Privacy Statement
Table of Contents
1. Introduction privacy statement STARCASINO
Here you are reading the privacy statement of STARCASINO, trading name and property of Green Island N.V., offering online gaming through the website Starcasino.co.uk. This privacy statement applies to any privacy sensitive information or personal data that you provide to us. For example, you provide personal data to us when you create an account with STARCASINO or contact customer service. We will clearly explain to you when we process your data, how we store your data, how long it is retained and what exactly is the purpose of the data processing. In addition, we will give you a clear understanding of how you can exercise your rights with respect to data processing.
As a gaming provider, STARCASINO must process a variety of personal data from you before you can use our services. An overview of the personal data we process from you can be found later in this Privacy Statement. STARCASINO always takes the highest possible care when processing your personal data. In doing so we always adhere to the applicable European privacy legislation, the General Data Protection Regulation (AVG) and other applicable laws and regulations, such as the Gaming Act and the Decree on remote gaming.
In any event STARCASINO does not process personal data of minors (persons under 18 years of age), nor is it permissible for minors to use the STARCASINO website and the services offered thereon.
In terms of supervision, there are two authorities of interest; the Personal Data Authority and the Gaming Authority. The Personal Data Authority is the regulator of all privacy-related matters within the Netherlands, and the Kansspelautoriteit is the regulator of the Dutch gaming market. In the case of data protection, the Personal Data Authority has the main role in the control of gaming providers, such as STARCASINO, with the Kansspelautoriteit focusing mainly on areas such as addiction prevention, the control of financial transactions and the issuance of licenses for being allowed to offer gaming in the Netherlands. STARCASINO will always follow instructions and policies of these authorities.
Do you have any doubts or questions regarding the processing of your personal data by STARCASINO? Please feel free to contact us using the link below:
starcasino.co.uk/help/contact
2. Categories of personal data
In order to provide you with the best experience at STARCASINO, it is necessary for us to collect/process certain data, including personal data. Personal data is any data that in itself or collectively can be traced back to a natural person. When personal data of a natural person is processed, this person is also referred to as the 'data subject'. The personal data that we process in any case are:
First and last name;
Address data;
Telephone number;
E-mail address;
Bank details;
Date of birth;
Copy of ID;
Citizen service number (once only).
In addition to the above personal data, it is possible that STARCASINO may process additional personal data. This may be the case, for example, if STARCASINO conducts an (additional) client survey. We shall only retain and use personal data that is necessary for statutory tasks, or that is provided directly by you, or that upon submission is clear that it is being submitted for processing by STARCASINO.
3. Grounds and purposes for data processing
Under the AVG, we are obliged to base the processing of personal data on lawful bases. Bases are the conditions, derived from the AVG, which must be met in order for the processing of personal data to be lawful. For the processing of your personal data, we rely on the following bases:
You have consented to the processing of your personal data (Article 6 paragraph 1 sub a AVG);
The processing is necessary for the performance of an Agreement between you and STARCASINO (Article 6 paragraph 1 sub b AVG);
The processing is carried out on the basis of a legal obligation of STARCASINO (Article 6 paragraph 1 sub c AVG);
The processing is carried out in order to protect the interests of STARCASINO (Article 6 paragraph 1 sub f AVG).
STARCASINO will not process "special personal data" in the first instance. Special personal data is a different category of personal data than normal personal data, as shown in the list in Section 2. An example of special personal data is personal data relating to your health. However, in some cases it may be necessary to process special personal data. This will mainly occur in the context of addiction prevention. This is because health data is understood to include not only physical but also mental health. A (development of a) gambling addiction falls under personal data on mental health. We always process this data within the framework of our legal obligation.
In addition to the aforementioned bases, we also name the processing purposes for which we process your personal data. To do this, we first give you some general information about processing purposes.
Why processing is linked to processing purposes.
Based on the AVG, all processing must be linked to processing purposes, in addition to the aforementioned bases. Processing purposes are the actual reasons for processing your personal data. An example of a processing purpose for which we process your personal data is to register an account with STARCASINO. Indeed, in order to register the account, we need your personal data, both to comply with our legal obligations and to provide you with the most complete and best experience.
