This privacy policy (“Privacy Policy”) governs [Optival LTD] (“Company”, “we”, “our”, or “us”) Personal Data (as defined below) collection and privacy practices.
This Privacy Policy applies to the websites owned and operated by us (including other digital assets we operate such as landing pages, ads, etc. , collectively “website(s)”), which provides information and compares between various goods and services offered by third parties, as well as enabling users to easily be directed and access to our third-party business partners websites where such goods and services are offered (respectively, “Business Partners” and “Business Partner’s Website”) (collectively “Services”).
This Privacy Policy provides the information and disclosure regarding the types of Personal Data collected from users when accessing, browsing or otherwise interacting with our website and Services, and any content available therein and other digital assets we operate (such as landing pages, ads, etc.) (collectively “websites”), including interaction with, the purpose for which we collect Personal Data and how we use it, third parties with whom we may share Personal Data and purpose of disclosure, as well your rights and choices related to your Personal Data.
This Privacy Policy constitutes an integral part of our Terms of Use (“Terms”). Capitalized terms used herein however not defined shall have the meaning assigned to them in our Terms.
You acknowledge that you are not under any statutory obligation to provide us with Personal Data. However, if you will not provide us with certain Personal Data, we will not be able to provide certain features of our Services. For example, we must obtain your email address if you contact us, in order to communicate with you and in addition, certain cookies on our website are essential for the website to work properly while others intended to either improve our Services or assist in our promotional efforts, can be opted-out. All as explained under this Privacy Policy. If you object to the collection of Personal Data we must obtain for certain Service, you have the option not to use such feature or to avoid from accessing our websites.
You are not legally obligated to provide us with Personal Information nor are you required to use the Site in the first place. By using the Site and engaging or interacting with the Services, you consent to this Privacy Policy and to our information practices described herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Site or the Services.
EU/UK Residents:
This Privacy Policy further includes information we need to disclose under the General Data Protection Regulations (“GDPR”) including our lawful basis for processing your Personal Data, our Data Protection Representative, your rights under the GDPR and how you may exercise your rights.
We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of the Privacy Policy will always be posted on the website. The updated date of the Privacy Policy will be reflected in the “Last Modified” heading. We will provide notice as shall be required under applicable data protection laws, including if these changes are material and, where required by applicable law, we will obtain your consent. Any amendments to the current practices of Personal Data we hold will become effective within 7-days upon the display of the modified Policy. We recommend you review it periodically to ensure that you understand our most updated privacy practices.
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
a. European Union (EU)
b. United Kingdom
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: Prighter | Compliance Landing Page of Optival LTD
You can find here information regarding the types of Personal Data we collect, the purposes for which we process your Personal Data as well as our lawful basis for processing (where the GDPR applies), the definition of “personal” and “non-personal” data and how it is technically processed.
Types of Information Collected and the Meaning of Personal Data
Under applicable data protection laws, “Personal Data” mainly refer to information that identifies an individual or may with reasonable effort identify an individual. This may include online identifiers such as IP address, Cookies ID, and also name, emails, etc. Personal Data also includes insights based on your preference and behavior, profiling, or other information that is identified with you.
We may further collect “Non-Personal Data”, meaning information which does not identify a specific natural person and cannot reasonably be used for such identification, for example, aggregated information regarding the use of the website and Services, such as the scope of users accessing our websites, click trends, territories, frequency, statistics regarding users time and date access, etc. as well as technical information transmitted for the browser and the device such as type of device, type of browser and operating system. This information is considered as Non-Personal Data when collected on an aggregate basis, or otherwise not combined with any online identifiers.
If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.
Source of Personal Data
Depending on your interaction with our website and Services, certain information will be collected, as further detailed below. We may collect the information by one of the following means:
(i) automatic means and tracking technologies (such as cookies, pixels and tags – see the “Cookies and Similar Technologies” Section of this Privacy Policy) implemented by us or third parties such as our service providers, Business Partners, and other third party marketing partners their services we use (see the table below as well as the “Data Sharing – Categories Of Recipients We Share Personal Data With” Section of this Privacy Policy). This further includes technologies known as “tracking links” implemented by us within the Business Partners content we display in our websites, which enables us and our Business Partners to know that a certain user (based on a unique online identifier assigned) was directed from our website to the Business Partner’s Website (as explained in the table below);
(ii) when you voluntarily provide us your information, for example, when you contact us; and
(iii) from our Business Partners, and mainly if you engage with such Business Partners after being directed from our websites).
