You may provide to Maltco Lotteries the following types of Personal Data:

5.1. At the point of your access and during the use of the Websites:

• IP Address.
• End user device data.
• General communication data.
• Browsing data/patterns.
• Information on user preferences regarding the Websites’ products/ services.

5.2. At the point of giving us permission to obtain Personal Data from personal accounts for social media and / or other online services of third parties:

• Information stored in such accounts.

5.3. At the point of submitting your C.V., cover letter and/or your contact information through our Websites’ forms or through an email communication with the Company:

• All Personal Data directly provided by you.

5.4. At the point of submitting your application through our Websites’ forms and/or when delivered directly at our Company’s Head Office:

1. a Vacant Point of Sale.
2. Maltco Lotteries Authorised Agent.
3. Maltco Lotteries Authorised Seller.
4. Maltco Lotteries Authorised Assistant.

• All Personal Data directly provided by you

5.5. At the point of contacting Maltco Lotteries via the Help Line Centre:

• A recording of the conversation(s).
• Service Request(s) logs.
• All Personal Data directly provided by you

5.6. Any other personally identifiable information directly provided by you during interaction with our social media channels.

5.7. Any personal information you provide during the course of communication(s) through mail, whether electronic (e-mail) or otherwise, with Maltco Lotteries.

5.8. Any information collected by the Company throughout its course of business for the provision of its services.

5.9. When visiting the Company’s Head Office situated in Iklin, the Company’s Point of Sale 501 situated in Birkirkara:

• Personal data acquired through CCTV footage.

5.10. When visiting the Company’s Head Office situated in Iklin and the draw premises in Gwardamangia:

• Personal Data acquired through the visitor management system (for attendance and security purposes).

5.11 At the point of registering an account on the Company’s remote gaming Websites:

• Personal Data provided at registration stage, including name and surname, full residential address, place of birth and date of birth, nationality, phone/mobile number (or other contact number), gender, e-mail address and identification document number.

5.12. At the point of request by Maltco:

• Personal Data required for identification and verification purposes in terms of Know Your Customer procedures (“KYC”) and for the purpose of prevention and detection of fraud, prevention of money-laundering and terrorist funding and ensuring responsible gaming, including identification and KYC documents, proof of residential address, and source of funds, source of wealth, information on occupation and any other information and documentation as may be deemed required and as may be specified in procedures issued by the relevant regulatory authorities, for the above stated purposes.

5.13. When the Company automatically generates transaction data when deposits and/or payments and withdrawals are made, and gaming data with gaming activity via the remote gaming Website:

• Transaction data including details relating to payments made to you and by you and gaming data including details relating to the games played by you on the Company’s Websites, that is, your gaming activity and all transactions effected.

5.14. Maltco Lotteries does not collect in any way special categories ("sensitive") of Personal Data or data relating to criminal convictions and offenses by its clients, unless this is explicitly required by a public authority and/or unless this is required in order to comply with any applicable law or regulation. You have an obligation to refrain from posting such data concerning yourself or third-party data subjects. In the event that you submit such data to the Company, these will be removed as soon as we become aware of them. We have no liability to you or to any third parties for any processing of sensitive data due to your actions or omissions in breach of this obligation.

5.15. Where Maltco Lotteries collects Personal Data by law, or under the terms of a contractual agreement we have with you and you fail to provide that data when requested, we may not be able to perform the contractual agreement we have or are trying to enter into with you.

6.1. Data protection laws and regulations provide for specific reasons and circumstances when the Company can collect, use and store your information. In Maltco Lotteries’ case, it is one of the following four reasons that will justify why we process your Personal Data:

1. The Personal Data is needed for you or the Company to fulfil our contractual obligations;
2. The Personal Data is needed for you or us to fulfil a legal requirement;
3. You have provided us with your consent to collect, use and store such Personal Data;
4. There is a legitimate interest to collect, use and store such Personal Data.

6.2. Personal Data necessary for the navigation and use of our Websites is collected and processed by Maltco Lotteries pursuant to article 6 § 1 (b) of the GDPR for the following purposes:

• Technical capability for the smooth operation of our Websites.
• Friendly and user-friendly operation of our Websites.
• Improve your online experience while navigating and using our Websites.
• Recording consumer habits through the use of anonymous statistical data.

