Privacy policy

Version 3.4
Date: 28.11.2024

Breckenridge Curaçao B.V. (“we”, “us”, “our”) is committed to protecting the privacy of any personal data that you provide to us or that we collect about you (“Personal Information”). Personal Information is information which identifies you and/or which relates to you, and may include your name, address, date of birth, payment card details, gaming history, account details, and any other information that we hold about you. We are a controller (also known as a “data controller”) in respect of your Personal Information. Data Controller is a legal term and means that we are responsible for determining the purposes for which your Personal Information is processed.

We will ensure that your Personal Information is processed in compliance with data protection laws and regulations in the countries where we operate. Accordingly, we have set out in this Privacy Policy how we use your Personal Information.

We may update this Privacy Policy from time to time, and therefore recommend that you review this Privacy Policy regularly. Where we make any material changes to this Privacy Policy, we will notify you that changes have been made.

How we collect your Personal Information

So that we can operate our Websites and mobile applications, you will be asked to provide your Personal Information for the purposes of registering and opening an account with us. You are under no obligation to provide Personal Information to us. However, certain Personal Information is essential in order for us to provide you with our services (for example, enabling you to play the games on the website) and you might not be able to obtain certain services if you choose to withhold information we have requested that is required for those services. We also collect information about the transactions you make, including details of payment cards used. We may collect Personal Information through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of our Websites, mobile applications and services. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Policy.

If you provide your name, address or any other Personal Information on the public area of our Websites, we will process this Personal Information also.

We may also collect Personal Information about you from third party service providers, such as fraud prevention companies. To fulfil our regulatory requirements, we may also collect Personal Information about you from identity verification services so we can ensure you are the owner of your identification documents when you use our Website. This includes your identity details and biometric information.

Finally, we also use “cookies” which may collect certain information about you, such as your devices’ IP addresses, which constitutes Personal Information. You can learn more about the cookies we use in the ‘Cookies’ section below.

How will we use your Personal Information?

In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are:

(i) where it is necessary to provide services to you under the performance of the contract we have with you;
(ii) where we are required to do so in accordance with legal or regulatory obligations;
(iii) where such processing is in the public interest;
(iv) where you have given your consent; and,
(v) where it is in our legitimate interests to process your Personal Information, provided that none of these prejudice your own rights, freedoms and interests.

The following is a list of the purposes for which we process your Personal Information, and the lawful basis on which we carry out such processing:

How we share your personal information

Sharing your Personal Information with our sister brands. We may share your Personal Information to other companies operating our sister brands in accordance with applicable data protection law and the terms of this privacy policy for purposes set out above in the section “how we use your Personal Information” (e.g., to manage any risks to our website and to our business, to comply with applicable laws, to send you marketing communications).

Sharing your Personal Information with our service providers. We may disclose your Personal Information to processors to provide services on our behalf. Such processors will only process your Personal Information in accordance with this Privacy Policy, and we will have a contract in place with each such processor to ensure your Personal Information is kept secure.

We also work with service providers with whom we may disclose your personal data to support our analytic reporting. One example is Adform, a service provider for programmatic campaigns. To learn more about how Adform handles your personal data, please visit Adform’s privacy notice.

We may also disclose your Personal Information to third parties that provide services to us in connection with the operation of our Website, (such as credit reference agencies, fraud prevention agencies, payment service providers, banks, financial institutions and similar third parties), in order for us and them to comply with applicable legal and regulatory obligations (including those relating to checking your identity, monitoring your behaviour on our Website, combatting money laundering, protecting our Website against any illegal use and any other activity we consider necessary to meet our obligations).

One such third party identity verification, credit reference and fraud-prevention agency is TransUnion. This credit reference agency, in conjunction with the relevant data protection regulators and the financial industry services, have developed a common form of notice called the TransUnion Bureau Privacy Notice. You can read about how TransUnion process your personal data by visiting their Privacy Centre and reading their Privacy Notice.

We may also disclose your Personal Information in the following circumstances:

• where required by applicable law or regulation to a governmental, regulatory or enforcement authority;
• in order to defend ourselves legally and/or in relation to legal proceedings; and
• where required to verify your identity, age and accuracy of your registration details, including disclosure of such information to third parties e.g. financial institutions and third party reference agencies.
• if we choose to outsource the operation of this Website to a third party service provider; and/or
• whilst negotiating a takeover, sale, purchase or merger, financing, investment, restructuring or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets, and pursuant to the same.

Third Party Services

We may use third party services for parts of our Website such as Google Maps services, including the Google Maps API(s). We do not own or control the services offered by Google and when you use their Google Maps services (including the Google Maps API(s), you will be interacting directly with Google and you may be providing information directly to Google, us or both. The use of these services is subject to their terms of use such as the Google Maps Terms of Service. When you are using the Google Maps services, Google will be processing your personal data in accordance with their Google Privacy Policy. We recommend you read Google privacy policy to understand how your personal data will be processed accordingly.

Transferring your Personal Information

We transfer your data to third party processors within the EU and also within Asia, we will take all reasonable steps to ensure that adequate measures are in place to keep your Personal Information secure and in accordance with this Privacy Policy.

We use service providers to verify your identification details, to provide you with certain marketing services, and ensure your can use our Website. Because of this, we may use service providers which are based outside the territory in which you reside. Some examples of service providers are OCR Labs and Adform. The processing of your Personal Information by OCR Labs involves the transfer of your Personal Information to certain jurisdictions which are not whitelisted for data protection and for which your prior consent is sought. The processing of your Personal Information by Adform involves the transfer of your Personal Information to the EU and for which your prior consent is sought.

