This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of collection, processing, distribution, use and storage of Website user’s Personal data including any dispute concerning privacy under current General Data Protection Regulation (GDPR), and in accordance with the data protection regulations in Malta applicable to the True Flip Gaming Ltd (hereinafter the “True Flip”, “Company”, “Us”, “We”, “True Flip”).

It is understood and presumed that by the fact of use of the Website and its services or by clicking ““I ACCEPT TERMS AND CONDITIONS AND PRIVACY POLICY” button the User gives Consent, that he/she/it has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Website and its services.

The following definitions and rules of interpretation apply in this Privacy policy:

For the purposes of this Regulation:

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

‘Restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

‘Profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

‘Pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

‘Recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

‘Third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

‘Personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

‘Genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;

‘Biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;

‘Data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

‘Website’ means a group of interrelated websites owned and operated by True Flip Gaming Ltd, available in the Internet via address: trueflip.com

‘Cookie’ is a text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.com.

‘Sensitive personal information’ An information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

This Privacy Policy may be modified, changed, supplemented, updated at any time with prior written notice from True Flip. Your continued use of the Website and its services after any amendments or alterations of this Privacy Policy without notification of True Flip shall constitute your consent hereto and acceptance hereof of an updated version of this Privacy Policy. At any case, the date of the most recent amendments and alterations will be indicated at the top of this web page. If the User does not agree to such revised terms of the Privacy Policy or Terms of Use he/she must stop using this Website and may withdraw from his/her obligations under this Privacy Policy.

The data controller of this Website is True Flip Gaming Ltd located at: Level G, (Office 1/1939), Quantum House 75, Abate Rigord Street, Ta'Xbiex XBX 1120, Malta. Contact details: [email protected]

The data processor of this Website is SUM AND SUBSTANCE LTD incorporated and registered in England with company number 09688671, whose registered office is at 80 Wood Ln, Central Working White City, London, United Kingdom, W12 0BZ Contact details: [email protected]

The Data Protection Officer can be contacted via: [email protected] Any authorized person or regulatory body may, at any time, contact Data Protection Officer directly with any request related to data protection.

All personal data of data subject is processed in compliance with Art. 6(1) of GDPR and in pursuance of the controller’s obligation to receive consent of data subject for specific processing operations with personal data.

The Website of the True Flip Gaming Ltd collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

The following information may be collected for general purposes:

When using these general data and information, True Flip Gaming Ltd does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, True Flip Gaming Ltd analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

The following information can be collected for services purposes:

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 are prohibited.

Such rule will not apply if one of the following applies:

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored for internal use by the controller. The controller may request transfer of the data to one or more processors or partners that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

On the website of True Flip Gaming Ltd, users are given the opportunity to subscribe to newsletter service. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller. The newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter. During the registration for the newsletter, an Website also store an IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter.

The website contains information that enables a quick electronic contact to True Flip Gaming Ltd. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. The transfer of this personal data to third parties/partners is allowed only on the basis of contractual relations between controller and such third party/partner provided that such transfer is accompanied by non-disclosure agreement with such third party ensuring the security of data subject’s data.

The data controller process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage. If the storage purpose is not applicable, or if a storage period expires, the personal data is routinely blocked or erased.

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting True Flip Gaming Ltd, DPO or sending an email to [email protected] :

In accordance with Article 77 of the General Data Protection Regulation, data subject have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his/her habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

We may disclose any information we collect about you, whether you are a current or former customer, including nonpublic personal information and any other information we collect, to True Flip Gaming Ltd affiliated companies and to non-affiliated third parties, which include non-financial companies, such as service providers and fraud verification services, and others, such as other True Flip Gaming users with which you engage in transactions. We may make such disclosures:

Please note that third parties that support our customer identification and anti-fraud controls may retain and use information about you to perform services on our behalf and to improve their services. By using our Services, you consent to the retention and use of such information by these providers to improve their services.

We may also share aggregated or de-identified information with our affiliated companies or non-affiliated third parties, which cannot reasonably be used to identify you.

We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information outside the EEA. It may be processed by a staff member operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

In case of the ‘leak’ of personal information or some technical problems leading to breakdown of the security system that ensures the data protection, the Company guarantees that it will contact and inform the regulatory data protection body as well as data subjects with regard of such leak or problems as soon as possible, but in any case within 72 hours from the moment when such problem is revealed. Such notification shall be made by the Data Protection Officer. The Company also guarantees that it will do its best to avoid such leaks or minimize the consequences of such leak or breakdown of the security system in case they take place.

We can also transfer your information outside the EEA or to an international organization in case we are required to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

The Website and any products or Services available on Website are not intended to solicit information of any kind from persons under 18 years of age or any other age of legal majority existing in the jurisdiction of the User.

Data controller does not use automatic decision-making or profiling to process and use data subject’s personal data.

True Flip Gaming Ltd use relevant electronic and procedural safeguards to protect the privacy of the information the User provide to True Flip Gaming Ltd from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that True Flip Gaming Ltd are not liable for the security of any data Users are transmitting over the Internet, or third party content.

True Flip Gaming Ltd takes and addresses its users' privacy concerns with utmost respect and attention. If you believe that there was an instance of non-compliance with this Privacy Policy with regard to your personal information or you have other related inquiries or concerns, you may write or contact True Flip Gaming Ltd at email: [email protected]. In your message, please describe in detail the nature of your inquiry or the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly. Please note that if you provide True Flip Gaming Ltd with inconsistent privacy preferences, True Flip Gaming Ltd cannot guarantee that your most recent privacy preference will be honored.