Listed below are the processing purposes for which STARCASINO processes your personal data. For each processing purpose, the applicable basis is also disclosed, or if there are several, the applicable bases. In Section 4 we indicate for how long personal data is retained for each purpose.
STARCASINO processes your personal data on the basis of the following processing purposes:
1. Contacting you
If you contact STARCASINO in any way, the data you provide will be retained and used so that STARCASINO can maintain contact with you. This contact may be via email or customer service chat, for example. If you have an active account, the data on your account will be processed and/or any additional information you provide to us.
The bases for processing in this context: our legal obligations (If your contact request concerns a complaint, we are obliged to process the data for statistical purposes in accordance with our reporting obligations), our legitimate interest (in order to be able to respond to your questions, complaints and contact requests as easily as possible, we process your data so that we can provide you with the best possible service).
2. Service and account
When you register with STARCASINO and create an account, STARCASINO requires certain data. Without this data it is not possible or even allowed to provide our services to you. These include first and last name, phone number, IBAN, a copy of your identity card, your citizen service number (once for the first check in the Cruks), but also possible data about your health.
The bases for processing in this context: our legal obligations (STARCASINO is obliged to establish your identity and maintain your account data for multiple tasks, such as client research according to the anti-money laundering policy or maintaining the control database), in performance of the agreement (in order to be able to offer you our services we need to maintain this data, if we do not do this we cannot grant you access to our services).
3. Financial administration
STARCASINO is required by law to maintain proper accounting records. In addition to accounting, STARCASINO is also obliged to monitor transactions under the anti-money laundering policy. To this end the data reasonably submitted in a payment transaction is retained. This includes your name and bank details, such as the IBAN.
The bases for processing in this context: our legal duties (STARCASINO is obliged to keep sound financial records including proper accounting. This duty is both to comply with anti-money laundering purposes and the administrative obligations of the organization for tax purposes), in performance of the agreement (to be able to offer you our services we need to keep this data, if we do not do this we will not be able to offer you services such as the distribution of funds).
4. Addiction Prevention
STARCASINO is required by gaming legislation to protect customers from adverse effects on their welfare as a result of the service. Part of this is addiction prevention, whereby your playing behavior is monitored and information about interventions, in the context of addiction, is kept.
The bases for processing in this context: our legal obligations (STARCASINO is obliged to implement a sound addiction prevention policy for your protection), in performance of the contract (in order to offer you our services we need to be able to carry out the relevant work, including the implementation of our addiction prevention policy).
5. Control database
STARCASINO is required to maintain data on players in the control database pursuant to gaming legislation. The following data is processed in the control database; playing behavior (games played wagers and duration of play), the data as displayed in the account (also player ID), bank details and all transactions, player complaints, intervention measures taken, changes in playing limits, duration of the playing session, player concerns (also known as 'red flags') and result of the casino.
The bases for processing in this context: our legal obligations (STARCASINO is obliged to establish a control database and process your data in the control database), in performance of the contract (in order to offer you our services we need to be able to process this data).
6. Central Register Exclusion Games of Chance (Cruks).
STARCASINO is required by law to check registration in the Cruks for each registration. Upon registration, the check in the Cruks is done for the first time by means of your citizen service number. After this initial check, we will receive a unique Cruks code and your citizen service number will be removed from our records. Further checks in the Cruks are done using the unique Cruks code, at each registration.
The bases for processing in this context: our legal obligations (STARCASINO is obliged to check your registration status in the Cruks), in performance of the contract (in order to be able to offer you our services we need to be able to perform these checks).
7. Money Laundering and Terrorist Financing Prevention Act.
STARCASINO conducts client investigations and match-fixing checks to comply with its legal duty. These checks are carried out in accordance with its own anti-money laundering policy, to prevent the financing of terrorism, carrying out PEP checks and sanctions list checks. This may include processing your name, bank details, address details and other personal data.
The bases for processing in this context: our legal obligations (STARCASINO is obliged to implement a sound anti-money laundering policy), in performance of the agreement (in order to be able to offer you our services we need to be able to perform these checks, such as for the disbursement of funds).
8. Search engine marketing
STARCASINO uses the services of search engines, such as Google Analytics, to offer relevant and sponsored advertising in your searches based on your surfing behavior. In addition, your personal data is also used to ensure that we do not target vulnerable groups. Think of data about your age and your surfing behavior.
