General Terms and Conditions of NAPOLEONGAMES - version 28 February 2020
Article 1 - Publishers of NAPOLEONGAMES
The following companies are the publishers of NAPOLEONGAMES:
Lunatim NV is a company limited by shares incorporated under Belgian law, with its registered office at 9320 Erembodegem (Aalst), Korte Keppestraat 23/6, registered with the Crossroads Bank for Enterprises under number 0424.851.684. Lunatim NV holds a B licence under Belgian law for the operation of offline games of chance in a Class II gaming establishment and an additional B+ licence under Belgian law for the operation of games of chance via information society tools.
Hereinafter referred to as Lunatim NV.
Napoleon Games Sports is a company limited by shares incorporated under Belgian law, with its registered office at 9320 Erembodegem (Aalst), Korte Keppestraat 23/6, registered with the Crossroads Bank for Enterprises under number 0880.462.268. Napoleon Games Sports NV holds an F1 licence under Belgian law for the operation of betting in a Class IV gaming establishment and an additional F1+ licence under Belgian law for the operation of betting via information society tools.
Hereinafter referred to as Napoleon Games Sports NV.
E.C.K. is a company limited by shares incorporated under Belgian law, with its registered office at 8300 Knokke-Heist, Zeedijk-Albertstrand 509, registered with the Crossroads Bank for Enterprises under number 0406.949.939. E.C.K. NV holds an A licence under Belgian law for the operation of offline games of chance in a Class I gaming establishment and an additional A+ licence under Belgian law for the operation of (casino) games of chance via information society tools.
Hereinafter referred to as E.C.K. NV.
Article 2 - Definitions
A Visitor is any natural person who uses at least one of the services of NAPOLEONGAMES.
A Cash Player is a Player who uses the services of NAPOLEONGAMES with a monetary Stake.
Customer Service is a service provided by NAPOLEONGAMES where every Visitor can go for further information or assistance.
A Free Player is a Player who participates in services of NAPOLEONGAMES without a monetary Stake.
The Stake is the entire financial means that the Player makes available to the risk of a Game or Betting.
Game of chance
A Game of chance is every game involving a Stake of any kind, which will result in either the loss of this Stake by at least one of the Players or Winnings of any kind by at least one of the Players or organizers of the game, and whereby chance is a secondary element in the process of the game, the
'NAPOLEONGAMES' should be understood to include all the services offered by the Company via information society tools. This includes, but is not limited to, www.napoleongames.be, social media and mobile application(s).
The Betting Regulations are the entire set of rules applicable to Betting.
A Game is a Game of chance that is offered in NAPOLEONGAMES.
A Player is every Visitor who uses the services of NAPOLEONGAMES after valid registration and after verification of their registration details.
Player's General Account
A player's General Account contains all the personal registration details, login details and Player Account.
A Player Account is the personal account of a Player at NAPOLEONGAMES, into which funds can be credited and debited.
Rules of the game
The Rules of the game are the entire set of rules applicable to the specific Game.
A Game session is the period between the start-up and shutdown of a Game, in which one or more Periods of play may take place.
Period of play
A Period of play is the time from the Stake until the result of the Game.
The Company is Lunatim NV, Napoleon Games Sports NV and E.C.K. NV.
A Bet is a game of chance in which each Player contributes a Stake and which results in Winnings or a loss which are not dependent on an action performed by the Player, but on the achievement of an uncertain event that occurs without the involvement of the Players.
The Winnings are the total financial means that the Player receives at the end of the Period of play or the Bet.
Article 3 - Services offered
NAPOLEONGAMES offers Visitors a legally authorized online gaming experience (approved by the Belgian Gaming Commission). The offer consists of:
Games of chance
It is possible to play with or without making a financial Stake.
It is only possible to play with a financial Stake.
Article 4 - General
NAPOLEONGAMES reserves the right to amend and update these Terms, the access to and content of NAPOLEONGAMES, as well as the Betting Regulations and the Rules of the game(s) at any time, without prior warning. In the case of a change in the current Terms, the Players will be informed of this at the next login to NAPOLEONGAMES. This change must be explicitly accepted by each Player that wants to continue using the services offered by NAPOLEONGAMES.
The fact that NAPOLEONGAMES, at a particular time, does not invoke any provision of these Terms and/or the Regulations, may not in any way be interpreted as renouncing the subsequent use of any right or provision.
If NAPOLEONGAMES allows an individual Player to deviate from these Terms and/or Regulations in an exceptional and personal capacity, this can never be considered by the Player in question as an acquired right.