Security

We have implemented extensive technical and organisational measures to protect your data from loss, manipulation and unauthorised access. Security measures include, but are not limited to, digital and physical perimeter protection, asset management, access control and operational security controls. While we will use all reasonable endeavours to keep your Personal Information safe and secure at all times, you should note that security can never be guaranteed and we may not be liable to you unless your security is compromised due to our negligence.

Marketing

We may engage the services of third party service providers and to provide you with certain marketing services. We take steps to ensure that arrangements with these parties protect your privacy by ensuring that these parties comply strictly with our instructions when they are processing your Personal Information.

Marketing communications about the website

Vera & John is a brand operated by Breckenridge Curaçao B.V., part of a group of companies that also owns other fantastic sister brands and gaming products. We do not want you to miss out on great offers, prizes and news about other current and future gaming products offered by our sister brands so when you have set out your permission to receive marketing communications from us or from our sister brands, you will also receive news about these other brands and gaming products. As a user of our Website, you can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you.

We may use your Personal Information to offer you personalised experiences on our Website. We may deliver from time to time personalised content by using cookies to understand your behaviour and online preferences. To understand how cookies are used, please see the table above and the ‘Cookies’ section below.

Marketing communications about the Website may contain details about:

• new games, jackpots and promotions available to you on our Website;
• our loyalty programme (e.g., VIP), your rewards and promotional pay-outs on our Website; and
• other promotional information about our Website.

You can opt-out from receiving marketing communications from us about the Website at any time by following the instructions below:

• Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences in your account;
• SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences in your account;
• Phone Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences in your account;
• Push notifications: to opt-out from receiving push notifications, you can disable push notifications in your device settings.

When you choose to opt-out from email, SMS or phone marketing channels about the Website, you will stop receiving marketing communications within 72 hours.

You can always change your contact preferences in the Subscriptions section of your Vera&John account page.

Social Media Marketing

We may also use information you provide to us to show you relevant advertising and personalised content about our gaming Website and from our sister brands on certain third party social media platforms (“Social Media Sites”) made available to us through those services (e.g. Facebook, Twitter). We do not control the way these Social Media Sites operate and collect your information, and you should read their respective privacy policies to understand how they use your personal information.

If you are a Facebook user, we may periodically use the Facebook Ads services to provide you with personalised content about our gaming Websites. When you are logged into your Facebook account, we may provide you with personalised content. To provide this personalised content, Facebook may be sharing information with us that you have chosen to make available pursuant to your Facebook settings. You can read more information about how Facebook uses your information in their privacy policy. We may also show you personalised and targeted advertisements on your Facebook account. If you no longer want to receive personalised and targeted advertisements from us on Facebook, you can manage your advertising preferences and decide what you want or do not want to see by using the settings in your Facebook account. You can read more details about how to manage your ad preferences on Facebook here.

Cookies

About Cookies: In this privacy policy, we use the expression ‘cookie’ to refer to cookies and similar technologies for storing information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website’s server, and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the website name and some digits and numbers.

Almost all websites and applications you visit, including our Website, will use cookies in order to improve your user experience by enabling that website and/or application to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).

Cookies do lots of different jobs that improve your use of a website or application, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. If a website or application doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the website.

Some websites, including our Website and any mobile or device specific version and any related applications of our Website (collectively referred to in this Cookies section as the “Website”), will also use cookies to enable them to target their advertising or marketing messages (based, for example, on your location and/or browsing habits).

Cookies may be set by the website you are visiting (“first party cookies”) or they may be set by other websites who run content on the page or application you are viewing (“third party cookies”).

Our Cookies: We use a number of different cookies on this Website to help us to recognise you, track your activity and improve your use and experience of the Website.

In addition, we use a number of third party service providers, who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your use and experience of the Website by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.

We and/or third parties may use cookies to collect or receive information from the Website and use that information to advertise to you on other websites. You can view the cookies used for such purposes on this Website and opt out of the collection and use of your information for such targeted advertising here: www.aboutads.info/choices.

What to do if you don’t want Cookies to be set: Some people find the idea of a website storing information on their computer or mobile (or other) device intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set but you need to be aware that you might lose some functions of that website. Most online browsers automatically accept cookies. However, if you wish to restrict or block cookies you can modify your browser settings. Information on deleting or controlling cookies is available at www.AboutCookies.org.

Retention of your Personal Information

We will retain your Personal Information for the period necessary for us to provide you with our services and to comply with our legal and regulatory responsibilities. Accordingly, your Personal Information will be retained for a minimum of six years following the closure of your account (if applicable) or the last contact with us from you. However, where deemed necessary, we will keep it longer.

Updating Your Personal Information

You can update your Personal Information at any time via your account. We request that where your Personal Information changes you update your account as soon as possible.

Your Rights

You have the following rights in relation to your Personal Information:

• a right to access your Personal Information as held by us (also known as a subject access request);
• a right to receive certain Personal Information in machine-readable format;
• a right to have inaccurate Personal Information rectified;
• where we have specifically requested your consent to process your Personal Information and have no other lawful basis to process it, you have the right to withdraw this consent; and
• a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;
• a right to object to processing where our lawful basis for processing it is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
• a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
• a right to complain to your national data protection supervisory authority;
• a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.

If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection supervisory authority.

If you would like to exercise any of your rights then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not necessarily absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

To use your name, image, username or location in publicity and marketing but only where you have provided your express and informed consent for us to do so

Contact Us

If you have any questions regarding our use of your Personal Information, or you would like to exercise any of your rights, please contact data@breckcr.com.