Wildies

At Wildies, we are committed to protecting the privacy and personal information of all individuals who use our services. This Privacy Policy outlines the types of personal information we collect when you utilise our services, the purposes for which we collect and process this information, the lawful bases for such processing, how we safeguard your information, and your rights in respect of the personal data we hold about you.

This Privacy Policy details our practices regarding the collection, use, storage, and disclosure of the personal information we obtain through your engagement with our services and website. It also informs you of your rights concerning the personal data we hold. The Privacy Policy is incorporated into our Terms of Service and is considered part of the Wildies User Agreement. By accessing or using the Wildies website, you acknowledge and agree to the collection, use, and disclosure of your information in accordance with this Privacy Policy.

Please be aware that this Privacy Policy constitutes a legally binding agreement between you and Wildies ("We", "Us", or "Our"). It forms an integral part of the Terms and Conditions of Wildies.

We may update this Privacy Policy from time to time and will notify you of any material changes by posting the revised version on our platforms. We recommend reviewing this Privacy Policy regularly to stay informed about how we protect your personal information. The date of the most recent revision will be indicated at the top of this Privacy Policy.

LAWFUL BASIS FOR PROCESSING

We process your personal information only where we have a lawful basis to do so, in accordance with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") where applicable. The lawful bases upon which we rely include:

Contractual Necessity: Processing is necessary for the performance of our contract with you, including the provision of our gaming services, the management of your account, and the processing of transactions.
Legal Obligation: Processing is necessary for compliance with legal and regulatory obligations to which we are subject, including those arising under the Computer Gaming Licensing Act 007 of 2005, the Money Laundering Prevention Act 008 of 2005 of Anjouan, anti-money laundering and counter-terrorist financing legislation, and any applicable requirements imposed by AOFA and ALSI.
Legitimate Interests: Processing is necessary for the purposes of our legitimate interests, including the detection and prevention of fraud, the improvement of our services, network and information security, and the administration of our business, provided that such interests are not overridden by your rights and freedoms.
Consent: Where none of the above lawful bases apply, we will process your personal information only with your explicit consent, which you may withdraw at any time by contacting us at the details provided in this Privacy Policy. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

INFORMATION COLLECTED

We define personal information as any data that can directly or indirectly identify an individual, including but not limited to first and last names, date of birth, physical address, email address, phone number, government-issued identification documents, and other relevant details ("Personal Information"). You may be required to provide Personal Information when using our website, creating an account, or accessing our services.

The Personal Information we collect may include, but is not limited to:

Identity Data: full name, date of birth, gender, nationality, copies of government-issued identification documents (such as passport or national identity card), and proof of address documentation;
Contact Data: email address, telephone number, postal address;
Financial Data: bank account details, payment card information, e-wallet details, deposit and withdrawal history, and transaction records;
Account Data: username, password (encrypted), account preferences, and account verification status;
Technical Data: IP address, browser type and version, device identifiers, operating system, time zone setting, access times and dates, pages visited, language preferences, and software crash reports;
Gaming Data: gameplay history, betting patterns, game preferences, wagering amounts, and responsible gaming settings (such as deposit limits, self-exclusion status, and session time limits);
KYC and AML Data: source of funds documentation, source of wealth declarations, enhanced due diligence information, politically exposed person (PEP) screening results, and sanctions screening results;
Communication Data: records of correspondence with our customer support team, feedback, complaints, and survey responses.

This information is stored on our servers located in Germany and, in compliance with ALSI requirements, replicated on ALSI-approved servers as mandated by the licensing conditions. When you interact with our services, our servers maintain a unique activity log that gathers specific administrative and traffic data. This information is essential for providing, improving, and securing our services. We do not collect Personal Information without your knowledge or without a lawful basis for doing so.

METHODS OF DATA COLLECTION AND PROCESSING

We may collect and process your Personal Information through the following methods:

Directly from you: when you register an account, complete identity verification, make deposits or withdrawals, contact our customer support, or otherwise interact with our services;
Automatically: through cookies, server logs, and similar technologies when you access and use our website and services (see Section 9 below);
From third-party sources: including online identity verification providers, credit reference agencies, fraud prevention agencies, payment service providers, and from customer lists obtained lawfully from third-party sources;
From regulatory and law enforcement bodies: where information is provided pursuant to legal processes or regulatory requirements.

We may engage third-party service providers for technical support, processing your online transactions, identity verification, fraud detection, and maintaining your account. We will have access to any information you provide to these vendors and service providers, and we will process the Personal Information as specified in this Privacy Policy. Such information will only be shared with third parties outside of our company in accordance with this Privacy Policy and in compliance with applicable data protection legislation.