Article 5 - Registration
Registration at NAPOLEONGAMES is only permitted for natural persons who are legally competent and at least 18 years old. Bets are open to natural persons aged 18 years and over. The remaining range of Games of chance is restricted to natural persons aged 21 years and over.
Every natural person is entitled to a maximum of 1 player's General Account at NAPOLEONGAMES. If NAPOLEONGAMES has a reasonable suspicion or determines that a single natural person has direct or indirect control over multiple Player Accounts, NAPOLEONGAMES explicitly retains the right to block every Player Account in which the data does not correspond with the actual identification data of the natural person, and also to block the money in that account without the Player being able to derive any right from this.
The player's General Account is strictly personal, may not be transferred to a third party and may not be used by third parties. Each Player is responsible for the truthful, complete and accurate entry of his/her data and for keeping it up-to-date. NAPOLEONGAMES reserves the right to monitor the accuracy of the data in every way.
To validly register, the following procedure should be followed. The Visitor is obliged to fill in the following information: National Register number, name and first name (as mentioned on ID card), gender, date of birth, address, postal code, city, nationality, mobile telephone number, e-mail address and confirmation of e-mail address, bank account number, username and password.
The name, first name, National Register number and date of birth are in principle not subject to change, unless by the express intervention of Customer Service.
NAPOLEONGAMES unilaterally reserves the right to prohibit the use a specific user name or password that it considers inappropriate or contrary to public order or morality.
In the event of loss, theft or forgetting login details, the Visitor should immediately contact Customer Service. After verifying the identity, NAPOLEONGAMES will take all necessary measures to again grant the Visitor access to his/her account.
Article 6 - Access
Each Player is responsible for the management of his/her player's General Account and the confidentiality of his/her login details (username and password). NAPOLEONGAMES is at no time and in no way liable for the use of login data and the management of the player's General Account by a third party, with or without the cooperation of the Player.
If the Player is aware of the fact that another person has access to his/her login data to NAPOLEON GAMES, he//she shall immediately inform NAPOLEONGAMES by e-mail at the following address: firstname.lastname@example.org.
The Player is further entirely and solely responsible for each activity on his/her player's General Account. NAPOLEONGAMES is not responsible for any loss or damage that the Player may have incurred through the unauthorized use of his/her login data by third parties, even if the Player was not aware of this.
NAPOLEONGAMES unilaterally reserves the right to refuse any Player access to NAPOLEONGAMES if they do not respect these Terms.
In the event of a dispute, the Player accepts that the registration and login data he/she has provided and is registered on the servers of NAPOLEONGAMES , have evidential value between the parties.
It is also forbidden to disrupt accessibility to NAPOLEONGAMES or to attempt this by any means.
Article 7 - Participation, Stake and Profit
The Visitor undertakes not to behave in such a way that could harm the reputation of NAPOLEONGAMES, its software, its Games of chance, its Betting or other Visitors, or negatively affect the proper functioning of NAPOLEONGAMES, its software and its Games of chance. Visitors undertake to refrain from manipulations or communications among Visitors that could interfere with the equality of the Visitors.
It is strictly forbidden to change the operation of the range of Games of chance and Betting or attempt to influence the operation, by any means whatsoever, specifically to change the results, impartiality or any constituent part of a Game of chance or Betting.
It is also prohibited to download, display or transmit any content from NAPOLEONGAMES in any way, by the use of computer viruses or any other code or software, designed for the sole objective of preventing, distorting, interrupting, destroying or limiting the normal operation of the functions of NAPOLEONGAMES, its software or its Games of chance, or to offer or (re-)use the modified content.
In the event that NAPOLEONGAMES reasonably believes that the Visitor has changed or attempted to change the instruments of the Games of chance or Betting offered, or has used or attempted to use a product with artificial intelligence, NAPOLEONGAMES reserves the right to immediately terminate or block the player's General Account, not to repay the credited amount on the Player Account and to prohibit the Visitor from access to any other internet sites, services and software that NAPOLEONGAMES would offer, and all this without any form of recourse of whatever kind.
Games of Chance
Participation in the Games of chance offered, with the exception of Betting, is open to Cash Players from 21 years of age.
Participation in a Game takes place by staking a certain sum, equal to one of the Stakes offered. The possible Stakes and potential Winnings can be consulted in the Rules of the game. The Stake may be chosen freely by the Player for each Period of play. Every Stake is immediately debited from the Player Account. If the Player Account of the Cash Player is insufficient for the selected Stake, the Cash Player cannot join a new game with this Stake.
