INTERWETTEN GAMING LIMITED PRIVACY NOTICE

Last updated October 2025

Welcome to https://www.interwetten.com (the "Website")

This Privacy Notice explains how Interwetten processes, uses, stores, and protects personal data, and describes your rights regarding your personal data. Interwetten processes personal data for various purposes, which are outlined in Section 5 of this Privacy Notice. This Privacy Notice applies to all scenarios explicitly mentioned in Section 5.

1. Who We Are

1.1. The Data Controller of Your Personal Data is Interwetten Gaming Limited, a Maltese Company with registration number C-35736 having its registered address at The Centre, North Shore, Ground Level, Tigne' Point, Sliema TPO 0001, Malta (“Company” “We” “Us” “Our”).

1.2. By visiting Our Website and using Our Services, You acknowledge reading and fully considering this Privacy Notice.

1.3. The Company acknowledges that it is bound by Maltese laws when collecting your personal data and that it will process your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, on the free movement of such data, and repealing Directive 95/46/EC ("GDPR"), as well as the Maltese Data Protection Act.
For any further request or query about how We use Your Personal Data, You may address Us/Our Data Protection Officer through the following email address: dataprotection@interwetten.com.

1.4. Any notice, demand, request or other communication which You address to the Company shall either be sent by certified mail, return receipt requested, or by e-mail. All communication done by e-mail shall be deemed received on the business day following the day of transmission.

2. Definitions

Capitalised terms in this Notice shall have the meaning assigned to them under the GDPR and shall be construed accordingly. Furthermore, the following definitions shall apply:

2.1. Account – an account provided to You by the Company upon Your registration and acceptance of the Terms and Conditions for use of the Services.

2.2. Services – the Services provided by the Company through the Website, as defined in our Terms and Conditions.

2.3. User – any person who registers an Account via our Website or accesses and browses our Website (“You”, “Your”).

3. Principles of Data Processing

3.1. We fully respect Your fundamental rights and consider the protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We respect the following basic principles:

3.1.1. We submit Your Personal Data only to lawful and fair processing, and We maintain full transparency vis-à-vis the way We handle Your Personal Data.

3.1.2. We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Notice, and We do not process it further in any manner incompatible with these purposes.

3.1.3. We process Your Personal Data only to the extent that it is necessary and appropriate to purposes for which it is collected.

3.1.4. We make reasonable efforts to ensure that Your Personal Data is accurate and updated, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.

3.1.5. We process Your Personal Data in a secure manner by using appropriate technical and organizational measures.

3.2. In general, We comply with all applicable laws and statutory obligations as Data Controller of Your Personal Data.

4. Types of Personal Data We Process

In this Privacy Notice, “personal data” refers to any information relating to an individual who is directly or indirectly identifiable—particularly by reference to an identifier such as a name, an identification number, location data, or an online identifier. Personal data also includes one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a person.

Special categories of personal data that require enhanced protection include the following:

  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic data
  • Biometric data
  • Physical or mental health or condition
  • Sexual life or sexual orientation
  • Data relating to criminal convictions and offenses

Special categories of personal data are not processed by Interwetten unless you provide them voluntarily. In such cases, they will be retained only as long as necessary, unless legal or regulatory reasons exist to retain them longer.

We collect and process the following personal data:

4.1. During your access to and use of the Website, technical data (including IP address, browser, etc.) is automatically captured by our system and temporarily stored in log files.

4.2. During your registration, “registration data” (including first and last name, email address, username, player ID, …) is processed.

4.3. During our business relationship, certain “Know Your Customer (KYC) data” (including identification or credit data) is processed. Depending on country-specific legal obligations, we may collect additional KYC data.

4.4. During the use of payment services, “payment data” (including credit card information or bank account information) is processed.
4.5. During communication with our customer service agents, “communication data” (including chat contents) is processed.

4.6. During our business relationship, “game-related data” (including limits such as operator-specific and cross-operator limits, game scores and histories, gaming behavior, login and logout histories, details of transactions you carry out, etc.) is processed.

4.7. Any personal data that you provide to us directly and voluntarily during our interaction.

5. Purposes and Legal Basis for Data Processing

5.1. The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions, for the following purposes:

  • Enabling Your use of the Website;
  • Processing Your Account registration and maintenance (including checks made to age verify You and to guard against fraud);
  • Identification of dysfunctions and abuse of Our Services;
  • Performing payment services;
  • Enhancement of User experience, including the provision of personalized Services and improvement of the Website and the Services;
  • Administering the Website; and
  • Responding to Your requests.