6.3. Personal Data necessary for the provision of our services within our contractual relationship is collected and processed by Maltco Lotteries pursuant to article 6 § 1 (b) of the GDPR for the following purposes:

• Performance of our contractual obligations towards our Users and clients which can change and/or require adaptation according to exigencies from time to time.
• Immediate, adequate and efficient provision of our services
• Tax use and use for pricing and proof of delivery of ordered products / services.
• Communicating with our clients in the framework of the execution of our services and for the resolution of any complaints.
• Improvement, management and review of our products and services to meet the needs of our clients as much as possible.
• Administration, organization and function of our business.
• Management of our clientele.
• Extrajudicial or judicial use for the protection of our lawful rights and interests.

6.4. Personal Data necessary for the recruiting process is collected and processed by Maltco Lotteries pursuant to article 6 § 1 (a) of the GDPR for the following purposes:

• Communicating with you and processing your employment application in accordance with Maltco Lotteries’ recruitment and hiring process.

6.5. Personal Data necessary for business opportunities (Vacant Points of Sale, Maltco Lotteries Authorised Agent, Maltco Lotteries Seller) is collected and processed by Maltco Lotteries for enterprising individuals pursuant to article 6 § 1 (a) of the GDPR for the following purposes:

• Communicating with you and processing your application in accordance with Maltco Lotteries’ process.

6.6. Personal Data provided at registration is collected and processed by Maltco Lotteries pursuant to article 6 § 1 (b) of the GDPR for the following purposes:

• Customer identification at registration stage on the Company’s Website and creation of unique customer account;
• Identification of customer when contact is made;
• Contacting customers for support purposes.

6.7. Personal Data required for verification purposes as Customer Due Diligence documentation in accordance with any applicable Anti-Money Laundering (“AML”) laws and regulations, including but not limited to, (i) when carrying out any transaction(s) of Eur 2,000 or more (whether in single operation or in several operations which appear to be linked) at any Maltco Point of Sale and/or Maltco’s Head Office is collected and processed by Maltco Lotteries and/or its Agents and/or (ii) when availing yourself of the services provided by Maltco Lotteries either through the remote gaming Website and/or upon request made by Maltco Lotteries through email or by any other means when operating your registered account, pursuant to article 6 § 1 (c) for the following purposes:

• Processing is necessary for compliance with a legal obligation under AML laws and regulations.

6.8. Personal Data necessary collected by Maltco Lotteries upon payment and/or deposit or withdrawal of funds into the account or where we have queries from you pursuant to article 6 § 1 (c) of the GDPR for the following purposes:

• Required for Know-Your-Customer (KYC) checks (source of funds and/or source of wealth, including but not limited to occupation and any other information as may be deemed required for the above stated purposes).

6.9. Personal Data, namely gaming activity data and transaction data, automatically generated when payment and/or deposits and withdrawals are made pursuant to article 6 § 1 (c) of the GDPR for the following purposes:

• Required to comply with remote gaming law and AML law.

6.10. Personal Data necessary to inform third party organisations forming part of the selection process regarding vacant Point of Sale applications, where applicable, pursuant to article 6 § 1 (f) of the GDPR:

• Processing is necessary to process your application in accordance with third party organisations’ selection process.

6.11. Personal Data necessary for business opportunities as Maltco Lotteries Authorised Assistant which is collected and processed by Maltco Lotteries for enterprising individuals pursuant to article 6 § 1 (f) of the GDPR for the following purpose:

• Processing is necessary to process your application and for communication purposes in accordance with Maltco Lotteries’ business operations.

6.12. Personal Data necessary for the provision of business operations by the Company pursuant to article 6 § 1 (f) of the GDPR for the following purposes:

• Processing of any Personal Data acquired through all mail communications, physical submission, telephone and CCTV footage.

6.13. Personal Data necessary for the provision of business operations by the Company pursuant to article 6 § 1 (f) of the GDPR for the following purposes:

• Processing of any Personal Data acquired through the Visitor Management System necessary for security purposes and the prevention of unauthorised access to the Company’s offices and draw premises.

6.14. Personal Data necessary for ensuring security of our Services, to comply with any local regulator or authority, to prevent corruption, fraud, hacking and/or cheats; and to facilitate our response to legal processes, including but not limited to a court order, warrant or subpoena pursuant to article 6 § 1 (f) of the GDPR:

• Processing is necessary for our legitimate interests as a business when those interests are not overridden by your interests, fundamental rights or freedoms.

6.15. Maltco Lotteries collects and processes your Personal Data solely for the purposes mentioned above and only to the extent that is strictly necessary to effectively serve such purposes. Data collected is relevant, appropriate and no more than what is required in view of the above purposes, whereas we strive to keep them accurate and up to date. Furthermore, your data is retained only for the period required to achieve the purposes, for which they are collected and processed, and are afterwards deleted.

