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Privacy policy

Privacy Policy

Privacy Policy
June 21, 2022

A. GENERAL INFORMATION
B. INQUIRIES AND DATA PROTECTION OFFICER
C. HOW MEGAPIXEL ENTERTAINMENT LIMITED PROCESSES PERSONAL DATA
D. DATA SECURITY
E. PLAYERS' RIGHTS REGARDING THEIR PERSONAL DATA
F. INQUIRIES
G. CHANGES TO THIS PRIVACY POLICY

A. GENERAL

Megapixel Entertainment Limited (together with other companies within the group), 122 Andrea Debono Street, Naxxar NXR4030, Malta, as the data controller responsible for the collection and processing of personal data on its website www.wunderino.de, is committed to strictly protecting players' personal data in accordance with applicable legal obligations, including the EU General Data Protection Regulation [Regulation (EU) 2016/679] as well as national Maltese and German data protection laws. This Privacy Policy describes how Megapixel Entertainment Limited processes personal data and informs players of their rights in this regard.

Personal data is any information relating to an identified or identifiable natural person.

Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, or any other form of disclosure, as well as the alignment or combination, restriction, erasure, or destruction.

Megapixel Entertainment Limited processes personal data only if the player has consented to such processing, if the processing is necessary for the provision of the services offered, the processing is carried out to comply with legal requirements applicable to Megapixel Entertainment Limited or with requirements arising from Megapixel Entertainment Ltd.'s license to operate virtual slot machine games in Germany, or the processing is necessary to pursue the legitimate interests of Megapixel Entertainment Limited, third parties, or the public, as defined in , provided that such legitimate interests are not overridden by the fundamental rights of the respective player in the individual case.

By accepting this Privacy Policy, the player agrees that Megapixel Entertainment Ltd. may collect and process their personal data as described in this Privacy Policy.

B. INQUIRIES AND DATA PROTECTION OFFICER

If you have any questions regarding data protection, inquiries, and/or would like further information about data processing by Megapixel Entertainment Limited, please contact the Data Protection Officer at:

Megapixel Entertainment Limited
DPO
122 Andrea Debono Street, Naxxar NXR4030, Malta
[email protected]

C. HOW MEGAPIXEL ENTERTAINMENT LIMITED PROCESSES PERSONAL DATA

1. Principles Governing Data Processing
Megapixel Entertainment Limited processes personal data exclusively in accordance with the principles set forth in Article 5(1)(a) through (f) of the EU General Data Protection Regulation ("GDPR"). These are:

a. Lawfulness, fairness, and transparency: Personal data is processed only lawfully, fairly, and in a manner that is transparent to the data subject;
b. Purpose limitation: Personal data is collected only for specified, explicit, and legitimate purposes and may not be further processed in a manner incompatible with those purposes;
c. Data minimization: Personal data is processed only to the extent that is appropriate and relevant to the purpose, and processing is limited to what is necessary for the purposes of the processing;
d. Accuracy: Personal data shall be processed only in a factually accurate manner and, where necessary, kept up to date;
e. Storage limitation: Personal data shall be stored only in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and
f. Integrity and confidentiality: Personal data is processed only in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, accidental destruction, or accidental damage, through appropriate technical and organizational measures.

2. Collection and Processing of Data on the Website and in Connection with Megapixel Entertainment Limited's Gaming Services
a. When visiting the website
While visiting the websites of Megapixel Entertainment Limited, the system automatically collects information generated by visitors' browsers and temporarily stores it in log files. This may include, but is not limited to:
• the IP address,
• the date and time of access/timestamp,
• the operating system
• the browser used by the visitor.

  • The Internet service provider (ISP),
  • The exit pages,
  • The platform type, and
  • the number of clicks,

to ensure a secure connection to the Megapixel Entertainment Ltd. website, analyze trends for website management, track visits to a specific website, monitor player activity on the website, and collect comprehensive demographic information. The log files may contain IP addresses that make it possible to identify a specific player or that, at the very least, make the player indirectly identifiable with the help of additional information. IP addresses may relate to the provision of web-based services involving personal data.
Processing is based on our legitimate interests pursuant to Article 6(1)(f) of the GDPR. These legitimate interests for this data collection are:
• to ensure a stable and secure connection to the website;

  • to personalize and optimize the services offered by Megapixel Entertainment Limited;
  • to detect misuse of the websites operated and/or the services provided by Megapixel Entertainment Limited;
  • to identify and resolve malfunctions on the websites of Megapixel Entertainment Limited.

b. Upon registration on the websites of Megapixel Entertainment Limited
Megapixel Entertainment Limited is legally required to collect the following personal data from players upon registration.

• All first and last names,
• Maiden name

• Gender,
• Full address/place of residence,
• Date of birth,

Place of birth
• Nationality,
• Email address, and

phone number.

This data collection and processing is legally required under the German Money Laundering Act ("GwG") and pursuant to Section 6a(2) of the State Treaty on Gaming ("GlüStV") 2021. The legal basis for data processing is therefore Article 6(1)(c) of the GDPR.

Megapixel Entertainment Ltd. reserves the right to modify the above data collection as necessary, in particular, but not limited to, in the event of changes in the law or due to relevant case law. In such cases, Megapixel Entertainment Ltd. will update this Privacy Policy accordingly.

Megapixel Entertainment Ltd. is required to verify, when registering players, whether the player is a Politically Exposed Person ("PEP"), a family member of a PEP, or a person known to be closely associated with a PEP (Section 10 of the Anti-Money Laundering Act) and, for this purpose, conducts a comparison with lists containing PEPs. Furthermore, Megapixel Entertainment Ltd. is legally required to cross-reference its data against sanctions lists containing individuals subject to financial sanctions (Section 10 of the Anti-Money Laundering Act). The legal basis for this data processing is, in turn, Article 6(1)(c) of the GDPR, due to the legal obligation to do so. This also corresponds to the legitimate interests of Megapixel Entertainment Ltd. Our legitimate interests for this processing are:
• the personalization and optimization of the services offered by Megapixel Entertainment Limited,
• detecting misuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
• the fulfillment of contractual agreements and/or legal obligations.