After a Period of play, the Cash Player is immediately informed of the results and any Winnings are immediately credited to his/her Player Account.
If a Period of play is interrupted before the end of the Period of play as a result of the actions of the Cash Player, the Cash Player will lose his/her opportunity for Winnings.
If a Period of play is interrupted before the end of the Period of play as a result of a technical problem, the Cash Player is requested to immediately contact Customer Service. After analyzing the game play and the technical problem, NAPOLEONGAMES will draw up a technical report taking into account the Rules of the game that are applicable. The technical report on the progress of this Period of play will count as the sole evidence for the calculation of Winnings or loss and may not be brought into question.
If it appears that the course of one or more Periods of play does not comply or was not in compliance with the Rules of the game or these Terms for any reason whatsoever, NAPOLEONGAMES reserves the right to correct the outcome of these Periods of play according to the normal game play. Any Winnings or losses of the Player during these abnormal Period(s) of play may also be corrected by NAPOLEONGAMES, without prior notice to the Player concerned. The technical report on the course of these abnormal Period(s) of play will be considered as the sole evidence for the calculation of (corrected) Winnings or loss and may not be brought into question.
The course of a Period of play, with or without a financial Stake from the past, cannot be used as a reference for Winnings or loss in future Periods of play.
Participation in the Betting offered is open to Cash Players from 18 years of age.
Participation in a Bet takes place by Staking a certain sum, which can be chosen freely by the Cash Player. The Stake of each Bet is immediately debited from the Player Account. If the Player Account of the Cash Player is insufficient for the selected Stake, the Cash Player cannot join a new Bet with this Stake.
The potential Winnings is determined by the Stake and the listing offered and can be consulted immediately. After a Bet, the Cash Player is immediately informed of the results and any Winnings are immediately credited to his/her Player Account.
If it appears that the result was an error and any Winnings are communicated to the Player, NAPOLEONGAMES reserves the right to correct this without prior notice.
NAPOLEONGAMES reserves the right to limit the amount of the individual or group Stake of each Bet and/or each day and/or each month.
Article 8 - Management of the Player Account
Each Cash Player has a player's General Account at NAPOLEONGAMES that he/she created at registration. The sums deposited in the Player Account can only be used to participate in Games of chance and Betting at NAPOLEONGAMES. In accordance with these Terms and the legal provisions, the Cash Player may at any time retrieve funds from the Player Account by transfer to the bank account of the Player.
NAPOLEONGAMES manages the Winnings and loss on the Player Account of the Cash Players who expressly mandate NAPOLEONGAMES for this purpose. At the start of each Period of play, the Player Account of the Cash Player is immediately debited by NAPOLEONGAMES for the Stake. After each Period of play, the Player Account of the Cash Player, if any, is immediately credited with the Winnings of the Cash Player.
NAPOLEONGAMES reserves the right at any time, without prior notice to the Player, to block a player's General Account, temporarily or permanently, partially or completely, in order to check the accuracy of the information provided, to prevent fraud or to conduct an investigation into the Game Sessions or Betting.
NAPOLEONGAMES always has the right to immediately block the account (even in the course of a Period of play) for non-compliance or suspected non-compliance with these Terms. In that case, NAPOLEONGAMES has a right on any sums in the Player Account of the Cash Player in order to recoup any administrative costs and any damages that the Player owes.
The payouts from the Player Account will take place only by bank transfer. NAPOLEONGAMES will only transfer the amounts to the European bank account that the Cash Player provided when he/she registered or on the payment application. NAPOLEONGAMES does not systematically verify the identity of the holder of the player's General Account. The transfer is carried out 5 bank business days following the request from the Cash Player, at the latest. The minimum payout is € 10.00, except in the case of a closure of a player's General Account by NAPOLEONGAMES.
If a Cash Player wishes to withdraw funds he/she has deposited into his Player's Account before having wagered these funds in any Game of Chance or Betting, NAPOLEON GAMES reserves the right to refuse the Cash Player to withdraw the deposited funds until such time as the entirety of the funds (100%) have first been wagered and this due to among other possible money laundering implications.
NAPOLEONGAMES is authorized to perform safety checks before making a transfer. In that case, at the request of NAPOLEONGAMES , the Player should confirm an application for payment in writing, with proof of his/her bank details and a copy (recto/verso) of his/her identity and if necessary, an official proof of residence issued by the city or town the Player officially resides. If this information does not correspond to the information provided to NAPOLEONGAMES, the payment cannot take place.
