Privacy Policy

Introduction

Rizoco Holdings (IOM) Limited (“the Company”) referred to as “We” “Our” or “Us” is committed to protecting the privacy and security of the personal data we collect about end customers and users of our services (“you/your”).

The purpose of this privacy notice is to explain what personal data we collect about you when you interact with our remote casino and gambling website. When we do this, we are the data controller.

Please read this privacy notice carefully as it provides important information about how we handle your personal information and your rights. If you have any questions about any aspect of this privacy notice you can contact us using the information provided below or by emailing us at [email protected]

Throughout this notice we refer to data protection legislation which includes the Isle of Man Data Protection Act 2018, the EU General Data Protection Regulation 2016 (“GDPR”) and other laws mandating data protection including (but not limited to) the e-Privacy Directive. This also includes any replacement legislation which may come into effect from time to time.

Rizoco Holdings Limited is registered with the Isle of Man Information Commissioner, registration number R003698.

Our collection and use of your Personal Data are subject to the data protection laws applicable in the jurisdiction where you reside. Rizoco Holdings currently targets individuals in the following locations:

1. 1. Canada – Personal Information Protection and Electronic Documents Act 2000 ('PIPEDA') which is governed by the Office of the Privacy Commissioner of Canada ('OPC')
2. 2. New Zealand – Privacy Act 1993 and Privacy Act 2020 which is governed by the Office of the Privacy Commissioner of New Zealand (OPC)

Although Rizoco Holdings Limited currently operates in the above locations, this may be subject to change from time to time whereby access to services may also be available in other locations. Rizoco Holdings Limited will always ensure that it complies with the applicable data protection law in the jurisdiction it operates irrespective of whether it is specifically set out in this Privacy Notice.

Rizoco Holdings Limited operates the website www.privecity.com in reliance to an Isle of Man licence with the Isle of Man Gambling Supervision Commission (“IOMGSC”) to provide remote casino and gambling to end users. For the purposes of data protection, the Company is the Data Controller with regards to customer data as we have determined the purposes of why personal data should be collected and processed.

You can contact our head office using the following details:
Attention: DPO
Postnet suite no 45
Private Bag X29
Gallo Manor
Johannesburg
2052
South Africa

Email: [email protected]

Data we collect from or about you

• Registration details: When you open an account and register to use our Services, you will be asked to provide us certain details about yourself, such as: full name, email address, date of birth, physical address, username, password, telephone number etc.

• Payment information: In order for you to use all of the functions of our services (e.g. place bets, make withdrawals, etc.), payment information will be collected from you, such as your credit card number and bank account details. This information is collected by third party payment service providers, and we do not collect or store this information ourselves. For further information you can contact us using our details as mentioned above.

• Government–issued ID: In certain instances, you will be required to provide a copy of a government-issued ID, in order for us to verify your identity. Please note that this information may be required in order for you to use or continue using our services.

• Public information: In certain instances, such as customer due diligence verification, we may need to search publicly available sources of information to confirm your identity or source of funds (for example, electoral rolls or databases regarding property values).

• Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email, live chat or otherwise, or share additional information about yourself through your use of our services. We also collect details of any deposit, spend or loss limits that you have set.

• Information we collect from third parties: We collect data about you from third party service providers, such as confirmation of your age and address and other financial information which is relevant and required for the provision of our services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

• Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: your device’s unique identifiers and geolocation data. We may also gather information with regard to other software which is running simultaneously with our Services for detecting if you are using software which is associated with fraudulent activity (e.g. bots, malware) or checking if the connection you are using is via a VPN or proxy.

• Gaming information: in order for us to provide our services, we automatically record different information related to your use of our services, including with respect to your transactions, balances, bets, withdraws, bonuses and winnings etc.

• Technical information: In order to enhance the functionality of our Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. your language preference, the type of browser and operating system your device uses, access time, the domain name of the website from which you linked to our services; etc.).

• Analytics information: We collect information about your use of our services, such as app usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research, profiling and analytics purposes about your use of our services, and providing you with tailored marketing and personalized products and services.

You are under no obligation to provide personal information to us. However, certain personal information is essential for the provision and quality of the services that we offer (for example, enabling you to place bets on the website or conducting verification as mandated by the law) 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.

Purposes for which we use personal data and the legal bases for processing

In accordance with data protection laws, we will only process your data where we have a lawful basis for doing so. There are four relevant lawful bases for processing personal data that may be relevant when we process data about you (depending on the type of processing being conducted):

1. Consent: you have given us consent.

2. Contract: the processing is necessary to perform a contract we have entered into with you, or because you have asked us to take specific steps before entering into a contract.

