Bankrolla Privacy Policy

Last Updated: April 4, 2025\ Version: 1.0

1. Introduction

a. This Privacy Policy

We encourage you to carefully read this Privacy Policy as it provides you with information about your personal data being processed in connection with your access to and use of the Platform. In this Privacy Policy we explain which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on.

b. Personal Data

In this Privacy Policy, personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual, as well as any information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Personal information excludes:

Aggregated information, meaning information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person; and
Anonymous information, meaning information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.

c. Definitions

Unless otherwise provided in this Privacy Policy, capitalized terms used in this Privacy Policy have the meaning determined in the Bankrolla Terms of Service (the “Terms”). We encourage you to read the Terms carefully as they affect your obligations and legal rights.

2. Data Controller

The data controller (business) is Epic Play Holding Inc., a Florida corporation. We process your personal data in accordance with this Privacy Policy and we endeavor to comply with the applicable legislation. If you have any questions regarding this Privacy Policy or the processing of your personal data, do not hesitate to contact us via the following contact details:

Name: Epic Play Holding Inc.

Address: 1287 E Newport Center Dr Ste 206, Deerfield Beach, Florida, 33442, USA.

Email: [email protected].

3. Collecting Personal Data

We collect the following categories of personal information:

Identity Data, such as: first name, last name, gender, date of birth, citizenship, and government-issued ID document.
Contact Data, such as: email address, address, phone number.
Location Data, such as: IP address, address.
Occupation Data, such as: education, career, source of funds.
Online Presence Data, such as: information available on social media and online commerce.
Watchlist Data, such as: information available in watch lists, AML checks (OFAC, FBI, FinServ, etc.), industry watch lists, customer blacklists.
Communication Data, such as: recorded communications with us, including calls, letters, emails, messages, forms.
Usage Data, such as: unique user identifiers, activity, technical and device information about your use of the Platform (e.g., content viewed, visit duration, hardware model, device type, operating-system version, browser type, IP address).

4. Sources of Personal Data

We collect your personal information as follows:

Directly From You: When you provide information such as Identity Data, Contact Data, or Communication Data while creating an account, using the Platform, or contacting us.
Automatically From Your Device: When you visit the Platform, certain data (e.g., Usage Data) is automatically shared via cookies and similar technologies.
Automatically From Third Parties: When information is supplied by an integrated Third-Party Service (e.g., Usage Data) or we validate your Identity Data via external sources (e.g., Watchlist Data). Technologies we use include:
- Cookies: Small text files stored in your browser. Blocking them may impact service performance.
- Pixel Tags / Web Beacons: Embedded code that tracks page visits or email engagement.
- Mobile Device Identifiers: Advertising IDs (e.g., Apple IDFA, Google Advertising ID) that you can manage in device settings.
- Event Tagging: Tools (e.g., Facebook App Events) that log actions like app installs to measure ad performance.

5. Using Personal Data

We use your personal data to operate the Platform, provide services, facilitate transactions, respond to inquiries, and meet regulatory requirements (e.g., anti-fraud, anti-money-laundering). Specifically, we may process data to:

Provide and manage the Platform (account setup, fraud checks, etc.).
Improve our services based on user feedback and usage trends.
Comply with legal and regulatory obligations (taxation, AML, responsible gaming, etc.).
Personalize your experience through aggregated analytics.
Contact you with service updates, offers, promotions, or surveys (opt-out anytime).
Send technical or legal notices.
Conduct targeted advertising about the Platform.
Resolve disputes that remain after our internal processes.

6. Sharing Personal Data

We may share your personal data to:

provide you with access to the Platform and perform our undertakings with you;
comply with applicable laws and regulations; or
maintain, improve, and develop the Platform.

Where sharing is necessary, we apply appropriate legal, organizational, and technical safeguards. Typical recipients include:

Affiliates;
contractors and suppliers enabling specific Platform functionality (e.g., game providers);
verification and compliance providers;
support and technical teams;
marketing teams;
advertising and analytics partners;
email delivery and verification services;
hosting providers;
government authorities (where legally required);
buyers or transferees if the Platform (or part of it) is sold; and
other integrated third-party solutions as needed.

7. Storing Personal Data

Retention periods depend on:

business or commercial needs;
legal, accounting, or regulatory requirements;
internal operational needs; and
any ongoing or anticipated investigation, dispute, or litigation.

We destroy or permanently de-identify data once it is no longer needed and we are not legally required to keep it. Generally, personal data is processed while your account is active and for seven (7) years thereafter.

8. Protecting Personal Data

We employ technical and organizational measures to preserve the confidentiality, integrity, and availability of personal data, including:

information-security and physical-security controls;
access-rights management for personnel and contractors;
regular testing and evaluation of our safeguards;
anonymization, pseudonymization, and/or encryption where appropriate; and
encrypted connections (e.g., SSL/TLS) for all Platform traffic.

9. Data Protection Rights

Subject to applicable law, you may have the right to:

Know whether we process your data and obtain a copy.
Correct inaccurate or incomplete data.
Delete data no longer required for contractual or legal purposes (subject to exceptions).
Limit use or disclosure of sensitive personal information.
Opt Out of the sale or sharing of personal information for cross-context behavioural advertising.
Manage Marketing Preferences at any time.
Data Portability – receive your data in a structured, machine-readable format.
Non-Discrimination for exercising your rights.
Opt Out of Automated Decisions with significant effects.
File a Complaint with a supervisory authority.

We may need to verify your identity before fulfilling requests. Standard response time is 45 days (15 business days for opt-out requests), extendable once for another 45 days. Appeals are answered within 45 days.

10. Third-Party Services

The Platform may link to or integrate Third-Party Services. Their privacy practices are outside our control; review their policies separately.

11. Personal Data of Minors

The Platform is not intended for individuals under 18 (or older where local law sets a higher age). We do not knowingly collect data from minors. Parents/guardians should contact us if they believe a minor’s data has been provided.

12. Changes to this Privacy Policy

This Privacy Policy is reviewed regularly and may be updated at any time. When changes occur, the “Last Updated” date and version number will be revised. Please check this Privacy Policy periodically for updates.