In any event of suspicion of identity fraud or bank fraud, NAPOLEONGAMES reserves the right to block or to close a Player Account and/or not to proceed to payment and to take all legal measures it deems necessary.
If the Player cannot provide a valid copy of his identity card and, in case of demanded by NAPOLEONGAMES, an official proof of residence issued by the city or town the Player officially resides of which the information (name - first name - date of birth - street name - house number - postal code - town/city) does not integrally corresponds with the information registered on the Player's Account, NAPOLEONGAMES will have the right to block the Player's Account and will not pay out the withdrawal. The credits which the Player has requested explicitly to be paid out will be irrevocably and without the possibility of resistance, after a period of 3 months in a request of payout, be possession of NAPOLEONGAMES, with loss of all rights for the Player and his legal successors, by which every visitor declares explicitly his/her in agreement, if the Player in question does not provide a valuable copy of his identity card and if asked by NAPOLEONGAMES, an official proof of residence of which the information (name - first name - date of birth - street name - house number - postal code - town/city) does not integrally corresponds with the information registered on the Player's Account.
NAPOLEONGAMES reserves the right to close the player's General Account of a visitor, without justification and at its sole discretion, if there is no activity on his/her Player Account for a period of 12 months. The visitor will receive an email in time at the specified email address that his/her Player's Account will be closed due to inactivity. The credits the specified visitor has on his/her Player's Account at the moment the 12 months at the least are expired since the last time the visitor has log in rightfully on the Player's Account, will be irrevocably and with no possibility of protest be possession of NAPOLEONGAMES after a period of 7 days from the date of notification, with loss of all rights for the Player and his legal successors, by which every visitor declares explicitly his/her in agreement.
NAPOLEONGAMES reserves the right to charge the Cash Player for depositing money in his/her Player Account with NAPOLEONGAMES .
Some service providers can limit the transfers to the Player Account for a Cash Player. Payments with credit cards are not allowed.
Article 9 - Customer Service
The Visitor can contact Customer Service through various channels in the event of problems, comments or complaints:
Telephone on number (+32) 078 077 013 (between 9 am and 1 am)
Chat (between 9 am and 1 am)
Contact form on the website
Email to the address email@example.com
Customer Service will analyze the request, comment or complaint from the Visitor and seek to help the Visitor as quickly as possible. If no immediate solution is possible, Customer Service will transfer the data to the appropriate department to be dealt with further. Customer Service will contact the Visitor as soon as the competent service has completed its investigation or if additional information is required.
The Customer Service is in no circumstance responsible for the exactitude of the provided information and cannot be in any way held responsible of the provided information.
Article 10 - Deregistration
The Player may at any time deregister from NAPOLEONGAMES, in accordance with this Article. Deregistration from NAPOLEONGAMES is independent of deregistration from the Belgian Gaming Commission.
The Player can deregister himself/herself by changing the profile of his/her player's General Account. After deregistration, the Player will be removed from all communication of NAPOLEONGAMES and the player's General Account will be placed on inactive.
NAPOLEONGAMES will not automatically proceed to debit the Player Account of the Player at the time of deregistration. Where appropriate, the Player may choose to debit his/her Player Account, but this is not required.
The Player may at any time reactivate his/her Player Account and make further use of the services of NAPOLEONGAMES via his/her last known registration and login details.
Deregistration Belgian Gaming Commission (BGC)
The Gaming Commission is an independent body with its own procedures. NAPOLEONGAMES cannot be held liable for the operation of these procedures.
The Player can deregister from the Belgian Gaming Commission at any time. The Player will no longer have access to games of chance. The procedure for voluntary deregistration is described on https://www.gamingcommission.be/opencms/opencms/jhksweb_en/protection/forbid/.
Players with an access injunction cannot participate in Games of chance or Betting with a monetary Stake offered by NAPOLEONGAMES.
Players can have their access injunction lifted by going through the procedure provided by the Belgian Gaming Commission. After a waiting period of 3 months from the day the Belgian Gaming Commission received the application, the Player will again have access to games of chance.
Article 11 - Intellectual property
NAPOLEONGAMES, and all rights in such respect, are the exclusive property of the Company or its partners. These elements form creations that are protected by intellectual property rights. The trademarks, logos, graphics, photographs, animations, videos, texts and other distinctive signs on NAPOLEONGAMES, are the intellectual property of the Company or its partners. Any reproduction, use or image thereof without the prior written consent of the Company or its partners is prohibited under penalty of prosecution.