For the purposes of PEP list screening and sanctions list screening, Megapixel Entertainment Ltd. uses the service provider EezyComply. EezyComply acts as a data processor for Megapixel Entertainment Ltd., processing players' personal data exclusively on the instructions of Megapixel Entertainment Ltd. To this end, Megapixel Entertainment Ltd. has entered into a data processing agreement with the service provider.

In addition, Megapixel Entertainment Ltd. is legally obligated under Sections 11 and 12 of the Anti-Money Laundering Act (GwG) and Section 6b(4) of the State Treaty on Gaming (GlüStV) 2021 to verify the personal data listed above , that is, to verify that this data is indeed accurate. For this purpose, Megapixel Entertainment Ltd. uses external service providers to whom it transfers the personal data for verification purposes. These include, in particular, the following service providers:

  • SCHUFA
  • Klarna Bank AB (for "Sign in with Klarna")
  • Advanced Living Technologies GmbH (SONIO: document upload and video verification via selfie with liveness detection)
  • Insinc (1-cent transfer with TAN, and, if necessary, video verification via selfie with liveness detection)

These service providers act as data processors on behalf of Megapixel Entertainment Ltd., processing personal data exclusively in accordance with Megapixel Entertainment Ltd.'s instructions for the purpose of data verification. A data processing agreement is in place with these service providers for this purpose.

Players may be required to submit additional documents for the purpose of identity verification and/or other regulatory checks.

Identity verification must be repeated at least once a year and whenever a player's personal data changes.

The legal basis for the legally required data processing described above is Article 6(1)(c) of the GDPR.

The player is obligated to keep their personal data up to date at all times.

This processing also serves our legitimate interests (Article 6(1), first sentence, subparagraph (f) of the GDPR).
Our legitimate interests in this processing are:
• the personalization and optimization of the services offered by Megapixel Entertainment Limited,
• detecting misuse of the websites operated and/or the services provided by Megapixel Entertainment Limited, and
• compliance with legal obligations. Furthermore, Megapixel Entertainment Ltd. collects the player's IP address upon registration and each subsequent login to the player account to ensure a secure and stable connection to the Megapixel Entertainment website and to guarantee the proper functioning of the services offered there. This data processing is based on the legitimate interests of Megapixel Entertainment Ltd. within the meaning of Article 6(1)(f) of the GDPR. The legitimate interests of Megapixel Entertainment Ltd. in collecting and processing the IP address during registration and each subsequent login to the player account are:

  • Ensuring a secure and stable connection to the Megapixel Entertainment Ltd. website and guaranteeing the proper functioning of the services offered there.
  • Detecting misuse of the websites operated and/or the services provided by Megapixel Entertainment Limited,
  • to identify and resolve malfunctions on the Megapixel Entertainment Limited website;
  • To personalize and optimize the services offered by Megapixel Entertainment Limited at and ,

c. Data processing for the purpose of processing payment transactions
To use the services of Megapixel Entertainment Limited, it is necessary to conduct transactions on the website, specifically deposits into the player's account and placing bets from that account to participate in games. Any winnings are credited to the player's account. Players may also withdraw funds from their player accounts at any time. Depending on the payment method selected by the player and, where applicable, other criteria, the personal data required for this purpose may vary, but typically includes:

  • Your player ID;
  • Your full name;
  • Bank account details (IBAN and BIC) or payment account number or payment account ID or payment card number;
  • The payment service provider/e-money institution/bank/payment card type (MasterCard/Visa);
  • The time and date of the transaction;
  • The transaction amount;
  • The transaction status (successful/unsuccessful);
  • The transaction type (deposit, wager, winnings, bonus, withdrawal) and
  • The resulting balance in the player's account .

This data is transmitted to third-party payment service providers-namely, banks, payment service providers, e-money institutions, and payment card processors-to the extent necessary for processing payment transactions. The banks/payment service providers/e-money institutions/payment card processors act as independent data controllers who process the data on their own responsibility to provide their payment services. Corresponding service agreements regarding the provision of payment services are in place with the payment service providers/e-money institutions/payment card processors.

This processing of your personal data for payment processing purposes is based on a corresponding legal obligation (Art. 6c(1), sentence 1, lit. c) of the GDPR-the prohibition on credit under § 4(5), No. 2 of the GlüStV 2021, crediting of deposits to the player's account immediately upon receipt of payment, withdrawal of funds immediately upon request for withdrawal (Section 6b(2) of the GlüStV 2021), etc. Furthermore, this processing of payment data is based on the contract concluded with you (the terms of which you can view in the General Terms and Conditions), Article 6(1), sentence 1, letter b) of the GDPR, and also aligns with our legitimate interests (Article 6(1), sentence 1, letter f) of the GDPR).

Our legitimate interests in this processing are:
• the personalization and optimization of the services offered by Megapixel Entertainment Limited,
• detecting money laundering and/or misuse of the website we operate and/or the services provided there by Megapixel Entertainment Limited,
• the fulfillment of contractual agreements and/or legal obligations.

In addition, Megapixel Entertainment Ltd. is legally required to verify players' account information. Deposits to and withdrawals from a player account may only be made from or to a bank or payment account held in the player's name at a credit institution, e-money institution, or payment institution based in the EU or the EEA (§ 16(4), (7) GwG, § 6b(4) GlüStV 2021). Megapixel Entertainment Ltd. performs this account data verification using the transaction data from the transfers or with the assistance of the e-money institutions/payment service providers. In this account verification process, the e-money institutions/payment service providers act as data processors for Megapixel Entertainment Ltd., processing the data exclusively on the instructions of Megapixel Entertainment Ltd. A data processing agreement is in place with the service providers for this purpose.

