Privacy & Cookies Policy
If you have any questions or feel you need to contact us.
SiberianCMS Modules (“we”, “us”, “Dalkin”, “our”), is a trading name of the Dalkin International Limited Group of Companies (“Group”). Dalkin International Limited operates the websites www.siberiancms-modules.com, and all variants thereof (the “Site” or “Sites”). The licensed companies of which the SiberianCMS Modules trading name is a part, include any holding company or subsidiary, as well as any entity there associated and forming part of the Group.
We have strict security measures designed to protect your personal data and are committed in respecting the privacy rights of our site visitors and customers (“you”, “your”, “yours”).
We consider the data that you provide us with as strictly private and it shall only be used by us, by members of our Group or by selected third parties who comply with data protection regulations to manage the Account which you open with us, to create customer profiles, to ensure the security of the Site, to send marketing communications. and to enable you to use our services.
Please note that you may choose whether you wish to permit us, a member of our Group or one of our partners to use your personal data for marketing purposes and your denial will not affect the Services we provide you.
2. What personal data is collected and for what purpose
A. Personal data processing for Service provision purposes
We collect the following information when you visit our Sites, use our Mobile Offer, register to use our Services by opening an Account or contact us:
- Registration data. This is information you provide us to open an Account with us, specifically we collect: first name, surname, gender, date of birth, place of residence, postal address, email address, phone number, language, currency, passport or ID card number, nationality, and place of birth. You will also be required to provide login details of your choice, namely a username, password and an answer to the secret question which will be kept by us. Additionally, when you make a pre-registration sign-up and before you fully register as a customer, we request the following information from you: title, first name, surname, date of birth and email address. We store this information to provide you with a pre-populated registration form if you decide to fully register with us.
- Financial and ID data. We additionally require you to provide us with a payment method and payment details (such as bank transfer, credit card or another acceptable means of payment) in order that you can credit your Account. Further, before your first withdrawal of funds from your Account, we will request that you send us a copy of an official document (e.g. passport, driving licence or other approved identity document) in order to confirm the accuracy of the data you have provided. We may request further information and/or documents about you, such as source of wealth or source of funds, should we feel it necessary to meet our AML obligations. We may use personal information provided by you in order to conduct appropriate anti-fraud checks and discharge our legal and regulatory obligations and duties. Personal information that you provide may be disclosed to a credit reference or fraud prevention agency, which may keep a record of that information. This is done only to confirm your identity – a credit check is not performed, and your credit rating is unaffected. In addition, when contacting the Customer Support, calls may be recorded and used for training purposes. Content can be disclosed when ordered to do so by any Governing Authority and/or under any legal provision contained in the Governing Law.
- Technical data. When you access the Mobile Offer, we collect the following information: IP address, access provider and type/version of browser used.
We require the above information in order to ensure that you can identify yourself when using the Site, to ensure that you are of legal age to use our services, to improve our services to you and to keep you informed regarding any of our services which may be of interest to you. We also use geolocation tools to record your internet protocol (IP) address and to compare it against your user identification in order to prevent fraudulent activities and to create an audit trail. Like most standard website servers, we use log files. This includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the Site, track user’s movement in the aggregate and gather broad demographic information for aggregate use.
In addition to the purposes listed above, we collect and process your data for the following purposes:
- sending you written communications in the case of changes to the Services, technical updates, maintenance causing temporary suspension of one or more of our Services and changes to the rules and / or terms and conditions which regulate the Services;
- providing customer support when you contact us;
- creation of player profiles and ensure access to site services and management of gaming accounts;
- prevention of fraudulent activity, and any illegal activity including those committed to the detriment of the integrity of the sports game;
- monitoring of complaints and disputes;
- request on behalf of institutional subjects as a result of emergency measures.
B. Personal data processing for marketing purposes
In case you have expressed an additional and specific consent at the time of activation of the requested Service or after activation of the gaming Account, some of your personal data may be processed by Dalkin for the communication / sending of advertising, information and commercial information of Dalkin or third parties.
