Privacy statement

Why reading this information is important

We recommend that you read this information carefully, so that you know the purposes for which NAPOLEONGAMES uses your personal data. This privacy statement also contains more information about your privacy rights and how you can exercise them.

NAPOLEONGAMES (the publishers of NAPOLEONGAMES are described in the General Terms and Conditions of NAPOLEONGAMES) may make changes to this privacy statement. The most recent version is always available at https://napoleongames.be/content/privacy. NAPOLEONGAMES will inform you of all substantive changes to its terms via its website.  

NAPOLEONGAMES processes your personal data conform the General Data Protection Act (GDPR) and other supplementary laws and regulations. You can find more information about the Belgian privacy legislation on the website of the Belgian Data Protection Authority (previously called the Privacy Commission) at www.dataprotectionauthority.be

NAPOLEONGAMES acts as a controller of your personal data. This means that NAPOLEONGAMES, alone or jointly with other controllers (e.g. the payment providers NAPOLEONGAMES works together with), determines the purposes and means of the processing of personal data. 

Your rights to privacy

1.    You can look at your data

If you would like to see the data NAPOLEONGAMES processes about you, let us know. You can view some of the data directly yourself when you sign in to your user account. If you want a more detailed overview, we ask you to address this request to us. 

2.    You can correct your data

It may happen that your personal data is not correct (anymore). You can correct some of the data yourself when you sign in to your user account. If you are of the opinion that other data should be corrected or completed, we ask you to address this request to us.  

3.    You can have your data deleted

You can ask us to delete the personal data we collected. Some data needs to be kept however,  due to  legal and/or contractual obligations. 

4.    You can object to your data being used for certain purposes

If you disagree with how NAPOLEONGAMES invokes its legitimate interests to process certain data, you can object. Objections will be respected unless there are overriding ground not to do so (for example, when we process data with the purpose of combating fraud).

5.    You can ask for your data to be transferred to another party

You are entitled to ask for personal data that you have provided NAPOLEONGAMES yourself, to be transferred back to you or to a third party. The data protection laws provide however different restrictions on the this right, so it is not applicable to all personal data.

 

6.    How to exercise your rights

If you want to exercise your data protection rights, NAPOLEONGAMES asks you to send an email to privacy@napoleongames.be. This email should contain at least the elements as listed in the below table, which can differ depending on which right you want to exercise. We invite you to formulate your specific questions in detail. We will need to verify your identity in as much details as possible, to guarantee that your rights are exercised by you and not by any other person. You may therefore be asked to provide your ID. If you want to receive a detailed overview of your data or exercising the right to transfer your data, we will ask you to visit our headquarters situated in Erembodegem since we want the data to be transferred to you in person.  

If you have a question about our privacy statement or a complaint about the exercise of your rights, you can address this by sending an email to our Data Protection Officer (DPO@napoleongames.be) or by writing a letter addressed to the attention of Napoleon Games’ DPO, Korte Keppestraat 23/6, 9320 Erembodegem. 

If you would like to receive more information or if you do not agree with the position adopted by NAPOLEONGAMES, be sure to visit the website of the Belgian Data Protection Authority at www.dataprotectionauthority.be. You can also lodge complaints there. 

In some cases you can also exercise your rights directly against third parties. That applies, for instance, to the databases maintained by the Belgian Gambling Commission (www.gamingcommission.be), such as its EPIS (Excluded Persons Information System).

Right I want to exercise

How

What should the request contain? 

I want to LOOK at my data

-        User profile

-        Send an email to privacy@napoleongames.be

Title of the email: LOOK

Content:
- Your unique user code (find your code on My profile > Personal details)
- Copy of your ID card’s front and back
- Proof of address (e.g. an invoice mentioning your name and address)

I want to CORRECTmy data

-        User profile

-        Send an email to privacy@napoleongames.be

Title of the email: CORRECT

Content:
- Your unique user code (find your code on My profile > Personal details)
- Copy of your ID card’s front and back
- Proof of address (e.g. an invoice mentioning your name and address)

I want to DELETEmy data

-        Send an email to privacy@napoleongames.be

Title of the email: DELETE

Content:
- Your unique user code (find your code on My profile > Personal details)
- Copy of your ID card’s front and back
- Proof of address (e.g. an invoice mentioning your name and address)

I want to OBJECT to the use of my data

-        Send an email to privacy@napoleongames.be

Title of the email: OBJECT

Content:
- Your unique user code (find your code on My profile > Personal details)
- Copy of your ID card’s front and back
- Proof of address (e.g. an invoice mentioning your name and address)