Personal Data Sets, Purpose and Use & Lawful Basis
Below details the Personal Data sets collected, processing of Personal Data, the purpose, lawful basis, and processing operations:
Online Identifiers When you access our website and interact with our Services, we collect online identifiers, such as IP address, user agent and Cookie ID. We may further assign a unique identifier (which is a random combination of numbers/letters) to each user accessing our website or such unique ID might be assigned when you interact with features that directs you to our Business Partner’s Websites through the tracking link (as explained under the “Source of Personal Data” paragraph above).(collectively “Online Identifiers “).
o Location Data We may further process your approximate location (i.e., country level) from your IP address.
o Device Information We collect information transmitted from your device such as the type of device you are using and its version, browser type from which you have accessed our website, operating system, etc.
o Usage Data We collect information regarding your use and your interaction with the website and Services. Such data may include the pages you have accessed on our website and content you have interacted with (for example clicked on) as well as the click stream, access and interactions time and date stamp, duration, etc. Such usage data might be stored by us, together with Online Identifiers, in log filed. (collectively “Usage Data”)
o ***Where the types of data listed above – i.e., location, device information and usage data – are associated with online identifiers, such will be considered and treated as Personal Data, however we may further collect such information on an aggregated statistical basis which will not be considered as Personal Data.
These data sets are processed for the following purposes: For operation, functionality, security and fraud prevention purposes, debugging purposes and to resolve technical problems.For analytic, marketing and advertising purposes. For example, we process this data to understand how users use our website, as well as to measure effectiveness of our content and advertising campaigns.We will further process these data sets to enhance our Services (for example to detect the applicable language) and for marketing campaigns performance, as well as for advertising purpose, including retargeting based on your visits in our website. We will use your unique ID or other Online Identifiers to track traffic flow from our websites to our Business Partner’s Website. This allows us to manage our business engagement effectively, analyze performance metrics, monitor business transactions, and track conversions.
We process these data sets through our or third-party cookies and tracking technologies (see the Cookies and Similar Technologies Section below).We use strictly necessary cookies to process these data sets for the proper operation of our website based on our legitimate interest. Further, we will use other cookies to process these data sets for marketing and analytics purposes subject to your consent, provided through the cookie preference settings. You may withdraw consent at any time by using the cookie settings on our website.
Business Partners’ Engagement Data
As explained above, when you click on a certain Business Partner’s offer through our website and directed to THE Business Partner Websites, the tracking link will assign to you a unique ID. We will retain such action (i.e., the fact you have clicked and were directed to the Business Partner’s Website) and in some cases, depending on our business model with such Business Partner, the Business Partner will share with us the action of your engagement with its offer made with the Business Partner. For example, if you have registered, purchased a product, opened an account, the amount paid or deposited, etc.
We process these data sets to enable out business operation. As explained under our Terms, we receive advertising fees from our Business Partners whenever a user was either directed to the Business Partner’s Website or otherwise engaged or completed an action. Thus, we process this data mainly to calculate the advertising fees we are entitled to and for record keeping purposes.
We may further use these data sets, in an aggregated manner, to enhance our content, campaigns, and obtain insights regarding users’ satisfaction and the popularity of a certain Business Partner (e.g., if statistically a high percentage of users engage with a Business Partner, this is a factor we consider as for the quality of its offers). We process these data subject to our legitimate interests.
Advertising Campaigns Interactions
When we advertise our websites and the Services, we use third party providers or tools to manage these ad campaigns. Through these tools, we collect information such as the user’s journey, when they clicked our ad, the URL and campaign from which they were directed to our websites, and if they have engaged with a Business Partner after they were directed from our website.
We collect and process these data sets to perform, facilitate and optimize our marketing campaigns, ad management and Services.
