At Multibrands Digital CY Ltd (from now on referred to as "Multibrands" or "we"/"us"), we handle personal information about our customers and visitors to our websites ("you"). Our ambition is to handle your personal data with care, to keep it safe and secure. Multibrands operates in so called "performance marketing" and "lead generation" on the Internet, with headquarters in Cyprus.
The purpose of this policy is to explain when, why and how we process information that may concern you ("personal data"). The policy also provides important information about your statutory rights. This policy is not intended to replace any rights you may have according to the data protection law.
1. Who handles your personal data?
Multibrands Digital CY Ltd, based in Cyprus at 28th October Street 319, Kanika Business Center, Office 101B, 3105 Limassol, has the main responsibility for handling your personal data (your data controller). Data controller refers to the company that determines the method and purpose of processing personal data.
It is important to emphasize that despite the fact that we bear the primary responsibility for handling your personal data, information can be stored in databases that are accessible to other companies. When accessing your personal data, all companies must comply with the standards provided in this policy.
3. What is your personal data used for and how do we handle it?
Multibrands will gather information directly from you when you use our services or visit our websites.
We use your personal data to
- send emails with marketing for our products and services. See paragraph 6 below about direct marketing.
- analyse information in our systems and databases to offer better services and to improve the user experience.
- improve and target ads that you receive from us.
- register you on an online forum or community, if we make one available, where you can write or leave comments.
- fulfil or exercise any of our legal obligations or rights.
We only handle your personal data for the purposes set forth in section 3 and when we are sure that
- you have given us permission to use the data in the mentioned ways, or
- if the use of your personal data is necessary to support "legitimate interests" that we have as a company (e.g. to improve our products or to perform analyses of the data that we aggregate in our business), in a proportionate way while also respecting your privacy.
4. Who do we share your personal data with?
We work with several third parties which help us to manage our business and to perform services. These third parties will sometimes need access to your personal data.
- Our email application provider Compost Marketing AB, based in Sweden, handle personal data on our behalf.
- Our providers of analytics services (e.g. Google) handle personal data for their own purposes as data controllers. Read more about our Cookies Policy below to learn how you can prevent access to your personal data by providers of analytics services.
- Service providers or personal data processors that handle your personal data on our instructions, e.g. cloud services.
- Potential subsidiaries that we may establish in other countries in the future, in or outside of EU/EES.
- If we have a legal obligation to reveal information or are forced to do so to protect our interests or our safety.
- If we sell, buy or reorganize one of our businesses or assets, or if our assets are acquired by a third party.
5. International transfers
International transfers mean that personal data is transferred to a country outside of the European Union. As mentioned in paragraph 4 above, third parties outside of the European Union may be allowed access to your personal data. We may also disclose your personal information if we receive a legal or a governmental request from a foreign law enforcement department outside the European Union.
We will always ensure that international data transfers are managed in a way that protects your rights and interests. Any request for information we receive from law enforcement departments or regulatory authorities will be carefully checked before personal data is disclosed. You have the right to ask us for more information about the safety measures described above that have been implemented. Contact us if you want more information, using the email address provided in section 8 below.
6. Direct Marketing
We will use your personal information to send direct marketing about products and services that we and our partners offer regarding e.g. online casino, online poker, horse racing, betting services and financial services. It can be via email or targeted ads on internet.
In some cases, our processing of your personal data for marketing purposes will be based on our legitimate interests (see paragraph 3 above). When required by law, it will be based on your consent. You can always say no to direct marketing at any time. You can use the link to decline any direct marketing or contact us (see section 8).
We do take measures to limit direct marketing to a reasonable and proportionate level, and to send communications that we believe may be of interest or relevance to you, based on the information we have about you.
7. How long do we keep your personal data?
Your personal data will be retained for as long as is reasonably necessary for the purposes set out in paragraph 3 of this policy.
Under certain circumstances, we retain your personal data for a certain period of time in order to e.g. comply with legal, tax related or accounting requirements.
8. Your rights
You have certain rights when it comes to your personal data. For more information about these rights, see the summary below.
To exercise your rights, you can contact us by sending an email to firstname.lastname@example.org, or by writing to Multibrands at the address stated in paragraph 1 above.