The bases for processing in this context: our legal obligations (STARCASINO may not tailor online advertising activities and search engine search functions to vulnerable groups, for this purpose we use age filtering among others), our legitimate interest (in order to effectively reach our target groups we use search engine optimization, so that we reach our target groups as much as possible).
9. Social media
If you interact with STARCASINO on social media, such as on Facebook, X, YouTube, Snapchat, LinkedIn, etc., your available personal data may be processed. Examples include a request to join a private group or a contact request where we process your name and age.
The bases for processing in this context: our legal obligations (STARCASINO should not tailor or offer recruitment and advertising activities to minors, to this end we use private groups for which we perform verification of your identity, age and account status with STARCASINO. If your contact request concerns a complaint, we are obliged to process the data for statistical purposes in accordance with our reporting obligations), our legitimate interest (in order to respond to your questions, complaints and contact requests as easily as possible we process your data so that we can provide you with the best possible service).
10. Marketing Partners
STARCASINO cooperates with partners to carry out marketing activities. For this purpose we deploy, among others, affiliate links that track you from our partners to our website. For this we use tracking links that follow you from our partners' website to STARCASINO's own website: Starcasino.com. In addition, we use partners such as (the techniques of) Amazon and Google to set up and execute marketing campaigns.
The bases for processing in this context: for the performance or establishment of the agreement (STARCASINO can only deliver the promotions offered if the offer made is made known to us, for this we use technologies that automate this process), our legitimate interest (STARCASINO compensates the marketing partners for recruitment and advertising activities on the basis of the referrals, in order to understand the volume of referrals we need insight into the origin of your referral).
11. Complaint Procedure
If you submit a complaint to STARCASINO, your personal data will be processed so that we can contact you and resolve the problem. The data will also be anonymized and used in the legally required annual statements. For the annual statements we use only anonymized and statistical data, however, your personal data are processed in the process of anonymization.
The bases for processing in this context: the performance of the agreement (in order to provide a compliant service we need to be able to answer any complaints or queries), our legal obligations (STARCASINO is required by law to process your personal data for statistical purposes in the annual reports), our legitimate interest (STARCASINO strives to improve its own services, for this purpose it is necessary to help you as best as possible in case of complaints).
12. Newsletters, SMS and push notifications
If you wish to receive our newsletters, at least your e-mail address will be processed for sending the newsletter. If you want to receive text messages from us, your cell phone number will be used for this purpose. If you want to receive push notifications, we process information about your web browser or mobile device for this purpose. If necessary, other data (such as your name) may also be processed. You can unsubscribe from our newsletters and other communications at any time.
The bases for processing in this context: your express consent (making it known to STARCASINO that you are interested in receiving our newsletter, SMSs, and/or push notifications), our legitimate interest (for open communication and information about STARCASINO, if possible for the provision of certain services or products we need to have the ability to contact our customers).
13. Inquiries under the suspension protocol.
STARCASINO shall collect data in order to initiate an investigation, at the time STARCASINO receives signals leading to such an investigation. This may include, for example, suspicion that the player is guilty of fraud. Such an investigation may take up to six months. The personal data processed in this context are the personal data as available on the account, or as processed at the time of registration, together with the playing behavior and data concerning financial transactions.
The basis for processing in this context: our legal obligations (STARCASINO needs to investigate possible "suspicious" behavior of players).
14. Cookies placed through Starcasino.com
In order to make use of the website and for the website to function properly some data is stored. This includes statistical data on surfing behaviour and website visits (scrolling and clicking behaviour).
Note: With regard to cookies, we conform to both the AVG and the Dutch Cookie Law (Telecommunications Act article 11.7A). This means that more extensive information about cookies is given in a separate document: our cookie declaration.
4. Period of storage
Above we have indicated the processing purposes for which we use your personal data. For each processing purpose we must, also on the basis of the AVG, indicate how long we store the personal data. For each processing purpose, we indicate for how long we retain the personal data and from what moment the retention period starts. Keep in mind that personal data initially processed for one processing purpose may be transferred to another processing purpose. The retention period of the last processing purpose is then leading. Under no circumstances will STARCASINO retain personal data for an indefinite period of time.