We process these data sets based on your consent provided through the cookie preference settings. You may withdraw consent at any time by using the cookie settings on our website.
Contact Information & Communications
If you voluntarily contact us following your interest in our website, support or other inquiries, by email or through other means of communications, you may be required to provide us with certain information such as your full name, email address, and any additional information you decide to share with us. We will further process and retain our correspondence and communications.(collectively “Contact Communications”).
We process such Contact Communications data for the purpose of contacting you and responding your inquiries or provide you with the support or information you have requested. The correspondence with you may be processed and stored by us for record keeping purposes, to improve our Service, as well as in the event we reasonably determine it is needed for future assistance or to handle any dispute you might have with.
When you voluntarily contact us, we process such Contact Communications data based on your consent. In other cases, including for our internal record keeping purposes, Contact Communications are processed and stored subject to our legitimate interests.
Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of Personal Data to third party countries as further detailed in the “Data Transfer” Section below is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.
We use “cookies” (or similar tracking technologies such as pixels, tags, web beacons, etc.) when you access the website or interact with the Services. The use of cookies is a standard industry-wide practice. These technologies are a small piece a text code or of information that a website assigns and stores on your computer or browser while you are viewing a website. These tracking technologies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes. You can find more information about our use of cookies here:www.allaboutcookies.org.
In addition, please see our Cookies Settings banner which details the cookies we use on our website.
Managing Cookies and Opting Out
Other than cookies classified as essential or strictly necessary for functionality purposes, you can always configure your cookies preferences and opt-out from use of certain or all cookies at any time, using the cookies preference management tool on our website or through your browser’s settings. In some cases, certain services, features and functionality may not be available to you or work properly if you disable cookies.
We share your data with third parties, including with trusted partners or service providers that help us provide and improve our Services:
• Business Partners – Unique ID, Online Identifiers – When you are directed to a Business Partner Website, we will share your unique ID and may, where needed for fraud detection prevention, etc., share IP address or similar data. Please note that, we share this data only for the purpose of our business operation and tracking conversion.
• Trusted agents and service providers – All data, as needed and applicable to the services provides- We may disclose Personal Data to our trusted agents (such counsel and advisors) and service providers (including, but not limited to, cloud providers, CRM provider, security technologies providers, etc.) so that they can perform the requested services on our behalf. These providers are prohibited from using your Personal Data for any purposes other than providing us with requested services. When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the requested services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
• Subsidiaries and affiliated companies or any acquirer of our business – All data – We may share Personal Data, internally within our group or in in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation, or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
• Advertising Partners – Online Identifiers, Device, Location and Usage Data – Where we use third-party advertising partner’s cookies or services (such as Google, social media, etc.), such third-party may independently collect, through the use of such tracking technologies, Personal Data and may combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies.
• Governmental agencies or disclosure due to a legal process – Subject to law enforcement authority requests- We may need to disclose your data to comply with legal obligations (including court orders and subpoenas), defend against potential, threatened, or actual litigation, or when we are legally obliged to share information with law enforcement.
Due to our global operation and location of our services providers (e.g., cloud storage, etc.), any Personal Data we collect may be transferred to and processed in countries other than the country from which you accessed the Services. We transfer Personal Data in compliance with applicable data protection laws. We take appropriate measures to ensure that your Personal Data receives an adequate level of protection, including by using contractual obligations or other data transfer mechanisms that were pre-approved by applicable data protection authorities to ensure your Personal Data is protected (such as the Standard Contractual Clauses). Where you consent is required under applicable data protection laws for the transfer of your Personal Data, by browsing our website and using our Services you are deemed to have consented to the transfer of your Personal Data, as described herein
As a principal, we will only retain Personal Data we collect for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, administrative, record keeping, or finance obligations. The criteria according to which we determine the retention periods for the Personal Data we collect are as follows:
(i) the type of Personal Data and purpose of collections: we consider for how long we need to retain the Personal Data to achieve the purposes for which such data sets were collected, as well as the nature and sensitivity of the Personal Data and the potential risk of harm from unauthorized access or usage;
(ii) our legal obligations: the retention period further depends on the laws of the applicable territory, as under certain laws, we are required to retain certain types of Personal Data. We may also retain certain types of Personal Data in the event we are required to do so subject to a binding legal request or a court order;
(iii) dispute, claims, and legal proceedings: we may retain certain types of Personal Data if we find it reasonably necessary to protect our rights, defend against a threatened or potential legal claim or enforce our terms and policies. In addition, in the event of a dispute between you and us, including any legal proceedings, we will retain the Personal Data until such dispute is resolved.
