Airport Casino Basel AG
Privacy Policy

Valid from: 01.09.2021

TABLE OF CONTENTS

1. General notes
2. Processing of personal data
3. Processing for other purposes
4. Social measures
5. Data storage
6. Disclosure of personal data
7. Disclaimer
8. Currency and changes

Airport Casino Basel AG (ACB) makes every effort to protect your personal data. The privacy of all persons who visit or use the website www.goldengrand.ch is protected as far as possible within the legal framework.

With this Privacy Policy, we would like to inform you about the collection of personal data when using our website and the related services. Your personal data will be kept confidential and handled in compliance with the Swiss Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection Act (OFADP). The Privacy Policy applies to the gaming platform www.goldengrand.ch, the entire range of games, and all related services.

The Privacy Policy forms part of the General Terms and Conditions and as such is binding. By us-ing the platform, and by opening a user account and with each login with your user account, you give your consent to this Privacy Policy and accept the rules contained therein. Please read it care-fully. 

1. GENERAL NOTES

Personal data as defined in data protection legislation is any information relating to an identified or identifiable natural person, e.g. name, address, email addresses, etc. 

‘Processing’ means any handling of personal data, regardless of the means and processes used, in particular the acquisition, storage, use, reworking, disclosure, archiving or destruction of data, whereby ‘disclosure’ means making personal data accessible, such as granting access, forwarding or publishing. 

If you have any questions or complaints regarding the processing of your personal data, please contact the data controller by email. 

1.1 Responsible body

Airport Casino Basel AG, Flughafenstrasse 225, 4056 Basel, Switzerland

E-mail: [email protected]

Website: www.goldengrand.ch

1.2 Rights of data subjects

In accordance with the law, the data subject may exercise the following rights with regard to per-sonal data concerning them: 
 

• Right to information concerning their personal data,
• Right to restrict the processing of their personal data,
• Right to object to the processing of their personal data,
• Right to rectification/correction or deletion of their personal data,
• Right to data portability of their personal data (or surrender thereof).

To exercise your rights, please contact us at [email protected]. We may require proof of identity to process your request. 

1.3 Basis for the processing

The processing of personal data is carried out in compliance with the principles of Art. 4 f. FADP. The data is only processed within the legally justified framework for permissible data processing pursuant to Art. 12 FADP. This covers, among other things, user consent; processing for the provision of the services offered; processing in order to comply with the legal obligations applicable to ACB; or processing in pursuit of the legitimate interests of ACB, a third party or the public, insofar as that this does not override the legitimate interests of the user in the individual case. 

ACB pursues legitimate interests in data processing with regard to, among other things: (1) optimising and improving the services offered; (2) tracking and mitigating abuse on its websites, within the scope of its services; (3) fulfilling contractual agreements and legal obligations; and (4) advertising and marketing activities. 

1.4 Specific legislation on casinos

As a casino, ACB is subject to the following laws and ordinances on gambling, which legally pre-scribe and justify the collection and processing of personal data: 
 

• Federal Act on Gambling (BGS)
• Ordinance on Gambling (VGS)
• Ordinance of the FDJP on Casinos (FDJP, SPBV-EJPD)
• Federal Act on Combating Money Laundering and the Financing of Terrorism (Anti-Money Laundering Act, AMLA)
• Ordinance of the Federal Gaming Board on the Diligence of Casinos in Combating Money Laundering and the Financing of Terrorism (FGB, AMLO-FGB)

In order to fulfil its legal obligations, ACB processes the following data in particular:  
 

• Online registration and user account data;
• Data on gaming behaviour and financial transactions;
• Data on the personal and financial situation of users; and
• Data on the suspension or gaming restrictions placed on the users.

This data may be disclosed to the supervisory authority and other competent authorities as appropriate.

The user data is transmitted pseudonymised and sent to a data recording system located in Switzerland, which provides the data for the supervisory authority. For the duration of storage, see item Section 5.

In order to comply with legal obligations to combat money laundering and the financing of terrorism, or for the purpose of early detection measures relating to a possible gambling addiction, ACB is entitled to request the user to provide proof of assets, salary statements, or tax documents. The personal data may additionally be obtained via third parties (e.g. public registers, credit agencies, subcontractors).

2. PROCESSING OF PERSONAL DATA

2.1 Data collection when visiting or accessing the website

A visit to the website for information purposes only, without transmitting any information, only leads to the collection of personal data which your browser transmits to our server and which is technically necessary to display the website, optimize the services, and guarantee stability and security. When you visit an ACB website, the system automatically collects information and stores it temporarily in log files. This includes but is not limited to: 
 

• The IP address (which enables the identification of a specific user);
• Date and time of the website visit;
• The operating system; and
• The browser used.

This usage data forms the basis for statistical, anonymous evaluations, including for demographic purposes, which allows us to improve our offers on the basis of trends. 

The data collected may be forwarded to external service providers/contractors (e.g. hosting, con-tent management system) for processing in accordance with the necessary purposes (for web presence).

2.2 Contact details / Creating a user account

If you contact us via one of the contact methods on the website, or if you create a user account, your data will be used to process your registration or answer your enquiry, to manage your user account and for contract-related communication or customer service. A user account is required in order to make use of the services on the website (Art. 47 VGS). 