We take appropriate measures to ensure that our agreements with third-party service providers and data processors include adequate contractual safeguards for the protection of your Personal Information, including, where appropriate, Data Processing Agreements that comply with Article 28 of the GDPR.

USE OF INFORMATION

We use the Personal Information collected from you for the following purposes:

to deliver and manage our gaming services, including account creation, maintenance, and closure;
to process your online transactions, including deposits, withdrawals, and wagering activities;
to verify your identity and conduct the necessary Know Your Customer (KYC) and anti-money laundering (AML) checks as required under the Computer Gaming Licensing Act 007 of 2005 and the Money Laundering Prevention Act 008 of 2005 of Anjouan, and any applicable regulations issued by AOFA and ALSI;
to conduct necessary security and fraud prevention checks;
to provide customer support and respond to your enquiries;
to comply with our legal and regulatory obligations, including responsible gaming requirements, reporting obligations to AOFA and ALSI, and the detection and prevention of money laundering, terrorist financing, and fraud;
to facilitate your participation in promotions, tournaments, or loyalty programmes;
to monitor and enforce compliance with our Terms and Conditions;
to send you promotional offers and information about our products and services, and those of our selected partners, subject to your marketing preferences and consent where required by applicable law;
to conduct research and analysis to improve and develop our services;
to implement responsible gaming measures, including monitoring player behaviour for indicators of problem gambling and applying appropriate interventions;
to meet our business and operational requirements, including maintaining records, conducting audits, and reporting to relevant regulatory authorities.

Occasionally, we may request your input through surveys or contests. Participation in these surveys or contests is entirely voluntary. By accepting any prize or winnings from us, you agree to the use of your name for advertising and promotional purposes without additional compensation, unless prohibited by law. Unless you have opted out of receiving promotional materials, we may also use your Personal Information (including email address and phone number) to send you information about our products, services, and promotions, including other gaming options and carefully selected third-party products and services.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your Personal Information to the following categories of recipients:

Regulatory Authorities: We may disclose your Personal Information to AOFA, ALSI, and any other competent regulatory, governmental, or law enforcement authority, where required by law, regulation, or pursuant to a lawful request;
Legal Compliance: We may disclose your Personal Information if required by law or if we believe, in good faith, that such action is necessary to: (1) comply with any legal process served on us, any of our websites, or the services, or in circumstances where we are under a similar legal obligation; (2) protect and defend our rights or property; or (3) ensure the safety of our users or the public;
Financial Institutions: We may share your Personal Information with banks, payment service providers, and credit card companies for the purpose of processing transactions and preventing fraud;
Service Providers: We may share your Personal Information with third-party service providers who process data on our behalf, subject to appropriate Data Processing Agreements;
Fraud and Integrity: If we determine, at our sole discretion, that you have cheated or attempted to defraud us, the company, or any other user of the services, including but not limited to manipulating games, engaging in collusion, or committing payment fraud, or if we suspect fraudulent payment activities (including the use of stolen credit cards or any other fraudulent actions, including chargebacks), we reserve the right to share this information (along with your identity) with other online gaming platforms, banks, credit card companies, relevant agencies, and law enforcement authorities;
AML/CFT Reporting: Where we identify suspicious transactions or activities, we may be required to file Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with the relevant financial intelligence unit, without notifying you, in accordance with the Money Laundering Prevention Act 008 of 2005 and any applicable regulations;
(g) Responsible Gaming: For research purposes related to addiction prevention, anonymised and aggregated data may be shared with appropriate institutions and research bodies;
Corporate Restructuring: In the event of a merger, acquisition, or sale of all or substantially all of our assets, your Personal Information may be transferred to the successor entity, provided that the successor agrees to be bound by obligations no less protective than those set forth in this Privacy Policy.

We will not sell, rent, or trade your Personal Information to third parties for their own marketing purposes without your explicit consent.

DATA RETENTION

We retain your Personal Information only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The specific retention periods are determined based on the following criteria:

Active Accounts: For the duration of your account relationship with us, and for a minimum period of five (5) years following account closure, in accordance with anti-money laundering record-keeping obligations under the Money Laundering Prevention Act 008 of 2005 and the requirements of AOFA and ALSI;
Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, or longer if required by applicable law;
KYC and AML Records: Identity verification documents and due diligence records are retained for a minimum of five (5) years after the termination of the business relationship, in accordance with applicable anti-money laundering legislation;
Responsible Gaming Records: Self-exclusion records and responsible gaming intervention records are retained for the duration of the self-exclusion period and for a minimum of five (5) years thereafter;
Regulatory and Legal Requirements: Where we are required by law, regulation, court order, or regulatory directive to retain information for a longer period, we will do so in accordance with such requirements;
Marketing and Communication Records: Records of your marketing preferences and opt-out requests are retained for as long as necessary to honour your preferences.