3. Legal obligation: the processing is necessary for us to comply with laws or regulations that apply to us (not including contractual obligations).

4. Legitimate interests: where it is in our legitimate interests to process your personal information, provided that our legitimate interests are not overridden by your own rights, freedoms and interests.

When providing services to you, we may use your personal data for the following purposes and on the following lawful bases:

If you do not wish for us to use your personal information in order to provide the personalised betting service to you, you can withdraw your consent by contacting us at any time or by the profile settings on our website.

Who we share your information with

• We share your personal data with the IOMGSC and other gaming regulators with whom we are licensed.

• We use third party payment service providers to process payments to and from your account. These third party providers will have access to or process your payment card information for the purpose of providing these services to us but we do not collect or store the payment card information.

• We use third party providers in order to manage aspects of your account; including antifraud and anti-money laundering checks, credit risk checks. These third party providers may have access to or process your personal information for the purpose of providing these services to us.

• We use third party service providers in order to advertise and market to you, if you have given us express consent to do so. Such consent can be withdrawn by you at any point.

• We use Customer Relationship Management (CRM) tools in order to manage our advertising activities. Your personal data may be shared with these third parties for this purpose. You will only receive advertising material from us or our partners if you have opted to receive marketing materials.

• We may share some or all of your personal information in connection with or during negotiation of any potential sale or investment in any of the companies in the Group or in the event of a corporate transaction (e.g. a sale of a substantial part of our respective businesses, a merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets). In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset. In the case that the new designated data controller wishes to process any personal data transferred as a business asset, consent must be obtained from the data subject(s) prior to any processing of the personal data in question.

• In some cases we may disclose your personal information and any other information and/or records relating to you, if we are under a duty to disclose or share these details in order to comply with any legal obligation, or when ordered to do so by any governmental or administrative authority. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law.

• The above list is representative and not exhaustive

As a gambling operator, we are subject to strict legal and regulatory obligations to ensure you can use our Services. Because of this, we may share your personal information with certain third party service providers (such as verification agencies, fraud prevention agencies, payment service providers and similar third parties) that are also “data controllers” in respect of the personal information about you that is held by them.

Upon request we can provide a full list of suppliers and third parties we use to process personal data. To request this please contact us using our details above.

Where we use data processors we always ensure that this is undertaken pursuant to a written contract that includes the necessary data processor clauses as set down under data protection legislation.

How long we keep your information

We will retain your personal information for as long as it is reasonably necessary for our legal and business purposes. Please note that we may be required in certain circumstances to retain your information indefinitely (for example, in order to comply with our policies and procedures in connection with responsible gambling and self-exclusion). As required by our regulators at the IOMGSC (as applicable), we will also keep your personal data and all the details of your financial transactions for a minimum period of five years after the closure of your account with us. We will take all necessary steps to ensure that the privacy of your information is maintained for the period of retention. Once any mandatory retention period has elapsed, we will delete or anonymize any personal information no longer required to be held by us.

Children’s Privacy

The Company does not knowingly collect information from children under the age of 18 years old. If we become aware of anyone under the age of 18 using our services we will delete their personal data and block them from accessing our services.

Your data protection rights

You have rights in respect of your Personal Data. The specific rights available to you depend on your country of residence. If you are in the European Economic Area or UK, please refer to Section EEA or UK Resident of this Privacy Policy. If you are a resident of Canada or New Zealand, please refer to you relevant Country below.

If the specific rights for your country of residence are not covered below, Rizoco Holdings Limited will still ensure that it adheres to any right requests under the applicable legislation in your country of residence.

EEA Rights

The right of access

You have the right to access your personal information.

You can ask us to provide you with all the personal information we hold and/or process about you.

The right to access is free of charge, unless this a repeat request or a manifestly unfounded or excessive. In such cases we can charge a reasonable fee for the administrative costs of complying with the request. We will provide the requested data within 1 month of the request (or within 3 months where the request is complex). If responding to your request will take us more than 1 month we will write to you prior to the expiration of the 1 month period to advise you that this is the case. In any event we have to provide a full response to you within 3 months.

The right to rectification

You have the right to request that we rectify and correct any personal information that we are processing about you which is incorrect, whether that is an accidental error (such as a typo), because something has changed (address/email) or otherwise.