The creation of a hyperlink to the home page of NAPOLEONGAMES, excluding any other address, is allowed provided that this link is not harmful to NAPOLEONGAMES and unless otherwise specified by NAPOLEONGAMES. Any links to an internal page of NAPOLEON GAMES is prohibited, subject to the prior written consent of the Company or its partners.
Article 12 - Social Media
NAPOLEONGAMES uses social media, including but not limited to:
All messages that are displayed via social media channels are merely informative, and can in no way be considered binding with respect to NAPOLEONGAMES.
NAPOLEONGAMES cannot be held liable for any messages that appear on social media channels.
Every person undertakes to respect the use of social media in the broad sense of the basic rules of good behaviour, politeness and courtesy and shall in particular:
remain courteous and friendly,
avoid personal attacks.
Visitors are expressly forbidden to distribute messages with a hateful, racist, anti-Semitic, xenophobic, homophobic, defamatory or injurious nature that are damaging to public order and morality or more generally derogatory or offensive, or to propagate or to contribute to their distribution in any medium whatsoever, which relate to NAPOLEONGAMES or its visitors.
Also prohibited on social media are messages that violate the spirit of NAPOLEONGAMES, such as but not limited to, messages that contain a particular political or religious standpoint or view, undesirable, exaggerated or misplaced messages, messages that mislead other Visitors about the Rules of the game or by taking other people's name and, in particular, by pretending to be an employee, member of staff or a partner of NAPOLEONGAMES.
Moreover, it is forbidden for the Visitor to impersonate another Visitor or to communicate under a false name, a false identity or false pseudonym or to lie about his/her age.
NAPOLEONGAMES reserves the right to remove messages on social media channels, which are contrary to these provisions.
NAPOLEONGAMES can in no event be held liable for the content, especially the illegal nature of the content in relation to the current legislation, any loss or damage resulting from the use of posted content, which is spread through social media. In the event that the responsibility of NAPOLEONGAMES is requested as a result of a breach by the Visitor to his/her obligations under these Terms or the statutory and regulatory provisions in force, NAPOLEONGAMES reserves the right to prosecute the Visitor.
Art. 13 - Live Casino
Live Casino is provided and managed by the Company.
The Company, the software supplier and the supplier of the player application, as well as their parent companies/subsidiaries and other related companies, are in no way whatsoever, even in cases of negligence, liable for direct, indirect, incidental, specific or consequential damage that can result from the use of or the incapacity to use Live Casino, related applications and/or other materials. The Player indemnifies the Company, the software supplier, the other suppliers of the Company, the employees, staff members, members of the Board, licensees, distributors, resellers, related companies, subsidiaries, advertising and other agencies, media partners, agents and retailers integrally for all costs, expenditure, liability and damage that can issue from the following activities: (i) access, use and re-use of Live Casino as well as the applications of Live Casino, (ii) participation in Live Casino and (iii) the acceptance of any price whatsoever. If the Visitor is not satisfied with the services related to Live Casino, his only recourse is to stop using Live Casino.
Article 14 - Cookies
What are cookies?
A cookie is a text file that the server of a website places in your computer's browser or on your mobile device when you visit the website. The cookie contains a unique code that enables the website to recognise your browser during your visit to the website (a 'session' cookie) or if you make subsequent repeat visits (a 'permanent' cookie). Cookies can be placed by the NAPOLEONGAMES server or by partners with which the NAPOLEONGAMES website is working together. The server of a website can read only the cookies that it has placed in your browser and cannot access other information on your computer or mobile device. Cookies on your computer or your mobile device are stored in your browser folder. The content of a cookie usually consists of the name of the server that placed the cookie, an expiry date and a unique number code.
Cookies generally make the interaction between the Visitor and the website easier and faster and help the Visitor to navigate between the various components of a website. Cookies can also be used to make the content of a website or the publicity on a website more relevant for the visitor and to adapt it to the visitor's personal taste and needs.
No personal data
A cookie consists of a (unique) number or value. It does not contain any personal data.
Which cookies does NAPOLEONGAMES use?
You can define the settings on your browser so that you will always receive a message that a cookie is being created or that it is not permitted to create cookies. However, you will then be usable to use all the options on the website or all the services of NAPOLEONGAMES, and NAPOLEONGAMES will not be able to guarantee access to its services or the effectiveness of those services if you have switched off the option to create cookies. You can also indicate whether or not the website may create tracking cookies and you can adapt this choice at all times.
