1. OVERVIEW

In its everyday business operations W138 makes use of a variety of data about identifiable individuals, including data about You. In collecting and using this data, the organization is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.

This Privacy Policy defines the handling of personal data including sensitive data and other non-personal data that W138 obtains from you in connection with your use of W138’s services. This Privacy Policy applies to W138.COM.

If you use W138 services, you consent to the collection, use and sharing of your personal data under this Privacy Policy. You have the option of using tools to control how we use and share your data. Detailed information about them has been included in this Privacy Policy. If you do not agree with this policy, do not access or use W138’s Services or interact with any other aspect of its business.

This Privacy Notice describes how W138.COM ('W138', 'Our', 'Us', as appropriate) collects, use, stores, shares or keeps your personal information when you use our services through our website and mobile application. It also describes your data protection rights, including a right to object to some of the processing which We carry out.

Your privacy on the Internet is very important to us. We are committed to maintaining the security, confidentiality and fair handling of the personal information collected by us in order to allow you to enjoy playing online at W138. At all times we aim to comply with our duties and your rights under data protection laws.

2. INFORMATION COLLECTED AND MEANS OF COLLECTING

We collect the following information about you :

  • Personal information you provide to us when you use our website or register for an account with us, this may include first and last name, date of birth, Banking and financial details, username and password, proof of age and identity, email address, phone number or other contact information;
  • Technical information about your device and the platform such as administrative and traffic information including but not limited to: source IP address, time of access, date of access, type of devise, web page(s) visited, language use, your location, roaming trace, software crash reports and type of browser used. This information is essential for the provision and quality of the Services.
  • Your public profile, including, name, photo and other information you make available to us when you like, post or otherwise interact with our social media pages such as Facebook, Twitter, Google+, Weibo, Zalo page and others.
  • We keep records of communications when you contact us or otherwise interact with us, including via e-mail, text message (SMS), online, messaging Apps such as WhatsApp ,Wechat, QQ, Zalo, Line, Telegram, Viber, Skype, telephone or live chat function on our Website;
  • When you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the services.
  • Information about Your deposits and withdrawals.
  • Other information from third parties databases to comply with our legal and regulatory obligations.
  • We may also receive your personal information from online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors.
  • We may collect additional information about you where you provide such information to us through your use of our services.

3. FAILURE TO PROVIDE INFORMATION

If you fail to provide that information – such as copies of documents to confirm your identity – we may be unable to provide your requested service.

