Last Updated: 15 March 2024

1. Introduction

This Privacy Policy explains how posletestiruya.co.uk ("we", "us", or "our") collects, uses, and protects your personal information when you use our Book of Treasures 2 social casino experience (the "Service").

Important Context: Our Service is a free-to-play social casino platform for entertainment purposes only. There is no real money gambling, no cash-outs, and no prizes of real-world monetary value. This Privacy Policy should be read in conjunction with our Terms & Conditions.

By accessing or using our Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service.

2. Information We Collect

2.1 Information You Provide Directly

When using our Service, you may voluntarily provide:

  • Account Information: Username, age verification (confirming you are 18+), and preferences
  • Gameplay Data: Progress, scores, achievements, and virtual currency balances
  • Communication Data: If you contact us, we collect your email address and message content

2.2 Information Collected Automatically

When you visit our website, we may automatically collect:

  • Technical Data: IP address (anonymised where possible), browser type, device type, operating system
  • Usage Data: Pages visited, time spent, features used, game interactions
  • Cookie Data: See our Cookies Policy for detailed information

2.3 Information We Do Not Collect

We do not collect:

  • Payment information (no real money transactions occur)
  • Sensitive personal data (racial/ethnic origin, political opinions, religious beliefs, health data, etc.)
  • Information from individuals under 18 years of age

3. How We Use Your Information

We use your information for the following purposes:

  • To Provide and Maintain the Service: Enable gameplay, track progress, and maintain your account
  • To Improve Our Service: Analyse usage patterns to enhance features and fix issues
  • To Ensure Compliance: Verify you are 18+ and ensure compliance with our terms
  • To Communicate: Respond to your inquiries and provide important service updates
  • For Security: Protect against fraud, abuse, and unauthorised access

Legal Basis for Processing (UK & EU): Our processing of your personal data is based on:

  1. Contract: Processing necessary to provide the Service you requested
  2. Legitimate Interests: Improving our Service, preventing fraud, and ensuring security
  3. Consent: Where required by law, we obtain your consent (e.g., for certain cookies)
  4. Legal Obligation: To comply with applicable laws and regulations

4. Data Sharing and Disclosure

4.1 When We Share Your Information

We may share your information in the following circumstances:

  • Service Providers: With trusted third parties who help us operate our Service (hosting providers, analytics services)
  • Legal Requirements: If required by law, regulation, or legal process
  • Business Transfers: In connection with a merger, sale, or acquisition of our business
  • Protection of Rights: To protect our rights, property, or safety, or those of others

4.2 What We Do Not Do

We do not:

  • Sell your personal information to third parties
  • Share your information with real-money gambling operators
  • Use your information for targeted advertising related to real-money gambling
  • Share your information with social media platforms without your explicit consent

5. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit using SSL/TLS
  • Secure server infrastructure with regular security updates
  • Access controls and authentication procedures
  • Regular security assessments and monitoring

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but we work to maintain appropriate safeguards.

6. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

  • Account Data: Retained while your account is active and for 2 years after inactivity
  • Gameplay Data: Retained to maintain your progress and for analytical purposes
  • Communication Data: Retained for 3 years after our last communication
  • Log Data: Retained for 12 months for security and analytical purposes

You may request deletion of your data at any time by contacting us (see Section 9).

7. Your Rights (UK GDPR & Data Protection)

Under UK data protection laws (UK GDPR and Data Protection Act 2018), you have the following rights:

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data in certain circumstances
  • Right to Restrict Processing: Request limitation of how we use your data
  • Right to Data Portability: Request transfer of your data to another service
  • Right to Object: Object to certain types of processing
  • Rights Related to Automated Decision-Making: We do not use automated decision-making with legal effects

To exercise these rights, please contact us using the details in Section 9. We will respond within one month of receiving your request.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe we have not complied with data protection laws.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyse usage, and support our Service. For detailed information about the cookies we use and how to manage them, please see our dedicated Cookies Policy.

We use cookies for:

  • Essential Operation: Maintaining your session and gameplay state
  • Analytics: Understanding how users interact with our Service
  • Preferences: Remembering your settings and choices

You can control cookie settings through your browser. Please note that disabling certain cookies may affect the functionality of our Service.

9. International Data Transfers

We are based in the United Kingdom and store data primarily within the UK and European Economic Area (EEA). If we transfer your data outside the UK/EEA, we ensure appropriate safeguards are in place, such as:

  • Adequacy decisions by the UK government or European Commission
  • Standard contractual clauses approved by UK/EU authorities
  • Other legally approved transfer mechanisms

10. Children's Privacy

Our Service is not intended for individuals under 18 years of age ("minors"). We do not knowingly collect personal information from minors. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

If we become aware that we have collected personal information from a minor without verification of parental consent, we will take steps to remove that information from our servers.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We encourage you to review this Privacy Policy periodically for any changes.

Material changes will be communicated to you through the Service or via email if you have provided your email address.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

By Email: [email protected]

By Post: Data Protection Officer, posletestiruya.co.uk, [Company Address, United Kingdom]

We aim to respond to all legitimate inquiries within 30 days.