Specifically we use the email address which you have provided us with to send you an email welcoming you to Dalkin. With your prior consent, we may send you emails, letters by post and SMS messages from time to time containing information ranging from special promotions to technical and other information relating to our services and the services of our Group companies. Should you wish to unsubscribe from our mailing list, you can do this easily by either changing your Account settings or clicking “unsubscribe” on the bottom of the email. If you have agreed to receive offers from Dalkin and/or partners on the pre-registration sign-up page and you later wish to unsubscribe, simply click on the ‘unsubscribe’ link on the email. Should you wish to unsubscribe from receiving SMS messages, you can do this easily by following the instructions to unsubscribe in the SMS message sent to you. If you have opted in to receive commercial offers from our select partners, you can unsubscribe from this mailing list by changing your settings in ‘My Account’ and ‘Newsletters’.
In addition to the purposes listed above, we process your data for the following purposes:
- disclosure or sending of advertising, informative and commercial offers that could be of your interest;
- perform direct and indirect sales activities;
- carry out market surveys and surveys of levels of customer satisfaction on the quality of Services provided and the Site/the Mobile Offer.
C. Personal data processing for legitimate interest purposes
Pursuant to article 6, f) of the GDPR we can process the data listed in point A above, also by automated means, in order to monitor your usage of our Services including log files, such as IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks, track user’s movement in the aggregate and gather broad demographic information for aggregate use.
We process this data for the following purposes:
- to analyse trends and administer the Site in order to improve the Services we provide to you;
- to keep you informed regarding any of our Services which may be of interest to you;
- to improve the efficiency and security of the Site;
3. Legal Basis For The Processing Of Your Personal Data
We take our responsibilities under Data Protection Law extremely seriously, and make sure we only collect and process personal data about you where we have lawful bases.
Once your personal data is submitted to us, it shall be protected, kept securely on our database and only used for purposes for which is collected.
Our processing of your personal data for the purposes listed under point A of section 1 will primarily be necessary for us to provide you with the Services i.e. for the performance of a contract or in order for us to comply with our various legal and/or regulatory obligations under the Anti-Money Laundering regulations and the relevant online gambling and betting laws and regulations. Failure, partial or incorrect provision of your data for the above purposes will unfortunately mean we cannot provide our Services to you, as to allow you to use our service would mean we would be in breach of our legal obligations.
Our processing of your personal data for the purposes listed under point B of section 1 above is based on your prior consent. The provision of data for such purposes of processing is optional and non-acceptance does not imply any consequence on the contract signed with us. We remind you that what is listed could contribute to the improvement of services offered and offers that may interest you. At any time, you will have the opportunity to check and revoke any consent provided for these purposes (by accessing the “Newsletter” option on the “My account” page).
Following the non-acceptance or revocation of your data will be processed only for the purposes indicated in point A and C of section 1 above.
Our processing of your personal data for the purposes listed under point C of section 1 above is based on Dalkin’s legitimate interest to the performance of the economic activities referred therein, which is adequately balanced with your interest since the data processing is performed within the limits strictly necessary to their performance.
4. Your Rights to access and control your personal data
To exercise your rights, you may contact us at any time and we will make every reasonable effort to respond to any request received from you within one month from the date of the request. Please note that we will need to verify your identity before accessing your request.
As per applicable law, you have the right to:
- to change or correct your personal data that may have changed or become obsolete;
- to request information about your data we are processing;
- to object to our processing of your information after you have registered with us. However, it must be made clear that once financial transactions have been processed on your account we are required to comply with remote gaming and anti-money laundering regulations (AML).
- to lodge a complaint with a Supervisory Authority in Malta (the Lead Authority) or at a Supervisory Authority in the EU Member State where you are resident if you believe you have suffered an infringement of your rights
- to request the erasure of your data, however, Dalkin is obliged by AML regulations to retain all data for a period of five years after closure of the account. Consequently, your data can only be erased after such period of time has elapsed. However, should you make such a request your account will be closed and not processed except to satisfy legal and regulatory obligations of the data controller.
- to request that a restriction on the processing of your data is implemented where: i) you challenge the accuracy of the personal data until Dalkin have taken sufficient steps to correct or verify its accuracy, ii) the processing is unlawful but you do not want us to erase your personal data, iii) Dalkin no longer needs your personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or iv) where you objected to processing justified on legitimate interests, pending verification as to whether Dalkin has compelling legitimate grounds to continue processing.
- to access your data and ask us a copy of your personal data you provided, in a structured, commonly used and machine-readable format and have the right to have those data transmitted to another controller when we are processing your personal data relying upon your consent or the fact that the processing is necessary for the provision of the Services and the personal data is processed by automatic means;
You also have the right to opt out of receiving marketing information about our, and/or our partners’, services to you.