Upon expiry of the applicable retention period, your Personal Information will be securely deleted or anonymised in accordance with our data destruction procedures.

YOUR RIGHTS (DATA SUBJECT RIGHTS)

Subject to applicable law and regulation, you have the following rights in relation to your Personal Information:

Right of Access: You have the right to request confirmation as to whether we process your Personal Information and, if so, to obtain a copy of such data, together with information about the purposes of processing, the categories of data concerned, and the recipients or categories of recipients to whom the data has been disclosed (GDPR Article 15);
Right to Rectification: You have the right to request the correction of inaccurate Personal Information and the completion of incomplete Personal Information held about you (GDPR Article 16);
Right to Erasure: You have the right to request the deletion of your Personal Information where: (i) it is no longer necessary for the purposes for which it was collected; (ii) you withdraw your consent and there is no other lawful basis for processing; (iii) you object to processing and there are no overriding legitimate grounds; or (iv) the data has been unlawfully processed. Please note that this right is subject to legal and regulatory obligations, including anti-money laundering record-keeping requirements, which may require us to retain certain data for specified periods (GDPR Article 17);
Right to Restriction of Processing: You have the right to request the restriction of processing of your Personal Information in certain circumstances, including where you contest the accuracy of the data or where you have objected to processing pending verification of our legitimate grounds (GDPR Article 18);
Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format, and to transmit such data to another controller without hindrance, where technically feasible and where processing is based on consent or contractual necessity and carried out by automated means (GDPR Article 20);
Right to Object: You have the right to object to the processing of your Personal Information where processing is based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims (GDPR Article 21);
Right Not to be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such decision is: (i) necessary for the performance of a contract between you and us; (ii) authorised by applicable law; or (iii) based on your explicit consent (GDPR Article 22);
Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw such consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal;

(i) Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the EU/EEA Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of your Personal Information infringes applicable data protection legislation (GDPR Article 77).

To exercise any of the above rights, please contact us using the details provided in Section 18 of this Privacy Policy. We will respond to your request within thirty (30) days of receipt, or such longer period as may be permitted by applicable law. We may request proof of identification before processing your request to ensure the security of your personal data.

You may also opt out of receiving promotional communications at any time by adjusting your account settings on our website, by following the unsubscribe instructions in any email you receive from us, or by contacting us directly.

COOKIES AND SIMILAR TECHNOLOGIES

Information Stored on Your Device

When you access our services, we may store information on your device. This information is known as cookies — small text files saved on your device when you visit online pages that record your preferences and activities. We also utilise Local Shared Objects or "flash cookies." Flash cookies serve a similar purpose to browser cookies, allowing us to remember aspects of your visits across our sites. Neither cookies nor flash cookies can access or use other information on your computer. We use these technologies to monitor your engagement with our services, track site traffic, enhance our services, and tailor them for your convenience and relevance.

We use the following categories of cookies:

Essential Cookies: These cookies are strictly necessary for the operation of our website and the provision of our services. They enable core functionality such as account access, secure areas, and the processing of financial transactions. Without these cookies, our websites would not function efficiently. These cookies do not require your consent as they are necessary for the provision of the service you have requested.
Registration Cookies: These cookies retain information gathered during your registration, enabling us to recognise you as a customer and deliver the appropriate services. We may also use this data to gain insights into your online interests and enhance your experience on our platforms.
Functional Cookies: These cookies enable the website to provide enhanced functionality and personalisation, such as remembering your language preferences and display settings.
Session Cookies: These are temporary cookies assigned to your computer for the duration of your visit. They facilitate navigation on our website and, if you are a registered customer, provide information tailored to you. These cookies expire automatically when you close your browser.
Persistent Cookies: These cookies remain on your computer for a set duration after the browser is closed. Flash cookies also fall under this category.
Analytical Cookies: These allow us to identify and count the number of visitors to our site and understand how they use our services. This information helps us enhance the functionality of our sites, ensuring that you can easily find what you need.

Cookie Consent and Management

You have the option to accept or decline non-essential cookies. Most web browsers are set to accept cookies automatically, but you can typically modify your browser settings to refuse cookies. The Help menu on most browsers will guide you on how to prevent your browser from accepting new cookies, how to be notified when you receive a new cookie, and how to disable cookies entirely. Please note that if you disable essential cookies, certain features of our website may not function correctly.