1. Contact
If the contact does not lead to the provision of a service, the data provided by you, such as your email address, will be retained for a maximum period of two (2) years.
2. Services and account.
All data related to your account, will be kept at least for the period that your account is active. At the time your account is closed, we will retain this data for at least three (3) years. Certain personal data from your account may be retained for at least seven (7) years in connection with our legal obligations. This personal data relates to the prizes won and the amount wagered. The data will be kept for the indicated periods, unless a longer storage period is necessary in connection with legal obligations, statutes of limitation and/or a foreseeable legal dispute.
3. Financial administration
In order to maintain proper accounting records, we must retain personal data associated with financial purposes for a statutory period of at least seven (7) years. This unless a longer storage period is necessary in connection with legal obligations, limitation periods and/or an anticipated legal dispute.
4. Addiction Prevention
Data processed in the context of addiction prevention are stored for different periods of time per section. Data on your status of enrollment in the Cruks can be found under point 6 of this section, data stored in the control database are kept for at least three (3) years from the time your account is closed, and information on interventions are kept for up to one (1) year .
5. Control database
Data in the control database should be retained for at least one (1) year. Certain data in the control database should be retained for a period of three (3) years and up to seven (7) years, such as financial transaction data.
6. Central Gaming Exclusion Registry (Cruks).
A note of your registration status will be kept for as long as you have a player account with us. Upon deregistration, this note is immediately deleted. If you do not have a player account with us and the data request to Cruks does not result in the creation of an account, this data will be deleted immediately.
7. Money Laundering and Terrorist Financing Prevention Act.
Your data will be kept for at least five (5) years after your player account with us is closed under our anti-money laundering policy.
8. Search Engine Optimization
Your data will be deleted in accordance with our cookie policy. See our cookie statement for more information about the cookies we use to gain insight into website visitors' browsing behavior.
9. Social media
Your data will be processed for the duration of your registration in our private groups, the duration of your contact request and if this contact request concerns a complaint, a period not exceeding one (1) year.
10. Marketing partners
Your data will be deleted in accordance with our cookie policy. Please see our cookie statement for more information about the cookies we use for tracking links.
11. Complaints procedure
STARCASINO will store your data for at least the duration of the handling of your complaint, with a maximum period of one (1) year. This unless a longer storage period is necessary in connection with legal obligations, statutes of limitation and/or an anticipated legal dispute.
12. Newsletters, SMS and push notifications.
STARCASINO retains the data until you unsubscribe from the newsletter or your subscription in the Cruks becomes known to us. In either case the data will be deleted immediately or within the duration of any contact request.
13. Inquiries under the suspension protocol
STARCASINO retains all data under the suspension protocol in the control database, with this data being kept in the control database for one (1) year. It is possible that these data may be retained for longer as part of the study (study end date).
14. Cookies placed through Starcasino.com
All information relating to cookies is explained in detail in our cookie statement.
5. Recipients of personal data
STARCASINO shares personal data with third parties in certain cases: this is only done when strictly necessary. In all cases STARCASINO will comply as a data controller with the AVG legislation, specifically Article 28 ff. AVG.
Below we provide you with an overview of third parties with whom we share your personal data.
Overview of third party(ies) receiving personal data from you:
Certain cookies on this website may collect certain data, this data may be shared with Google depending on the website visitor's cookie setting. For more information about Google's privacy policy, please see Google's Privacy Statement.
Dutch Gaming Authority
The Dutch Gaming Authority has access to the control database of STARCASINO. As a gaming provider, STARCASINO is required by law to be transparent about the execution of the games of chance offered. For this reason, the Dutch Gaming Authority has access to the control database and associated data.
The Central Register Exclusion Games of Chance is also covered by this.
Social media channels
STARCASINO uses its own social media channels as well as the marketing tools offered by social media channels. Through social media, Players can contact STARCASINO. For this purpose the data, which you make available, is processed by the social media platform.
Third Parties for the provision of services
STARCASINO uses partners who provide, for example, the games of chance that you can play on our website. These partners receive certain data, such as wagers made on their own games.