When you visit our Website, we automatically collect certain personal data. The data we collect automatically includes information such as your IP address, device type, unique device identification number, browser type, geographic location (e.g. country or city), and other technical information. We also record how your device interacted with our website, including pages accessed and links clicked. This allows us to gain better insights into our website visitors, their location, and which content is of interest to them. We use this information for internal analytical purposes and to improve the quality and relevance of our website for our visitors.

We use cookies and similar tracking technologies to collect this information, as explained in the Cookie Policy.

Our Website uses Google Analytics (“Google”) to provide reports, visualizations, and analyses of data. Google processes the following types of personal data: your IP address (to create geosegmentation reports and to identify internal and external users accessing our Website) as well as user IDs, email addresses, names, and passwords to the extent these are directly provided by Website visitors. Your personal data is processed by Google for the following purposes: (i) to capture web metrics about user journeys within our site (e.g., pages viewed and links clicked), (ii) to analyze and understand general information about Website traffic, (iii) to enable us to make informed decisions about our Website, and (iv) to authenticate users and enable their access to our Website.

Interwetten Gaming Limited is the data controller. Google Analytics is provided to us by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes the website usage data on our behalf and is contractually committed to measures that ensure the security and confidentiality of the processed data. No personal data such as name, address, or contact details is transmitted to Google Analytics. This data is transferred to Google servers in the United States. We point out that the same level of data protection as within the EU cannot be guaranteed in the United States.

Google Analytics stores cookies in your web browser for a period of two years from your last visit. These cookies contain a randomly generated user ID that can recognize you on future Website visits. The recorded data is stored together with the randomly generated user ID, which enables the analysis of pseudonymous user profiles. This user-related data is automatically deleted after 14 months. Other data remains stored indefinitely in aggregated form. If you do not agree with this data collection, you can prevent it by installing the browser add-on to deactivate Google Analytics once, or by rejecting cookies via our cookie settings dialog.

Our website also uses various social media plugins. The purposes for which we process your personal data when you visit our website include:

  • Providing and ensuring the security and stability of our website
  • Managing our website, including verifying and authenticating your identity, and preventing unauthorized access to secure areas of our site
  • Personalizing our website to your needs by displaying content that may be relevant and of interest to you
  • Analyzing data from our website visitors
  • Identifying the company, organization, institution, or authority you work for or are otherwise associated with
  • Expanding our business and services
  • Conducting benchmarking and data analysis (e.g., regarding website usage and demographic analyses of our visitors)
  • Analyzing usage of our website’s offerings and features
  • Monitoring and ensuring compliance with applicable terms of use
  • Reviewing quality and risk management
  • Any other purposes for which you have provided Interwetten with information

The processing of personal data of our website visitors is based on the following legal grounds:

  • Our legitimate interest in providing you with information and services effectively and in carrying out our business activities efficiently and lawfully
  • Our legitimate interest in developing and optimizing our website and your user experience

5.2. The Company may process Your Personal Data to comply with its legal obligations, for the following purposes:

  • Detection, investigation and prevention of money laundering and the financing of terrorism;
  • Protection of minors; and
  • Implementation of responsible gaming measures.

5.3. The Company may process Your Personal Data based on Our legitimate interest to promote Οur Services and develop Our business, for the following purposes:

  • Commercial communication, marketing and advertising of Our Services;

5.4. The Company may process Your Personal Data only with Your lawful consent for the following purposes:

  • Commercial communication, promotional campaigns, and advertising.

5.5. You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Notice. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your Data prior to its revocation.

6. Social Media Plugins

6.1 We use various social media platforms, for example, for recruitment or marketing purposes. We use social media to provide you with easy access to relevant information regarding opportunities at Interwetten and events we organize, and to promote our services and brand.

6.2 While Interwetten will be responsible for the content it publishes using social media platforms, Interwetten will not be responsible for managing the social media platforms (such as creating user statistics or placing cookies). When using these social media platforms, you are obliged to adhere to the legal and privacy terms imposed by the social media platform providers. Such providers collect personal data about you, including statistical and analytical data regarding your use of the social media platforms, such as an overview of pages you have accessed, “likes,” recent visits, posts you publish or find interesting.