The legal basis for the account/card data verification described above is Article 6(1)(c) of the GDPR, based on the legal obligation to do so. Furthermore, this verification is in accordance with our legitimate interests (Article 6(1)(f) of the GDPR).

Our legitimate interests in this processing are:
• the detection of money laundering and/or misuse of the website we operate and/or the services provided by Megapixel Entertainment Limited,
• the fulfillment of contractual agreements and/or legal obligations,

d. Data Processing for the Purpose of Providing Services

(1) For the purpose of OASIS verification

Megapixel Entertainment Ltd. is legally obligated to exclude players listed in the nationwide OASIS player exclusion database-which is centrally managed by the Darmstadt Regional Council-from participating in games (Section 8(3) GlüStV 2021). To this end, immediately prior to activation in the central LUGAS activity file (see below), it must perform a cross-check with OASIS by submitting a query via the OASIS Status API. For the purpose of this cross-check with OASIS via the OASIS Status API, Megapixel Entertainment Ltd. transmits the following personal data to OASIS:

  • The player's full name
  • The player's address
  • The player's date of birth

After the comparison, OASIS notifies Megapixel Entertainment Ltd. whether the player in question is listed in the suspension file-i.e., suspended-or not.

The legal basis for this data processing is Article 6(1)(c) of the GDPR, based on the legal obligation to do so.

Furthermore, Megapixel Entertainment Ltd. is obligated, at the player's request, to enter a permanent self-exclusion in OASIS, or, if it knows-based on the observations of its staff or reports from third parties-or must assume based on other factual evidence that the player is at risk of gambling addiction, is heavily in debt, is failing to meet their financial obligations, or is placing wagers that are disproportionate to their income or assets, to enter a permanent third-party exclusion in OASIS (Section 8a GlüStV 2021). For the purpose of entering a self-exclusion or third-party exclusion, Megapixel Entertainment Ltd. enters the following personal data into the exclusion file in accordance with § 23 GlüStV 2021:

  • Last names, first names, birth names,
  • alias names, false names used,
  • date of birth,
  • place of birth,
  • address,
  • Photographs
  • Reason for the suspension,
  • Duration of the suspension, and
  • Reporting suspension.

Megapixel Entertainment Ltd. also enters a temporary self-block lasting 24 hours into OASIS after the panic button is used-and, for this purpose, transmits the above data to OASIS to record a 24-hour temporary block in OASIS.

Due to the legal obligation to do so, Article 6(1)(c) of the GDPR also serves as the legal basis for data processing for the purpose of entering a suspension in OASIS.

(2) For LUGAS

Megapixel Entertainment Ltd. is legally obligated to ensure that players, upon registration, either set a new, cross-provider monthly deposit limit or specify that an existing cross-provider monthly deposit limit should be maintained. To this end, Megapixel Entertainment Ltd. must also register every newly registered player in the LUGAS central files (limit and activity file, which are jointly maintained by the competent gambling regulatory authority-the Joint Gambling Authority of the German States, "GGL"). For the purpose of this registration in LUGAS, Megapixel Entertainment Ltd. transmits the following personal data to LUGAS:

  • Last name, first name, birth name
  • Date of birth,
  • Place of birth,
  • Address,
  • Player ID
  • Amount of the maximum monthly cross-provider deposit limit set by the player
  • Date the limit was set

After the above data transfer, LUGAS pseudonymizes the player's name, date of birth, place of birth, and address (but not the player ID). However, the player remains identifiable to LUGAS via the player ID.

Before each deposit, Megapixel Entertainment Ltd. transmits the following personal data to the LUGAS limit file :

  • Last name, first name, maiden name
  • Date of birth,
  • place of birth,
  • Address,
  • Player ID
  • Amount and date of intended deposits

The LUGAS limit file reports back to Megapixel Entertainment Ltd. whether the cross-provider deposit limit for the relevant calendar month has already been exhausted and whether the intended deposit would exceed it. If the cross-provider deposit limit for the relevant calendar month has already been exhausted, Megapixel Entertainment Ltd. must reject the deposit. If the cross-provider monthly deposit limit has not yet been exhausted and would not be exceeded by the intended deposit, the intended deposit is stored in the limit file as a completed deposit. In this case, Megapixel Entertainment Ltd. may authorize the intended deposit in full. If the cross-provider deposit limit has not yet been exhausted prior to the intended deposit, but would be exceeded by the intended deposit, the limit file will additionally transmit to Megapixel Entertainment Ltd. the amount of the cross-provider deposit limit that has not yet been exhausted. Megapixel Entertainment Ltd. may then inform the player of this remaining unused monthly cross-provider deposit limit. The player may then initiate a new deposit transaction for this amount. (See § 6c GlüStV 2021).

The legal basis for this data processing by Megapixel Entertainment Ltd. is Article 6(1)(c) of the GDPR, based on the company's statutory obligation to do so. In addition, Megapixel Entertainment Ltd. is subject to civil law duties of care toward players (see § 242 BGB), which is why registration in LUGAS and the execution of queries to the LUGAS limit file are also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1)(b) of the GDPR as a legal basis.

Megapixel Entertainment Ltd. holds a license to grant increased monthly cross-provider deposit limits. In order to grant such increased monthly cross-provider deposit limits, Megapixel Entertainment Ltd. is subject to strict regulatory requirements arising from its license. These requirements include conducting a review of the player's financial capacity to determine whether the player can afford the increased limit. To conduct this financial capacity assessment, Megapixel Entertainment Ltd. uses external service providers, specifically the SCHUFA-G-Check from SCHUFA Holding AG, which provides a credit report. Megapixel Entertainment Ltd. transmits the following personal data of the player to SCHUFA for the purpose of conducting the financial capacity assessment:

  • The name,
  • The date of birth, and
  • The address.