5. Recipients of Data
If you choose to use the Refer-A-Friend service in order to inform a friend about our Site, we will ask you for your friend’s email address and we will automatically send the friend a one-time email inviting him/her to visit our Site and to register with us. We will provide your friend with your name as a ‘referrer’. If the friend does not sign up with Dalkin, we do not store the friend’s email address in any database and we will not contact the friend after sending this email unless the same or another customer refers the friend to Dalkin again via the Refer-A-Friend service. The Refer-A-Friend service may not be available in all jurisdictions or to all customers.
- the installation / maintenance of IT / telematic systems;
- the provision of assistance, advertising, promotions and commercial communications to our customers (e.g. call centres);
- printing and shipping documentation to our customers.
A complete list of the data processors is available upon request sending a communication to this form.
The personal data submitted by our customers may be stored and/or processed in any country in which we or our affiliates, suppliers, subsidiaries or agents maintain facilities including destinations outside the European Economic Area (“EEA”). For transfers from EU to countries not considered adequate by the European Commission, we have put in place appropriate and suitable safeguards to protect your personal data. Accordingly, your personal data are transferred in compliance with the requirements and the obligations provided by applicable Data Protection Law. Dalkin is committed to taking all necessary steps to ensure that whenever personal data is transferred, such transfer takes place solely within the Group and the Group’s select partners in which companies the standards of privacy and confidentiality should be of an acceptable standard, irrelevant of location.
Dalkin may also transfer your personal data to a third country outside UE, If the Commission has decided that this third country, a territory or one or more specified sectors within that third country ensure an adequate level protection.
To the United States the transfer falls within an EU-US Privacy Shield.
6. Retention of your personal data
As our customer, you or we can close your Account with us at any time. Following closure of your Account, we will retain your personal data collected for the purposes listed under point A and C of section 1 on record for a minimum period of five years except when the detention of the data is necessary to respond or to file a legal action, upon request of the competent authorities or in compliance with the applicable AML, Tax and VAT laws and regulations as is required by the AML regulation. Financial transactions will be retained for a further period of five years to satisfy Tax and VAT laws and regulations. We will only use your data should such use be required by competent authorities in cases of fraud or investigation into any other illegal activity. This will be the sole exception to use of your personal data until its complete deletion from our records.
Personal data collected for the purposes listed under point B of section 1 above relating for example to the delivery of marketing communications and running of surveys are retained for the duration of the contract with Dalkin and a subsequent period of 24 months.
7. Automated Processing
For your protection, for our legitimate interest to protect against fraud and our reputation as well as to satisfy our legal obligations under remote gaming and AML regulations we use automated systems to assist us in monitoring and reviewing our customers. These systems help us to identify customers where particular attention should be focused. All final decisions taken on any actions are done so through human intervention and human decision-making process.
8. Protection of minors
The online betting and gaming services that we offer are strictly prohibited for persons under 18 years of age or under the age of legal consent for using online betting and gaming services under the laws of the jurisdiction in which the person is located. Consequently, minors may not register on our Site or on the Mobile Offer and should not provide us with any personal data. We collect proof of identification from our customers as part of our age verification process.
Any minor who is found to be gambling on Dalkin shall have any winnings confiscated and his/her Account will be immediately blocked. Dalkin reserves the right to conduct a security review to validate your identity and age. Acceptance of our Privacy & Cookies Policy authorises us to conduct such security reviews which may include ordering of credit reports or verification of the information supplied by you against third party databases.
What is a cookie?
Different types of cookies are used on our website and each has it specific target.
Cookies deemed as strictly necessary
These cookies allow you to use the main functionalities of our website and access to secured areas of the website (example: access to your account). Without these cookies, our website cannot run normally. These cookies also ensure security of the website for Dalkin and its users. For example, we use Session Identification Cookies to monitor the time of your connection. That’s why you are requested to re-connect after a certain time lapse. Somehow, we also use a permanent Identification Cookie that registers your Username (but not your password) to ease you next connections by filling in advance the « Username » field.
Those cookies enable us to measure the website frequentation, to know how it is used and how users react to proposed products. Thus, the collected data enables us to improve our website and your navigation experience. The collected data remains strictly anonymous and is only subject to a purely statistical process. With this respect, we use a third-party service: Google Analytics. If you do not wish that Google Analytics collects or uses your information, you can directly unregister through your browser on the following Google page (https://tools.google.com/dlpage/gaoptout).
