1. General
This Player Privacy Policy forms an integral part of the MrQ General Terms and Conditions, and contains information on how Tek Fox Ltd (“we”) uses, processes and stores your data, marketing communications and preferences, and your legal rights.
Tek Fox Ltd is a company lawfully incorporated in Malta, with registration number C96152. Tek Fox Ltd is licensed and regulated in Great Britain by the Gambling Commission under account number 60629.
Tek Fox Ltd is committed to protecting your privacy. We’ll protect your personal information and respect your privacy in accordance with best business practices and all relevant laws and regulations.
If we make any material updates to this Policy, we will inform you.
Data Controller: Please note that the Data Controller of your personal data is Tek Fox Ltd.
2. Personal Information
2.1 Personal Information
"Personal Information" is any information about you which by itself or together with other information, could be used to identify you or that relates to an identifiable individual.
2.1.1 Personal Information you provide
Most personal information is provided voluntarily by you during the process of registration. This includes information such as your name, postal address, phone number, email address, birth date, username, and other account credentials.
Furthermore, at certain points whilst you hold an account with us, due to Anti Money Laundering legal requirements, we are required to ask you for supplementary documents for the purposes of verification, such as identification documents including your photo ID, utility bill, documents evidencing your source of wealth and/or source of funds, affordability and other checks that we are required to carry out in line with our regulatory obligations. Information contained within these documents is considered in full during the process of verification and may be logged and stored, in line with Social Responsibility and Safer Gambling obligations.
2.1.2 Information We Receive from Third Parties and public sources
Some personal information is gathered as part of our legal, regulatory and security checks. We collect information for AML/CFT purposes on the background of a player from open public sources where these are available and the processing is permitted by law, and/or from third party providers (private companies working mostly with public sources). We use publicly available information (on social media sites, search engines etc) to help verify information provided to us and we log and store the results.
Due to regulatory requirements, we collect know your customer (KYC) information from specialised third parties when it is reasonably necessary to do so, in line with legal requirements, including whether the individual is politically exposed person and whether any international and/or financial sanctions have been imposed and/or information on any corporate or property ownership, court judgements and/or insolvency.
In order to comply with regulatory requirements, we may also share your personal information with specialised third parties to provide financial vulnerability and affordability profiling.
If a player is registered with a National Self-Exclusion Register, certain Self-Exclusion Data is also received from such a register.
We may combine the information we collect from you with information that we receive about you from other sources.
2.1.3 Information collected from your device
We collect Personal Information from your device at registration and at future logins in order to prevent and detect fraud and misuse of our systems. We and our third party service providers may collect information automatically from your device, including through your browser or device such as your IP address, VPN usage, device type, language, time-zone and the browser type you are using. We use this information to ensure that our services function properly and to fulfil requirements such as anti-fraud checks
We also record and store all transactional and usage data, including communication data, during periods of activity with us, in order to allow for profiling and ongoing risk monitoring in line with Anti Money Laundering regulations and Responsible Gambling obligations.
2.1.4 How do we use your personal information?
Your Personal Information will be processed by Tek Fox Ltd and its providers and suppliers for legitimate and legal interests only and so that we can offer you our products and services in a way that is legal and in accordance with our operating licence. This includes:
- to set up, run and manage your account
- to deliver our gaming service and products
- to provide support and payment services
- to carry out necessary security and identity verification checks (including disclosure of information to third parties including financial institutions, age verification, credit reporting agencies, and as authorised by you or required by law)
- to process any of your transactions
- to personalise your experience and deliver content tailored to your interests
- to process any of your legal and regulatory requests for information
- to monitor website usage and the quality of the gaming service we provide
- to tell you, from time to time, about products and services that we think may interest you if you have agreed to receive marketing messages from us
- to regularly send you written communications to announce important service changes, technical issue updates and changes to terms and conditions and/or rules
- to comply with our regulatory duties, obligations and responsibilities with relevant regulators, including in relation to responsible gambling profiling and financial vulnerability and affordability profiling
- to conform to legal requirements or comply with legal processes
We will only process your Personal Data as described in this Privacy Policy. In some instances, we will use your personal information for research purposes, to evaluate player experience and identify how we can improve our services and products.
2.1.4.1 International Transfer Of Your Personal Information
Personal Information collected by us may be stored and processed in any country where our affiliates, subsidiaries, suppliers or agents are located. We may also need to transfer data (including Personal Information) to other group companies for the purpose of the supply of our services.
If this happens, all information will be managed according to and subject to all relevant national, European and international data protection and privacy laws and regulations, including the UK Data Protection Act 2018 and the EU General Data Protection Regulations.
