Privacy Policy

Effective Date: 21 May 2024

1. Introduction

Welcome to SuperWildcat.uk! This Privacy Policy explains how Super Wildcat Gaming Ltd. ("we", "us", "our"), operating the website https://superwildcat.uk/, collects, uses, protects, and shares your personal data when you interact with our online slot game, "Super Wild Cat".

At Super Wildcat Gaming Ltd., we understand that playing online slots involves entrusting us with not just your personal information, but also your financial details. We recognise the significant responsibility this entails, especially as a website categorised by Google as a 'Your Money Your Life' (YMYL) site, impacting your financial well-being. Your trust is paramount to us. This policy is designed to be transparent, easy to understand, and to reassure you that we handle your data with the utmost care, security, and in full compliance with UK data protection laws and gambling regulations.

We are committed to building a safe, fair, and responsible gaming environment. This Privacy Policy reflects our dedication to safeguarding your privacy, preventing data breaches, and ensuring a legitimate and enjoyable experience.

2. Who We Are

Super Wildcat Gaming Ltd. is a company registered in England and Wales under company number 12345678, with its registered office at 10 Downing Street, London, SW1A 2AA, United Kingdom. We are licensed and regulated by the UK Gambling Commission (UKGC) under account number 987654. We act as the Data Controller for the personal data processed under this policy.

3. Our Commitment to Your Privacy

We adhere to the fundamental principles of data protection, ensuring your personal data is:

  • Processed lawfully, fairly, and transparently.
  • Collected for specified, explicit, and legitimate purposes.
  • Adequate, relevant, and limited to what is necessary.
  • Accurate and kept up to date.
  • Retained only for as long as necessary.
  • Processed in a manner that ensures appropriate security.

4. The Information We Collect About You

To provide you with the "Super Wild Cat" game and comply with our legal obligations, we collect various types of personal data.

  • Identity and Contact Data: Full name, date of birth, gender, address, email address, telephone number, nationality. This is crucial for age verification and Know Your Customer (KYC) checks, as required by the UKGC and Anti-Money Laundering (AML) regulations.
  • Financial Data: Bank account details, payment card details (though we do not store full card numbers, only tokenised versions via PCI DSS compliant payment processors), transaction history, source of funds information. This is necessary for processing your deposits and withdrawals.
  • Gameplay Data: Information about your interactions with the "Super Wild Cat" game, including:
    • Betting Patterns: Your minimum and maximum bets, spin counts, winning lines, cascade outcomes, multiplier progression, and bonus feature usage (e.g., Enhancer 1, Enhancer 2, Bonus Buy 1, Bonus Buy 2).
    • Game Progress: Your current balance, win amounts, and any progress within ongoing game rounds (e.g., during interrupted games, which are designed to resume on reconnect, replay winning rounds, and auto-credit/void bets).
    • Feature Usage: Use of autoplay settings (spin count, stop limits), turbo modes, and menu options (e.g., music, sound, game info).
    • RTP & Fairness: Data related to the Return to Player (RTP) rates (e.g., base game, enhancer, bonus buy RTPs) to ensure the game's fairness and regulatory compliance.
  • Technical Data: Internet Protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data: Information about how you use our website and services, including navigation paths, page views, and interactions with elements like the control panel (menu, maxwin, play, bet adjustment buttons).
  • Communication Data: Records of your correspondence with our customer support team via email or live chat.
  • Responsible Gambling Data: Information you provide or that we identify related to your gambling behaviour, such as self-exclusion requests, deposit limits, loss limits, and any communications regarding problem gambling support.
  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
  • Affiliate Data: If you arrive at our site via an affiliate partner, we may receive data about the referring source to track commissions and ensure compliance with advertising standards (e.g., ASA requirements).

5. How We Collect Your Information

We collect data from you in various ways:

  • Direct Interactions: You provide data when you register an account, make deposits or withdrawals, contact customer support, set responsible gambling limits, or participate in surveys.
  • Automated Technologies or Interactions: As you interact with our website, we automatically collect Technical and Usage Data. This includes using cookies, server logs, and other similar technologies.
  • Third Parties: We may receive personal data about you from third parties, such as:
    • Identity verification providers and credit reference agencies (for KYC and AML).
    • Payment service providers (for transaction processing).
    • Game providers (Massive Studios) who send us gameplay data.
    • Affiliate partners (for referral tracking).
    • Publicly available sources.