NAPOLEONGAMES uses the following cookies:
1. Necessary cookies
Without these cookies, you will be unable to visit NAPOLEONGAMES or use particular parts of the website. For example, these cookies enable you to navigate between the various parts of the website or to fill in forms. If you refuse these cookies, certain parts of the website will not work (properly).
2. Functional cookies
Functional cookies are cookies that make it easier and more fun for you to use NAPOLEONGAMES and they ensure that you have a more personalised surfing experience. They include the cookies that remember your preferences.
3. Performance cookies
4. Third-party cookies
NAPOLEONGAMES can also include elements that belong to third parties.
You can use your browser settings to refuse the installation of cookies.
In addition, you can remove cookies that have been installed on your computer or mobile device whenever you wish.
Article 15 - Limitation of Liability
The information on NAPOLEONGAMES is regularly updated and checked. NAPOLEONGAMES cannot be held liable for unauthorized use that Visitors directly or indirectly make of such information, in breach of these General Terms and Conditions. NAPOLEONGAMES disclaims any liability in this respect, while offering no guarantee regarding the services offered through NAPOLEONGAMES .
NAPOLEONGAMES cannot ensure the continuous availability, without error or interruption, of all functions of NAPOLEONGAMES , nor the immediate correction of errors or the total absence of viruses or other harmful elements on NAPOLEONGAMES and on the infrastructure on which the services are provided. The Company cannot be held liable for temporary restrictions that may be due to technical problems such as the interruption of telecommunications, programming errors or hardware problems, etc. or any loss or damage (direct, indirect, movable or immovable) resulting from these temporary restrictions, or in connection with the use of NAPOLEONGAMES or inability to use the services of NAPOLEON GAMES. Visitors are responsible for the proper operation and upgrade of their hardware, their software and their access to the Internet.
NAPOLEONGAMES reserves the right to interrupt or suspend one or more of the Games of chance or Betting offered on NAPOLEONGAMES , at any time and without warning, or to limit or change the listing of the Stake, without having to be accountable for this. In such case, NAPOLEONGAMES cannot be held liable that the Players in any way can claim compensation.
NAPOLEONGAMES may contain links to websites that are not from NAPOLEONGAMES. The latter cannot be held liable for the content of these websites or for the consequences of access and/or use of these websites.
NAPOLEONGAMES may not in any event be held liable to pay damages in the case of bankruptcy of the bank(s) or other third parties with which NAPOLEONGAMES works for the operation of NAPOLEONGAMES.
Every visitor declares explicitly to be in agreement with the decisions NAPOLEONGAMES has to make considering settling an agreement.
Article 16 - Invalidity of a clause
The invalidity, revocation or non-enforceability of all or part of the General Terms and Conditions, will never lead to the nullity of these General Terms and Conditions in their entirety. The wholly or partially invalid, void or unenforceable provision shall be deemed to be unwritten. NAPOLEONGAMES undertakes to replace this provision with another provision which performs the same function, to the extent possible.
Article 17 - No distance
Not, or not in time, claiming a right or not, or not in time, applying a sanction by NAPOLEONGAMES does not mean, in any way, an abandonment of right. NAPOLEONGAMES will, at all times, have to right to pursue its rights under consensus.
Article 18 - Governing Law & Courts
Any dispute concerning the Terms and Conditions, NAPOLEONGAMES or its use shall be governed exclusively by Belgian law. In disputes the courts of Gent, department Dendermonde have exclusive jurisdiction.
If these Terms and Conditions are translated into another language, the Dutch version shall prevail in the case of conflict between the translation and the Dutch version.
Below Privacy Statement is not part of our General Conditions. It aims to inform you on the use of your personal data by NAPOLEONGAMES.
Privacy statement - version 25 May 2018
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.privacycommission.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 firstname.lastname@example.org. 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.privacycommission.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
What should the request contain?
I want to LOOK at my data
- User profile
- Send an email to email@example.com
Title of the email: LOOK
Content: User ID
I want to CORRECTmy data
- User profile
- Send an email to firstname.lastname@example.org
Title of the email: CORRECT
Content: User ID
I want to DELETEmy data
- Send an email to email@example.com
Title of the email: DELETE
Content: User ID
I want to OBJECT to the use of my data
- Send an email to firstname.lastname@example.org
Title of the email: OBJECT
- User ID
- Purpose for which you want to object to your data being used
I want to TRANSFERmy data
- Send an email to email@example.com
Title of the email: TRANSFER
- User ID
- 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:
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 customers 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 marketing
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.
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.
 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
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.