7.1. Maltco Lotteries may process Personal Data only with your lawful consent for the following purposes:

• For the purposes of commercial communication, marketing and advertising of our services or third-party services via SMS, telephone, e-mail, internet, fax, mail, social media and / or any other appropriate communication channels.
• For personified market research and / or analysis purposes to better understand your needs, preferences, interests, experiences and / or habits as a consumer.
• To operate and manage any promotions and/or reward programs.

7.2. You give us your consent to the processing of your Personal Data for the above purposes with an electronic statement in a manner clearly distinguishable from other consents or notice and in an intelligible and easily accessible manner using clear and plain language. Your consent is freely given and your Personal Data is given without such a provision being a legal or contractual obligation or a requirement on behalf of Maltco Lotteries for the performance of a contract between us.

7.3. In this context, by giving your consent, you explicitly state that you wish to provide your consent for the above purposes in accordance with the terms and conditions of this policy. You may provide your consent in the following ways:

• When submitting your CV, cover letter and contact details.
• When submitting your application for Vacant Points of Sales, become a Maltco Lotteries Authorised Agent / Maltco Lotteries Seller.
• When submitting queries at our Contact Us web form.

7.4. You have the right to withdraw your consent at any time, including the right to ask us not to process your Personal Data for marketing purposes. Your consent is also revoked in the same manner as provided. You can withdraw your consent by contacting our Customer Support on . In the case of a registered account on Maltco Lotteries’ remote gaming Website, you can alternatively withdraw your consent by selecting the ‘decline’ option from the ‘My Terms’ section of your account. Withdrawal of your consent does not affect the lawfulness of the treatment of your Personal Data prior to its revocation.

8.1. Maltco Lotteries may share your Personal Data with its parent company INTRALOT SA and /or its subsidiaries based in the EU, in the process of pursuing the purposes of data processing at Group level and for group reporting purposes.

8.2. Maltco Lotteries may share your Personal Data with (i) the duly appointed auditor(s) for the purposes of statutory audits; (ii) regulatory authorities for the purposes of investigation, supervision, compliance and other lawful reasons as required by law.

8.3. Maltco Lotteries does not assign your Personal Data or interconnect its database with any third parties or other organizations for financial or other consideration.

8.4. For the execution of the purposes mentioned in this Privacy Policy, Maltco Lotteries may provide access to or transmit the following types of your data to the following processors:

• Your Personal Data to third party organisations forming part of the selection process for vacant Points of Sale, where applicable, as referred to in clause 6.10 herein this Policy.
• Your Personal Data to our internet and data hosting providers for hosting purposes and to cloud service providers.
• Your Personal Data to our information technology maintenance and support providers for the smooth operation of our Websites and our information and communication systems.
• Your Personal Data to third-party consultants to provide data analysis services.
• Your Personal Data to a third-party provider for identity and verification purposes in terms of KYC and AML obligations. In order for us to be compliant with AML legislation, we work with this third party to analyse your Personal Data and create a player profile on you based on the Personal Data you provide to us and the information we collect on you from time to time.

8.5. The processing of your Personal Data by our data processors mentioned above is executed under our control and orders and is subject to the same data protection policy or to a policy of at least the same level of protection.

8.6. In the event that we are required by a court or other administrative authority and in any other case that we are legally bound to do so, Maltco Lotteries may transfer your Personal Data to public and/or judicial authorities to the extent specified by law prior to you being informed.

8.7. The Company does not process, collect, assign or transfer Personal Data you yourself provide to payment service providers, banks, payment card and financial services providers you make use of to make and receive payments on the Company’s Website through the operation of your registered account. Such Personal Data will be collected and processed solely by such banks, payment card and financial services providers.

Generally, the data Maltco Lotteries processes about you will be stored and processed within the European Economic Area (EEA). However, some of the service providers outlined in the previous section may be based in countries which do not form part of the EEA. Whenever such transfers of your Personal Data are made to data processors located outside of the EEA, Maltco Lotteries will seek to take additional steps to ensure that your Personal Data is protected in the same way as it is in the EEA through either

1. contractual means such as entering into an agreement containing Standard Contractual Clauses. These Standard Contractual clauses are approved by the European Commission and should give Personal Data the same protection it has in Europe. These clauses also ensure that the Personal Data is afforded the same protection as it is in the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or
2. other means such as implementing European Commission decisions determining that specific countries provide an adequate level of protection. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;

Please contact us if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

10.1. In order to ensure the proper use and integrity of your Personal Data and to prevent their unauthorised or accidental access, processing, deletion, alteration or other use, Maltco Lotteries applies appropriate internal policies and takes all appropriate organizational, technical, physical, logical and procedural security measures, as well as technical standards, in accordance with the applicable laws and regulations.