- Purpose for which you want to object to your data being used

I want to TRANSFERmy data

-        Send an email to privacy@napoleongames.be

Title of the email: TRANSFER

Content:
- Your unique user code (find your code on My profile > Personal details)
- Copy of your ID card’s front and back
- Proof of address (e.g. an invoice mentioning your name and address)

- Third party details to which you want your data to be transferred to

 

 

Why we process your data

The GDPR allows NAPOLEONGAMES to process your data for a number of reasons. These are split into three main categories: 

1.    Legal obligations

NAPOLEONGAMES is obliged to comply with some laws and regulations imposing the processing of your personal data. Below you can find an overview of the main ones: 

-       Gambling Law

NAPOLEONGAMES is requested to collect and to store the personal identification data of all of its players. NAPOLEONGAMES is also obliged to transfer these data to the Belgian Gambling Commission (www.gamingcommission.be).

-       Anti-Money Laundering Law

Gambling providers must deploy all means to prevent and uncover money laundering and take part in the fight against terrorism. Therefore, NAPOLEONGAMES stores and verifies both the personal identification data and the financial transactional data of all of its players.

NAPOLEONGAMES is obliged to report any suspicious transaction in terms of money laundering to the Financial Intelligence Processing unit (www.cfi.be).

 

2.    Contractual obligations

To become a NAPOLEONGAMES customer, you must create a player account and accept our Terms & Conditions. This means that you will enter into a contract with NAPOLEONGAMES. In order to enable  NAPOLEONGAMES executing the obligations stated in that contract, it might be possible that we will use your personal identification data and transactional data. Some of these obligations will enable us to reply to your requests (through customer support) and any other complaint(s) that you may have. This means that these data might be passed on between the internal departments and/or external third parties which handle these requests and complaints. 

We will also use your personal identification data for sending out service messages related to our service, such as warning messages when you have received a message from our customer support department. You can view the types of service messages you may receive in your personal preference page when you are logged in to your user account. 

3.    Legitimate interest

As a commercial business, NAPOLEONGAMES has set out a vision: “to conquer the regulated gambling market and boost brand value by putting our customers at the center of our products, services and the company culture”. In order to do so, NAPOLEONGAMES has a legitimate interest in using your personal data in order to be able to carry out this vision. By all means, we ensure that the impact on your privacy remains proportional to our interests. Below you can find the categories of activities where we use your personal data for our interest. If you object to your data being used for these activities, you can exercise your right to object. 

-       Improving user experience

It is our aim to optimize our customer’s experience while playing at NAPOLEONGAMES. Therefore, we track several variables (such as how does one navigate through the website, what are the bottlenecks,…) and draw conclusions from them in order to optimize our products and services. 

-       Improving our services

Calls to our customer support are recorded and used to improve our services. 

We regularly carry out customer experience surveys, to which you are not obliged to participate. But if you participate,  the data linked to these survey will also be kept and used in order to improve our services. 

-       Combatting fraud and internal infringements

Personal identification data and transactional data can be used to prevent, detect and investigate fraud as it is in the interest of both NAPOLEONGAMES’ and its customers that assets are protected from misuse. At times, personal data is transferred to third party fraud experts, which help us in our battle against fraud. 

4.    Direct marketing1

As part of optimizing your playing experience, NAPOLEONGAMES will provide you with interesting information about the products and services through newsletters, both generalized and personalized. 

NAPOLEONGAMES will also provide you with both generalized and personalized offers (for example bonuses). 

In order to do this, NAPOLEONGAMES uses your personal identification data, transactional data and cookies. 

Different channels will be used to send you these newsletters and offers: email, sms, push-notifications and telephone calls. 

You can easily opt-out (or re-opt-in at times you want to start receiving our information again) to all forms of direct marketing in your own preference center when logging on to your user account. 

([1]Processing activity that entails a legitimate interest of NAPOLEONGAMES, but for which the opt-out possibility can be executed easily and at all times by the customer)

5.    Consent

You can become a VIP-player of NAPOLEONGAMES. When this happens, you will be offered the opportunity to connect with one of our account managers, who will provide you with a more personalized playing experience (for example, invitations to NAPOLEONGAMES’s events, personal follow-up,…). Personal data that is gathered via our account managers will be stored in a player file, which is only accessible by NAPOLEONGAMES’ VIP team. NAPOLEONGAMES will ask you to explicitly consent to the use of your data by the VIP team. 

Discover the Napoleon Sports & Casino app

Casino games, live casino and sports in one app! Download the app now!
download on iPhone download on Android