According to the criteria set forth above – we determine when we no longer have a legal justification for retaining Personal Data, and accordingly, at the lapse of such period we will delete or de-identify the Personal Data so it can no longer be associated with you by reasonable means.
Except as we are required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
We implement security measures to reduce the risks of damage, loss of information and unauthorized access or misuse of Personal Data we retain, in accordance with applicable laws. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our Services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse. As the security of information depends in part on the security of the computer, device or network you use, please make sure to respond appropriately to protect this information.
You have the right to exercise certain choices, rights, and controls in connection with your Personal Data collected or retained by us. Depending on your relationship with us and the applicable data protection laws that apply in your jurisdiction or your Personal Data, these rights may include one or more of the principal rights detailed in the table below, and how you can exercise them.
Note that, as further explained below, some of your rights can be exercised independently, and to exercise certain rights – you will be requested to submit your request to us by contacting contact our privacy team at: contact@best10bingosites.co.uk EU and UK residents can further submit their requests to our Data Protection Representative at: Prighter | Compliance Landing Page of Optival LTD
When you contact us, please clarify which right you wish to exercise and further provide us with an applicable information that will enable us to verify your identity or associate the data with you. Please note that we may be required to ask you for further information to confirm your identity before we provide the requested information.
• Right to be Informed – You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy, however, if you have any questions or you require for additional information, you may exercise your right by contacting us, as set forth above.
• Access Rights – You have the right to confirm whether we collect Personal Data about you, as well as to know which Personal Data we specifically hold about you and receive a copy of such or access it. You may exercise your right by contacting us, as set forth above.
• Right to Correction/ Rectification – You have the right to request any incomplete or inaccurate Personal Data is corrected or deleted, taking into account the nature of the processing and the purposes. You may exercise your right by contacting us, as set forth above.
• Right to Be Forgotten, Right to Deletion – You have the right to request the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, other legitimate interests such as record keeping with regards to our engagements, completing transactions, taking actions reasonably anticipated within the context of our ongoing business relationship with you, detecting security incidents, or exercising another right provided for by law. You may exercise your right by contacting us, as set forth above.
• Right to Restrict Processing – You may be entitled to limit the purposes for which we process your Personal Data if one of the following conditions are satisfied: where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data; where the processing is unlawful and you oppose the erasure of Personal Data and request the restriction instead; where we no longer need the Personal Data for the purposes of the processing, but we are required by you to retain it for the establishment, exercise or defense of legal claims; where you objected to processing (as detailed below) pending the verification whether our legitimate grounds override your request. You may exercise your right by contacting us, as set forth above.
• Right to Data Portability – You have the right to receive a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another entity without hindrance. We will select the format in which we provide your copy. You may exercise your right by contacting us, as set forth above.
• Right to Withdraw Consent/Object/Opt-Out – When the lawful basis for processing your Personal Data is your consent, you may withdraw such consent at any time. This can be done by contacting us, however, for certain Personal Data processing, your rights can be exercised independently. For example, you change your cookies preference at any time as explained under the “Cookies and Similar Tracking Technologies” above. You further have the right to object to the processing of Personal Data and the right to opt-out, in the event the basis for processing is our legitimate interests. However, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise, or defend a legal claim or right.
• Right To Appeal or Lodge Complaint- If we decline to take action on your request, we will inform you as required under applicable laws. The notification will include a justification for declining to take action. Under the GDPR you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.
The Services are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us.
Our websites and Services include links to third-party websites, including Business Partner’s Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-parties’, including Business Partner’s practices and are not responsible for their privacy statements. To exercise your rights – you should contact the Business Partners directly.
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