4. INFORMATION USE AND LEGAL BASIS

  1. To provide a requested service or carry out a contract with you:
    • Provide customer support and service messages, including messages requesting your feedback on our services and notifying you about changes to our website, services or changes to our terms, conditions and policies.
    • To conduct security reviews at any time to validate your identity, age, the registration information provided by you and to verify your use of our services and your financial transactions for potential breach of our General Terms and Conditions and of applicable law. Security reviews may include for example, ordering a credit report and/or otherwise verifying the information you provide against third-party databases.
    • To process any of your online transactions and payments (including disclosing your personal information to third party payment processors, and other financial institutions as necessary).
  2. To conduct our business and pursue our legitimate interests:
    • To investigate and address inquiries, questions and complaints and respond to any feedback.
    • To post in-game activity to your news feed and share content with other players which may lead to any Points or any Rewards (such posting of in-game activity can be controlled in your privacy settings).
    • To assist your participation in third-party promotions, market research and events.
    • Customer telephone , email and chat conversations may be recorded to allow us to improve the quality of our customer service and our products, train staff and to record what is said in the event of a subsequent complaint.
    • Provide you with promotional offers and information where you have indicated or we have inferred an interest in our Products.
    • We monitor use of our websites and online services, and use your personal information to help us improve and protect our content, services and websites, both online and offline.
    • We use personal information to personalise our website and services for you.
    • We monitor customer accounts to prevent the use of unfair practices in our website.
    • We use personal information to investigate any complaints received from you or from others, about our websites or our services.
    • We may be required to share your data with trusted third parties who provide us with services relevant to our provision our gambling services, including customer support, information security, payments, marketing, data analysis, research and surveys.
    • We will use personal information in connection with legal claims, and for compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
    • We use your personal information in order to build up a profile of your demographics, likely behaviours and preferences. This is used to inform the decisions we make in relation to the services, content and promotions we offer. We also report on the different contribution to our commercial performance from different customer profiles. We create profiles through manual or automated processes, including from third-party providers.
  3. In accordance with your preferences:
    • Subject to your marketing preferences (if applicable) , we will use your personal information to deliver marketing communications which may be of interest across various platforms, such as email, text message (which includes WhatsApp, and Skype instant messenger), telephone, mail post, online, inbox messaging, push notifications or other available channels to provide you with information regarding our products, services and promotions, including other gaming products (such as online poker, casino, betting and bingo services).
    • To share your contact details with selected media partners and affiliates for the purposes of them being able to offer their own marketing services to you. We only do this where we have your consent and in line with your marketing preferences.
    • If we send you a marketing email or SMS, it will include instructions on how to opt out of receiving these marketing communications in the future. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
    • We will, from time to time, send you marketing material which may of particular interest to you based upon your behaviours i.e. your betting and gameplay activity, trends and interests. These marketing messages will provide you with information about the products, services, active promotions or offers available to you by W138 and information about products and services provided by our selected partners and third parties.
    • Except where we use your personal data for marketing purposes on the basis of your prior written consent and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.
    • We may publish players’ aliases and/or chat names, along with any winnings and prizes received, on our websites in accordance with our legitimate interests.
    • To enter you into surveys or promotions you have agreed to.
    • We place cookies and use similar technologies in accordance with our Cookies Notice for more information please refers to our Cookie Notice.
    • On other occasions where we ask you for your permission, we will use your personal information for the purpose which we explain at that time.
    • Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You can opt-out of this at any time by updating you marketing preference.
    • Most browsers and applications also allow you to control notifications settings. For example, when you first download our betting application on IOS, you will be asked to allow or block notifications from our application.
  4. For purposes which are required by law:
    • In response to requests by government or law enforcement authorities conducting an investigation.
    • Investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.

5. HOW LONG

Personal data may be processed and stored as long as W138 has a legally legitimate interest and this interest overrides your interests and fundamental rights. If the interest of W138 regarding the processing and storage of your data is not superior to your interests and fundamental rights, the data can still be processed and stored if necessary by law. In such cases, the data may be stored only for the purpose of meeting the requirements of legal provisions.

How long W138 keeps information it collect about you depends on the type of information. W138 will retain your personal data only as long as it is necessary to meet the objectives set out in this Privacy Policy. After such time, W138 will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible regarding legal and technical possibilities.

6. MONITORING

We may monitor and record communications with you (such as telephone or chat conversations and email) for the purpose of quality assurance, fraud prevention and compliance.

7. MINORS

W138 takes our responsibility to protect children from the social impact of wagering seriously, until they are legally able to make such decisions. W138 will not accept information from minors for the purpose of opening a wagering account.

We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected]

8. CONFIDENTIALITY

W138.com undertakes substantial efforts to protect your confidentiality, identity, preferences and other information it has collected about you and we will not knowingly allow access to this information to anyone outside W138.com, other than as described in this Policy.

All W138.com employees are required to comply with the terms of this Policy. This Policy provides that employees are obligated to keep your information strictly confidential. This obligation continues once an employee has left W138.com.

You should also do your part in protecting your information. Your W138.com Player password is confidential and we recommend that you not divulge it to anyone or enable others to discover it.

Limits of confidentiality : Due to the existing legal, regulatory and security environment, W138.com may be required, under certain circumstances, to disclose personally identifiable information about our Players. W138.com will use its best reasonable efforts to limit such disclosure to the following:

  • Where W138.com believes in good faith that it is required to do so in response to a subpoena, warrant or other legal process; or
  • where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce W138.com’s rights.

Further, we can, and you authorize us to, disclose your identification, name, street address, city, post code, country, phone number, e-mail, and company to third party agents of W138.com as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.