ACB is legally obligated (Art. 48 VGS) to collect users’ personal data at the time of registration. This includes but is not limited to: 
 

• First and last name;
• Gender;
• Place of residence;
• Date of birth;
• Nationality; and
• Email address.

Users must always keep their personal data up-to-date. The user guarantees that the information which they provide is accurate. Players may be required to provide additional documents for identification purposes or for authentication of details. 

For this purpose, ACB may also request information from third-party databases (e.g. public registers, credit agencies). ACB is legally obligated to verify the information provided by users (Art. 49 VGS). This serves, among other things, to comply with legal obligations pursuant to Art. 3 and 13 AMLO-FGB.

2.3 Money transactions

The websites of ACB offer the possibility of financial transactions. Depending on the payment method chosen by the user, the processing of different personal data may be required. This data is passed on to third parties, namely payment providers, so that transactions can be processed.

2.4 Cookies

When you visit or use our website, cookies or similar technologies such as pixels (hereinafter: ‘cookies’) are used. Cookies are small text files that are stored by your browser on your end device to save certain information. On your next visit with the same end device, the information stored in cookies is sent back either to our website (‘first-party cookie’) or to another website to which the cookie belongs (‘third-party cookie’). This allows the website to recognise that it has already been accessed by the browser on your end device. This information is used for optimal layout and dis-play, according to your preferences. Only the cookie itself is identified on your end device and no further personal data is stored. This is only done with your explicit consent, or if absolutely necessary to ensure that you can use the service which you have accessed.

You can independently adjust the settings for cookies in your browser and, if necessary, generally exclude the acceptance of cookies. Please note: if you disable cookies, you may not be able to use all of the functions on our website.

2.5 User profile/marketing

ACB processes information collected through cookies, log files, clear gifs and/or with the help of third parties to create user profiles and offer corresponding individual or personalised offers. 

A profile contains information about an individual user, such as preferences and activities on the website. Profiles are used, among other things, to customise the experience on the websites and to provide targeted advertising. For example, data is collected on games played, stakes, winnings, services used, events attended, payment transactions, and correspondence. This serves to optimise the services. 

The user account settings can be changed individually. Depending on the settings, personal data may be used for marketing activities via different channels, e.g. email or instant messaging. Con-sent to processing for marketing activities can be revoked or restricted by the user at any time.

ACB reserves the right to publish gambling data (e.g. game results), the user’s first name, the first letter of the user’s last name, and the user’s country of origin on its websites, provided the player cannot be identified either directly or indirectly as a result of the publication of this information. The purpose of publishing such information is to advertise the services offered.

2.6 Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc Ireland Limited (hereinafter: ‘Google’). Google Analytics uses ‘cookies’, which are text files that are stored on your computer and enable analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. If IP anonymisation is activated on this website, your IP address is truncated by Google be-forehand within member states of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and truncated there. On behalf of the operator of this web-site, Google uses this information to analyse your use of the website, to compile reports about website activity, and to provide other services relating to website and internet usage to the website operator.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Information of the third-party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Service: https://marketingplatform.google.com/about/analytics/terms/gb/.

2.7 Social Plug-ins

Our websites use what is known as social plug-ins (‘plug-ins’) from social media networks, in particular Facebook Connect from the provider ‘Facebook’, whose website facebook.com is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. Instagram (Facebook) and Twitter are also used. The data controller for individuals living outside the United States is Twitter Inter-national Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland. 

The plug-in provider stores the data collected about you as a usage profile and uses it for the purposes of advertising, market research and/or tailoring its website to meet your needs. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. 

Via the plug-ins, we offer you the opportunity to interact with the social media networks and other users, so that we can improve our website and make it more interesting to you as a user. For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the privacy policies of these providers. 

3. PROCESSING FOR OTHER PURPOSES

In principle, personal data is only processed for the purposes for which it was collected. Nevertheless, processing may also be carried out for other purposes, insofar as these are provided for by law or there are reasons compatible with the original purposes.

4. SOCIAL MEASURES

ACB also processes personal data for the personal protection of users, in particular if there are signs of a potential gambling addiction. The user may be asked to fill out a questionnaire or provide financial or tax documents in order to clarify the situation. The data generated during use of our range of games, including the profiling of gaming behaviour, is processed in order to identify problematic gaming behaviour and take the appropriate action. It is also used to verify that the user is not listed in a register of persons subject to a gambling suspension. 

ACB is obligated by law (Art. 76 to 81 BGS and Art. 87 to 91 VGS) to take measures and impose gambling suspensions as soon as there is any suspicion of over-indebtedness or excessively risky behaviour. 

The data concerning gambling suspensions is stored in a nationwide register and is processed accordingly under legal obligations. If there is no legal obligation, the processing is carried out on the basis of the legitimate interest in the responsible use of the services.

