Data Protection Notice  

 

This notice contains the information on personal data required by articles 13 and 14 of the EU General Data Protection Regulation (2016/679) which we process in relation to our website and offered games (“Games”) at airdice.com (“the Service”).

 

Controller (“the Supplier”)

Air Dice, Business ID: 1785373-9
Address: Hämeentie 19, 00500 Helsinki
Domicile: Helsinki

Contact for data protection matters:
Data Protection Officer
Peter Granfelt
Address: Hämeentie 19, 00500 Helsinki
Email: privacy@airdice.com

Categories of personal data

This notice concerns personal data which we process on the users of the Service and/or corporate users’ contact persons, as well as on other people whose personal data need to be processed for the provision and usage of the Service.

The following three categories of users, data subjects, are identified:

  • Category 1: Website users
  • Category 2: Clients and Business Partners
  • Category 3: Players, end users of Games

Category 1: Website users

Contact information

Did you give us information through sending an e-mail? In this case; it is possible that we store your information. We will use this only to be able to contact you about the requested matter: we will never approach you in the context of marketing (or other unsolicited approaches).

For this processing purpose we collect the following data: Name, E-mail address, Telephone number if we received this, your Message (might contain information), possibly other personal information that is being shared with us.

The grounds for processing in the context of this purpose: Legitimate interest (to be able to communicate with you, to handle and follow up on the questions, complaints or requests that you submit via the contact form).

Analytics, Cookies

We collect the following data: IP address, location data, statistical and aggregated data about surfing behavior and website visits (scroll and click behavior).

The grounds for processing in the context of this purpose: Legitimate interest: Consent (for the use of analytical cookies, via the cookie banner on the website) and legitimate interest (for our website to function properly, to gain insight into the website visit, to recognize the visitors to our website, count the number of visitors and determine how they use our website (this helps us to improve our website and to allow visitors to find what they need faster and easier).

More detailed information about cookies is provided in our Cookie Statement.

Category 2: Clients and Business Partners

Financial administration

For this processing purpose we collect the following data: Name, Job title, Contact details including telephone number and e-mail address, Invoice address, Bank details (Name of bank/ IBAN/ BIC), Outstanding balance and/ or data on payment arrears.

The bases for processing in the context of this purpose: Performance of the agreement (in case the agreement has been concluded with the data subject himself); legal obligations (including our administration and retention obligations, tax obligations and obligations regarding the preparation of annual accounts and annual reports); our legitimate interest (to be able to perform our regular business activities correctly and effectively; to be able to provide and improve our services, to represent our interests, for example during a dispute or legal procedure; to prevent fraud, swindling or other unlawful behavior; for communication, commercial and administrative purposes).

Invoicing

For this processing purpose we collect the following data: Company name, Invoice address, Chamber of Commerce number, VAT number, Customer number, Telephone number, E-mail address.

The bases for processing in the context of this purpose: Execution of the agreement (if the agreement has been concluded with the data subject himself), our legitimate interest (to be able to conduct our regular business operations and to prepare, process and administer invoices).

Relationship management

For this processing purpose we collect the following data: Name, E-mail address, Telephone number, Chamber of Commerce number, business address. In some cases we process data in the context of satisfaction surveys (name, email address).

The bases for processing in the context of this purpose: Performance of the agreement and our legitimate interest (to be able to initiate, maintain and maintain the customer relationship and to be able to carry out the associated administration, correspondence and relationship management activities perform).

General services: entering into and executing business relationships, contacts with consultants, (legal) advisers, suppliers, contractors and maintenance companies.

For this processing purpose, we collect the following data: Name, Contact data, File data, Financial data; other data which is relevant for the case.

The bases for processing in the context of this purpose: Performance of the agreement (in case the agreement has been concluded with the data subject himself); legal obligations (including our administration and retention obligations, tax obligations and obligations regarding the preparation of annual accounts and annual reports); our legitimate interest (to be able to perform our regular business activities in a correct and effective manner; to be able to provide and improve our services, to represent our interests, for example during a dispute or legal procedure; to prevent fraud, swindling or other unlawful behavior; for communication, commercial and administrative purposes and for marketing purposes).

 

Category 3: Players, end users of Games

Personal data processed and stored by the Supplier:

  • IP address
  • Browser User Agent
  • Account balances
  • Transactions
  • Game actions, behavior
  • User ID, pseudonymised

Account balances and transactions are collected to have complete financial records, to support analyzing potential fraud cases and to comply with anti-money laundering regulations and other legal obligations.

IP addresses are collected for analyzing geographic distribution of the players and game popularity, to support analyzing potential fraud cases and to comply with anti-money laundering regulations and other legal obligations.

