Privacy policy
1. Definitions
Personal Data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.
Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Recipient means a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third Party means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
Group of Undertakings means a controlling undertaking and its controlled undertakings.
Supervisory Authority means an independent public authority which is established by a Member State pursuant to Article 51 GDPR.
2. General
This notice, together with the General Terms and Conditions available on the Site, sets 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. By registering a Player Account on the Website, you confirm your acceptance of this Privacy Policy. Please note that if you do not accept the terms outlined in this Privacy Policy or choose not to provide the necessary personal information, your access to certain features and services offered on this Website may be limited.
Please also note that this Privacy Policy constitutes an agreement between you and the Company. It may be updated or revised periodically. While we will make reasonable efforts to inform you of any significant changes, we recommend that you review this Privacy Policy regularly to remain informed about our current practices regarding the collection, use, and protection of your personal information. Your continued use of the Website and/or its services will constitute your acceptance of the revised Privacy Policy.
Axecasino.com values your privacy and is committed to managing all personal data in a transparent, fair, and lawful manner. This Privacy Policy (together with the Terms & Conditions and the Cookie Policy) sets out the basis on which Axecasino.com collects, stores, and uses your personal data when you visit our Website, as well as your rights and how the law protects those rights 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 and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
This Website is intended solely for persons over the age of 18. We do not knowingly collect data relating to persons under this age. If it becomes apparent that we have collected personal data relating to persons under the age of 18 as a result of misuse of our Website, we will take all reasonable steps to ensure that such data is handled in accordance with applicable law.
3. About us
The website axecasino.com (“Casino”, “Website”, “Company”, “We”, “Us”, “Our”) is owned and operated by Dama N.V., a company incorporated under the laws of Curaçao, with company registration number 152125 and its registered address at Scharlooweg 39, Willemstad, Curaçao. Dama N.V. operates under E-gaming licence No. OGL/2023/174/0082 issued by the Curaçao Gaming Control Board.
As a data controller, we are under a legal obligation pursuant to gambling regulations to process personal data from players in order to enable their participation in games and to provide ancillary services.
When we refer to “Company”, “Group”, “We”, “Us”, or “Our” in this Privacy Notice, we mean Dama N.V.
We take your privacy seriously. For this reason, we have appointed a Data Protection Officer (DPO) whose responsibility is to ensure that the Company complies with its legal obligations regarding the processing of your personal data. The DPO also serves as your contact point for any questions related to this Privacy Policy.
If you have any queries about this Policy, including requests to exercise your legal rights or complaints regarding violations of your rights, please contact our DPO at dpo@damacasino.com
4. Contact Us
You may contact us at any time regarding this Policy if you wish to:
- Confirm the accuracy of the personal information we hold about you;
- Enquire about our use of your personal information;
- Object to the future use of your data for direct marketing purposes;
- Receive a copy of the personal information stored about you;
- Update or rectify any information you have provided to us (in such cases, you must provide any evidence we may reasonably require to verify and implement such changes).
Please note that it is illegal to provide false information about yourself, and it is your responsibility to ensure that we are always informed of accurate and up-to-date data.
Unless you have opted out of receiving promotional materials, we may use your personal information, including your email address and phone number, to send you marketing communications about our products, services, and promotions. This may also include information about products and services provided by our business partners, such as casino game suppliers.
If you decide to stop receiving marketing or advertising materials, you may: opt out by adjusting your preferences in your Player Account settings, or by contacting our Customer Support at support@axecasino.com or via Live Chat. You can also configure your marketing preferences in your personal account at www.axecasino.com/profile.
To fulfil your requests in accordance with this Privacy Policy, you may contact us through any of the following:
- Email: support@axecasino.com
- Live Chat: Axe Casino
- Data Protection Officer: dpo@damacasino.com
Please note that, for technical reasons, some emails may be filtered into spam or may fail to reach the intended recipient.
If your request is not answered within 10 days, we strongly recommend contacting us again using an alternative communication method for clarification.
We respect and value your privacy. You can always contact our Data Protection Officer at dpo@damacasino.com if:
- You believe your privacy rights have been violated;
- The deadline for fulfilling your data access request has been exceeded;
- You require clarification regarding any provisions of this Privacy Policy; or
- You wish to receive a copy of your personal data stored across all Dama N.V. licences.
We aim to respond to all legitimate requests within one month. Occasionally, it may take longer if your request is particularly complex or if you have made several requests. In such cases, we will notify you and keep you informed of progress.
5. Information we collect
1. Information You Provide to Us This includes any information you provide when completing forms on our account registration pages, as well as any other data you submit through the Website or via email. It includes details you provide when you register to use our Website, subscribe to our services, make deposits, place bets, or request withdrawals, participate in chat rooms, accept bonuses or other promotions, or share due diligence documentation with us (including a source of wealth questionnaire and supporting documents). It also includes information you provide when reporting a problem or submitting a complaint. The information you give us may include your name, username, address, date of birth, country of residence, identification number, email address, telephone number, financial and credit card details, personal description, proof of identification, proof of address, proof of funds, and a photograph.
2. Technical Information This includes the Internet Protocol (IP) address used to connect your device to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform, and information about your visit (including full Uniform Resource Locators – URLs) as well as data received from cookies. Please refer to our Cookie Notice for further details on the types of cookies in use.
3. Gameplay Information This includes data such as the games you have played, the duration of each session, page visits, and interaction information.
4. Analytics Information In some cases, we may collect information about your use of the Services, such as application usage, log files, user activity (for example, pages viewed, time spent on specific pages, online browsing actions, clicks, and other interactions), timestamps, and alerts. This data is collected for purposes including troubleshooting, error and bug resolution, research, and analytics concerning your use of the Services.
5. Information We Receive from Other Sources We may receive information about you if you use any of our Websites or services operated by the Group. If you hold accounts on multiple sites operated by the Group, we may consolidate data generated from each site into a single repository. Such data is important for statistical purposes and, in particular, for fulfilling our legal obligations regarding Anti-Money Laundering and Responsible Gambling.
6. Information from Third Parties In providing our services, we may work closely with third-party data processors and joint and/or independent data controllers. These include business partners and subcontractors providing technical, payment, and delivery services, as well as partners delivering marketing information (such as CRM tool providers, email marketing partners, SMS providers, direct mail distributors, and outbound call providers), advertising and affiliate networks, analytics providers, due diligence and intelligence firms, search information providers, and credit reference agencies. This may also include information received from our publishers, advertisers, and other partners who help us deliver ads and personalised content to you and recognise you across browsers and devices. This may include pseudonymous advertiser identifiers shared by certain advertisers or third-party ad platforms.
Data processors handle personal data strictly in accordance with our written instructions, and their activities are limited to those necessary to assist us in providing our services to you.
6. Categories of Data We Store About You
Personal data means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data).
The personal data collected and processed about you can be grouped into the following categories:
1. Identity Data Includes first name, middle name, last name, username or similar identifier, date of birth, gender, and email address.
2. Contact Data Includes residential address, email address, telephone number, and other available means of communication.
3. Financial Data Includes details of your salary and wealth, the sources of funds used for deposits, as well as your bank account, payment card, or payment account details. It also covers information contained within bank statements, scanned documents confirming your income, and other documentation collected for Know Your Customer (KYC) purposes.
4. Transaction Data Includes details about deposits and withdrawals, wagering activity, and other records of games you have played on our Websites.
5. Technical Data Includes Internet Protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform, and other technologies used on the devices you access our Website with.
6. Usage Data Includes information about how you use our Website, products, and services; online identifiers; encrypted passwords; games played; login and logout times; duration of play; bonuses and promotions claimed; responsible gaming information; limits and history; and anti-money laundering (AML) classification.
7. Marketing and Communications Data Includes your preferences for receiving marketing communications from us and our third parties, as well as your communication preferences.
8. Special Categories of Personal Data In limited circumstances, and in fulfilment of our legal obligations, we may collect certain special categories of personal data if you provide them to us. These may include:
Information related to responsible gaming that may be considered medical data;
Information about your racial or ethnic origin, which may be obtained from documents you have uploaded.
7. Information you give to us:
– To fulfil our obligations arising from the Terms and Conditions entered into between you and us, and to provide you with the gaming services you request, including accepting deposits, processing withdrawals, carrying out fraud management procedures, responding to any queries or complaints you may have, and performing other ancillary activities related to the services we provide.
– Provided that you have granted consent, to contact you with marketing information from the Group, including details about our services, bonus schemes, and promotions, as well as information about products and offers from related sites operated by the Group or its brands.
– To provide customised advertising on the Website based on your interactions with the site or your usage data.
– To notify you about changes to our services.
– To meet obligations arising under anti-money laundering legislation, related rules and regulations, and any other applicable laws to which we are subject from time to time.
8. Information we collect about you:
We may use your personal data for the following purposes:
– To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. Such information is typically collected through the use of cookies. For more information, please refer to our Cookie Notice, which also provides guidance on how cookies may be disabled.
– To contact you with marketing information, including details about services, bonus schemes, and promotions offered by the brand with which you registered, based on our legitimate interests. We may also provide marketing information about partner brands where you have given your consent to receive such materials.
– To carry out fraud and risk management activities, including assigning a risk profile or status to your account.
– To assess your behaviour and patterns on the Website in order to help build a detailed customer profile for purposes including, but not limited to:
Maintaining a register of bonus abusers. Individuals identified on this list may be excluded from future promotions or blocked from using the Company’s services. This also includes analysis of other types of fraud and fraudulent behaviour.
Screening and monitoring your transactions and behaviour for responsible gambling purposes, ensuring that your interaction with us remains a form of entertainment and does not become harmful. We may assign a Responsible Gambling Score to your account based on information we collect and any responsible gambling questionnaire you complete. Following our assessment, you may be categorised as a Problem Gambler or identified as being at risk of gambling-related harm.
Analysing your personal data as part of our anti-money laundering (AML) and counter-terrorist financing measures. This may include comparing your data with third-party sources, building an AML profile, and assigning a risk score to your account. We also maintain a register of customers identified as high risk from an AML perspective.
Please note that for these purposes we may use profiling. The final decision is always made by a human. However, the logic and parameters behind the profiling cannot be disclosed, as doing so could enable individuals to circumvent control mechanisms designed to protect our business and ensure compliance with legal obligations.
– To improve our Website and ensure that content is presented in the most effective manner for you and your device.
– To enable you to participate in interactive features of our services when you choose to do so.
– To help keep our Website safe and secure.
– To measure and understand the effectiveness of the advertising we serve to you and others, and to deliver relevant promotions to you.
– To make suggestions and recommendations to you about products or services that may be of interest.
– We may also collect, use, and share Aggregated Data, such as statistical or demographic information, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as it does not directly or indirectly identify you. For example, we may aggregate your usage data to calculate the percentage of users accessing a particular Website feature. However, if we combine or connect Aggregated Data with your personal data in a way that could identify you, we treat the combined data as personal data and handle it in accordance with this Privacy Notice.
9. Information we receive from other sources:
We may combine the information you provide to us with information we collect about you and information obtained from other sources. We will use this combined data for the purposes set out above, depending on the nature and type of information received.
Other sources may include third-party service providers such as age verification tools, identity and address verification services, regulators, or entities maintaining central databases of problem gamblers, as well as providers of Politically Exposed Person (PEP) and Sanctions screening services, and other similar providers with whom we may contract from time to time.
We may also receive information about you from other websites operated by the Group. This enables us to improve the services we provide to you and to prevent bonus abuse or the participation of problem gamblers in our services.