6.3 If you require access to such data or want to invoke one of your other rights (such as the right to object to the processing of your data), you should contact the social media platform provider. Some social media providers provide us with aggregate data relevant for our pages, such as the amount of “likes” triggered by our content or the amount of posts, visitors to our web sites, photos that are downloaded or links that are clicked.

6.4 On our website, we implement so-called social media plugins. When you visit a page that displays one or more of such buttons, your browser will establish a direct connection to the relevant social network server and load the button from there. At the same time, the social media provider will know that the respective page on our website has been visited. We have no influence on the data that the social media providers collect on the basis of the buttons. If you wish to prevent this, please log out of your social media accounts before visiting our website. Social media providers set cookies as well, unless you have disabled the acceptance and storage of cookies in your browser settings.

6.4.1 Facebook

Our website includes plugins for the social network, Facebook. The Facebook plugins can be recognized by the Facebook logo or by the like button on our websites. For an overview of Facebook plugins, click here.

When you visit our website, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our website from your IP address. If you click on the Facebook “like button” while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our website with your user account. If you are not yet logged into your Facebook account, clicking a Facebook button will show you the Facebook login page for you to enter your login credentials. Please note that we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook’s privacy policy.

6.4.2 X

Functions of the X service have been integrated into our website. When you use X and the “retweet” function, the websites you visit are connected to your X account and made known to other users. If you are not yet logged into your X account, clicking the X button will show you the X login page for you to enter your login credentials. In doing so, data will also be transferred to X. We would like to point out that we have no knowledge of the content of the data transmitted or how it will be used by X.

For more information, see X Privacy Policy.

6.4.3 Instagram

Our website contains functions of the Instagram service.

If you are logged into your Instagram account, you can click the Instagram button to link the content of our pages with your Instagram profile. This means that Instagram can associate visits to our pages with your user account. If you are not yet logged into your Instagram account, clicking an Instagram button will show you the Instagram login page for you to enter your login credentials. We expressly point out that we receive no information on the content of the transmitted data or its use by Instagram.

For more information, see Instagram’s privacy policy.

6.4.4 YouTube

Our website uses plugins from YouTube, which is operated by Google.

If you visit one of our pages featuring a YouTube plugin, it is a connection to the YouTube servers. Here, the YouTube server is informed about which pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. If you are not yet logged in, clicking a YouTube button will show you the YouTube login page for you to enter your login credentials.

For more information, see Google’s privacy policy.

7. Supplier

We process personal data about our suppliers (including subcontractors, and individuals associated with our suppliers and contractors) in order to manage our contract and to receive services from our suppliers.

The personal data we process is generally limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).

Legal grounds for processing personal data of our suppliers are:

  • Performance of a contract
  • Compliance with a legal or regulatory obligation
  • Our legitimate interest in managing payments, fees and charges, and to collect and recover money owed to us

8. Data Recipients

8.1. For the execution of the purposes mentioned in this Privacy Notice, We may disclose or transmit Your Personal Data to the following third party recipients (“Data Processors”):

  • Group companies for operational purposes;
  • Game providers for gameplay purposes;
  • Payment providers for payment facilitation purposes (including Klarna, BankID or Unzer)
  • Information technology provider for Website operational purposes (including Microsoft or Cloudflare)
  • Statistics and reporting providers for data analysis and regulatory monitoring purposes;
  • Providers supporting with identification checks (including Veriff)
  • Customer support providers; and
  • Sales and marketing partners for marketing related purposes;
  • Courts, authorities or legal and tax advisors

The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Notice.

Should it be necessary to verify your identity or creditworthiness as part of our business relationship, we will transmit the required data to CRIF GmbH, Rothschildplatz 3/Top 3.06.8, 1020 Vienna, which, as an independent controller, will process the transmitted data for its own purposes as a credit reference agency and address publisher, as described at https://www.crif.at/datenschutz/.

8.2. We transfer your personal data to third parties outside the European Union only if:
• you have given your explicit consent, or
• it is necessary for us to fulfill a contract you have entered into with us, or
• to comply with a legal duty or obligation.

We shall only disclose Your Personal Data to third parties located outside of the European Union in cases where:

  • The recipient is located in a jurisdiction which is subject to an Adequacy Decision issued by the European Commission.
  • The recipient guarantees a standard of data protection comparable to that in place in the European Union, through the implementation of the Standard Contractual Clauses issued by the European Commission.

In some cases, we may be required by law to disclose your personal information to third parties and may have limited control over how it is protected by that party.