5. DATA STORAGE

The data will only be stored as long as is necessary to fulfill the purpose, as long as the contractual relationship is in place or until you withdraw your consent or request that we delete it. Legal retention periods are reserved. There is a legitimate interest on our part in processing the contact data in accordance with the legal requirements, for internal review or in accordance with the respective communication request. With the information you provide, you grant permission for us to forward the data required for invoicing both to the institution issuing the invoice and to the institution charged with any debt collection or, in the event of a legal dispute, to the lawyer dealing with the matter as well as to the relevant governmental authorities.

In principle, ACB stores personal data for up to five years after the customer relationship has end-ed. This is to comply with legal requirements and to support the player if needed if they return to the platform. Afterwards, the data is deleted or anonymised so that it can no longer be linked to the person.

For data relating to combating money laundering and terrorist financing (Art. 21 AMLO-FGB), a retention period of 10 years after termination of the client relationship applies. This data includes: 
 

• List of identified players;
• Copies of proof of identity;
• Documents relating to transactions;
• Declarations of the players as beneficial owners;
• Documents with comments on the results of special clarifications;
• Documents containing comments on the risk ratings and risk assessment outcomes; and
• the data collected in connection with the reporting obligation under Art 9 para 1 AMLA.

6. DISCLOSURE OF PERSONAL DATA

Data will only be disclosed in accordance with this Privacy Policy to persons who are authorised to process it and who have undertaken to maintain confidentiality or who are subject to a legal obligation. Otherwise, personal data will only be disclosed to third parties if the data subject has consent-ed to the disclosure.

ACB may also be obligated to disclose personal data due to legal or regulatory requirements and instructions from authorities. This applies in particular if a criminal offence is suspected. In the event of a legal obligation and at the request of legally authorised authorities or law enforcement agencies, we explicitly reserve the right to disclose data.

6.1 Data processing by third parties

The processing of personal data may, by agreement or by law, be entrusted to third parties, provided that the data is processed only in the manner in which the party entrusting the data would be permitted to do; and no legal or contractual confidentiality obligation prohibits this. ACB must en-sure that the third party guarantees data security. Third parties may assert the same grounds for justification as ACB.

ACB works together with the data processors listed below. These are companies which process personal data on behalf of ACB and in accordance with contractual instructions for the provision of services:  
 

• Games providers;
• IT companies for technical support;
• Payment services providers;
• Companies that provide services to detect and combat criminal or unlawful acts of any kind; and
• Companies in the field of marketing (e.g. communication and advertising agencies). 
   

The data is disclosed solely for the purposes for which it was collected, for example to fulfill contractual obligations. 

6.2 Third-party games on the websites of ACB

Third-party games may be provided as part of the services of ACB. Only partners as defined in Section 6.1 who process user data on behalf of ACB are covered by the guarantees of the ACB Privacy Policy. We are not liable for partners who provide their own services on their own behalf. To this extent, ACB cannot accept any liability for the data that may be collected via third-party websites.

The following third-party providers offer games on the websites of ACB: 
 

• Evolution Gaming
• Microgaming
• Greentube
• Gamanza
• iSoftBet

6.3 Transmission of personal data

Personal data is preferably processed within Switzerland, the European Union (EU) and the Euro-pean Economic Area (EEA). Personal data is primarily processed through a data centre in Switzerland and a data centre in the EU. In cases that require transfer of personal data outside Switzerland or the EU/EEA, e.g. for the transfer of personal data to a data processor (or its subcontractors) in a country outside Switzerland or the EU/EEA, the necessary and appropriate legal, technical and organisational measures will be taken to ensure that the level of protection is equivalent to that in Switzerland. When personal data is transferred to a country outside Switzerland, the level of protection is guaranteed either by the Federal Data Protection and Information Commissioner’s List of Countries, or by the fact that the company is linked to Switzerland via the Swiss-US Privacy Shield agreement. Other equally appropriate safeguards include approved codes of conduct in the recipient country, and the application of internal, binding company policies.

7. DISCLAIMER

Access to the ACB website is at the user’s own risk and responsibility. ACB makes every effort to guarantee the secure operation of the website and to protect it from unauthorised access or unauthorised processing of data. However, defects such as data loss or data corruption, virus attack, interruption of operations, etc. cannot be fully excluded. 

In order to protect personal data when communicating with the web browser, ACB uses the encryption technology of a trustworthy certification company. In addition, online transactions are protected by the security system of a globally accredited partner. In addition, all player data is protected from unauthorised access by firewall and intrusion prevention systems.

ACB accepts no liability whatsoever for damage or consequential damage arising from the use of the website or individual parts thereof (e.g. downloaded documents), the use thereof (or the impossibility of access) or links to other websites.

The following measures, among others, are taken: (1) the greatest possible restriction on the group of persons who are authorised to access personal data; (2) restriction of the authorised persons’ ability to make changes; and (3) technical barriers against breaches, including encryption during transmission and storage, firewalls, strict requirements for passwords, and alarm functions with notification of attempted breaches. If possible, data is pseudonymised for the best possible protection of privacy.

8. CURRENCY AND CHANGES

If there are differences between the different language versions for the Privacy Policy, the German version shall be binding. This Privacy Policy may be amended if the website undergoes further development or if there are changes to legal requirements. We reserve the right to amend this Privacy Policy at any time, in compliance with current legal requirements.