Legal right - Meaning
Access - You can ask us to
- confirm if we are handling your personal data
- give you a copy of the information
- give you other information about your personal data, e.g. what information we have, what we use it for, who we share it with, if it is shared outside of the EU and how we protect it, how long we store it, what your rights are, how to make a complaint, where we got the data from and if there has been any automatic decision-making or automatic profiling, to the extent that the information has not already been shared with you in this policy.
Correction - You can ask us to correct inaccurate personal data.
Delete - You can ask us to delete your personal data, but only if
- it is no longer needed for the purposes for which it was collected or
- if you have withdrawn your consent (when processing was based on consent) or
- if you have a successful right to object (learn more about "objections" below) or
- if it was handled illegally or
- if it is needed to fulfil a legal obligation.
We are not obliged to fulfil your request to delete your personal data if it is necessary
- to process it to fulfil a legal obligation or
- to establish, exercise or defend legal claims.
Limitation - You can ask us to limit (i.e. keep, but not use) your personal data, but only
- if the accuracy is disputed (see Correction), so that we can verify its accuracy or
- if the processing is illegal, but you do not want it to be deleted or
- if it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims or
- because you have exercised the right to object, and the verification of the main reasons are ongoing.
We may continue to use your personal data following a request for limitation
- if we have your consent or
- if it is needed to establish, exercise or defend legal claims or
- if it is needed to protect another physical or legal person's rights.
Portability - You can ask us to share your personal data with you in a structured, accepted, machine-readable format, or you can ask us to have them "ported" directly to another data controller, but only if
- the processing is based on your consent or a fulfilment of an agreement with you and
- the processing is done with automatic methods.
Objection - You can object to the processing of your personal data that has our "legitimate interests" as a legal basis, if you believe that your fundamental rights and freedoms outweigh our legitimate interests. We have the opportunity to show that we have compelling legitimate interests that are more important than your rights and freedoms.
International transfers - You can request a copy of or a reference to the safety measures under which your personal data is transferred outside the European Economic Area, if that would happen.
Regulatory authority - You have the right to make complaints to the appropriate local regulatory authority regarding our processing of your personal data. First and foremost, we hope that you will try to sort out an eventual problem with us, even if you have the right to contact the authority at any time.
9. Cookies Policy
What are cookies? A cookie, pixel or similar technology is a small file that is saved on your computer or other technical device when you visit a website. It allows the website to remember your actions and preferences (e.g. login, language, font size and other settings) over a certain period of time, so that you do not have to change or re-add that information when you return to the site.
Your choices - By using our website you consent to the use and storage of cookies on your computer or device.
You can view our website without cookies, subject to certain parts of it might not work exactly as they should.
If you don't want cookies to be stored on your computer or device, you can deactivate them in the system settings in your browser. You can also delete saved cookies at any time in the same system settings.
- necessary in technical terms (technical necessity)
- stored or used for a certain period of time (storage duration)
- placed and stored by us or a third party (cookies provider).
Cookies that are technically
- necessary: We use certain cookies because they are technically necessary in order for the website and its functions to work properly. These cookies are automatically placed on your computer or device when you enter the site or a certain function, unless you have set your browser to reject cookies.
Session cookies: Some cookies are only needed during your session on the website, so-called session cookies. They will be deleted or invalidated as soon as you leave it or your current session ends. Session cookies are used, for example, to retain certain information during your session.
Persistent Cookies: Some cookies are stored for a longer period of time. This means, for example, that we can recognise you when you return to our site at a later date and use the saved settings. As a result, you can access web pages faster with greater ease. Permanent cookies are automatically deleted after a predefined time period.
Browser Cookies: These cookies are used for communication between our own servers within our company. They are placed on your computer or device when you start navigating the website and are deleted when you are finished navigating it. Browser cookies get a unique identification number, but do not allow us to draw conclusions about the actual customer or user.
Cookies Providers: These are cookies that are placed by us or the operator of our website, which are ordered by us.
You can deactivate Google Analytics with the help of a browser extension if you don not want the website analysis to take place. You can download the extension here: https://tools.google.com/dlpage/gaoptout?hl=
This browser addon stores information about opting out on your device, which matches your Google Analytics deactivation. Note that this type of waiver only results in Google Analytics being deactivated on the device and browser from which the waiver was enabled. The waiver may also need to be reactivated / repeated if you delete cookies from your device.