Browser User Agents are collected for gathering statistical view of the browser versions and devices the players use and to assist in technical support requests.

Game actions are collected to have complete records of each game event to help resolve disputes, to support analyzing potential fraud cases and to comply with legal obligations.

Pseudonymised user identifiers are collected for being able to connect each game action and transaction to a specific player of a given Customer and to allow storage and processing of data that is retained over multiple game rounds as is required by certain games as part of their game mechanics. User identifiers are used to help resolve disputes and potential fraud cases. Customer support requests are based on user identifiers not on actual player identities.

Cookies

More detailed information about cookies is provided in our Cookie Statement.

Period of storage

Category 1: Website users

We keep data that we receive after a contact request for at least 1 year. This has to do with efficiency for our working method. Furthermore, it will be assessed per request whether it is necessary to keep data longer.

We keep data that we receive because of a complaint for a maximum of 2 years (unless the nature of the complaint makes it necessary to keep it longer, or it is a legitimate interest for us: improving our services).

Category 2: Clients and Business Partners

Financial administration, Invoicing

The financial information is kept indefinitely.

Relationship management

All business relations correspondence is kept as long as it is relevant, for example due to an ongoing contract, plus 10 years thereafter.

General services: entering into and executing business relationships, contacts with consultants, (legal) advisers,  suppliers, contractors and maintenance companies

The retention period for such items depends on the nature of the matter, but a minimum retention period of 5 years is adhered to.

Category 3: Players, end users of Games

Data is stored in our own secured servers and/or backups indefinitely. This is in connection with applicable regulations regarding terrorism financing, anti-money laundering and possibly other regulations.

Recipients of personal data

In some cases we are (legally) obliged to share certain personal data with third parties. For example, if we are involved in legal proceedings, have to comply with a legal obligation, comply with a court order or instructions from a government agency; and also for the implementation of agreements. Below is an overview of recipients of personal data:

General

  • Bookkeeper
  • Insurance Company
  • Work Healthcare
  • Legal Services

Government agencies

If Air Dice is asked by a relevant government agency to share (certain) data, Air Dice will always comply with this when the grounds of the request are GDPR compliant.

Where this is required under the GDPR, we have concluded a processor agreement with the recipient concerned. We take our role as controller seriously and monitor it closely. Your personal data will remain within the European Economic Area at all times.

Your rights with regard to your personal data

The rights that you can exercise in relation to your personal data are listed below. We hereby indicate in as much detail as possible how the relevant right can be used.

Please note: we do not have direct contact with the Players in the context of player information. Any form of rights that the Player wants to use must go through the relevant casino operator.

Right of access (Article 15 GDPR)

You always have the right to view the personal data processed and stored by Air Dice. To exercise this right, you can send an email to privacy@airdice.com

Right to rectification (Article 16 GDPR)

If the data stored by Air Dice turns out to be incorrect, you have the right to have this data rectified. Air Dice will then replace the current incorrect data with the correct data.

Right to data portability (Article 20 GDPR)

You have the right to have your personal data transferred by Air Dice to a similar party. This refers to a party that offers and performs roughly the same services as Air Dice.

Right to erasure of data (Article 17 GDPR)

In certain cases you can request Air Dice to have your data removed. You have the option to do so with the right to be forgotten. Below is a list of situations in which Air Dice should delete your data:

  • If the data processed by Air Dice is no longer necessary for the processing purpose.
  • If the consent for the use of the personal data is withdrawn by you.
  • If Air Dice processes data unlawfully, you have a direct option to have the data removed by Air Dice. 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, Air Dice is obliged to delete the processed personal data.
  • If you as a data subject are younger than 16 years of age and no permission from a parent or guardian has been granted for the processing of the personal data. In this case, Air Dice will immediately delete your personal data.

There may be exceptions to the right to erasure of data.

Right to submit a complaint to the Finnish Data Protection Authority

You always have the right to file a complaint with the Finnish Data Protection Authority, the moment you believe that Air Dice does not properly handle your personal data.

Data protection

Access to material is limited solely to the controller’s employees and service providers who have the right to access pursuant to their duties. The controller uses appropriate technical and organizational measures to protect data from unauthorized access, alteration, disclosure, loss or other unauthorized processing. The Controller requires confidentiality, appropriate data security and commitment to applicable statutory data protection requirement and principles of all the service providers it uses.

Updates to the notice

From time to time we may update this notice due to changes in legislation or our business operations. We will strive to inform the data subjects about changes in a way appropriate to the significance of the changes.

Contacting Us

For general matters, please contact us via email at info@airdice.com

For security and data protection matters, please contact us via email at privacy@airdice.com

In case you are a player of our games and are looking for support or have questions regarding your personal data, please contact the online casino where you have played our games.