Bankrolla Privacy Policy

Last Updated: March 26, 2025
Version: 1.0
Previous Version: N/A

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.
Transaction Data, such as: transaction history, banking and financial details, credit card details and bank account statements. We do not store your full card details, this information is processed by our authorised licensed payment agent.
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, such as the content you view, the time and duration of your visit on our Platform, how often you use the Platform, how you first heard about the Platform, website you used before the Platform, your preferences and information about your interaction with the Platform, your hardware model, device type, other unique device identifiers, operating system version, browser type and IP address.

4. Sources of Personal Data

We collect your personal information as follows:

Directly From You: When you directly provide your personal information to us, such as Identity Data, Contact Data, Communication Data that you provide to us when you create an Account or otherwise use the Platform or contact us.
Automatically From Your Device: When you visit the Platform, your device automatically shares certain information with us, including via cookies, such as Usage Data described above.
Automatically From Third Parties: When the information is provided from a Third-Party Service integrated with the Platform, such as Usage Data, or when we request information about you from third-party sources, such as Watchlist Data or when we validate your Identity Data or Transaction Data. We use various tracking technologies to automatically collect the Usage Data, these include:
Cookies: Small text files stored in your browser to remember preferences and improve functionality. You can block or delete cookies through your browser settings, but doing so may affect service performance.
Pixel Tags/Web Beacons: Embedded code on our website or emails that tracks user interactions, such as page visits or email engagement, to measure the effectiveness of content and advertisements.
Mobile Device Identifiers: Unique advertising identifiers (e.g., Apple IDFA, Google Advertising ID) that help us and our partners deliver relevant ads. You can manage ad preferences through your device settings.
Event Tagging: Technologies (e.g., Facebook App Events) that track user actions such as app installs and purchases, enabling us to measure ad performance and improve targeting.

5. Using Personal Data

We use your personal data to operate the Platform, provide our products and services, facilitate your transactions within the Platform, respond to your inquiries, and fulfill all applicable regulatory requirements, including anti-fraud checks and compliance with anti-money laundering and other relevant legislation. We can also use your personal data if it is necessary for litigation or protection of our or third-party rights.

In particular, we may process your personal data for the following purposes:

To provide and manage the Platform: This includes processing your registration, setting up and maintaining your account, and conducting checks to detect fraud or unauthorized access.
To improve our services: The information you provide helps us respond to your requests and enhance our services.
To process transactions: We may use your personal information to process your orders or distribute prizes.
To comply with legal and regulatory obligations: We may use the information we collect about you to assess your social gaming activity for taxation compliance, adherence to fraud and anti-money laundering laws (including verifying identity and the source of funds for transactions) or responsible gaming purposes. Additionally, we may use this information to detect, investigate, and prevent activities that violate the Terms or may be illegal.
To personalize user experience: We may analyze aggregated data to understand how users interact with the Platform.
To contact you: We may reach out via email, live chat, telephone, text message, mail, or social media regarding your use of our services, account-related updates, offers, promotions, competitions, surveys, and new features available to you. You may opt out of marketing communications at any time.
To send technical or formal notices: From time to time, we may send important notices regarding Platform accessibility, purchase confirmations, or legal updates.
To conduct advertising: We may use the information we know about you to conduct targeted advertising, so you know more about the Platform and its offerings.
To resolve a dispute: If a dispute remains unresolved through our internal processes, we may process your personal data for the purpose of resolving the dispute.

6. Sharing Personal Data

We may share your personal data to:

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

If we share any portion of your personal data with third persons, we will reasonably endeavor to secure such transfer using appropriate legal, organizational, and technical measures.

In particular, we may share your personal data with the following categories of recipients:

Affiliates;
contractors and suppliers who need to have access to your data in order to allow you to use certain functionality of the Platform, including the Game providers;
verification and compliance providers;
support and technical teams;
marketing teams;
advertisement and analytical solution providers;
email delivery service providers;
email verification service providers;
hosting service providers;
payment processors and payment service providers;
government authorities, upon their request or if necessary to comply with our legal obligations;
another person or entity if we sell or otherwise transfer the Platform or its parts; and
other third-party solutions, which may be from time to time integrated in relation to the Platform.

7. Storing Personal Data

We will retain your personal information for various periods of time to reasonably fulfill the purposes specified in this Privacy Policy which will be determined based on the following:

the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained;
any legal, accounting, reporting or regulatory requirements applicable to such information;
internal operational needs; and
any need for the information based on any actual or anticipated investigation, dispute or litigation.