Alternatively, Megapixel Entertainment Ltd. uses the account review process provided by the service provider Semla to conduct the financial capacity assessment. For this purpose, the player is redirected to a page on the service provider's website where they can log in to their bank account. Before doing so, the player must agree to Semla's terms and conditions. Semla then reviews the player's bank details stored there and forwards an income and expense summary to Megapixel Entertainment Ltd.

The financial eligibility check must be repeated annually.

The two service providers act as data processors for Megapixel Entertainment Ltd. in conducting the financial eligibility check. Megapixel Entertainment Ltd. maintains a data processing agreement with these service providers for this purpose.

The legal basis for data processing for the purpose of conducting the financial eligibility check is Article 6(1)(c) of the GDPR, due to the regulatory obligation to do so. In addition, Megapixel Entertainment Ltd. also has civil law duties of care toward players (see § 242 BGB), which is why conducting the financial capacity assessment is also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), first sentence, letter b) of the GDPR as a legal basis.

Furthermore, the license authorizing increased monthly cross-provider deposit limits also obligates Megapixel Entertainment Ltd. to conduct enhanced monitoring of players with such increased limits. The license specifies various monitoring criteria for this purpose. Megapixel Entertainment Ltd. is required to submit - anonymized - reports on the enhanced monitoring to the GGL every six months (which, due to anonymization, do not contain any personal data). However, Megapixel Entertainment Ltd. must report specific players to LUGAS in cases where the conditions for granting an increased monthly cross-provider deposit limit no longer apply (the player can no longer afford the increased limit, the player is at risk of gambling addiction, or the player's account is closed), so that LUGAS can decide on the setting of the new cross-provider monthly deposit limit.

The legal basis for data processing for the purpose of conducting enhanced monitoring and reporting to LUGAS is Article 6(1)(c) of the GDPR, due to the regulatory obligation to do so. In addition, Megapixel Entertainment Ltd. also has civil law duties of care toward players (see § 242 BGB), which is why the implementation of enhanced monitoring and reporting to LUGAS is also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), sentence 1, subparagraph (b) of the GDPR as a legal basis.

Due to our authorization to offer higher betting limits, we are also required to subject players with a betting limit exceeding EUR 3.00 to special limit monitoring. This monitoring serves to detect at-risk behavior and gambling addiction at an early stage, to ensure player protection, and to comply with the regulatory requirements of the 2021 State Treaty on Gambling (Sections 1, 6i, and 22a of the 2021 State Treaty on Gambling).

For this purpose, in addition to the data described in Section C. (4)-in particular information regarding

  • previous or third-party exclusions, including use of the 24-hour short-term exclusion (panic button),
  • The frequency, amount, and timing of deposits and wagers, including the exhaustion of the individual deposit limit within short periods of time,
  • Unusual patterns in the payment methods used (e.g., use of multiple credit cards, various payment methods, failed deposits),
  • Number and duration of gaming sessions, particularly nighttime sessions and very long continuous gaming periods.

The legal basis for this processing is Article 6(1)(c) of the GDPR (fulfillment of our legal and regulatory obligations under the GlüStV 2021 and the corresponding licensing decisions) and, supplementarily, Article 6(1)(f) of the GDPR. Our legitimate interest lies in the prevention of addiction, the protection of players from health and financial harm, and ensuring the proper conduct of gambling in accordance with the objectives of Section 1 of the GlüStV 2021."

If a player meets a certain number of these criteria within a 90-day observation period, they are classified as at risk of gambling addiction. In such cases, we are obligated to consider special protective measures and to inform the GGL on a quarterly basis about the affected players and the measures taken.

To the extent that this monitoring involves assessing, based on the player's and transaction behavior, whether there are indications of a gambling addiction or a risk of gambling addiction, the processing of this particularly sensitive information is additionally based on Article 9(2)(g) of the GDPR in conjunction with the legally mandated and addiction prevention obligations under the 2021 State Treaty on Gaming, as well as the relevant decisions issued by the gaming authorities. This processing is then carried out exclusively for the purpose of player protection and to fulfill our regulatory obligations.

In addition, Megapixel Entertainment Ltd. is legally required to query the activity file before it may permit participation in games; see Section 6h of the 2021 State Treaty on Gambling (GlüStV 2021). It may only permit participation in games if it has previously transmitted the following personal data and the information that the player is to be activated to the activity file, and the activity file has not immediately returned confirmation that the player is already active in the activity file:

  • Last name, first name, birth name
  • Date of birth
  • Place of birth,
  • Address

If the player is already active in the activity file, Megapixel Entertainment Ltd. must deny participation in the game. If the player is not yet active in the activity file, the activity file will note, based on the notification from Megapixel Entertainment Ltd., that the player is now active.

Megapixel Entertainment Ltd. grants players the option at any time to terminate their participation in the game and have their status changed to inactive in the activity file. When a player logs out of their account, an inactivity notification is automatically sent to the activity file (using the same personal data as for activation). The same applies if more than 30 minutes have passed since the player's last interaction on the website (any activity on the website, not necessarily participation in the game).

After a player has been marked as inactive in the activity file, Megapixel Entertainment Ltd. must have the player reactivated in the LUGAS activity file before the player can participate in gaming again.

Due to the legal obligation to carry out the data processing described above (see § 6h GlüStV 2021), the legal basis for this is again Art. 6(1), sentence 1, lit. c) of the GDPR. In addition, Megapixel Entertainment Ltd. also has civil law duties of care toward the players (see § 242 BGB), which is why querying the activity file (to mark players as active or inactive) is also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), sentence 1, subparagraph (b) of the GDPR as a legal basis.

