1. Who We Are

Rocksteady Club is an online casino operated by Rocksteady Entertainment N.V. and licensed by the UK Gambling Commission (licence number 000-039483-R-319422-001). In this policy, "we", "us" and "our" refer to Rocksteady Entertainment N.V. We are the data controller for personal information collected through Rocksteady Club. If you have any questions about how we handle your data, please contact us at the details in Section 10.

2. What Personal Data We Collect

We collect the following categories of personal data:

• Identity data: full name, date of birth, gender and copies of identity documents provided during verification.
• Contact data: email address, postal address and telephone number.
• Payment data: payment method details (such as Visa, Mastercard, PayPal or bank account information), transaction history, deposit and withdrawal records.
• Device and technical data: IP address, browser type and version, operating system, device identifiers and login timestamps.
• Usage data: pages visited, games played, session duration, betting and wagering history, and interactions with our platform.
• Communications data: records of your correspondence with our support team, including live chat transcripts.

3. Why We Collect Your Data and Our Legal Bases

Under the UK General Data Protection Regulation (UK GDPR), we must have a lawful basis for processing your personal data. Here is why we collect each type and the basis we rely on:

1. Account creation and management - to set up and maintain your account. Legal basis: performance of a contract.
2. Know Your Customer (KYC) and Anti-Money Laundering (AML) checks - to verify your identity and comply with UK Gambling Commission requirements and financial crime legislation. Legal basis: legal obligation.
3. Processing payments - to handle deposits and withdrawals via your chosen payment method. Legal basis: performance of a contract.
4. Responsible gambling - to monitor play patterns, apply self-exclusion or deposit limits, and fulfil our duty of care obligations under our gambling licence. Legal basis: legal obligation and legitimate interests.
5. Marketing communications - to send you promotional offers, bonuses and news about Rocksteady Club. Legal basis: consent. You may withdraw consent at any time by clicking unsubscribe in any marketing email or contacting us directly.
6. Fraud prevention and security - to detect and prevent fraudulent activity and protect our platform. Legal basis: legitimate interests.

4. How Long We Keep Your Data

We retain your personal data for as long as your account is active and for a minimum of five years after account closure, in line with our obligations under UK gambling and anti-money laundering regulations. Payment records may be kept for up to seven years to comply with financial reporting requirements. Where data is no longer needed, we securely delete or anonymise it.

5. Who We Share Your Data With

We do not sell your personal data. We may share it with:

• Payment providers - including Visa, Mastercard, Apple Pay, PayPal, Paysafecard and bank transfer processors, solely to process your transactions.
• Regulators and law enforcement - including the UK Gambling Commission and relevant authorities, where required by law or to protect against fraud and financial crime.
• Identity verification and KYC service providers - third-party suppliers who assist us in meeting our regulatory obligations.
• IT and platform service providers - companies that support the operation of our website, apps and customer support systems, acting as data processors under our instruction.

All third parties are required to handle your data securely and in accordance with applicable data protection law.

6. Cookies

We use cookies and similar tracking technologies to keep you logged in, remember your preferences, analyse site usage and, with your consent, deliver relevant marketing. You can manage your cookie preferences through the cookie banner shown when you first visit our site, or via your browser settings. Disabling certain cookies may affect the functionality of the platform.

7. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Right of access - request a copy of the data we hold about you.
• Right to rectification - ask us to correct inaccurate or incomplete data.
• Right to erasure - request deletion of your data where there is no lawful reason for us to keep it.
• Right to restriction - ask us to limit how we use your data in certain circumstances.
• Right to data portability - receive your data in a structured, machine-readable format.
• Right to object - object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent - where processing is based on consent, withdraw it at any time without affecting prior processing.

8. How to Exercise Your Rights

To exercise any of the rights above, please contact us using the details in Section 10. We will respond within one calendar month. We may need to verify your identity before processing your request. If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Any significant changes will be communicated to you by email or via a notice on the Rocksteady Club platform. The date of the most recent revision will always be shown at the top of this page.

10. Contact Us

For any data protection queries or to submit a rights request, please reach out to our support team via 24/7 live chat on the Rocksteady Club website or app. You may also write to us at the registered address of Rocksteady Entertainment N.V. We are committed to resolving your concerns promptly and in plain English.