8.3. Upon indication of transactions and/or activities that may raise suspicions of criminal activities, We will report to the relevant authorities, sporting bodies and associations (e.g. police, sporting bodies/associations, private associations aiming at the prevention of criminal and fraudulent activities in sports betting and/or games of chance). In this context, Your Personal Data may be disclosed.

8.4. In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that We are legally bound to do so, We may transfer Your Personal Data to public authorities to the extent required by law.

8.5. In certain instances (e.g. for AML, KYC and Due Diligence checks) We may transmit Your Personal Data to credit rating agencies that conduct creditworthiness assessments and suppliers for identity verification checks (e.g. Verify, Sonio).

9. Data Security and Confidentiality

9.1. In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, the Company applies internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.

9.2. The processing of Your Personal Data by the Company is conducted in a secure and confidential manner, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.

9.3. In particular, payment information will always be encrypted. Whereas sensitive information is protected online by SSL encryption, We strive to ensure the protection of players' Data in all other areas. Only authorised employees, or employees of third parties contractually bound to confidentiality, have access to players' information. At regular intervals, all employees are given training on the applicable security and data protection standards. All relevant servers are located in a secure environment.

9.4. In order to protect players' Personal Data during communication with the web browser, We use encryption technology of Our certification partners. In addition, online transactions are shielded by the security system of a worldwide-accredited partner. In addition, all player Data is protected from unathorised access by firewall and intrusion prevention systems.

10. Retention of Personal Data

10.1. We retain Your Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Notice, in accordance with the Data Minimisation and Storage Limitation principles. Please note that retention periods vary from country to country and are determined in accordance with local legal retention requirements.

10.2. In order to comply with legal obligations, assert, exercise, or defend our legal claims, and for archiving and tracking purposes, we must retain information for an extended period of time.

10.3. Retention periods differ in length, and in justified individual cases (e.g., preservation of evidence), the retention period may be even longer (for example, due to limitation periods of up to 30 years, with the standard limitation period being ten years). If the data in question is subject to different retention periods, the longest applicable retention period shall apply.

10.4 Upon expiry of the retention period, Your Personal Data is erased from Our databases and systems.

10.5 For more information about data retention terms in relation to specific Personal Data, please contact Us at dataprotection@interwetten.com.

11. Your Rights

11.1. You have the right:

  • You may object to receiving marketing communications at any time.
  • You may request that the processing of your personal data be restricted or stopped, or that your personal data be deleted (under certain circumstances and in accordance with applicable law).
  • You may request the restriction of the processing of your personal data in cases explicitly provided for by law.
  • You have the right (under certain circumstances and in accordance with applicable law) to receive a copy of the personal data you have provided to Interwetten in a structured, commonly used, and machine-readable format (known as data portability). You may also request the transfer of your personal data to another data controller in such a format.
  • You may object to the processing of your personal data in cases explicitly provided for by law.
  • You may object to a decision made solely on the basis of automated processing, including profiling, that affects you or significantly impacts you.
  • If you have voluntarily provided personal data or otherwise consented to its use, you have the right to withdraw your consent at any time.
  • You have the right to lodge a complaint with a data protection authority (see Section 13 “Complaints”).

11.2. Any requests relevant to the above Section 10.1 must be addressed in writing to dataprotection@interwetten.com.

11.3.If You feel that Your rights are infringed, You have the right to file a complaint with the Malta Office of the Information and Data Protection Commissioner at the following website https://idpc.org.mt/en/Pages/contact/complaints.aspx.

12. Complaints

If you suspect that Interwetten may have violated data protection laws or other legal regulations, you can contact the Data Protection Officer at dataprotection@interwetten.com. They will investigate your complaint and inform you about the next steps.

In addition, you have the right to file a complaint with the relevant data protection authority.

13. Minors

Our website is not intended for use by individuals under the age of 18. We do not knowingly collect, publish, or sell the personal data of minors under 18 years of age. If you are under 18, please do not provide any personal data, even if prompted to do so. If you believe you have accidentally submitted personal data, please ask your parents or legal guardians to notify us, and we will delete your personal data.

14. Your Obligations

By using Our Website and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.

15. Changes to the Privacy Policy
This Privacy Policy is updated from time to time to reflect changes in our services. When changes are made to this Privacy Policy, the date at the top of this statement will also be updated to indicate the revision date. If there are significant changes to the way personal data is collected, used, or shared, a clear notice regarding the changes will be provided on the website.