9. DISCLOSING YOUR PERSONAL INFORMATION

We may disclose information about you;

  • To other companies in the W138, which its direct and indirect subsidiary companies for internal reasons, primarily for business and operational purposes in line with this privacy notice;
  • To third party service providers, who will process it on our behalf for the purposes identified above. Such third parties include providers of website hosting, maintenance, call centre operation, identity checking, information verification services, marketing, data analysis, research and surveys, third-party electronic payment processors and/or financial institutions to process financial transactions and other organizations that provide technical support, process your online transactions and maintain your account;
  • With law enforcement and public authorities in order to comply with any legal obligation or where We believe we are under a duty to comply with an obligation.
  • With third parties in order to enforce our terms of use and any other agreement; or to protect the rights, property, safety, or security of W138, third parties or the public;
  • With other online gaming sites, banks, bank card companies, and appropriate agencies, where you are found to have cheated or attempted to defraud us or any other user of our services, which may include but not limited to game manipulation, payment fraud, or prohibited transaction (including money laundering); and
  • With third parties in the event of sale, purchase of assets, merger, bankruptcy or reorganization proceeding.
  • In the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
  • In order to enforce or apply our website terms of use

10. ADVERTISEMENTS

We use a third-party advertising technology to serve advertisements when you visit the platforms and use the services. This technology uses non-personal information (technical, gameplay, device and connection, analytic, anonymous, data combination) with regards to your use of the services to serve advertisements to you (e.g. by placing third-party cookies on your web browser). We may also use our third parties and share with them non-personal information to assist us in evaluating the success of our advertising campaigns and help us retargeting our users. You may opt-out of many third-party ad networks.

Where we have the appropriate consent or lawful basis and subject to your preferences, some of your personal data can be processed by our 3rd party marketing partners in order to allow us to communicate with all our customers either by (i.e. phone, email, push notifications).This may include Email & SMS sending platform providers, prize or gift suppliers, etc.

All our marketing communications, will include instructions on how to opt out of receiving this specific type of marketing communication. It can take up to 48 hours following on from your request for this to be fully carried out.

11. YOUR RIGHTS

By law, you have a number of rights when it comes to your information. You can exercise any of these rights by contacting us through our contact information below.

  • The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing.
  • The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
  • The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice).
  • The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold.
  • The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold. This right is not absolute and will not apply when legitimate and overriding reasons apply.
  • The right to restrict processing. You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but will not use it further.
  • The right to data portability. You have rights to obtain and reuse your information for your own purposes across different services. This is not a general right however and there are exceptions.
  • The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See contact section above.
  • The right to withdraw consent. If you have given your consent to anything we do with your information you can withdraw your consent to the processing of your information at any time.

12. SECURITY

We understand the importance of information security and the techniques needed to secure information. We use reasonable organisational, technical and administrative measures to protect your personal data from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold and we take steps to ensure our subsidiaries, agents, affiliates and suppliers also employ adequate levels of security.

We employ industry standard procedures and controls to ensure the safety of our users ‘information, such as:

- Secure network topology, which includes instruction prevention and Firewall system;

  • Encrypted communication;
  • Authentication and access control;
  • External and internal audit tests; etc.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the services, and we make no warranty, express, implied or otherwise, that we will prevent such access. You acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the interne

In order to comply with our legal and regulatory requirements, personal data will not be kept for longer than is necessary (generally not more than six years after the closure of your account). All such information will be held in accordance with this privacy policy.

Our W138.com website is registered with site identification authorities to enable your browser to confirm our security identity before any transmission is sent. With this technology, the identity of our site is automatically confirmed behind the scenes prior to the transmission of any customer information requested to complete an online order and ensures that your data reaches your intended target or your browser notifies you (prior to your sending any personal information) that the potential receiving site looks suspicious and should be avoided. Security Guarantee If you are using a security-enabled browser (such as Microsoft Internet Explorer, Firefox, Chrome), the information you send us regarding your purchase is encrypted, making it extremely difficult to read even if it is wrongly intercepted. At W138.com, we utilize industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of: potentially sensitive information such as your name and address and other critically sensitive information like your credit card number. Standing behind our security technology, we also provide our Website Security Guarantee, further ensuring that you are protected every time you buy online with us. For more details, take a look at this guarantee.