Those cookies allow you to personalize your experience on our website (for example to remind you to make a first deposit, or to direct you to your favourite universe). Thanks to those cookies, you may also be informed of Specific Promotional Offers depending on your place of connection. They may also provide you with functionalities you have personally requested. We may also use a cookie to help us route traffic between servers and thus measure loading times. Sometimes, we also store data on your browser or your device so that functionalities you usually use are automatically uploaded and thus respond quicker.
These cookies are used to display advertisement related to your centre of interests during your navigation on the web. They are also used amongst other to limit the number of times you are exposed to see a single advertisement and allow to measure their efficiency. We work with web editors, advertisers, and service providers to promote Dalkin on other websites. Dalkin may then use your navigation data through cookies managed by a partner. The collected data remains strictly anonymous and is only subject to a purely statistical processing. Displayed banners are thus personalized.
Cookies and Device Identifiers for Transactions Safety
How to manage your cookies
At the moment, it is not technically possible to adjust your cookie settings at our individual websites, but you can manage your cookies through your browser. We recommend that you do not block or delete your cookies as it may limit the experience of some of the websites you visit. The Cookies can usually be changed on the “Settings” section of your browser. Below you can find some more information on the most popular web browsers: Firefox, Internet Explorer, Chrome, Opera, Safari.
Dalkin uses its best endeavours to protect the confidentiality of your personal data and to prevent any unauthorised external or internal users from accessing such information without your consent. However, Dalkin shall take no responsibility whatsoever for events beyond its control inclusive of, but not limited to, acts of god or natural disasters and including power cuts and strikes.
We are sure that, as our customer, you understand the evolving nature of our business due to continuous technological innovation and, although we endeavour to do our best to ensure the protection and privacy of your personal data at all times, we cannot guarantee that the performance of our service will be free from error at all times. Should any such error have an effect or consequence on the privacy of your personal data, we shall not be liable in any manner whatsoever in damages or otherwise.
We may use personal information provided by you in order to conduct appropriate anti-fraud checks. Personal information that you provide may be disclosed to a credit reference or fraud prevention agency, which may keep a record of that information. This is done only to confirm your identity – a credit check is not performed, and your credit rating is unaffected.
We strongly recommend that you do not divulge your personal data to strangers or third parties during live chat. Remember that your personal data is sensitive and it’s important to stop and think before passing on personal information.
11. Log Files
Like most standard website servers, we use log files. This includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the Site, track user’s movement in the aggregate and gather broad demographic information for aggregate use.
12. Data Encryption
All sensitive data which is transmitted between your computer and Dalkin is transferred securely via the internet, using strong encryption. Dalkin uses secure and tested encryption technology bearing certificates provided by renowned certificate authorities.
13. Other security measures
When users submit sensitive information via the Site, their information is protected both online and offline. When our registration form asks users to enter sensitive information (such as a credit card number), that information is encrypted and is protected using Secure Socket Layer– (SSL) technology. While on a secure page, such as our deposit page, the lock icon at the bottom, or in the url, of your web browser becomes locked. The lock icon is unlocked, or open, when users are simply ‘surfing’ and are not inputting sensitive information. All payments made on our Site and Mobile Offer are secured, in compliance with the relevant EU rules and regulations.
While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information offline. All our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only authorised Dalkin employees/contractors are granted access to personally identifiable information. Our employees/contractors are regularly made aware of security best practices within the industry and security audits are carried out on a regular basis. Finally, the servers that store personally identifiable information are in a secure environment.
14. Changes in our Company/Business
Should the Group undergo any changes to its company structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that our customers’ personal data will be included within the sale or transfer. We will, as part of our policy, inform our customers by email prior to affecting such transfer of the personal data.
It may become necessary, at any time, for us to make modifications to the Site and/or Mobile Offer or to the House Rules, Terms and Conditions or Privacy & Cookies Policy governing our services, in any event any changes made will be notified to our users. The purpose of such modifications may be to further simplify user processes or to further reinforce security measures in order to upgrade to future technological innovations. In such cases, customers previously registered on our Site will keep their user name and password; no modifications will be required on their part. Continued use of our Site by the members after any modifications to the Site, Mobile Offer, House Rules, Terms and Conditions or Privacy & Cookies Policy will be considered as their acceptance thereof. It is the responsibility of each customer to regularly check the House Rules, Terms and Conditions and Privacy & Cookies Policy for updates.