Last Updated: 11 Sep 2023
1 Introduction
At JUNGLE ("We") are committed to protecting and respecting your privacy.
This policy (together with our Terms of Use) and any other documents referred to in it) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
When using the JUNGLE application (“the App”) or the JUNGLE website (“the Website”) at https://bet.jungle.xyz/, or any other websites or services provided, owned, or operated by us, you and your personal data are subject to the provisions described in this policy.
For the purpose of the Data Protection Act 2018 (the Act), the data controller/processor is JUNGLE X IE Limited of 2nd Floor, Palmerston House, Denzille Lane, Dublin 2, Dublin D02 WD37.
2 Information we may collect from you
Personal data means any information about an individual from which that person can be identified.
There are instances where we invite or request you to provide us with your personal data through our website.
We may collect and process the following personal data about you:
Information you give us
You may give us information about you by filling in forms on the Website or the App or by corresponding with us by phone, e-mail or otherwise.
This includes information you provide when you register to use the App, subscribe to our services, participate in discussion boards or other social media functions on the App, enter a competition, promotion or survey and when you report a problem with the App.
The information you give us may include your name, date of birth, address, email address and phone number, financial information, personal description and photograph.
Information we collect about you
With regard to each of your visits to the Website and the App we may automatically collect the following information:
details of the deposits/withdrawals you carry out when using our services, including geographic location from which the deposit/withdrawal has been made;
technical information, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plugin types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources
We may receive information about you if you use any of the other websites we operate or the other services we provide.
We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Non-Personal Information
For research and promotional purposes, we may use non-personal, non-specific information to generate statistics on your general playing activity, including transactional patterns, payout amounts and gaming preferences.
These initiatives will never include your personal data without your consent.
Cookies
The Website uses cookies to distinguish you from other users of the Website.
This helps us to provide you with a good experience when you browse the Website and also allows us to improve our site.
Our website may, from time to time, contain links to and from other websites.
If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies.
Please check those policies before you submit any personal data to those websites.
We strongly recommend that you take the time to read through the privacy policies of those new websites that you access when you access a new page via a link on the Website or the App.
Sensitive data
We process a limited amount of sensitive data when we carry out verification of identity documents and documents we are required to obtain for anti-money laundering and other regulatory purposes.
When processing data for these purposes, we are relying on the substantial public interest condition in Article 9(2)(g) of the GDPR and condition 14, and Preventing fraud in Part 2 of Schedule 1 of the DPA 2018.
Children’s data
Our products and services are directed at adults aged 18 years and over, and not intended for children.
We do not knowingly collect or process data from this age group.
Our verification process prevents us from collecting this data.
3. How we protect your personal data
We take the safeguarding of your information very seriously, and take a number of steps to ensure it stays secure:
Our technical security team proactively monitors for abnormal and malicious activity in our servers and services.
When the information you’ve given us is not in active use, it is encrypted. This means it’s unreadable from server hard drives without the decryption key.
We are required by our operating licence conditions to complete an annual security audit with an independent auditor, to assess compliance against the security requirements of the remote gambling and software technical standards.
We restrict access to your personal information to those employees of JUNGLE who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorised access.
Personal data relating to closed customer accounts is masked and transferred to an archived user table. Only permitted administrators can access data in the archived user table.
As effective as our security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation. We will continue to revise policies and implement additional security features as new technologies become available.
4. How we use personal data we collect
We use information held about you in the following ways:
Data Categories | Purpose(s) for Processing | Legal Basis |
• Contact information that you provide including your name, address, email address and phone number, and any phone number used to call our customer service number.
| • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us. | • To perform our contract with you. |
• Contact information that you provide including your name, address, email address and phone number, and any phone number used to call our customer service number.
| • To provide you with information about other services we offer that are similar to those that you have enquired about. | • Your consent – which can withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal. |
• Contact information that you provide including your name, address, email address and phone number, and any phone number used to call our customer service number.
| • To provide you, or permit selected third parties to provide you, with information about services we feel may interest you.
| • Your consent – which can withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal. |
• Contact information that you provide including your name, address, email address and phone number, and any phone number used to call our customer service number. | • To notify you about changes to our services. | • To perform our contract with you. • To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights - you have the right to object at any time. |
• Technical information about your session, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug¬in types and versions, operating system and platform. | • To ensure that content from the App is presented in the most effective manner for you and for your computer. | • To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights - you have the right to object at any time. |
• Technical information about your session, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug¬in types and versions, operating system and platform.
| • To administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. | • To perform our contract with you.
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• Technical information about your session, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug¬in types and versions, operating system and platform.
| • To improve the App to ensure that content is presented in the most effective manner for you and for your mobile device. | • To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights - you have the right to object at any time. |
Nickname | • To allow you to participate in interactive features of our services when you choose to do so. | • To perform our contract with you.
