BetPRIMEIRO Casino Privacy Policy

Last Updated: July 25, 2025
Effective from: July 25, 2025
Version: 2.1.0 (CA Edition)

1. General

This Privacy Policy, together with our General Terms and Conditions, sets out the basis on which we process any personal data collected from you or provided by you. By registering a Player Account with https://betprimeirocasino.ca/ (“Casino,” “Website,” “Company,” “We,” “Us,” “Our”), you confirm your acceptance of this Privacy Policy.

This policy constitutes a legal agreement between you and the Company. It may be periodically updated, and while we will endeavour to inform you of significant changes, we recommend you review this page regularly. Your continued use of the Website constitutes your acceptance of the updated policy.

We are committed to managing all your personal data in a transparent, fair, and lawful manner, in accordance with global standards like the General Data Protection Regulation (GDPR) and Canada’s federal privacy law, the Personal Information Protection and Electronic Documents Act (PIPEDA).

This website is intended strictly for individuals over 18 years of age (or the legal age of majority in your Canadian province or territory). We do not knowingly collect data from minors.

2. Definitions

Personal Data: Any information relating to an identified or identifiable natural person (‘data subject’).
Processing: Any operation performed on personal data, such as collection, recording, organization, storage, use, disclosure, or destruction.
Profiling: Any form of automated processing of personal data to evaluate, analyze, or predict aspects concerning a natural person’s behaviour, preferences, or economic situation.
Controller: The legal person (Dama N.V.) which determines the purposes and means of the processing of personal data.
Processor: A legal person which processes personal data on behalf of the controller.
Recipient: A person or body to which the personal data is disclosed.
Consent: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, signifying agreement to the processing of personal data.
Personal data breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of, or access to, personal data.

3. About Us (The Data Controller)

The Website is owned and operated by Dama N.V., which is the data controller for your personal information.

Company: Dama N.V.
Registration Number: 152125
Address: Scharlooweg 39, Willemstad, Curaçao
License: E-gaming license No. OGL/2023/174/0082, issued by the Curaçao Gaming Control Board.

We have appointed a Data Protection Officer (DPO) to oversee compliance with our legal obligations. If you have any questions or wish to exercise your rights, please contact the DPO at [email protected].

4. Information We Collect

We collect data in several ways to provide our services and meet our regulatory requirements.

Information You Provide Us: This includes information you provide when filling in registration forms, making deposits, participating in chats, accepting bonuses, or submitting due diligence documentation (e.g., source of wealth questionnaire). This data may include your name, username, address, date of birth, email, phone number, financial and credit card information, and identity/address verification documents.
Technical Information: This includes your Internet Protocol (IP) address, login information, browser type and version, time zone setting, operating system, and platform.
Gameplay Information: This includes the games you played, the duration of play, and page interaction information.
Analytics Information: We may collect data on your use of the Services, such as log files, user activity (pages viewed, time spent, clicks), timestamps, and alerts for troubleshooting and research purposes.
Information We Receive from Other Sources: We work with third-party data processors and controllers, including business partners, payment and technical service providers, advertising networks, analytics providers, and due diligence intelligence companies. This includes information from other sites operated by the Dama N.V. Group, which helps us with anti-money laundering and responsible gambling obligations.

5. Categories of Data We Store About You

The personal data we process can be grouped as follows:

Identity Data: First name, last name, username, email, date of birth, gender.
Contact Data: Residential address, email address, phone number.
Financial Data: Details of your salary/wealth, sources of funds, bank account, and payment card details.
Transaction Data: Details about deposits, withdrawals, and wagers.
Technical Data: IP address, login data, browser type, location, etc.
Usage Data: Information on how you use our website, including login/logout times, games played, bonuses claimed, and responsible gaming limits.
Marketing and Communications Data: Your preferences for receiving marketing from us.
Special Categories of Personal Data: To fulfill our legal obligations, we may collect data related to responsible gaming (which can be considered medical data) or racial/ethnic origin (which may be obtained from identity documents).

6. Lawful Basis for Processing Personal Data

The following table describes how we use your data and the legal basis for doing so. While structured around GDPR principles, this framework aligns with PIPEDA’s requirement for appropriate and consented use of personal information.