13. RETENTION OF PERSONAL INFORMATION

The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether any legal obligations require the retention of the data (for example, for regulatory compliance). We will retain data about you for at least as long as is necessary to fulfil the purposes for which the data was collected. Where We process your personal information for marketing purposes or with your consent, We process the personal information until you ask Us to stop and for a short period after this (to allow us to implement Your requests). We also keep a record of the fact that you have asked Us not to send you direct marketing or to process your personal information indefinitely so that We can respect your request in future.

Where We process your personal information for compliance with our legal obligations, We will do so in accordance with all retention periods specified by applicable law.

14. COOKIES

You agree that we may, from time to time, place cookies on your device to save information (such as user name, password, other personal details, e-mail address, technical device information such as the model and its IP address) to make full use of the functionality and services on our website and to allow your browser to identify you as a user. These cookies cannot be used to run programs or deliver viruses to your computer, and are uniquely assigned to you. It can only be read by the web server(s) that placed the cookies on your device

We may use cookies as a means of collecting information from a web server for the above purposes following a customer's use of the Website. If you register with us or if you continue to use the website, you agree to our use of cookies.

A cookie is a text-only string of information that we send to the cookie file of the browser on the hard disk of your computer, smart phone or another device, if you agree. These cookies allow us to distinguish you from other users when you visit and/or use our website. We may use the data generated from cookies to compile statistical data on your use of our website. You are not obliged to accept cookies from us and you have the ability to accept or decline cookies at any time by modifying the settings in your browser.

Online browsers can usually be set to either accept or decline cookies. However, if cookies are declined You may not be able to fully experience the interactive features of the Service.

If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Website, you can do so by deleting your existing cookies and/or altering your browser's privacy settings to block cookies (the process you follow will different from browser to browser). Please note that deleting our cookies or disabling our future cookies means that you may not be able to access certain areas or features of the Website.

To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of services. W138 and its third party partners also collect information using web beacons (also known as "tracking pixels").

Many browsers include their own management tools for removing HTML5 local storage objects.

You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the services.

For help on how to modify your browser settings, see our FAQs here.

15. SOCIAL MEDIA

We want social media to be a friendly and relaxed environment for all to enjoy. We use social media to talk to you, answer your questions, supply you with news and let you know about things you might be interested in, including market movers. Views and news published by W138 does not constitute betting advice and should not be treated as such.

To ensure our social media pages are enjoyable for all users please adhere to the following rules:

  • Our social media channels are restricted to individuals aged 18 and older.
  • You may not advertise or promote non-W138 products via our social media channels without prior consent from W138 via [email protected]
  • Any betting opinion or news expressed by W138 does not constitute betting advice and should not be treated as such.
  • W138 cannot be held responsible for the content of others on our social media channels.
  • No gambling of any kind may take place between W138 and its customers via W138 social media channels.
  • Any racism, sexism, bullying or harassment of any kind will be removed and the original poster may be blocked temporarily or permanently.
  • Any defamatory language will be removed and the original poster may be blocked temporarily or permanently.
  • W138 retain the right to remove any content or block any user, temporarily or permanently.
  • Content on our social media channels could change at any time and should not be solely relied upon.
  • If you have any problems regarding our social media pages please email us: [email protected]

16. CHANGES TO OUR PRIVACY NOTICE

  • By opening an Account with W138.com, you agree to the terms of this Policy, we may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on this website. We encourage you to review this Privacy Policy regularly for any changes.
  • Your continued use of the Services, following the notification of such amendments on this website, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
  • If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavors to inform you by email, notice on the Website or other agreed communications channels. If you do not agree to the changes you should cease using this website. If there is any conflict between these terms and specific local terms appearing elsewhere on W138.com then the latter shall prevail.

17. HOW TO CONTACT US:

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email [email protected]

We will make an effort to reply within a reasonable time frame. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.