We reserve the right to show your Personal Information to relevant recipients if we’re required to do so by law, or if we believe, in good faith, that disclosing such information is necessary to:
- comply with any legal or regulatory process served on the company or its gaming service
- protect and defend our rights and/or property
- protect the safety of other users of the gaming service or the public
- investigate any suspected violations of our General Terms and Conditions or user guidelines or Licence Agreement, fraud or other similar and/or unlawful activity performed by you
Your Personal Information may (for the purposes described in this Policy) be transferred or disclosed to any group company and to specialised third parties for the processing of that Personal Information on our behalf, such as Payments Providers, anti-fraud, risk and compliance providers. Any third parties we transfer or disclose your information to are also bound by privacy and data protection laws.
We may transfer your Personal Information in the event of a business sale or insolvency. If this happens you’ll be contacted to let you know what is happening with your data and your rights.
Your information will not be passed on to other third parties for marketing purposes without your consent.
2.1.5 Information demands from Regulators:
As required by law, your Personal Information may be disclosed to an applicable governmental, regulatory or enforcement authority. Those bodies may then use your Personal Information to investigate and act on any such breaches in accordance with their procedures. We do not pass on your data to third parties for any other purpose, unless you have given explicit permission for us to do so or this is permitted by law.
2.1.6 What if I don’t want you to use or process my data?
If you don’t want us to use or process your Personal Information in the ways we outline in this Privacy Policy, you should stop using our sites, products and services and contact us to tell us what you do and do not consent to.
If you want to withdraw your consent for us to use or process your data in a certain way, your access to our sites, products and services may be affected. By using our sites, products and services you’re acknowledging that you’ve read the terms of this Privacy Policy and that you’re happy for us to use your Personal Information for the reasons and in the ways set out below.
3. Retention Policy
We will retain your data for as long as is necessary to comply with legal requirements. If you close your MrQ account, we will retain your information just to the extent necessary to comply with our legal obligations such as the applicable tax/revenue laws, Anti Money Laundering regulations and other applicable regulatory requirements and to resolve any disputes.
For more specific information about data retention terms, please contact us at support@mrq.com.
4. Changes to this Policy
From time to time we’ll have to update our Privacy Policy. Where we make any changes of material impact, you will be informed of this upon your next log in to your account or via email to your registered email address. At this point, you’ll be required to confirm that you’ve read and accepted the changes before you can continue to use our sites, products or services.
If, for any reason, we don’t or can’t confirm your acceptance of the changes, but you continue to use our sites, products or services, we’re allowed to assume that you have accepted the changes.
All activity undertaken before the notification and acceptance of the change will be managed by the terms in place at the time that activity was undertaken.
If you have any concerns or questions about how we use your data, you should stop using our sites, products and services and contact us for more information.
5. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In order to comply with UK data protection obligations, various technical controls ensure data and information are secure. This ensures confidentiality and integrity at all times.
The handling of all information is governed by our Information Security Policies. All of our employees undertake regular training on Information Security and are required to comply with confidentiality obligations as well as internal policies and procedures whenever they handle your information. We limit access to your personal data to employees, contractors and other third parties on a permissions and need to know basis. We have in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. Market Research
Occasionally, we may carry out some research and analysis on customers who have registered with us. We’ll use this for internal purposes only. The main reason is to help us make sure that we give you everything that you – our customer – is looking for.
We will not sell, lease, share or disclose your Personal Information except as explained in this Privacy Policy. We’ll also never send you unsolicited information about any third-party commercial offers or adverts.
Any phone calls, emails and live support chat logs to and from our Player Experience, Payments and Fraud & Security Teams may be recorded for training and security reasons.
All recipients of your Personal Information will be bound by this Privacy Policy and appropriate data protection and privacy laws to keep your Personal Information private.
If at any time you wish us to stop processing your Personal Information for the above purposes, please contact us at support@mrq.com.
7. Cookies
We use cookies to obtain non-personal information from our online visitors to give them the best possible personalised online experience. Cookies are small markers sent by our web server to your web browser and they let us improve our websites and better tailor them to your needs.
We use cookies to analyse site usage, improve our content and product offers and to customise promotions, site content and layout. You can find out more about how Internet sites use cookies on www.aboutcookies.org.
If you wish to turn off cookies, please use the "Help" menu on the menu bar of most browsers, which will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies and how to stop cookies altogether.
If you do disable cookies, we may be unable to optimise your visit to our site and/or you may not be eligible for certain offers or promotions and your experience on our website could be a little poorer than you are used to.
8. Marketing Communications
As part of our customer account registration process, you’ll be asked to tell us whether you’d like to get marketing communications from us, including information about bonuses and promotions.
Once your customer account has been set up you’ll have the option to choose how you’d like to receive marketing communications. You can choose from email, SMS, phone or post, by changing your communications preferences settings on your account. The channels used to deliver marketing communications may change from time to time at our discretion.
You can also choose to opt-out of, or unsubscribe from receiving any marketing communications at any time by de-selecting the communication preference settings on your Account, or clicking on the unsubscribe link, texting STOP (or similar) contained in all of our marketing communications.
You may also change your communications preferences by contacting us at support@mrq.com.