Other partners may for example be suppliers of security devices or software for communication tools, such as the chat service. What personal data these parties receive, if any, depends entirely on the service these parties provide. A processor agreement is in place with each party to ensure the security of the processing of your personal data as much as possible. The following partners are used for this purpose:
Partner for the Control Database;
Partner for the verification of PEP status holders and sanction lists;
Marketing partners;
Customer support.
Furthermore, we will not provide the data you provide to other parties. Should we nevertheless share personal data with any party other than the parties listed above, we will first seek your consent to do so, for example by amending STARCASINO's privacy statement.
6. Central Games of Chance Exclusion Register
In this privacy statement you have been able to read about the Central Register of Games of Exclusion, also known as Cruks. The Cruks is used to check whether you and other players are excluded from participating in any form of gambling. It is a database where all persons who are excluded from gambling are listed. This database is held by the Gaming Authority and not by STARCASINO.
However, STARCASINO does have the ability to check whether you are listed in the register. Upon registration we first check whether you are registered in the Cruks by means of your citizen service number. The citizen service number is then immediately removed and replaced with a unique Cruks code. With every login attempt at STARCASINO, your registration in Cruks will be checked with this unique code. If you appear in the registry you cannot participate in the games of chance offered on STARCASINO.
Because STARCASINO does not administer the Cruks itself, we cannot provide you with further support in the event of complaints about the Cruks, you should contact the Kansspelautoriteit. You can reach them at info@kansspelautoriteit.nl, 070 302 1300 or any of their social media channels on Twitter or Facebook.
7. Control database
The control database is the system by which STARCASINO stores near-real-time data of every transaction and every gaming session. This system is separate from the main system, which you use, for example, when playing games of chance at STARCASINO. This system logs all play data and all transactions to and from your account.
The Gaming Authority is constantly connected to this system and can view the data (pseudonymized or not). This means that all incoming and outgoing transactions are constantly monitored, along with all wagers and payouts of winnings. Before the monitoring database was put into operation, it was extensively tested for security and reliability of the system itself and its connection to the Gaming Authority.
8. Security
Strict requirements are imposed on the security of the digital systems, through which STARCASINO can offer games of chance. These requirements are set out in laws and regulations, to which additional detail is provided by the Gaming Authority. The requirements to be met by STARCASINO are in accordance with standards from the ISO-270001 standard. This is a globally recognized standard for information security. STARCASINO complies with this standard at all times, using state-of-the-art security techniques and the best partners to ensure that your personal data is secure.
Personal data processed by STARCASINO can only be accessed by the authorized staff of STARCASINO and the Dutch Gaming Authority to the extent required by law. The devices on which your data is stored are locked with a password and/or fingerprint scan and/or facial recognition. This obviously involves the necessary devices, such as data servers, computers, laptops and cell phones.
For the website or digital transmitted data, STARCASINO uses firewalls and virus scanners. Also, your visit to STARCASINO's website is protected by ''https'' security. This means that your connection to STARCASINO is private.
Furthermore, we use a locked system that is additionally password protected. Only authorized personnel have access to this system. For the sake of completeness, more information about online security;
All devices that access your personal data and are part of the processing of personal data are password protected;
Access control according to the principle of least privilege (only the person who has access to specific information can actually see it);
Staff is trained in the use of personal data;
The use of an incident response plan;
Security software, such as a firewall and locked program;
Encryption of sensitive data;
We send your data via a secure Internet connection. You can tell this by the address bar 'http' and the padlock in the address bar;
We use a locked software;
No personal data is kept physically (on paper).
9. Your rights regarding your personal data
Listed below are the rights you can exercise with respect to your personal data. Here we indicate in as much detail as possible in what way the respective right can be exercised.
a. Right of access (Article 15 AVG) {#sub-1}
You have the right to inspect the data processed and stored by STARCASINO at any time. To exercise this right, please send an email with your request to: klantenservice@starcasino.nlYou can indicate here which data you would like to access.
b. Right of rectification (Article 16 AVG) {#sub-2}
If the data held by STARCASINO is found to be incorrect, you have the right to have this data rectified. STARCASINO will then replace the currently incorrect data with the correct data.
c. Right to transfer of data (Article 20 AVG) {#sub-3}
You have the right to have personal data transferred by STARCASINO to a similar party. This means a party that offers and performs the same or virtually the same services as STARCASINO.