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• Technical information about your session, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug¬in types and versions, operating system and platform.
| • As part of our efforts to keep the App safe and secure. | • To perform our contract with you. • To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights - you have the right to object at any time. |
• Browsing information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our App (including date and time); products you viewed or searched for; length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse¬overs), and methods used to browse away from the page. | • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. | • To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights - you have the right to object at any time. |
• Verification and anti-money laundering information that you provide including certain financial information, a personal description, your date of birth and your photograph. • Details of the deposits/withdrawals you carry out when using our services, including geographic location from which the deposit/withdrawal has been made. | • To analyse or investigate any actual or suspected criminal activity in respect of any JUNGLE service. | • To comply with our legal obligations, including under gambling and anti-money laundering legislation (such as the Gambling Regulation Bill 2022, the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010). |
• Contact information that you provide including your name, address, email address and phone number, and any phone number used to call our customer service number.
| • To make suggestions and recommendations to you and other users of the App about goods or services that may interest you or them. | • Your consent – which can withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal.
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5. Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in sections 7 and 8 of the Companies Act 2014.
We may share your information with selected third parties including:
Business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you
Affiliates, Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others
Analytics and search engine providers that assist us in the improvement and optimisation of the Website and the App; and
Our group entities or subsidiaries
We do not disclose information about identifiable individuals to our advertisers or affiliates, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day).
We may also use such aggregate information to help advertisers or affiliates reach the kind of audience they want to target (for example, women in Dublin).
We may make use of the personal data we have collected from you to enable us to comply with our advertisers' or affiliates’ wishes by displaying their advertisements to that target audience.
We may disclose your personal information to third parties including:
To regulatory or sporting authorities in connection with policing the integrity or enforcing the rules of a game or sport or the prevention or detection of a crime; and where we have reasonable grounds to believe or suspect that you may be in breach of such rules or the law.
To our ID, age verification, fraud prevention and anti-money laundering service providers in connection with the use of our services.
To GAMSTOP, in connection with checking the national remote gambling self-exclusion scheme.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If JUNGLE or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of JUNGLE our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Customer Agreement and other applicable agreements; or to protect the rights, property, or safety of JUNGLE, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
to prevent and detect fraud or crime;
in response to a subpoena, warrant, court order, or as otherwise required by law;
to assess financial and insurance risks;
to recover a debt or in relation to your insolvency; and
to develop customer relationships, services and systems.
In the event of self-exclusion, the information held about you will not be passed on to advertisers, affiliates or any third parties. JUNGLE will use all reasonable endeavours to recover any information held by third parties.
6. Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA").
We will ensure appropriate safeguards are in place to protect the transfer of your personal data to these non-EEA countries, including [Singapore].
To obtain more information concerning these safeguards, see Contact Us below.
Your data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
Such staff will be appropriately trained in GDPR compliance and confidentiality measures.
By submitting your personal data, you agree to this transfer, storing or processing.
Unfortunately, the transmission of information via the internet is not completely secure.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. How long we hold your personal data for
Your information will not be kept for longer than 7 years post account closure.
Please note that our retention periods may be dictated by our legal obligations, including under gambling and anti-money laundering legislation (such as the Gambling Regulation Bill 2022, the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010).
8. Your rights
You have the right to access the information we hold about you.
Your right of access can be exercised in accordance with the relevant data protection legislation.
If you have any questions in relation to our use of your personal information, contact us. Any access request may be subject to a fee of €10.00 to meet our administrative costs in providing you with details of the information we hold about you.
Under certain conditions, you have the right to require us to:
provide you with further details on the use we make of your information;
provide you with a copy of the information that you have provided to us;
update any inaccurate, incorrect, or out of date personal information we hold;
delete any personal information that is no longer necessary, or no longer subject to a legal obligation to which JUNGLE is subject. JUNGLE has legal and regulatory obligations to retain data for specified periods, so it may not be possible to delete your data immediately at the time of the request. Once the required retention period has passed, then we will be able to comply with your request;
where processing is based on consent, to withdraw your consent so that we stop that particular processing;
cease direct marketing to you, by contacting us or adjusting your notification preferences in the settings section of your account;
object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
restrict how we use your information whilst a complaint is being investigated
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish regulator for data protection issues (website: https://forms.dataprotection.ie/contact ).
If you are based in another EEA country, you also have the right to make a complaint at any time to your local regulator for data protection.
9. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you in the App or by email. Please check back frequently to see any updates or changes to our privacy policy.
10. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be sent via "Contact Us" in the App or by e-mail to support@jungle.xyz.