Megapixel Entertainment Ltd. is legally obligated to operate a secure server on which it accurately records all data necessary for the performance of gambling supervision, stores it in a digitally tamper-proof manner, and enables electronic monitoring at any time, including direct access by the GGL/LUGAS; see Section 6i(2) of the GlüStV 2021. The aforementioned registration of players in LUGAS also applies here. The legal basis for data processing for the purpose of operating the secure server and storing data on the secure server is Article 6(1), sentence 1, letter c) of the GDPR, due to the statutory obligation to do so. LUGAS retrieves the data stored on the secure server at least once a day via a crawler. In addition, Megapixel Entertainment Ltd. is subject to civil law duties of care toward the players (see § 242 BGB), which is why data processing for the purpose of operating the Safe Server and storing data on the Safe Server is also necessary for the proper performance of the gaming contracts . Megapixel Entertainment Ltd. may therefore also rely on Article 6(1)(b) of the GDPR as a legal basis.

(3) Game Developers

Megapixel Entertainment Ltd. does not develop the virtual slot games it offers itself, but rather licenses them from game providers, whose gaming platforms-featuring the virtual slot games they offer-Megapixel Entertainment Ltd. links to via an API for the purpose of offering these games on its website. Megapixel Entertainment currently offers virtual slot games from the following game providers on its website :

Apparat

Blueprint

BoomingGames

Edict Merkur

ELK Gaming

Evolution Gaming

Games Global

Greentube

Hell Games

No Limit City

Oryx Gaming Limited

Pariplay

PlaynGO

Playson

Playzia

Pragmatic

Push Gaming

Quickspin

RedRake

Relax Gaming

RGS Matrix

Skywind

Spinomenal

Swintt

Synot

Wazdan

Gamomat

Yggdrasil

Zeal

Megapixel Entertainment Ltd. transmits the following personal data to these game providers for the purpose of enabling participation in the games:

  • The player ID,
  • The player's balance in their gaming account
  • The IP address, and
  • The device from which the player participates in the games.

This data processing, which is carried out to enable participation in games, is based on the game participation agreements concluded with you. The legal basis for this is therefore Article 6(1)(b) of the GDPR.

(4) Monitoring for the Early Detection of Gambling Addiction

Megapixel Entertainment Ltd. is legally obligated to implement and use an automated system-based on scientific findings and algorithms-for the early detection of gambling addiction and players at risk of gambling addiction; see § 6i(1) GlüStV 2021. For the purpose of monitoring players to detect problematic gaming behavior at an early stage, Megapixel Entertainment Ltd. monitors and processes all player participation data derived from their transaction and gaming behavior, in particular the frequency, duration, and regularity of gaming participation, the times of gaming participation, the frequency and amount of deposits, the amount of wagers, etc. All transaction and gaming activities are recorded.

The legal basis for this data processing is Article 6(1)(c) of the GDPR, due to the statutory obligation to do so. In addition, Megapixel Entertainment Ltd. is subject to civil law obligations to protect players (see § 242 BGB), which is why the recording of transaction and gaming activities, as well as their monitoring for the early detection of gambling addiction, are also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), sentence 1, letter b) of the GDPR as a legal basis. Furthermore, , Megapixel Entertainment Ltd. has a legitimate interest in recording all transaction and gaming activities, as well as in monitoring them for the early detection of gambling addiction or a risk of gambling addiction within the meaning of Article 6(1), sentence 1, subparagraph (f) GDPR, in order to be able to address players with a gambling addiction or at risk of gambling addiction at an early stage, to take protective measures regarding their player accounts, and, if necessary, to exclude them from participating in games, as well as to enter a third-party block in OASIS if necessary; see above.

(5) Money Laundering Monitoring

Megapixel Entertainment Ltd. is legally obligated to continuously monitor players, including the transactions they carry out during their participation in games at Megapixel Entertainment Ltd. to ensure that these transactions correspond to the data stored by Megapixel Entertainment Ltd. regarding the player, their financial background, and the purpose of their participation in games, in order to detect money laundering or terrorist financing as early as possible; see § 10(1)(5) GwG. For the purpose of monitoring players to detect money laundering or terrorist financing at the earliest possible stage, Megapixel Entertainment Ltd. monitors and processes all transaction and gaming participation data of players, in particular deposits and withdrawals as well as gaming activities carried out.

The legal basis for this data processing is Article 6(1)(c) of the GDPR, due to the statutory obligation to do so. In addition, Megapixel Entertainment Ltd. also has civil law protection obligations toward all players, including those other than the specific player taking action (see § 242 BGB), to protect them from criminal and other fraudulent activities; therefore, monitoring for the prevention of money laundering, terrorist financing, and fraud is also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), first sentence, subparagraph (b) of the GDPR as a legal basis. Furthermore, Megapixel Entertainment Ltd. has a legitimate interest in conducting monitoring to prevent money laundering and terrorist financing within the meaning of Article 6(1), sentence 1, subparagraph (f) of the GDPR, in order to prevent the misuse of its gaming platform for financial crime and fraud.

(6) EDD

Megapixel Entertainment Ltd. is legally required to apply enhanced due diligence measures if it identifies an increased risk of money laundering and/or terrorist financing. Such an increased risk exists, in particular, if a player is a PEP, a family member of a PEP, or a person known to be closely associated with a PEP, as well as in the case of unusual transactions and transactions involving third countries with an increased risk of money laundering and/or terrorist financing; see § 15 GwG. The specific scope of the enhanced due diligence measures is at the discretion of Megapixel Entertainment Ltd. and depends on the specific increased risk identified. These may include, in particular but not limited to, the following personal data:

  • The player's basic information,
  • The player's financial background (occupation, income, assets, etc.)
  • Transaction and gaming behavior
  • etc.