For more detailed information about the specific cookies we use and their purposes, please refer to our Cookie Policy, which is available on our website.

CONSENT TO USE OF ELECTRONIC SERVICE PROVIDERS

To participate in real money gaming on our platform, you must send and receive funds through us. We may utilise third-party electronic payment systems and payment service providers for processing these financial transactions. By agreeing to this Privacy Policy, you give your explicit consent for the collection and processing of Personal Information necessary for transaction processing, which may include the transfer of information to payment processors located outside your country of residence.

We ensure that our agreements with payment service providers include appropriate contractual and technical safeguards for the protection of your Personal Information, including compliance with the Payment Card Industry Data Security Standard (PCI-DSS) where applicable. All payment processors engaged by us are required to process your Personal Information only in accordance with our instructions and in compliance with applicable data protection legislation.

CONSENT TO SECURITY REVIEW

We reserve the right to conduct security reviews at any time to verify the registration details you provided and to ensure your use of our services and financial transactions comply with our Terms and Conditions, the Computer Gaming Licensing Act 007 of 2005, the Money Laundering Prevention Act 008 of 2005, and all other applicable laws and regulations. By using our services and accepting our Terms and Conditions, you authorise us to use and disclose your Personal Information to third parties for verification and due diligence purposes, including, if necessary, the transfer of your information outside your country of residence.

Security reviews may involve ordering a credit report, verifying your identity against third-party databases, conducting enhanced due diligence checks, and screening against politically exposed persons (PEP) lists and international sanctions lists. You agree to provide any requested information or documentation to facilitate these security reviews. Failure to comply with such requests may result in the restriction or termination of your account in accordance with our Terms and Conditions.

SECURITY

We recognise the critical importance of securing your Personal Information and have implemented appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, loss, or destruction.

These security measures include, but are not limited to:

Encryption: All Personal Information transmitted between your device and our servers is encrypted using Transport Layer Security (TLS) 1.2 or higher with industry-standard encryption protocols;
Secure Storage: All Personal Information is stored in encrypted and password-protected databases within secure network environments protected by advanced firewall technology and intrusion detection systems;
Access Controls: Access to Personal Information is restricted to authorised personnel on a need-to-know basis, and all staff members are bound by confidentiality obligations;
Data Replication: In compliance with ALSI licensing conditions, player data is replicated on ALSI-approved servers to ensure data integrity and availability;
Regular Testing: We conduct regular security assessments, penetration testing, and vulnerability scanning to identify and address potential security risks;
Third-Party Security: We require our subsidiaries, agents, affiliates, and suppliers to implement appropriate security measures consistent with our own standards.

Notwithstanding the above, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and in any event within seventy-two (72) hours of becoming aware of the breach, as required by applicable data protection legislation (GDPR Article 33 and Article 34).

PROTECTION OF MINORS

Our services are not intended for, and must not be used by, individuals under eighteen (18) years of age (or the legal age of majority in their jurisdiction, whichever is higher). By providing information to us and using our services, users confirm that they are at least eighteen (18) years old (or of the legal age of majority in their jurisdiction).

We actively employ measures to detect and prevent any attempts by minors to access our services, including age verification checks during the registration and KYC processes. Where we have reasonable grounds to suspect that a user is a minor, we will initiate a security review and may suspend the account pending verification.

If we learn that a minor has provided personal information through our services, we will not accept such information and will take immediate steps to delete it from our records, close the associated account, and return any deposited funds to the rightful source, minus any winnings obtained in contravention of our Terms and Conditions. Any such instances may be reported to the relevant regulatory authorities.

INTERNATIONAL TRANSFERS

Personal Information collected through our services may be stored and processed in any country where we, or our affiliates, suppliers, service providers, or agents maintain operations, including but not limited to the Autonomous Island of Anjouan (Union of the Comoros), the European Union/European Economic Area, and other jurisdictions.

By using our services, you acknowledge and consent to the transfer of your Personal Information outside your country of residence, including to countries that may not provide the same level of data protection as your home jurisdiction. Where we transfer Personal Information outside the European Economic Area, we ensure that appropriate safeguards are in place, including:

transfers to countries that have been deemed to provide an adequate level of data protection by the European Commission;
the use of Standard Contractual Clauses approved by the European Commission (pursuant to Article 46(2)(c) of the GDPR);
binding corporate rules; or
other legally recognised transfer mechanisms.

We take all reasonable measures to ensure that our agents, affiliates, and suppliers adhere to data protection standards that are consistent with or equivalent to those set forth in this Privacy Policy, regardless of their location.