10.2. The processing of your Personal Data by Maltco Lotteries is conducted in a manner that ensures their confidentiality and physical and logical security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for your rights and freedoms, which are applicable in each circumstance.

10.3. The processing of your Personal Data is limited to authorised personnel of Maltco Lotteries, authorised agents, and other third parties who have a business need to know. They are contractually bound by strict obligations of confidentiality and only process your Personal Data on instructions provided by and in accordance with agreed terms with Maltco Lotteries.

11.1. We keep your Personal Data for as long as it is necessary in order to fulfil our contractual, regulatory and statutory obligations.

11.2. Maltco Lotteries shall retain your Personal Data in accordance with the following periods:

1. a Vacant Point of Sale Application – for one (1) year after the expiry of its Licence, or any extension granted thereto.
2. Maltco Lotteries Authorised Agent Application – for one (1) year after the expiry of its Licence, or any extension granted thereto.
3. Maltco Lotteries Authorised Seller Application – for one (1) year after the expiry of its Licence, or any extension granted thereto.
4. Maltco Lotteries Authorised Assistant Application – for one (1) year after the expiry of its Licence, or any extension granted thereto.
5. Curriculum Vitae (CV) - for one (1) year after the expiry of its Licence, or any extension granted thereto.
6. Call recordings and Service Requests logs – for one (1) year after the expiry of its Licence, or any extension granted thereto.
7. Mail and Email communication – for one (1) year after the expiry of its Licence, or any extension granted thereto.
8. Point of Sale information – for one (1) year after the expiry of its Licence, or any extension granted thereto.
9. Customer Due Diligence / KYC information – for a minimum of five (5) years commencing from the date on which the business relationship is terminated or the occasional transaction carried out (for AML purposes). When there is a series of occasional transactions, the five (5) year period starts to run on the date the last transaction in that series was carried out.
10. Gaming and Transaction data for all transactions effected through your use of the Websites – for a minimum of five (5) years commencing from the date on which the business relationship is terminated or the occasional transaction carried out (for AML purposes). When there is a series of occasional transactions, the five- (5) year period starts to run on the date the last transaction in that series was carried out.
11. CCTV Footage – unless required for longer for legal and investigative purposes, for a period of seven (7) days.
12. Visitor management system data – for one (1) year after the expiry of its Licence, or any extension granted thereto.

11.3. Maltco Lotteries may retain your Personal Data after the expiration of their relevant processing purposes in the following limited cases:

• In case that there is a legal obligation under a relevant statutory provision.
• For reasons of tax and social security audit reasons within the statutory limitation period.
• For research or statistical purposes for the proper organization and operation of our business provided that anonymity or pseudonymization of your Personal Data takes place.
• In case of any claims against Maltco Lotteries, for as long as necessary to defend our rights and legitimate interests before any competent court and any other public authority.

11.4. After the period of retention, your Personal Data is erased from our databases and systems in accordance with our data protection policies and provided that their retention is no longer required for the fulfilment of the purposes we have described above.

12.1. Without prejudice to the applicable law and subject to any limitations thereof, you have the following rights:

• Request for access to your Personal Data and information related to their processing and obtain a copy thereof. Some of the Personal Data held about you can be accessed by logging into your registered account. Additional information may be requested by contacting us on .
• Request for the rectification of any inaccuracies or any missing Personal Data of yours, though we may need to verify the accuracy of the new data you provide to us.
• Request for the erasure of your Personal Data. You have the right to ask us to delete any Personal Data we hold about you which is not relevant to the purpose for which we collect it. You may thus ask us to delete or remove personal data where you believe there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (as mentioned below), where you believe that we may have processed your information unlawfully, where you withdrew your consent on which the processing is based and there is no other legal ground for the processing, or where we are required to erase your personal data to comply with a legal obligation. We will not be able to fulfil your request if we are under a legal obligation (such as AML legislation) to retain this information, or where the retention of your Personal Data is necessary for the establishment, exercise or defence of legal claims or for us to defend ourselves in a legal dispute. In the event that your account on the Company’s remote gaming Website is deleted by the Company upon your request to exercise the right for erasure of your Personal Data, you agree that such request is attributed to your account username as provided by you and therefore you may be precluded from using the same account username and/or other identifying criteria for the re-opening of a new account.
• Request for the restriction of the processing of your Personal Data in cases explicitly provided for by law.
• Request for the portability of your Personal Data to another controller in a structured, commonly used and machine-readable format (e.g. cd). This means you may ask us to transfer certain data we process about you to you or others. This right only applies to data which you provided us with and consented us to use and which were necessary for us both to honour our mutual contractual obligations.
• Withdraw consent at any time where we are relying on consent to process your Personal Data, as further explained in Section 7.4. of this Privacy Policy.
• Object to the processing of your Personal Data in cases explicitly provided for by law.
• Object to a decision taken solely on the basis of automated processing, including profiling, which has an impact on you or significantly affects you. This does not affect Maltco Lotteries’ obligations at law to carry out customer due diligence exercises which include automated processing on you in terms of AML law.