For the purpose of carrying out the enhanced due diligence obligations, Megapixel Entertainment Ltd. is further entitled to request additional documents directly from players, which may contain information regarding the above points and, if necessary, additional personal data as well. The player is legally obligated to provide Megapixel Entertainment Ltd. with the requested documentation, and Megapixel Entertainment Ltd. is authorized under Section 11a(1) of the Anti-Money Laundering Act (GwG) to process personal data for the purposes of preventing money laundering and terrorist financing, to the extent necessary for these purposes.

The legal basis for this data processing, due to the statutory obligation, is Article 6(1)(c) of the GDPR. In addition, Megapixel Entertainment Ltd. also has civil law protection obligations toward all players, including those other than the specific player in question (see Section 242 of the German Civil Code (BGB)), to protect them from criminal and other fraudulent activities; therefore, the implementation of enhanced due diligence measures is also necessary for the proper execution of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), sentence 1, subparagraph (b) of the GDPR as a legal basis. Furthermore, Megapixel Entertainment Ltd. has a legitimate interest in implementing enhanced due diligence measures within the meaning of Article 6(1), sentence 1, subparagraph (f) of the GDPR to prevent the misuse of its gaming platform for financial crime and fraud.

(7) Reporting Obligations

In the event of a suspicion regarding facts that may indicate money laundering or terrorist financing, Megapixel Entertainment Ltd. may be obligated to file a suspicious activity report pursuant to Section 43 of the German Anti-Money Laundering Act (GwG) with the Financial Intelligence Unit ("FIU"-in Germany, the Central Office for Financial Transaction Investigations at the General Customs Office).

To file such a suspicious activity report, Megapixel Entertainment Ltd. processes the following personal data:

  • the player's master data
  • where applicable, data regarding the player's financial background (see above),
  • where applicable, data regarding the player's transaction and gaming behavior,
  • the facts indicating suspicion of money laundering or terrorist financing,
  • and, if applicable, additional personal data, particularly if the FIU requests further data from Megapixel Entertainment Ltd.

The legal basis for this data processing is Article 6(1)(c) of the GDPR, due to the statutory obligation to do so. In addition, Megapixel Entertainment Ltd. also has civil law obligations to protect all players-including all players other than the specific player in question (see § 242 BGB)-from criminal and other fraudulent activities; therefore, the submission of suspicious activity reports to the FIU is also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), sentence 1, subparagraph (b) of the GDPR as a legal basis. Furthermore, Megapixel Entertainment Ltd. has a legitimate interest in submitting suspicious activity reports within the meaning of Article 6(1), sentence 1, subparagraph (f) of the GDPR to prevent the misuse of its gaming platform for financial crime and fraud.

e. Use of Service Providers for Back-Office Operations

Megapixel Entertainment Ltd. uses the service provider EveryMatrix to manage player data and player accounts in its back office. All player data (master data, verification results, payment data, KYC data, transaction data, and gaming participation data) is stored, managed, and processed by EveryMatrix. In this context, EveryMatrix acts as a data processor for Megapixel Entertainment Ltd., processing players' personal data exclusively on the instructions of Megapixel Entertainment Ltd. To this end, Megapixel Entertainment Ltd. has entered into a data processing agreement with EveryMatrix. The use of a service provider for data management and processing in the back office is in accordance with the legitimate interests of Megapixel Entertainment Ltd.

Our legitimate interests for this processing are:

  • the efficient and proper provision of services and the delivery of an optimized player experience;
  • making the services offered by Megapixel Entertainment Limited accessible, optimizing them, and improving them;
  • detecting money laundering and/or misuse of the operated website and/or the services provided by Megapixel Entertainment Limited;
  • the fulfillment of contractual agreements and/or legal obligations;

f. Use of storage services, server maintenance services, and other IT services related to data storage

Megapixel Entertainment Ltd. uses server services-including the provision of storage capacity, server maintenance services, and other IT services related to data storage-provided by the service providers Snowflake Inc. and Amazon Web Services. In this process, players' personal data is transferred to servers provided and maintained by these two service providers. In providing this storage capacity and maintenance services, these two service providers act as data processors for Megapixel Entertainment Ltd., processing the players' personal data exclusively on the instructions of Megapixel Entertainment Ltd. To this end, Megapixel Entertainment Ltd. has entered into data processing agreements with Amazon Web Services and Snowflake. The use of service providers for server capacity and server maintenance is in accordance with the legitimate interests of Megapixel Entertainment Ltd.

Our legitimate interests in this processing are:

  • the efficient and proper provision of services and the delivery of an optimized player experience;
  • making the services offered by Megapixel Entertainment Limited accessible, optimizing them, and improving them;
  • the fulfillment of contractual agreements and/or legal obligations.

g. Communication with Players
Megapixel Entertainment Limited stores communications with players or website visitors, such as those with customer support. These communications may include the following personal data:

  • the name of the person initiating contact, if provided,
  • contact information provided voluntarily, if applicable
  • any other information voluntarily provided that may identify the person seeking contact or, in any case, make them indirectly identifiable.

This processing of personal data is based on the contract concluded with players or website users (the terms of which can be found in the General Terms and Conditions), Article 6(1)(b) of the GDPR, and is also in accordance with our legitimate interests.

Legitimate interests for this collection are:

  • the ability to provide the requested information,
  • the personalization and optimization of the services offered by Megapixel Entertainment Limited, and
  • the fulfillment of contractual agreements and/or legal obligations

Megapixel Entertainment Ltd. uses the services of Intercom R&D Unlimited Company for customer service, as well as the services of another group company. These two service providers act as data processors for Megapixel Entertainment Ltd. when providing their customer service, and they provide their customer service exclusively in accordance with the instructions of Megapixel Entertainment Ltd. Megapixel Entertainment Ltd. has entered into data processing agreements with these service providers for this purpose.

Megapixel Entertainment Ltd. also reserves the right to use a chatbot-specifically, an AI-for customer service at .

g. For Marketing Purposes
Depending on the account settings-which the player can configure and modify at any time-personal data may be used for marketing activities via various channels, including mail, email, instant messaging, etc.