Data collected	How do we collect your data?	Purpose for collection	Legal basis for processing data
Identification data	Requested upon registration	(1) Customer identification (2) Customer verification for AML (3) Identification when you contact us	(1) Performance of contract (2) Legal obligation (3) Performance of contract
Contact details	Requested upon registration and/or KYC	(1) Customer identification (2) Customer support (3) Marketing (brand-specific) (4) Marketing (Group brands) (5) Identity verification	(1) Performance of contract (2) Performance of contract (3) Consent (4) Consent (5) Legal obligation
Verification data	Uploaded to player profile upon request	(1) Verification of player identity (2) Compliance with AML law	(1) & (2) Legal obligation
Financial data	Collected upon deposit or withdrawal	(1) To provide the service (2) KYC checks (source of funds) (3) Cybercrime checks (4) To ensure a closed-loop policy	(1) Performance of contract (2) Legal obligation (3) Legitimate interest (4) Legal obligation
Transaction data	Automatically generated	(1) To provide the service (2) Compliance with AML & gaming laws (3) To track for responsible gaming	(1) Performance of contract (2) Legal obligation
Gaming data	Automatically generated	(1) To provide the service (2) Compliance with gaming law	(1) Performance of contract (2) Legal obligation
Communications data	Email, live chat, recorded phone calls	(1) To provide the service (support) (2) To manage risks and defend legal claims	(1) Performance of contract (2) Legitimate interest
Profile data	Automatically generated with gameplay/cookies	(1) To improve service (aggregated) (2) Personalized user experience (3) AML/Responsible Gaming segmentation (4) Targeted marketing	(1) Legitimate interest (2) Consent (3) Legal obligation (4) Consent
Responsible Gaming Data	Self-assessment test	(1) Responsible gaming profiling (2) Investigation for responsible gaming	(1) Legal obligation (2) Legitimate interest
Technical & Usage data	Cookie data	(1) Block restricted/high-risk countries (2) Prevent fraud & bonus abuse (3) Improve website functionality	(1) Legal Obligation (2) Legitimate interest
My RTP data	Automatically generated with gameplay	To ensure compliance with RTP requirements	Legal Obligation

7. Sharing of Your Data

To provide our services, we may need to share your personal data with trusted third parties, including:

Any member of the Dama N.V. Group for fraud prevention, AML, and responsible gaming purposes.
Employees of the Company, specifically the DPO, Money Laundering Officer, Payments & Anti-Fraud analysts, Customer Support agents, Customer Retention teams, VIP managers, and other selected employees.
Game providers, who may require access to select data like your username and IP address.
Payment providers to process your transactions.
Marketing partners, if you have given consent, to manage our promotional communications.
Governmental or regulatory authorities, such as law enforcement or the Curaçao Gaming Control Board, when required by law.
Client communication software providers who help us communicate with you via email and live chat.
AML and fraud verification tool providers to help us meet our KYC legal obligations.
Professional advisors like lawyers and consultants to manage risks or defend legal claims.

We ensure any third party with access to your data is bound by a data processing agreement to protect your information and process it only according to our instructions.

8. Transfers of Personal Data Outside of Canada & the EEA

It may be necessary to transfer your personal data to countries outside of the European Economic Area (EEA) and Canada. We ensure the protection of your data during these transfers by implementing appropriate safeguards, such as the European Commission’s standard contractual clauses, which contractually require the recipient to protect your data to a high standard.

9. Data Retention

We retain your personal data only for as long as necessary. Due to anti-money laundering regulations, we are obliged to retain the personal data of players for a minimum of five years from the last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be fulfilled.

10. Your Data Protection Rights

Under Canadian and international data protection laws, you have the right to:

Request access to the personal data we hold about you.
Request correction of incomplete or incorrect data.
Request erasure of your personal data (this is not an absolute right and is subject to our legal retention obligations).
Object to the processing of your data where we rely on legitimate interests.
Request the restriction of processing of your personal data.
Request the transfer of your personal data (data portability).
Withdraw your consent at any time where consent is the basis for processing (e.g., for marketing).
Lodge a complaint with a supervisory authority. In Canada, this would be the Office of the Privacy Commissioner of Canada (OPC).

To exercise these rights, please contact us. We may need to request specific information to verify your identity. We aim to respond to all legitimate requests within one month.

11. Automated Decision Making

We generally do not use fully automated decision-making in our business relationship. However, as noted in Section 6, we use profiling and automated systems for AML, fraud prevention, and responsible gaming monitoring. If a fully automated decision is made in a specific case, we will inform you separately if required by law.

12. Security of Your Data

We are bound by strict legal provisions on data protection and are committed to protecting your personal information. We take all reasonable precautions to ensure your data remains safe, including:

Implementing appropriate security measures to prevent accidental loss, unauthorized access, or disclosure.
Limiting access to your personal data to employees and third parties who have a business need to know.
Offering two-factor authentication (2FA) for your account. You are responsible for keeping your login information confidential.

13. Contact Us

If you have any questions or wish to exercise your rights, you can reach us through the following channels:

Customer Support: [email protected]
Live Chat: Available on the www.betprimeiro.net website.
Data Protection Officer: [email protected]

If your request is not answered within 10 days, we recommend contacting us again through an alternative method.