d. Right to erasure of data (Article 17 AVG) {#sub-4}
In certain cases, you may request STARCASINO to have your data deleted. To this end, you have the option with the right to oblivion. Below is a list of situations in which STARCASINO shall delete your data:
If the data processed by STARCASINO is no longer necessary for the purpose of processing;
If the consent to the use of the personal data is withdrawn by you, For example through the 'unsubscribe button' on the STARCASINO newsletter;
If you object to the processing of your data. In the case of direct marketing, you always have an absolute right to object;
If STARCASINO processes data unlawfully, you have an immediate option to have the data deleted by STARCASINO. This is the case, for example, if there is no legal basis for the processing of personal data;
If a legal retention period has been exceeded, STARCASINO shall be obliged to delete the personal data processed;
If you as a data subject are under 18 years of age, your data shall be deleted immediately, as soon as STARCASINO is informed or notified, of the processing of your personal data.
There may be exceptions to the right to oblivion. For more information, please visit the following page consult.
e. Right to stop data use, objection (Article 21 AVG) {#sub-5}
You have the right to object to the processing of your data. You may do so in the event that STARCASINO processes the data under Article 6(1)(e) (public interest) or Article 6(1)(f) (legitimate interest) of the AVG. This means that when you request to STARCASINO that your personal data should no longer be processed, as a rule STARCASINO agrees. There may be exceptions to this, for example where there is a legal obligation to retain the data or where STARCASINO's interest in the continuation of the processing outweighs your interest.
f. Other rights {#sub-6}
In addition to the rights explicitly named as rights in the AVG, you have some other possibilities to restrict or stop the processing of your personal data. Please note the following rights:
Right to restrict (part of) the processing: under conditions, you have the right to request STARCASINO to restrict the processing of your data. In brief, this means that STARCASINO temporarily "freezes" the processing of the data. You may invoke this right in four situations: (1) pending assessment of a correction request, (2) where data should in fact be deleted but you do not wish deletion, (3) where STARCASINO no longer requires the data while it is still required for (the preparation of) legal proceedings and (4) pending assessment of an objection.
Withdrawal of consent: you have this right insofar as we process from your data on the basis of your consent. You have the right to withdraw the given consent at any time. This has no consequences for past processing, but does mean that we no longer process that data as of the granting of the request. STARCASINO may no longer be able to provide you with certain services as a result.
Filing a complaint with the Personal Data Authority: if you have made a request under any of the aforementioned rights, and STARCASINO has failed to respond or does not agree, you may file an objection with the Personal Data Authority. You may do so by clicking on this link and filling in the form.
Using the above rights?
In most cases an email to klantenservice@starcasino.nl is enough to exercise the aforementioned rights. If we have doubts about the validity of your identity, we can take other measures to find it out. In addition, verification can take place by logging into the account, our system will then establish the verification. If necessary, you will be asked for confirmation through some form of two-step verification, such as a sent e-mail, which allows you to confirm that you are the correct person.
Please note that the rights described above are not absolute rights unless otherwise indicated. There may be circumstances that make it impossible for STARCASINO to comply with a particular request. We will always assess each request on its own merits. Should we (be unable to) comply with a particular request, we shall inform you of the reasons.
10. Duties
STARCASINO processes your personal data, as indicated, on the basis of various legitimate interests. STARCASINO guarantees that your personal data will never be sold to a third party.
The data required to be provided are the minimum personal data required in order for us to perform our services. If you do not provide these mandatory data to us, STARCASINO cannot provide and perform the services (properly). In addition, refusing to provide certain data upon registration means that you cannot use the services of STARCASINO.
If it is necessary to share your data with party(ies) other than those listed in Section 5, STARCASINO will first seek your consent to do so. We do this by amending our privacy statement and informing you of this. We will always notify changes via the STARCASINO website or by email to the email address you provide.
STARCASINO reserves the right to disclose data when required to do so by law, or when STARCASINO deems it justified to comply with a legal request or process. Also when it concerns property or to protect STARCASINO. In doing so, we will respect your right to privacy as much as possible.
For more information and answers to the most common questions, please also visit our Help page.