PROFILING AND AUTOMATED DECISION-MAKING

We may use automated systems and profiling techniques for the following purposes:

Fraud Detection and Prevention: Automated analysis of transaction patterns, login behaviour, and device information to identify and prevent fraudulent activity;
AML/CFT Compliance: Automated transaction monitoring and screening against sanctions and PEP lists, as required under the Money Laundering Prevention Act 008 of 2005 and regulatory requirements imposed by AOFA and ALSI;
Responsible Gaming: Automated monitoring of gameplay patterns to identify potential indicators of problem gambling, enabling timely intervention and player protection measures;
Risk Assessment: Automated risk scoring for the purposes of KYC/CDD and enhanced due diligence.

Where any automated decision produces legal effects concerning you or similarly significantly affects you, you have the right to request human intervention, to express your point of view, and to contest the decision. For further information on your rights in relation to automated decision-making, please refer to Section 8(g) of this Privacy Policy.

THIRD-PARTY PRACTICES

We cannot guarantee the protection of any information you provide to third-party websites that may be linked to or from our services, or any information collected by third parties managing our affiliate programmes (if applicable). Such third-party websites operate independently and have their own privacy policies and data protection practices. We are not responsible for the content, security, or privacy practices of any third-party website.

Any Personal Information collected by these third parties is governed by their respective privacy policies. We strongly encourage you to review the privacy policies of any third-party website before providing your Personal Information to them. Our inclusion of a link to a third-party website does not constitute an endorsement of that website's privacy or data protection practices.

LEGAL DISCLAIMER

Our services are provided on an "AS-IS" and "AS-AVAILABLE" basis. While we implement robust security measures and privacy practices as described in this Privacy Policy, given the inherent nature of internet-based services and the complex and evolving technological landscape, we cannot guarantee completely error-free performance regarding the privacy of your Personal Information.

To the maximum extent permitted by applicable law, we shall not be liable for any indirect, incidental, consequential, or punitive damages arising from the unauthorised access to, or use or disclosure of, your Personal Information as a result of events beyond our reasonable control.

Nothing in this clause shall limit or exclude our liability for any matter in respect of which it would be unlawful for us to limit or exclude our liability, including liability for fraud or for personal injury or death caused by our negligence.

CONTACT INFORMATION AND DATA PROTECTION

If you have any questions, concerns, or requests regarding this Privacy Policy, the processing of your Personal Information, or wish to exercise any of your data subject rights as set out in Section 8 above, you may contact us by the following means: [email protected]

We are committed to resolving any complaints about our collection or use of your Personal Information. If you wish to make a complaint, please contact us using the details above, and we will endeavour to resolve the matter promptly and in accordance with applicable law.

If you are not satisfied with our response, you have the right to lodge a complaint with the competent supervisory authority in your jurisdiction, as set out in Section 8(i) of this Privacy Policy.

CONSENT TO PRIVACY POLICY

Your use of our services constitutes your acknowledgement and agreement to this Privacy Policy, which represents the entirety of our privacy practices and supersedes any prior versions. This Privacy Policy should be read in conjunction with our Terms and Conditions, our Cookie Policy, our Responsible Gaming Policy, and any additional applicable terms available on our platforms.

We may update this Privacy Policy from time to time and will inform you of any material changes by posting the revised version on our platforms and, where appropriate, by notifying you directly. Your continued use of our services after any such changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

In accordance with Article 77 of the GDPR, you have the right to lodge a complaint regarding the processing of your personal data with a supervisory authority, particularly in the EU/EEA Member State of your habitual residence, place of work, or the place where you believe an infringement of data protection law has occurred.

OTHER WEBSITES

Our website may contain links to external websites that we do not control and which are not governed by this Privacy Policy. If you access other sites via these links, the operators of those sites may collect information from you, which will be used in accordance with their own privacy policies, which may differ from ours. We are not responsible for the content, functionality, or privacy practices of linked sites, and the operators of those sites bear sole responsibility for their own data processing activities.

We strongly recommend that you review the privacy policy of every website you visit before providing any Personal Information.

GOVERNING LAW AND JURISDICTION

This Privacy Policy, and any dispute or claim arising out of or in connection with it (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the Autonomous Island of Anjouan, Union of the Comoros, and the Computer Gaming Licensing Act 007 of 2005.

To the extent that the GDPR or any other data protection legislation of a relevant jurisdiction applies to the processing of your Personal Information, such legislation shall apply in addition to and, where there is a conflict, shall take precedence over this clause in respect of the relevant data processing activities.

Any disputes arising under this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts of the Autonomous Island of Anjouan, save where mandatory provisions of applicable data protection law require otherwise.