Version number: 1.1 Last update: 05-12-2025
INTRODUCTION
Welcome to Tarnelux Holdings Limited's Privacy Notice.
Tarnelux Holdings Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can print a version of the notice by pressing the button at the bottom of this page. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
PURPOSE OF THIS PRIVACY NOTICE
INTRODUCTION
We have implemented a Privacy Notice because your privacy, and the privacy of other Site users, is important to us. We provide this Privacy Notice explaining our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site and certain services that we offer through or in connection with the Site.
“Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information. It does not include data where the identity has been removed (anonymous data).
English and Translated Versions. If you are reading a translation of this Privacy Notice in a language other than English, you acknowledge and agree that (i) the English version is the official version; (ii) the non-English version is provided for your convenience only and the translation will not be valid as an agreement; and (iii) in the event of any inconsistency between the English and a non-English version, the English version will prevail and govern.
Consent and Modification. By using the Site, you consent to the terms of this Privacy Notice and to the processing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Notice, please do not use the Site. We reserve the right, at our discretion, to change the Privacy Notice at any time; most current version will always be posted on our Site (as reflected in the “Last Revised” heading); we encourage you to review this Privacy Notice regularly for any changes. In case of material changes we will notify you through our Services or by email.
Personal Data Changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
CONTROLLER
Tarnelux Holdings Limited, referred to as the Company in this Privacy Notice, is the Controller and responsible for determining the purpose and means of personal data processing (this can be determined alone, or jointly with another person/company/body).
Contact Details
Our full details are:
MERCHANT OF RECORD
The Merchant of Record is Elidessa Limited, which is a company registered in Cyprus (registration number HE 477602), with its registered address at Cheilonos 2A, The Riverside Forum, 2nd Floor, 1101 Nicosia, Cyprus.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications, which may have privacy practices that differ from ours. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We do not currently require you to provide Personal Information in order to have access to general information available on the Site.
We may however, collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
AGGREGATED DATA
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
SPECIAL CATEGORIES OF PERSONAL DATA
Note that, unless you provide this to us yourselves, we do not request, nor do we collect, any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). In the same manner, we do not collect any information about criminal convictions and offences.
COOKIES
To enable the working of certain functions during your visit to our website, we make use of cookies on various pages. Cookies are small text files that are stored on your device. We use two types of cookies: (i) 'session cookies' which are stored temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; (ii) 'persistent cookies' which are read only by our website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial Data and Verification Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, logs files and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
CONSENT
If we wish to process your personal data for purposes not directly related to the provision of gambling services - such as for marketing - we will request your specific, informed consent. You are under no obligation to provide it, and withholding consent will not affect your ability to access or use our services.
Once given, your consent makes the processing lawful for that specific purpose. You may withdraw it at any time; however, this will not affect the legality of any processing carried out before withdrawal. In some cases, we may rely on another legal basis to continue processing your data, and we will inform you accordingly if this applies.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
MARKETING
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that marketing.
OPTING OUT
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product service experience or other transactions.
CHOICE
At all times, you may choose whether or not to provide or disclose Personal Information. The notices that we provide on the Site in circumstances where we collect Personal Information should help you to make this choice. If you choose not to provide the Personal Information we request, you may still visit parts of the Site, but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
CHANGE OF PURPOSE
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not rent, sell, or share your Personal Information with third parties except as described in this Privacy Notice.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
LEGAL OBLIGATIONS AND GOOD FAITH DISCLOSURES
We may disclose your Personal Information or any information you submitted via the Site if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:
MERGER, SALE OR BANKRUPTCY
In the event that the Company is acquired by or merged with a third-party entity, we reserve the right to transfer or assign Personal Information that we have collected as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how Personal Information is treated, transferred, or used. In any of the circumstances described in this paragraph, the information will be subject to the privacy notice of the purchaser or assignee.
THIRD-PARTY SERVICE PROVIDERS
We may disclose your personal data to the following categories of recipients, subject to confidentiality obligations and in line with data protection requirements:
We require all third parties to respect the security of your personal data and to process it lawfully and in accordance with our instructions. These parties are contractually bound to maintain appropriate safeguards and are not permitted to use your personal data for their own purposes.
INTERNAL ACCESS AND SPECIFIC USE CASES
Access to your personal data is also granted to relevant Tarnelux Holdings employees, including customer support agents and other personnel performing their job duties to provide services and support to you.
The Company may also disclose your personal data to the extent required or permitted under applicable data privacy laws and regulations.
We share your personal data within the Company and with third party service providers. This will involve transferring your data outside the European Economic Area ( EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
“Automated decision-making” is the process of making a decision by automated means without any human involvement. A decision is therefore solely automated if there is no meaningful input by a human in the final decision being made about a person. In most cases, we do not use automated decision-making when processing Personal Data as decisions will generally have human involvement. If this changes, we will take reasonable steps to confirm this to you and provide meaningful information about the logic involved, as well as the significance and the envisaged consequences for you. However, certain third parties (e.g. credit referencing agencies) may use certain automated decision-making tools or software, including artificial intelligence (“AI”). We are not responsible for any automated decision-making by third parties. “Profiling” means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's economic situation, personal preferences, interests, reliability, behaviour, location or movements etc. The context of our profiling activities is generally limited to assigning a risk-profile to our customers based on AML/CFT/CPF obligations and/or to analyse certain trends or patterns concerning gambling behaviour (particularly in the context of our responsible gambling obligations). Relevant exemptions from applicable data protection laws (such as the “EU GDPR”) allow us to undertake such activity without needing to provide further information to you if it is in the context of assigning risk profiles and reducing financial crime. We reserve our right to refuse to do business with any customer, and our non-acceptance or discontinuance of services may or may not be related to a profiling decision and/or legal obligation(s) imposed on us.
The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. To the extent that we collect certain Personal Information from you (for example, your credit card number or other financial Personal Information), we use Secure Sockets Layer (SSL) encryption to protect that information.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider factors such as the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
All data will be retained for the duration of your relationship with us and for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. After the termination of the relationship, the following data will be retained in the following manner:
· 5 years: - Identity Data, Contact Data, Technical Data, Usage Data, KYC Data, Public Sources Data, Self-Exclusion Data and Financial Data
· 10 years: - Account data
· Indefinite: - Records of indefinite self-excluded Players confirming Problem gaming
Unless otherwise instructed by you, we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary in paragraph 11 to find out more about these rights:
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
COMMITMENT
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right tooo: