Privacy and Cookie Policy
At Acroud (” Acroud ,” ” we ,” ” us “), we process personal data concerning our customers and visitors to our websites (the ” User “). We undertake to treat the User’s personal data with diligence, to guarantee its security and to comply with data protection laws.
How this Policy works
The purpose of this Policy is to explain when, why and how we process information that may concern the User (the ” personal data “). It also provides important information on the User’s legal rights. This policy does not override the terms of any contract the User has entered into with us, nor does it exclude the rights the User may enjoy under data protection laws.
Click on a topic in the list below to get more detailed information on the individual topics by following the various links. We have marked the sections of the Policy to facilitate navigation to the most relevant information for the user.
1. Who is responsible for the protection of the User’s personal data?
Acroud AB and subsidiaries., registered office in 114, Floor 5, The Strand, Gzira GZR1027, Malta, is the main controller of the User’s personal data (the Data Controller). The Data Controller is the company that determines the means and purposes of the processing of personal data.
The User should be aware that, although we are the main controller of the User’s personal data, the information may be stored in databases to which other companies may have access. In accessing the User’s personal data, all companies will comply with the standards set out in this Policy.
Acroud is a group of companies with subsidiaries in various countries, for example in the European Union and the United States of America.
2. What personal data do we process?
We can process the following personal data relating to the User:
- Email address
- IP address
- Location data
3. For what purposes and when do we process the User’s personal data?
Acroud will collect information directly from the User when using our services or visits our websites. We follow industry standards to protect your personal information from unauthorised access and against unlawful process, accidental loss, destruction and damage.
We use the User’s personal data to:
- send promotional emails regarding products and services. See also Section 6 on Direct Marketing below.;
- analyse the information contained in our systems and databases to improve the way we manage our business and our websites based on user preferences, in order to provide a better service and user experience;
- improve and target the ads you receive from us;
- meet or exercise any of our legal obligations or rights.
We will only process your personal data for the purposes described in this Section 3 and where we are sure that:
- the User has given his consent for the data to be used in this way, or
- our use of the User’s personal data is necessary to support “legitimate interests” that we have as a commercial activity (for example, in order to improve our products, or to carry out analyzes on our sets of data), proportionately and respecting the User’s privacy.
4. With whom do we share the User’s personal data?
We work with some third parties, who help us run our business and deliver services. These third parties may occasionally need to access the User’s personal data:
- Aweber.com as the postal application service provider and processes personal data on our behalf – link to Aweber privacy policy;
- Our analytics service providers (such as Google, Hotjar and VWO), who process personal data for their own purposes as Data Controllers.
Cookie Policy in the Appendix below in order to see how the User can prevent access to their personal data by data analytics service providers.
- Service providers or data processors who manage your personal data on instructions from us, for example cloud service providers.
- If we are subject to a disclosure obligation to comply with a legal obligation or to protect our interests or safety.
- In the event of a sale, purchase or reorganization of any business or asset, or if our assets are acquired by a third party, including potential sellers or buyers.
5. International transfers
The term “International Transfers” indicates the cases in which personal data are transferred to a country outside the European Union.
In accordance with the foregoing Section 4, we may grant access to the User’s personal data to third parties located outside the European Union, as long as they provide an adequate level of protection for personal data.
We may also disclose your personal data if we receive a legal or supervisory request from a law enforcement authority outside the European Union.
6. Direct Marketing
We will use your personal data to send you direct marketing communications relating to products and services offered by us or our partners, for example for online casinos, sports betting and financial services. These communications may be in the form of emails or targeted online advertisements.
In some cases, the processing of your personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When the law requires it, it will be based on the User’s consent.
The User always has the right to refuse any further direct marketing activity at any time. You can use the opt-out link found in any direct marketing communication for this purpose, or you can do so by contacting us (see Section 8).
7. How long do we keep the User’s personal data?
We will retain your personal data for as long as reasonably necessary for the purposes set out in Section 3 of this Policy. In some circumstances we keep your personal data for a certain period of time, for example in order to meet legal, tax or accounting requirements.
We maintain a data retention policy for personal data entrusted to us. When your personal data is no longer needed, we will ensure that it is securely deleted or anonymised.
8. What are the rights of the User?
The User enjoys various rights regarding their personal data. More information about each of these rights can be found by consulting the table below. To assert their rights, the User can contact us by sending an email to [email protected] or by writing to Acroud at the address indicated in Section 1 above.
Please note the following if you wish to assert your rights:
| Right | What does it mean |
| Access | The User can ask us to confirm whether we are processing and storing any personal data. Requests to provide copy of such data can also be made. |
| Rectification | The User may ask us to rectify inaccurate personal data, and we may try to verify the accuracy of such data before rectifying it. |
| Cancellation | The User can ask us to delete their personal data, but this only if: they are no longer necessary for the purposes for which they were collected; orthe User has withdrawn his consent (in cases where the data processing was based on the User’s consent); orupon obtaining a right to object (see “Opposition” below); orin order to comply with a legal obligation. |
| Limitation | The User can ask us to limit the processing (that is to say, keep but not use) his personal data, but this only where: their correctness is contested (see Rectification), so that we can verify their correctness; orthe processing is unlawful, but the User does not want the data to be deleted; orare no longer necessary for the purposes for which they were collected, but are still necessary to establish, exercise or defend legal rights; orthe User has exercised the right of objection, and the verification of prevailing reasons is in progress.We may continue to use your personal data following a restriction request, where:we have the consent of the User; orto establish, exercise or defend legal rights; orin order to protect the rights of another natural or legal person. |
| International transfers | The User may request to obtain a copy of, or reference to, the safeguards under which the User’s personal data are transferred outside the European Economic Area. For reasons of commercial confidentiality, we may make parts of the text illegible. in data transfer agreements or related documents (i.e. obscuring some information contained in such documents). |
| Data Portability | The User has the right to request a transfer of data collected to another organisation, or directly to the User, under certain conditions. |
| Supervisory authority | The User has the right to lodge a complaint with the competent local supervisory authority regarding the processing by us of the User’s personal data. We ask the User to first try to resolve any problems with us. However, the user has the right to contact the competent supervisory authority at any time. |
9. Cookie Policy – Appendix A
In order to offer the User a full range of features when visiting our website, to recognize the User’s preferences and to make the use of our website more comfortable and convenient, we use “cookies.”
User Options
By using our website, the User accepts the use and storage of cookies on their computer or device.
These cookies are useful in making the website work properly and efficiently, and also to help improve the service and usability.
If the User does not want cookies to be stored on his computer or device, he can disable the corresponding option in the system settings of the browser. It is also possible to delete stored cookies at any time from the system settings of the browser.
More information on how to disable or delete cookies can be found here: https://www.allaboutcookies.org/.
How do we use cookies?
We use cookies for different purposes and with different functions.
Some cookies are:
- necessary in technical terms (technical necessity)
- stored and used for a certain period of time (duration of storage)
- entered and stored by us or by third parties (cookie provider).
Technical necessity
Cookies that are technically:
Necessary: we use certain cookies because they are strictly necessary for the website and its features to function properly. These cookies are automatically saved on the User’s computer or device when they access the website or a specific function. Without these, the websites wouldn’t be able to work properly.
Performance and Functional: cookies that are not strictly necessary are saved on the user’s computer or device to improve the convenience and performance of our website or to save certain settings made by the user. We also use cookies that, in technical terms, are not strictly necessary, in order to obtain information on the frequency of use of certain areas of our site, so that we can adapt it to the needs and requirements of the User in a more targeted manner.
Duration of storage
Session cookies: some cookies are necessary only during the User’s session on the website. These are so-called “session cookies.” They are deleted or become invalid as soon as the User leaves our website or at the end of the current session. Session cookies are used, for example, to store certain information during the session.
Permanent cookies: some cookies are stored for a longer period. These allow, for example, the recognition of the User, when he accesses our website again later, and access to the saved settings. As a result, they allow you to access web pages faster or more conveniently, for example without having to set certain options again, such as the selected language. Persistent cookies are automatically deleted after a predefined period of time.
Cookie Providers
First-party cookies: These are cookies saved by us or by the operator of our website, who is commissioned by us.
Third party cookies: “Third party cookies” are stored and used by other organizations or websites, such as web analysis tools. External suppliers may also use cookies to show advertisements or to integrate content from social networks, such as social plugins. For more information on web analytics tools and reach measurement , see below in this cookie policy.
Use of cookies for web analytics and coverage measurement
We use Google Analytics, a web analytics service from Google Inc. (“Google”). Google Analytics uses cookies to identify the frequency of use of certain areas of our website and to determine preferences. The information relating to the use of this website generated by the cookie (including the truncated IP address of the User) is transferred to a Google server in the United States and stored there. Google will use this information to analyze the use of the website by the User, compile reports on website activity for us and provide other services regarding the use of the website and the Internet. Google may also transmit this information to third parties where this is required by law or to the extent that such third parties process this information on behalf of Google.
The cookies that we use are from the following providers:
| Cookie provider | Purpose |
| Google Analytics | This cookie is saved by Google. It allows our website to obtain information about the use of our site by our users, such as the time of the visit, the pages viewed, whether the user has visited the site previously and the websites visited before ours. Google Analytics cookies to track users as they navigate the website and help improve the website’s usability. |
| Cloudflare | These cookies help Cloudflare detect malicious visitors and minimizes blocking legitimate users. It may be placed on the devices of the Users to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare’s security features. |
| Matomo (Pikwik) | These cookies store a few details about the user such as the unique visitor ID and attribution information that the referrer initially used to visit the website. |
| WordPress | These cookies are enabled on the browser to provide appropriate user experience to the users. |
| Hotjar | These cookies are saved by Hotjar to collects non-personal information, with the overall goal of providing a better website experience, diagnosing technical issues and analyzing trends. |