10. Lawful Basis for Processing of Personal Data
| Data collected | How do we collect your data? | Purpose for collection | Legal basis for processing data |
|---|---|---|---|
| Identification data – this includes full name, email, username of choice, date of birth, gender | Requested upon registration | (1) Customer identification and creation of unique customer profile (2) Customer verification for Anti-Money Laundering (“ AML”) purposes (3) Identification of customer when contact is made | (1) Performance of contract (2) Legal obligation (3) Performance of contract |
| Contact details – this includes email address, home address, mobile phone number, skype or any other available mean of communication | Requested upon registration and/or KYC procedure | (1) Customer identification and creation of unique customer profile (2) Contacting customers for support purposes (3) Dissemination of marketing material of the brand (4) Dissemination of marketing material of another Group brands (5)Verification of player identity | (1) Performance of contract (2) Performance of contract (3) Consent (4) Consent (5) Legal obligation |
| Data required for verification purposes – this includes your identification documents, proof of address, and possibly source of funds, source of wealth. | Must be uploaded on player profile upon request; may be requested either through pop up on website or via email. | (1) Verification of player identity (2) Required in order for us to comply with AML law | (1) Legal obligation (2) Legal obligation |
| Financial data – this would include the financial details relating to your deposit and withdrawal methods of your choice, therefore your bank details, payment card details, or all relevant details relating to the chosen payment methods. | Collected upon deposit or withdrawal of funds into the player account. Could also be collected where we have queries via email / chat / calls. | (1) Required to provide you with the service (i.e. to deposit funds into player account) (2) Required for Know-Your-Customer (“KYC”) checks (source of funds) (3) Required for cybercrime checks (4) To ensure a closed-loop policy | (1) Performance of contract (2) Legal obligation (3) Legitimate interest (4) Legal obligation |
| Transaction data – this includes details relating to payments made to and by you; | Automatically generated when deposits and withdrawals are made | (1) Required to provide you with the service (2) Required to comply with AML law and gaming license requirements (3) Required to track your activity for social responsibility measures | (1) Performance of contract (2) Legal obligation (3) Legal obligation |
| Gaming data – this includes details relating to the games you play on our website (i.e. your gaming activity) | Automatically generated with gaming activity | (1) Required to provide you with the service (2) Required to comply with remote gaming law | (1) Performance of contract (2) Legal obligation |
| Data relating to your communications with us (via email, live chat, phone call) | Email correspondence and live chat when contact is made, phone calls may be recorded for record-keeping requirements | (1) Required to provide you with the service (for customer queries, communicating necessary issues) (2) May be used to manage risks, obtain professional advice, or to establish and defend our legal claims, whether in court or in an out-of-court procedure | (1) Performance of contract (2) Legitimate interest |
| Profile data - Data relating to your gaming habits and your preferences | Automatically generated with game play, or using cookies to log preferences | (1) May be used in aggregated and anonymized form to improve service (2) May be used for a more personalized user experience (3) Segmentation for AML and social responsibility measures (4) Targeted marketing | (1) Legitimate interest. Data in anonymized form is not personal data after that. (2) Consent (3) Legal obligation (4) Consent |
| Responsible Gaming Data | Self-assessment test | (1) Responsible gaming profiling (2) Identification and investigation of gaming activity for responsible gaming purposes | (1) Legal obligation (2) Legitimate interest |
| Technical data - this may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform. Usage data – includes data relating to how you use our website | Cookie data | (1) Location data / IP used to ensure customer is not from a restricted or high-risk country (2) Location data / IP address also used to ensure that they do not use proxies or VPNs, to ensure that they do not abuse bonuses or defraud by application fraud (3) All other data (including location and IP) is used to improve website functionality, troubleshoot technical issues, create more products for different platforms | (1) Legal Obligation (2) Legitimate interest (3) Legitimate interest |
| My RTP data – May include your hit rate, total number of spins, overall RTP on your account, your own RTP compared to the games’ RTPs, biggest win on specific games and bet placed to achieve that win | Automatically generated with gameplay | (1) To ensure we are in line with all the relevant requirements regarding the RTP of our services. | (1) Legal Obligation |
| Cookie data – please see our Cookie Policy for further information on how and for which purposes we collect your cookies. | |||
12. Transfers of personal data outside of the EEA
It may be necessary for us or our service providers to transfer your personal data to countries outside the European Union (EU), the European Economic Area (EEA), and the European Free Trade Association (EFTA) regions in order to provide you with our services or to engage with service providers and data processors. In accordance with the General Data Protection Regulation (GDPR), we are committed to ensuring the protection of your personal data during such transfers.
These transfers may be necessary for purposes including: a) Processing your bets and payment transactions; b) Providing you with gaming and other ancillary services requested through our Website; c) Conducting identification and verification checks.
To guarantee an adequate level of protection for your personal data during transfers to third countries, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs) for data protection. We also take all necessary measures to ensure that your personal data is handled securely and in full compliance with this Privacy Policy and all applicable data protection legislation.
By using our services and accessing our Website, you acknowledge and accept that your personal data may be transferred to third countries under these safeguards. If you have any questions or concerns regarding such transfers, please contact us.