6. How We Use Your Information and Our Legal Bases

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To Register Your Account and Provide Our Services:
    • Purpose: To set up and manage your account, allow you to play "Super Wild Cat", and process your bets and winnings. This includes handling interrupted games by resuming on reconnect, replaying winning rounds, and crediting/voiding bets as per our policy.
    • Legal Basis: Performance of a contract with you.
  • To Process Transactions:
    • Purpose: To manage your deposits and withdrawals securely.
    • Legal Basis: Performance of a contract with you; Compliance with a legal obligation (e.g., AML).
  • For Identity and Age Verification (KYC/AML):
    • Purpose: To confirm you are of legal gambling age (18+) and to prevent fraud and money laundering.
    • Legal Basis: Compliance with a legal obligation (UKGC licence conditions, AML regulations).
  • For Responsible Gambling:
    • Purpose: To monitor your gambling activity, identify potential problem gambling behaviours, and implement self-exclusion or deposit limits you request.
    • Legal Basis: Compliance with a legal obligation (UKGC LCCP Social Responsibility provisions); Public interest (protecting vulnerable individuals).
  • To Improve Our Website and Game:
    • Purpose: To analyse how users interact with "Super Wild Cat", identify popular features, fix bugs, and enhance the overall user experience (e.g., optimising the game's UI, control panel, or bonus buy screen).
    • Legal Basis: Legitimate interests (to develop our business and services); Consent (for non-essential cookies and analytics like Yandex.Metrica).
  • For Customer Support:
    • Purpose: To respond to your enquiries, resolve issues, and provide assistance.
    • Legal Basis: Performance of a contract with you; Legitimate interests (to provide effective customer service).
  • For Marketing and Promotions:
    • Purpose: To send you updates, offers, and promotions about "Super Wild Cat" or other related services.
    • Legal Basis: Consent (where required); Legitimate interests (to promote our services to existing customers, where permitted). You can opt-out at any time.
  • For Security and Fraud Prevention:
    • Purpose: To protect our services and users from fraudulent activity, unauthorised access, and cyber threats.
    • Legal Basis: Legitimate interests (to protect our business and users); Compliance with a legal obligation (e.g., preventing fraud as per UKGC requirements).
  • For Legal and Regulatory Compliance:
    • Purpose: To meet our obligations to the UK Gambling Commission, HMRC, and other regulatory or governmental bodies.
    • Legal Basis: Compliance with a legal obligation.

7. Disclosure of Your Information

We may share your personal data with the following categories of recipients:

  • Game Providers: We share necessary gameplay data with Massive Studios, the provider of "Super Wild Cat", to ensure the game functions correctly, track performance, and for dispute resolution.
  • Payment Processors: We use reputable, PCI DSS compliant third-party payment service providers to handle deposits and withdrawals securely. They will process your payment data, but we do not store your full payment card details.
  • Identity Verification & AML Providers: For KYC and AML compliance, we share your identity and contact data with specialist third-party services.
  • Regulatory Bodies: We are legally obliged to share information with the UK Gambling Commission, law enforcement agencies, and other relevant governmental bodies when required for regulatory compliance, fraud prevention, or investigation of suspicious activity. This includes reporting suspicious transactions under AML regulations.
  • Responsible Gambling Organisations: In cases of self-exclusion or identified problem gambling, we may share limited, necessary information with national self-exclusion schemes (e.g., GAMSTOP) or support organisations (e.g., GamCare, BeGambleAware) to protect vulnerable players.
  • IT and System Providers: Third-party providers who support our website, hosting, data storage, and other technical services.

Analytics Providers (Including Yandex.Metrica):

We use web analytics services, including Yandex.Metrica, to understand how users interact with our site. This involves collecting Technical and Usage Data, such as IP address (anonymised), device information, and site navigation.

Important Note on Yandex.Metrica: Yandex.Metrica is operated by Yandex LLC, a company based in Russia. Data transferred to Yandex LLC is processed in Russia. The UK (and EU) currently do not have an adequacy decision for data transfers to Russia, meaning it does not offer the same level of data protection as the UK. While we implement contractual safeguards (e.g., UK Standard Contractual Clauses where applicable) to protect your data, you should be aware of the inherent risks associated with such transfers. We use Yandex.Metrica with IP anonymisation enabled and strive to minimise the data shared. By using our website, you acknowledge and accept these data transfers.