Before we are permitted to carry out marketing activities addressed to specific individuals, we are required to submit a request to OASIS via the Marketing API to prevent online gambling advertisements from being sent to players who have been blocked in OASIS, § 5(5) GlüStV 2021. For this OASIS query via the Marketing API, Megapixel Entertainment Ltd. transmits the following personal data to OASIS:

  • The player's full name
  • The player's address
  • The player's date of birth

Furthermore, advertising for online gambling addressed to specific individuals may only be sent if the intended recipient has given prior consent to receive advertising and to the advertising online gambling provider's query of the exclusion file, § 5(5) GlüStV 2021. Megapixel Entertainment Ltd. will therefore always obtain the player's consent before sending personalized advertising to a specific player. The legal basis for data processing is thus Article 6(1)(a) of the GDPR. The player may revoke or restrict this consent to the use of their personal data for marketing activities at any time.

Furthermore, conducting the OASIS query via the OASIS Marketing API is required by law before sending personalized advertising; therefore, Megapixel Entertainment Ltd. may also rely on Article 6(1), sentence 1, subparagraph (c) of the GDPR regarding the conduct of the OASIS query via the OASIS Marketing API.

In addition, no bonuses, free spins, and/or other rewards may be granted to players whose OASIS suspension was lifted within the last four weeks. Megapixel Entertainment Ltd. is therefore legally obligated to perform an OASIS query via the OASIS Bonus API before granting bonuses, free spins, and/or other rewards, in order to prevent it from granting bonuses, free spins, and/or other incentives to players whose suspension in OASIS was only lifted within the past four weeks; see § 8(4), sentence 2, GlüStV 2021. For this query, Megapixel Entertainment Ltd. once again transmits the following personal data to OASIS:

  • The player's full name
  • The player's address
  • The player's date of birth

The legal basis for this data processing is Art. 6(1), sentence 1, lit. c) of the GDPR, due to the statutory obligation to do so. In addition, Megapixel Entertainment Ltd. is subject to civil law protection obligations toward all players (see § 242 BGB) to protect them from developing or relapsing into their previous gambling addiction, which is why conducting the OASIS query via the Bonus API is also necessary for the proper performance of the gaming contracts. Megapixel Entertainment Ltd. may therefore also rely on Article 6(1), sentence 1, letter b) of the GDPR as a legal basis. Furthermore, Megapixel Entertainment Ltd. has a legitimate interest in conducting the query via the OASIS Bonus API prior to granting bonuses and/or other discounts within the meaning of Article 6(1), sentence 1, subparagraph (f) of the GDPR, in order to ensure a safe gaming experience for its players and to protect them from the health risks associated with gambling participation .

g. For the purpose of creating player profiles
Megapixel Entertainment Limited processes information collected through cookies, log files, clear GIFs, and/or with the assistance of third-party providers to create player profiles. A profile contains information about an individual player, including preferences regarding that player's activities. Megapixel Entertainment Ltd. uploads contact information for players who have consented to receive personalized advertising to Simplify and creates groupings there based on the player profiles. Based on these groupings, Simplify then sends personalized advertising to the grouped players who have consented to receive personalized advertising. Profiles are also used to personalize the player experience on the website and to provide specific marketing information.

This profiling is in accordance with the legitimate interests of Megapixel Entertainment Ltd. These legitimate interests for profiling are:
• making the services offered by Megapixel Entertainment Limited available, optimizing them, and improving them,
• designing more effective and better-personalized advertising for the services offered.

Apart from the profiling described above for marketing purposes and the creation of risk profiles for players for player protection and anti-money laundering purposes, no profiling within the meaning of Article 22 of the GDPR takes place.

h. For Other Purposes
In exceptional cases, Megapixel Entertainment Limited may need to process personal data for other purposes. However, the conditions set forth in Section C.1 apply in all cases; processing will only take place if the conditions listed above in Section C.1 are met.

i. Content and Third-Party Tracking Software
Megapixel Entertainment Limited uses cookies. Cookies are small files that are automatically created by the user's browser and stored locally (on the user's laptop, tablet, smartphone, etc.) when the user visits Megapixel Entertainment Limited's websites. Megapixel Entertainment Ltd. also uses tracking software and website analytics tools on its websites, enables the use of social media plug-ins and single sign-on technology, and may provide third-party content on its websites.

(1) Tracking Software Megapixel Entertainment Limited uses tracking software to learn more about user behavior and player preferences on its websites.

Tracking software collects user data such as IP address, the website from which access is made, advertising preferences, and other marketing information.

The following tracking software is integrated into Megapixel Entertainment Limited's websites:

  • Adform
  • AppsFlyer
  • Cookie yes
  • Google Ads
  • QuantCast
  • Meta
  • MyAffiliates

(2) Website Analytics
Megapixel Entertainment Limited uses website analytics tools to understand player behavior on Megapixel Entertainment Limited's websites and to optimize the services provided by Megapixel Entertainment Limited.

Website analytics tools collect data using cookies and IP address tracking for this purpose.

The following website analytics tools are integrated into Megapixel Entertainment Limited's websites:

  • Firebase
  • Google Analytics
  • Google Tag Manager
  • Leadlink
  • Quantcast
  • Posthog
  • Spoteffect

(3) Social Media Plugins
Megapixel Entertainment Limited uses social media plugins to enable players to interact between social media and Megapixel Entertainment Limited's websites, thereby allowing them to share their gaming experience with others.
Social media plugins allow users to log in to both their social media accounts and their Megapixel Entertainment Limited accounts and to link Megapixel Entertainment Limited content to the player's social media profile.

Social media plugins collect user data such as IP address, login credentials, the website from which access is made, and cookie data.