We will take reasonable steps to destroy or permanently de-identify any personal information where:

we no longer need the personal information for any purpose for which the personal information was collected, considering the foregoing reasons for determining the retention periods; and
we are not required by law, a regulator or a court/tribunal order, to retain the personal information.

As a general rule, we will process your personal information as long as you remain an active Account and for 7 years after its termination.

8. Protecting Personal Data

We strive to do our best to keep your personal data secure. We always review and update appropriate technical and organizational measures to:

keep your personal data secure in accordance with the applicable legislation, our internal policies and procedures regarding the storage of, access to, and disclosure of personal data; and
protect you against unauthorized or unlawful processing of personal data and accidental loss or destruction of, or damage to them.

We endeavor to implement and maintain reasonably necessary technical and organizational measures to protect the confidentiality, integrity and availability of your personal data. This includes:

information security measures;
physical security measures;
measures to control access rights for our personnel and contractors; and
processes for regularly testing, assessing and evaluating the effectiveness of the technical and organizational measures implemented by us.

Your personal information may undergo anonymisation, pseudonymisation, and/or encryption to ensure safe transfer and/or processing. Furthermore, all connections to the Platform are protected via the use of encrypted connections, such as the Secure Socket Layer (SSL) protocol.

9. Data Protection Rights

According to the applicable legislation, you may have the following rights (note that residents of certain states may have additional rights according to their local legislation):

Right to Know: You can request to see if we process your personal data. If we do, you can ask for details about the processing and a copy of the data to verify its accuracy and legality.
Right to Correction: You can request to correct or complete any incomplete or inaccurate data. We may need to verify the accuracy of the new information you provide.
Right to Deletion: You can request the deletion of your personal data if we no longer need it to perform a contract or under the law. We may not always be able to fulfil your request due to legal or technical reasons, which will be explained in our response.
Right to Limit Use & Disclosure of Sensitive Personal Information: You can limit how we use and disclose sensitive personal information, such as: social security numbers, financial details, precise geolocation, racial or ethnic data, health data.
Right to Opt-Out of Sale or Sharing: You may opt-out of the sale or sharing of your personal information at any time. “Sale” commonly means disclosing or making available personal information to a third party for valuable consideration, including money. “Sharing” means sharing, disclosing, making available or otherwise communicating your personal information for cross‐context behavioral advertising (targeted advertising).
Right to Manage your Marketing Preferences: If we send or intend to send marketing materials to you, you may ask us to stop such processing at any time.
Right to Data Portability: You can request a copy of personal data in a structured, commonly used, machine-readable format.
Non-Discrimination: This protects you against any discrimination for exercising any of your rights under the applicable legislation. We cannot discriminate against you in any way, including, but not limited to, denying use of the Platform, charging different prices or rates for the Platform, providing a different level or quality of the Platform to you, etc. based on your personal data.
Automated Decisions: You have the right to opt out of decisions made solely through automated processing, including profiling, that may impact your rights. You may also request information about how we use automated decision-making.
Right to File a Complaint: You can file a complaint with a supervisory authority if we violate your rights or legal obligations. The competent authority may depend on your location.

We will not discriminate against you for exercising your rights, but provision of our services may become limited. To exercise your rights, contact us according to the details provided in this Privacy Policy. In this case, we may request certain information from you to verify your identity and confirm that you are entitled to exercise such rights. We will aim to respond within 45 days, unless otherwise required by law, with the right to additionally extend the response period for 45 days. However, opt-out requests will be processed within 15 business days. If you disagree with our response, you can appeal by contacting us, and we will respond within 45 days.

10. Third-Party Services

The Platform may include links and social media plugins or may reference Third-Party Services. Clicking on them may allow third parties to collect or share your data. We do not control or endorse these third parties and are not responsible for their privacy practices. You should review the privacy policies of anyThird-Party Services you visit or use.

11. Personal Data of Minors

The Platform is not intended for children under 18 years (or older if local laws set a higher age). We do not knowingly collect or use personal data from children. If we learn that a child has provided us with personal information, it will be promptly deleted, unless we have a reason and a legal ground to process it. Parents or guardians who believe their child’s data has been collected should contact us.

12. Changes to this Privacy Policy

This Privacy Policy is under regular review, and may be updated at any time. If any changes to this document are made, we will change the “Last Updated” date and version number at the top of this Privacy Policy. Please review this Privacy Policy to check for the updates.