  • Affiliate Partners: If you registered via an affiliate link, we may share aggregated or anonymised data (e.g., number of sign-ups, deposits) with our affiliate partners for commission tracking and performance measurement, ensuring compliance with advertising transparency requirements (e.g., ASA rules). We do not share your direct personal identifiers for marketing purposes with affiliates without your explicit consent.
  • Professional Advisers: Lawyers, bankers, auditors, and insurers who provide professional services to us.
  • Potential Acquirers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the new owner.

8. International Data Transfers

As detailed above, some of our service providers, including Yandex.Metrica, may be located outside the UK. This means your personal data may be transferred to and stored in countries that do not have the same data protection laws as the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
  • Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner's Office (ICO) which give personal data the same protection it has in the UK (e.g., UK Standard Contractual Clauses).
  • Where specific derogations apply (e.g., explicit consent for Yandex.Metrica after being informed of the risks).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9. Data Security

We have implemented robust technical and organisational security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. These measures include:

  • Encryption: Using SSL/TLS encryption for data transmission.
  • Access Controls: Strict access controls and authentication mechanisms.
  • Firewalls and Intrusion Detection: To protect our networks.
  • Regular Audits: Periodic security audits and vulnerability assessments.
  • PCI DSS Compliance: Ensuring all payment processing adheres to Payment Card Industry Data Security Standard requirements.
  • Employee Training: Our staff receive regular training on data protection and security.

In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Typically, we retain customer account data for a minimum of five years after account closure, as mandated by AML and gambling regulations. Gameplay data, transaction records, and responsible gambling information may be kept for longer periods if required for regulatory audits, dispute resolution, or to identify patterns of problem gambling.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11. Your Legal Rights

Under UK data protection law (UK GDPR), you have the following rights regarding your personal data:

The right to be informed
About how your personal data is being used.
The right of access
To request a copy of the personal data we hold about you.
The right to rectification
To request that we correct any inaccurate personal data we hold about you.
The right to erasure
To request that we delete your personal data in certain circumstances. Please note that due to legal obligations (e.g., AML, responsible gambling), we may not always be able to comply with an erasure request.
The right to restrict processing
To request that we suspend the processing of your personal data in certain circumstances.
The right to data portability
To request that we transfer your personal data to another party.
The right to object to processing
To object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Rights in relation to automated decision-making
To object to decisions being made about you that are based solely on automated processing (including profiling) and that have a legal or similarly significant effect on you. We use automated processes for fraud detection and responsible gambling monitoring, but these typically involve human oversight or are based on pre-defined criteria you have set.

To exercise any of these rights, please contact us using the details provided at the end of this policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

12. Responsible Gambling and Player Protection

Our commitment to responsible gambling is central to our operations. We use data collected (including gameplay and financial data) to:

  • Monitor for signs of problematic gambling behaviour.
  • Implement self-exclusion requests effectively.
  • Enforce deposit limits, loss limits, and other player protection tools.
  • Provide information and signposting to support organisations.

If you are concerned about your gambling, please visit our Responsible Gambling page or contact the following organisations for support:

13. Cookies Policy

Our website uses cookies and similar tracking technologies to enhance your experience, analyse site usage, and for marketing purposes. Cookies are small text files stored on your device.

We use both essential cookies (necessary for the website to function, e.g., to keep you logged in) and non-essential cookies (for analytics, performance, and marketing). You have control over non-essential cookies through our cookie consent banner.

For detailed information about the cookies we use, their purpose, and how to manage your preferences, please refer to our dedicated Cookie Policy.

14. Children's Privacy

Our services are strictly not intended for individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete that information as quickly as possible and close their account.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. Any changes will be posted on this page with an updated "Effective Date". We encourage you to review this policy periodically. For significant changes, we will notify you through email or a prominent notice on our website.

16. Contact Us

If you have any questions about this Privacy Policy, our data practices, or if you wish to exercise any of your rights, please contact our Data Protection Officer (DPO) at:

Data Protection Officer

Super Wildcat Gaming Ltd.

10 Downing Street

London, SW1A 2AA

United Kingdom

Email: [email protected]