We want the information we keep about you to be as accurate as possible. You can amend your personal information in the My Account section of the Website or contact us and ask us to correct and/or erase incorrect and/or inappropriate data.

The right to erasure

You have the right to request that we erase your personal information where there is no compelling reason for us to continue processing it (“right to be forgotten”).

We will respond to requests to exercise the right to be forgotten within 1 month of the request. However, this right is not absolute and only applies in certain circumstances.

If the request relates to marketing that you had previously opted into, we will assist you in opting out of this.

If we cannot comply with your request, we will let you know why this is and the reason for retaining your data.

The right to restrict processing

You have the right in certain circumstances to request that we suspend our processing of your personal information.

If you think the data we hold is inaccurate or has been unlawfully processed then you can contact us to request that the data you provided is restricted from processing.

Where we agree to suspend our processing of your personal information we will still be permitted to store your personal information, but any other processing of this information will require your consent, subject to certain exemptions.

The right to data portability

You have the right to be provided with personal information that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a structured, machine readable and commonly used format and you may also have the right to request that we transfer the personal information directly to another data controller without hindrance, if it is technically feasible for us to do so.

The right to object

You have the right to object to our use of your personal information which is processed on the basis of our legitimate interests.

However, we may continue to process your personal information, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal information in connection with any legal claims.

The right to be informed about automated individual decision-making, including profiling

If automated decision-making is necessary for the performance of the contract we have with you or based on your consent, you have the right to obtain human intervention, to express your point of view and to contest the decision.

The right to withdraw consent

Where we have relied upon your consent to process your personal information, you have the right to withdraw that consent.

To exercise any of your rights regarding your personal data please contact us. Some changes can be made directly by you on the website from “Profile > My Account > Account details”. Please note that not all of your rights are absolute, and we may be entitled to extend the period for dealing with your request if it is complex. We also have the right to take suitable steps to confirm your identity before responding to a request.

We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

The right to complain

You have a right to raise concerns with, or complain to, us by sending an e-mail or letter using the contact details provided at the top of this Privacy Notice.

You can also report any concerns or complaints to the Isle of Man Information Commissioners Office at htttps://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/data-protection-complaints/

Canada – Data Protection Rights

PIPEDA gives you the following rights in relation to your personal data:

• You have the right to access your personal information.

• You may be asked to confirm your identity, you will only be charged a fee for this request in limited circumstances.

• An organisation has 30 days to respond to an access request, unless within this timeframe there is a justifiable reason to extend the period. There are situations where a request can be refused.

• You have the right to challenge the accuracy and completeness of the information you are provided access to, and to have it amended as appropriate.

• You may be entitled to request deletion of information involved in an accuracy challenge.

• You have the right to withdraw your consent.

New Zealand – Data Protection Rights

The New Zealand Privacy Act gives individual’s various rights including the right to:

• request access to, or correction of, your personal information; and

• the right to make a complaint about how your personal information has been handled.

• We will respond to your request as soon as is reasonably practicable after receiving the request, and in any case, no later than 20 working days.

Where we store, process and/or transfer your information

All information you provide to us is stored on secure servers maintained by us or suitable third parties. All payment transactions are encrypted using Transport Layer Security (TLS) technology and our payment processors are PCI DSS accredited thus ensuring the protection of your payment details.

The personal information we hold about you is primarily stored and processed within the EEA (European Economic Area). However, when your information is transferred to our 3rd party suppliers, then your data may be processed outside of the EEA.

Where we transfer Personal Information from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take steps to ensure that your data is treated securely and in accordance with this privacy notice. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it.

How we secure your information

We employ various technical and organisation security measures to protect your personal data.  We maintain technical safeguards relating to secure system configuration, access control, data encryption and monitoring which are designed to protect against unauthorized access, disclosure, modification or loss of information.  We maintain a principle of least privilege to ensure access to your information is restricted only to those employees who have a legitimate 'need to know' within the remit of their role.  You also have an important role in protecting your personal information; account credentials should be unique, with complex passwords and should never be shared or re-used across other services.

If we become aware of any loss, misuse, alteration of personal data we will work closely with our IT team, DPO and other parties as necessary to investigate the incident at hand. We have put into place the relevant procedure and policies in place to investigate, mitigate and report (when needed to relevant parties) such instances.

Cookies, tags and other identifiers

1. Introduction

Rizoco Holdings Limited (“Rizoco Holdings Limited”, “we, “our”) uses cookies on its website. This Cookie Policy explains more about cookies and why we use them. It also explains how you can control and opt out of receiving them.