If you’ve opted-out and you decide to start receiving marketing communications from us again, you can do so by reactivating your communications preferences on your Account at any time, or contacting us at support@mrq.com.
9. Your rights
All UK data subjects have a number of rights under the Data Protection Act 2018 (UK General Data Protection Regulations). Some of these apply at any time, but some may only apply in certain circumstances.
Right to be informed
- We are required to be transparent in how we are using personal data, hence this Privacy Policy
- You have the right to be informed what your rights are and how you can lodge a complaint
Right of access
- You have a right to request us to confirm if we are processing personal information that concerns you and have the right to request a copy of the personal information that we hold about you, including:
- what personal data we have
- why and how we process this
- who we disclose this to
- how long we intend on retaining this
- whether we transfer this to third parties and what safeguards are in place
- where we got your personal data from and
- whether we have carried out any automated decision-making
- Should you wish to exercise this right and submit a Subject Access Request, please contact us at support@mrq.com detailing the information you would like to receive.
- We shall, where possible without adversely affecting our own rights or those of other individuals, provide this information within 30 days of your request. This period may be extended where necessary and you will be informed of such an extension and the reason for the delay.
Right to rectification
- You have a right to rectify the personal data we hold about you
- We kindly request you to inform us promptly of any changes to your personal data. You are able to update some of your personal information from within your account. If the change relates to information that cannot be amended within your account, please contact us.
- You have the right to ask us to rectify inaccurate or incomplete personal data relating to you. We may require additional documentation to verify the accuracy of the information before rectifying it.
- If you want to update your Personal Information, you can, at any time, by contacting our support team.
Right to Erasure (right to be forgotten)
- You have the right to ask us to delete your personal data however we shall not be legally bound to comply with your erasure request if the processing of your personal data remains necessary for compliance with a legal obligation to which we are subject (including but not limited to data retention obligations) or for the establishment and defence of legal claims.
We shall comply only where:
- The personal data is no longer necessary for the purposes for which it was collected
- you have withdrawn your consent (in those instances where we process on the basis of your consent)
- we have no other legal grounds to process your personal data
- you have successfully exercised your right to object (as explained below)
- your personal data has been processed unlawfully
- there exists a legal obligation to erase the data to which we are subject
Should you wish to exercise this right, please contact us at support@mrq.com detailing the information you would like us to erase.
Right to restrict data processing
- You have the right to ask us to restrict processing (but continue to store) your personal data where:
- the accuracy of your personal data is contested
- the processing is unlawful, and you oppose the erasure of your personal data
- we no longer need the personal data for the purposes for which they were collected but you want this to be retained in case of legal claims
- you exercised your right to object and are waiting for us to confirm our legitimate grounds to override your objection
Following your request for restriction, we will only process your personal data where we have your consent, for the establishment and defence of legal claims, or for the protection of the rights of another natural or legal person.
Right to data portability
- You have the right to receive personal data in a structured and machine-readable format and to retain and reuse your personal data for your own purposes. You also have the right to request that we transfer your data to another organisation directly.
Right to object
- This gives you the right to object to the processing of your personal data in some circumstances.
- If you object to receiving marketing material you can remove consent for us to send it. You have the absolute right to object to the processing of your personal data for direct marketing purposes, including profiling in the extent that it is related to direct marketing.
- You can also object where processing is for a task carried out in the public interest; the exercise of official authority vested in you; your legitimate interests (or those of a third party); or in relation to automated decision making and profiling.
Right to withdraw consent
- In cases where we process personal data on the basis of your consent (which we have obtained in a clear manner from you), you have the right to withdraw your consent at any time and in the same manner in which you have provided this to us.
- Consent is not the only ground that permits us to process your personal data and as such, should you exercise your right to withdraw consent, we may determine that an alternative legal basis exists for processing your personal data.
Rights related to automated decision making including profiling
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to lodge a complaint to relevant supervisory authority
- We ask that you attempt to resolve any issues directly with us first by contacting us at support@mrq.com
- You do also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority.
- The competent authority in the UK is Information Commissioner’s Office
- The competent authority in Malta is the Office of the Information and Data Protection Commissioner (IDPC).
- When exercising any of the rights detailed above, we are permitted to request specific information from you to help us confirm your identity and ensure your right to access your personal data, prior to fulfilling your request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
10. Contacting Us
Our goal is to always be as clear and transparent as possible, if you need any clarification on this Privacy Policy, we would be happy to provide any such information.
If at any time you believe that we have not followed or adhered to this Privacy Policy, please tell us by email at support@mrq.com and we’ll do everything we can to quickly identify and correct the problem.
Questions regarding this Privacy Policy should be directed to: support@mrq.com, or by post to Tek Fox Ltd, The Brewhouse, Mdina Road, Zone 2, Central Business District, Birkirkara, Malta.
This Privacy Policy is effective as of 1 August 2024.