The following social media plugins are integrated into the Megapixel Entertainment Limited websites:

  • Facebook Connect
  • X (formerly Twitter)
  • LinkedIn

Unless cookies are technically essential for the proper functioning of the Megapixel Entertainment Ltd. website-that is, unless they are non-essential, functional cookies, analytics tools, tracking tools, social media plugins, etc.-you must consent to the use of these cookies, tools, and plugins. To this end, Megapixel Entertainment Ltd. requests your consent when you visit the website. The legal basis for data processing is therefore Article 6(1)(a) of the GDPR. This consent to the use of personal data through the setting of cookies, tracking and analytics tools, social media plug-ins, etc., that are not technically necessary may be revoked or restricted by the website visitor at any time (e.g., limited to only certain cookies, tracking and analytics tools, social media plug-ins, etc.).

Insofar as technically necessary cookies are concerned-which must be set to ensure the proper functioning of the website-their use is based on the legitimate interests of Megapixel Entertainment Ltd. within the meaning of Article 6(1), first sentence, (f) of the GDPR.

4 Transfer and Disclosure of Personal Data to Service Providers in Third Countries
Megapixel Entertainment Limited will under no circumstances transfer personal data to countries outside the European Economic Area, unless the recipient guarantees a level of data protection comparable to European standards (e.g., through acceptance of approved contractual clauses, binding corporate rules, or other measures, or based on the existence of an adequacy decision by the European Commission) to ensure that recipients of personal data maintain an adequate level of data protection at all times.

5. Anonymized Data
Megapixel Entertainment Limited reserves the right to publish gaming data (e.g., game results), the player's first name, the first letter of the player's last name, and the player's country of origin on its websites, , provided that the player cannot be identified, either directly or indirectly, by the publication of this information.

Such publication is carried out to promote the services offered.

6. Data Sharing Within the Corporate Group
Megapixel Entertainment Ltd. may share your personal data with other companies within the corporate group, in particular to leverage synergies. Such data may also include information regarding your self-exclusion with us.

7. Retention Period for Personal Data
Pursuant to Section 6g(1) of the GlüStV 2021, personal player data must be retained for five years from the closure of the player account. Section 8 of the GwG requires entities subject to anti-money laundering regulations to retain KYC data-that is, all data concerning player identity, verification data, and EDD data-for a period of five years beginning at the end of the year in which the business relationship was terminated. All other personal data collected for the purposes of preventing money laundering and terrorist financing-in particular transaction and monitoring data, as well as suspicious activity reports-must be retained for a period of five years beginning at the end of the year in which they were collected, in accordance with § 8 of the GwG. However, tax laws and commercial law provisions regarding proper bookkeeping may require a longer retention period of at least 6 years beginning at the end of the year in which the data was collected, or even 10 years beginning at the end of the year in which the data was collected. No later than the end of the longest resulting period (10 years after the end of the year in which the data was collected or 5 years beginning at the end of the year in which the business relationship ended, whichever is longer), Megapixel Entertainment Ltd. will delete the players' personal data.

D. DATA SECURITY

All data is processed automatically. Megapixel Entertainment Limited takes all reasonable technical and organizational measures to protect players' data from access by unauthorized persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration, or damage.

In addition, payment information is encrypted during processing in accordance with PCI DSS.

Confidential information is protected online through SSL encryption. Furthermore, Megapixel Entertainment Limited takes reasonable measures to protect player data in all other areas.

Only authorized personnel of Megapixel Entertainment Limited or third-party companies that are contractually bound to comply with Megapixel Entertainment Limited's data protection principles and the terms of this Privacy Policy are granted access to player information.

Megapixel Entertainment Limited monitors the trustworthiness and reliability of all employees and service providers. Every employee receives regular training on applicable security and data protection standards. Relevant servers are located in a secure environment.

E. PLAYER RIGHTS REGARDING THEIR PERSONAL DATA

The player has the right at any time
• to submit a request for access under Article 15 of the GDPR to view their personal data,
• to request the rectification of their personal data, Article 16 of the GDPR
• to withdraw consent to the processing of their personal data at any time (e.g., for advertising purposes), Article 7(3) of the GDPR-withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal,
• to request the erasure of their personal data, Article 17 of the GDPR
• to receive their personal data, upon request, in a structured, commonly used, and machine-readable format (data portability), Art. 20 GDPR
• to request the restriction of the processing of their personal data, Art. 18 GDPR; and
• to object to the processing of their personal data for reasons arising from their particular situation, provided that the data processing is based on the legitimate interests of Megapixel Entertainment Ltd. within the meaning of Article 6(1)(f) of the GDPR, including data processing for profiling based on this provision (see above), unless Megapixel Entertainment Ltd. can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defense of legal claims, Article 21 of the GDPR.

Furthermore, without prejudice to any other administrative or judicial remedy, the player has the right at any time to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or the place of the alleged infringement, or with the Maltese Data Protection Authority Office of the Information and Data Protection Commissioner (IDPC), Floor 2, Airways House, Triq Il-Kbira (High Street), Tas-Sliema SLM 1549, Malta, idpc.org.mt, if the data subject believes that the processing of their personal data violates this Regulation.

Some of these rights are subject to certain conditions set forth in European data protection regulations, including the General Data Protection Regulation.

F. INQUIRIES

For inquiries or complaints regarding the processing and collection of data on the Megapixel Entertainment Limited website, please contact[email protected] or the Maltese data protection authority responsible Office of the Information and Data Protection Commissioner (IDPC), Floor 2, Airways House, Triq Il-Kbira (High Street), Tas-Sliema, SLM 1549, Malta, idpc.org.mt.

G. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be subject to changes from time to time, of which players will be notified immediately upon their next login to their Megapixel Entertainment Limited player account and may be required to consent to such changes. Nevertheless, Megapixel Entertainment Limited recommends that players review this Privacy Policy regularly for any changes.