This policy should be read together with our Privacy Notice which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

We update this Cookie Policy from time to time in response to changes in applicable laws and regulations, changes to our processing practices and to products and services we offer. When changes are made, we will update the final section of this policy. Please review this Cookie Policy periodically to check for updates.

2. About Cookies

Cookies are NOT viruses. A cookie is a small text file which may be downloaded to your device when you visit our website. We use cookies to allow our website to function correctly, make services more user-friendly, remember your preferences and to track visitors to our website.

The cookies we use on our website fall into the following categories:

Statistics or Analytics Cookies

We use cookies to collect information about the use of our website by visitors such as the pages they visit most often, how they arrived at our website and associated information. These do not collect any directly identifiable personal information about visitors.  We use these cookies to learn more about how our website is used to identify problems and areas for improvement.

Performance Cookies

This type of cookie collects information about how you use our website e.g. which pages you visit, and if you experience any errors. The information collected is anonymous and is only used to help us improve how our website works, gauge what interests our users and assess the effectiveness of advertising.

Functionality Cookies

Functionality cookies remember the choices you make when you visit our website. This includes, for example, your consent to the use of cookies on our website. This type of cookie remembers your preferences for tools found on our website, so you don't have to re-set them each time you visit. Some of them are managed by third parties.

Marketing or Targeting Cookies

These are cookies placed by third parties on our website which record your visit to our website, the pages you have visited and the links you have followed. They use this information for advertising purposes.

We and our service providers use these log files, tags, and tracking technologies to collect and analyse certain kinds of technical information, including:

• The type of device you are using;
• Your operating system version;
• Your mobile device's identifiers, like your MAC Address, Identifier for Advertising, and/or International Mobile Equipment Identity (IMEI);
• Your browser types;
• Your browser language;
• Referring and exit pages, and URLs;
• Platform type;
• The number of clicks on a page or feature;
• Domain names;
• Landing pages;
• Pages viewed;
• The amount of time spent on particular pages; and
• Game state and the date and time of activity on our websites or games.

Learn More About Cookies

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see details in the table below.

For further information on cookies generally, including how to control and manage them, please visit www.aboutcookies.org or www.allaboutcookies.org.

3. Cookies Used by Rizoco Holdings Limited

The cookies we use on our website and their purposes are as set out in the following table:

4. Cookie Sharing with Third Parties

Please note that we do not share the information collected the cookies we set with any third party. A third party may share the information collected by the cookie [e.g. Google Analytics] with third parties for the purposes of targeted advertising. Please visit their privacy policies for more information, using the links set out in the table above.

5. Changing Your Cookies Preferences

You can allow or block cookies by activating the setting on your browser that permits you to change the setting of all or some cookies. Please note that disabling cookies may affect the availability or functionality of our website. Most of the website will function normally, however, functions that rely on cookies such as (e.g. the use of our online enquiry form) will be disabled.

If you would like more information on how to manage cookies on some popular browsers, please click on the links below.

• Internet Explorer
• Google Chrome
• Apple Safari
• Microsoft Edge
• Mozilla Firefox

In addition, Google Analytics provides its own opt-out options: http://tools.google.com/dlpage/gaoptout 

N.B. In the case of some mobile devices, it may be necessary to consult the device's instruction manual to manage cookies effectively.

6. Contact Us

Please contact using the details set out in our Privacy Notice if you have any questions about this Cookie Policy or the information we hold about you.

7. Changes to this Policy

This policy was published on 05/04/2023 and last updated on 11/06/2024.

Third Party Websites

The website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we are not responsible for and have no control over information that is submitted to, or collected by, these sites.

Review and Updates

We will review this notice and make changes to it from time to time. We recommend that you check this notice to see where changes have been made and to ensure you are able to review updated information at all times.

Privé City is operated by Rizoco Holdings Limited a company registered in the Isle of Man, under company number 020031V, having its registered address situated at Second Floor, 14 Athol Street, Douglas, IM1 1JA, Isle of Man. Rizoco Holdings Limited is licensed and regulated by the Isle of Man Gambling Supervision Commission pursuant to a licence issued under the Online Gambling Regulation Act 2001 on 2 March 2023. All gambling debts are enforceable in Law in the Isle of Man. Rizoco Holdings Limited strictly prohibits participation by persons under the legal age of 18 years.