completed if it is incomplete
The right to complain to us or your data protection authority if you are concerned with how we process your information. See more in section 12 below.

In addition, you have certain rights relating to automated decision-making and ‘profiling’. Further information and advice about your rights can be obtained from your country’s data protection regulator or reviewing the 2018 EU GDPR articles of interest to you. What are your rights? – The details Right to access, amend and rectify the information we hold about you You have the right to request a copy of the personal information we hold about you, known as a “data subject access request.” You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. Right to delete/erase your data In some circumstances, you can ask us to erase personal information we hold about you. This is known as the so-called “the right to be forgotten” in section 17 if the GDPR. This includes when:

The information is no longer necessary in relation to the purpose for which it was collected;
If you previously gave consent to the use of your information, but decide to withdraw it and we cannot justify another legal ground for using it under data protection law;
We process your information based on our legitimate interests and we cannot demonstrate overriding legitimate grounds to continue processing the information;
We don’t have a lawful ground under data protection law to process your information;
The data has to be erased to comply with a legal requirement;

This right is subject to mandatory retention periods under EU/local laws. Right to restrict processing In section 18 of the GDPR, you have the right to ask us to restrict (‘block’ or ‘suppress’) the processing of your personal information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future. This right is available to you when:

You dispute the accuracy of the personal information;
The processing is unlawful, and you object to the erasure of the information and request that we restrict processing instead;
We no longer need the data, but you require it to establish, exercise or defend a legal claim; and
We process your information for our legitimate business interests but you object and while we verify the grounds for continued processing.

Right to Data Portability You have the right to receive personal information you provide to us, in a ‘commonly used machine-readable format’. This allows you to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a different provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however, and only arises when the processing of your information is:

Based on your consent or where it is necessary for the performance of a contract, and
When the information is processed by solely by automated means.

Right to object Based on your particular situation, you can object to the processing of your personal information, that is:

Based on our legitimate business interests (including profiling); or
Done for research and statistical purposes.

You also have the ‘absolute right’ to object to the use of your personal information for direct marketing purposes (including profiling), such as when you receive emails from us notifying you about other casino brand services which we think will be of interest to you. Right to withdraw consent When we rely on your consent as the basis to process your personal information. This consent is provided to us by your when you read, consider and accept our Terms if Use when you sign up and register for our services. Be it known, clearly, that you have the right to withdraw your consent at any time. It is our desire and goal to make it easy for you to withdraw consent by choosing an “unsubscribe” option in marketing communication you receive from us. If you find this isn’t the case, then just get in touch with our Data Protection Officer in the ways outlined above in Section 3, and we will work with you with to settle your concern. Rights related to automated decision making, including profiling We sometimes use systems to make automated decisions based on your personal information and playing history. These automated decisions can affect the products, services or features we may offer you now or in the future, or the ability to use our services. We do not rely solely on these systems. We may use automated systems in the following situations:

Tailoring products and services – we may place you in groups with similar customers (segments) to study and learn about preferences and your needs, and offer a more tailored experience for you;
Detecting fraud – we use your personal information to help decide and detect if your account may be being used for fraud or money-laundering. If we think there is a risk of fraud, we may block or suspend an account;
To detect “associated groups.” If we feel your account is linked with other accounts by more than one reasonably defined “association or link” activity or action;
Opening account – when you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position;
We may cross reference your details, personal or devices, against so-called “bad data” already in place within our systems to prevent fraud, restricted players and self-excluded players, or banned persons, stolen user list or spam list being promoted by you;
Risk (bad data) or reward (i.e. player club rewards) assessment connected to your referred users wagering.

Data protection law seeks to safeguard individuals against harm that may arise from decision-making – including profiling – that takes place without human intervention. You have the right not to be subject to a decision – including profiling – when it is based on the automated processing of your personal information and it has a legal effect or a similarly significant effect on you. Please note that the right does not apply when the processing is:

Necessary for entering into or for the performance of a contract with you; or
When it is authorized by law; or
When it is based on your explicit consent.

12. Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by emailing [email protected]. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, please inform us again so that we may work with you to resolve the matter. If after, you are still not satisfied, you can file a complaint with your national data protection regulator.

13. Changes to Convert Stars Privacy Notice

This Privacy Notice may be updated from time to time to reflect changes and the latest version will be date stamped on this page. Please check this page from time to time for updates. However, for ease and transparency, if significant changes are made to the Privacy Notice, we will provide a more prominent notice by email as a non-marketing notice. If you do not agree to these changes, please do not continue to submit personal information to Convert Stars or use Convert Stars services in any way. Otherwise, by continuing to do this, you will be deemed to have accepted the changes to the Privacy Notice. You can also delete your Convert Stars account at any time.