You can exercise your rights at any time by contacting us at . For players having a registered account on Maltco Lotteries’ Website, all communications with us must ideally be through the e-mail address that is associated with the registered account or from any other communication means provided that Maltco Lotteries shall verify the player’s identity prior to responding to any request.

12.2. Maltco Lotteries will respond to any of your requests within one (1) month from their receipt. Upon prior notice, this period may be extended by a further two (2) months if necessary, taking into account the complexity of the request and the number of any other pending requests. For Maltco Lotteries to be able to action any of your requests made in accordance with your rights as described above, we may need to request specific Personal Data about you to help us verify your identity. This is a security measure to ensure that we are certain that the person to whom we disclose your Personal Data is really you. In the case of rejection of your request, we will provide relevant justification.

12.3. If your request does not meet the requirements of the applicable law, Maltco Lotteries reserves the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject your request.

12.4. In the event of any violation of your Personal Data, which may place your rights and freedoms at a high risk, and provided that it does not fall under one of the exceptions expressly provided for by the applicable law, we undertake to inform you without undue delay.

12.5. If there are any doubts as to the identity of the individual submitting the request, we reserve the right to request the provision of additional information necessary to confirm his / her identity.

12.6. You may file a complaint with our lead supervisory authority, the Office of the Information and Data Protection Commissioner through their dedicated online form (https://idpc.org.mt/raise-a-concern/) or contact them as follows:

Office of the Information and Data Protection Commissioner
Floor 2, Airways House,
High Street
Sliema SLM 1549
Malta
(+356) 2328 7100

13.1. By using our Website, Services and by providing your Personal Data upon your consent, you acknowledge that you are required to state your actual, accurate and complete information requested by Maltco Lotteries. Furthermore, you must inform our Company of any changes to your information so as to ensure it is kept up-to-date and accurate.

13.2. If you are found to be in breach of your obligations or if the Company has reasonable suspicion that the information you provide is false or incomplete or in any way contrary to the applicable law or this Privacy Policy, we retain the right to reject your application for registration or to suspend or terminate your account immediately without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.

13.3. You acknowledge that the Company may delete, cross-check, supplement or modify the information you provide based on information lawfully provided by third parties. In this case, the Company will provide you with relevant notice in compliance with the applicable law.

13.4. By using our Websites you confirm that you are over eighteen (18) years old. If you are under the age of eighteen (18) you have the obligation to abstain from any use of Maltco Lotteries’ Websites and from any transfer of your Personal Data without the consent of the person who exercises your parental responsibility. If you fail to comply with the foregoing obligations, you must immediately notify Maltco Lotteries. In any case, using the Websites, you acknowledge that Maltco Lotteries is not responsible for your violation of the obligations mentioned above to the extent that it is unable, even if it makes reasonable efforts, to verify your age or to receive consent from your guardian.

14.1. Our Websites use Cookies. For further information about Maltco Lotteries’ use of cookies, please read Maltco Lotteries’ Cookie Policy.

15.1. Any dispute between you and Maltco Lotteries arising from or in relation to the subject matter of this Privacy Policy shall be governed and construed in accordance with Maltese law without reference to its conflict of laws principles and shall be subjected to the exclusive jurisdiction of the competent courts of Malta.

15.2. If a provision of the present Privacy Policy is cancelled by a decision of a competent court as unlawful, invalid or unenforceable, this will not affect the validity and enforceability rest of its provisions, which will remain in full force and will be accordingly applied.

16.1.Maltco Lotteries keeps this Privacy Policy under regular review and places any updates on the Company’s Websites. Any changes to this Privacy Policy shall come in force and effect from the instance they appear online on the Websites. This Privacy Policy (v4.0) was last updated on 03rd May 2021.