13. Data Retention
We will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.
When determining the appropriate retention period for your data, we consider several factors, including the purposes for which the data was collected and processed, the applicable legal and regulatory obligations, the nature and sensitivity of the personal data, and the potential risks of unauthorised use or disclosure.
As stated in our Terms and Conditions, both you and the Casino may close your Player Account at any time. Following account closure, we will retain your personal data for as long as required by law. Such data will only be used where necessary to respond to lawful requests from competent authorities in connection with financial or fiscal records, fraud prevention, anti-money laundering (AML) investigations, or other lawful enquiries.
We may also retain anonymised or aggregated versions of your data to improve our content and marketing communications, provided that no automated decision-making or profiling is involved.
Please note that under anti-money laundering regulations applicable in licensed gaming jurisdictions within the European Union, we are legally obliged to retain personal data collected during registration and throughout the operational period of a Player Account for a minimum of five years from the date of the last transaction or account closure. Accordingly, requests for data erasure submitted before the expiry of this period cannot be accommodated.
14. Your Rights
Under data protection law, you, as a data subject, have certain rights in specific circumstances. In accordance with applicable law, you have the right to:
Request Access to Your Personal Data – You have the right to request, free of charge, a copy of the personal data we hold about you.
Request Correction of Your Personal Data – If any personal data we hold about you is incomplete or inaccurate, you have the right to request that it be corrected. However, we may require supporting evidence or documentation (such as identification or proof of address) to verify your request. Please note that such requests may be declined if we are legally obliged to retain the existing data.
Request Erasure of Your Personal Data – You may request that we delete your personal data where there is no longer a lawful basis for processing or retaining it. This right is not absolute: we may be required by law to retain certain information or may need to keep it to establish, exercise, or defend legal claims.
Object to Processing – You may object to the processing of your personal data where we rely on legitimate interests (ours or those of a third party) and you believe such processing infringes upon your fundamental rights and freedoms. In some cases, we may demonstrate compelling legitimate grounds for processing that override your rights. You can submit your objection by contacting our Data Protection Officer (DPO).
Request Restriction of Processing – You may ask us to suspend the processing of your personal data temporarily in one of the following scenarios: (a) you wish to verify the accuracy of the data; (b) our use of the data is unlawful, but you prefer restriction to deletion; (c) you require the data to establish, exercise, or defend legal claims even if we no longer need it; or (d) you have objected to our use of your data and we are verifying whether overriding legitimate grounds exist.
Request Data Portability – You may request to receive certain personal data in a structured, commonly used, and machine-readable format, or request that it be transferred to another controller. This right applies only to data processed by automated means based on your consent or where necessary for the performance of a contract.
Withdraw Consent – Where processing relies on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before your consent was withdrawn. However, withdrawal may prevent us from providing certain services (for example, marketing communications). You may withdraw consent at any time via your account profile settings on the Website.
Lodge a Complaint – You have the right to lodge a complaint with a supervisory authority if you believe that your data has been processed unlawfully.
To exercise any of your rights, we may request specific information to verify your identity. This security measure ensures that personal data is not disclosed to unauthorised individuals.
We aim to respond to all legitimate requests within one month of receipt. If your request is particularly complex, or if you have made multiple requests, we may require additional time. In such cases, we will inform you of the extension and keep you updated.
15. Automated Decision Making
In establishing and maintaining our business relationship, we do not generally make use of fully automated decision-making processes. If we implement such procedures in individual cases, we will inform you separately, where required by law.
16. Security of your Data
We acknowledge that, in collecting and processing your personal data for the purpose of managing your Player Account, we are bound by strict legal provisions governing data protection.
Accordingly, we are committed to safeguarding your personal information and respecting your privacy in line with best business practices, applicable regulations, and current technological standards. As part of our commitment to providing a secure environment for our players, we take all reasonable precautions to ensure that the data you provide remains protected.
We have implemented appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorised manner. Access to personal data is restricted to employees, agents, contractors, and third parties who have a legitimate business need to access it.
Player Accounts are accessible only by means of a unique player ID and password. You may also enable two-factor authentication (2FA) for additional protection against unauthorised access. You are responsible for keeping your login credentials confidential and ensuring they are not accessible to any other person.