The purpose of the SLOT.MD platform’s Privacy Policy is to align the policies of S.A. ‘Loteria Națională a Moldovei’ with the requirements of Law No. 133/2011 on the protection of personal data, in order to ensure compliance of the activities related to the organization and operation of gambling games with increased social risk.
This Privacy Policy is intended to inform participants in gambling activities and explains how SLOT.MD collects, uses, and protects their data when the website is accessed and the services provided are used.
We are committed to respecting the confidentiality and security of your information and to providing transparency regarding how it is handled, in accordance with applicable legislation.
By using our services, you confirm that you have read and understood this Privacy Policy. If you have any questions or requests regarding your personal data, you may contact us at datepersonale@slot.md.
We reserve the right to modify and/or update this Privacy Policy at any time, at our discretion or as required by changes in applicable legislation. Whenever we make changes, we will post the updated version on our website, SLOT.MD.
1. Processing of personal data
Personal data is any information that identifies a natural person, either directly or indirectly. A person is considered identifiable when they can be recognized, for example, based on an identification number or elements related to their physical, psychological, economic, cultural, or social identity.
The processing of personal data is usually carried out with the consent of the data subject. The data subject has the right to withdraw their consent at any time.
However, there are situations where consent is not required, namely when data processing is required by law in order to fulfill the controller's legal obligations (e.g., AML, tax, or reporting obligations).
2. Personal data administrator
The administrator responsible for collecting and processing personal data is SLOT.MD, an online gambling platform managed by S.A. "Loteria Națională a Moldovei" (National Lottery of Moldova), which operates in accordance with the provisions of Law No. 291 of 16.12.2016 on the organization and conduct of gambling. The platform is referred to throughout this document as "the Operator" or "we."
2.1 What information do we collect and for what purposes?
The data collected from users varies depending on the purpose of the activities for which it is necessary, being collected directly from users or generated through the use of our services, as detailed in the list below.
2.1.1 Data for registration and use of services
To access our online platform, users must provide essential data such as:
· Identification data: Name, surname, date of birth, age, gender, IDNP, automatically generated user ID, IP address;
· Contact details: Email address and phone number;
· Login details: Username and password;
· Verification documents: ID card, passport, residence permit. All documents issued by the competent authorities of the Republic of Moldova;
· Compliance and regulatory data: Information on politically exposed person (PEP) status.
The data is processed for the entire duration of the contractual relationship, as long as you use our services.
2.1.2 Compliance with legal obligations
In accordance with applicable laws, such as Law No. 308 of 22.12.2017 on the prevention and combating of money laundering and terrorist financing, we collect the following data:
· Identification data: first name, last name, citizenship, IDNP, home/residence address, photo, occupation;
· Document data: type of document (ID card, passport, residence permit), series and number of the document, issuing organization, date of issue;
· Financial data: source of income, payment method, deposit and withdrawal transaction history;
· Contact details: phone number and email address;
· Compliance and regulatory data: information regarding political connections and affiliations and the identity of the beneficial owner.
This data is collected for:
· Player identification and identity verification (KYC);
· Monitoring of suspicious transactions;
· Fraud prevention and protection of the platform against illegal activities.
2.1.3 Personalization of user experience
We analyze your platform usage history to provide you with personalized recommendations, products, and offers tailored to your needs. For this purpose, we use:
· Identification data: details about your user account, including certain attributes used for account management and proper platform operation;
· Contact details: phone number and email address;
· Account activity data: betting history, history of interactions with the website's products and features, as well as the duration of use of the platform, history of bonus use;
· Financial data: deposit and withdrawal transaction history;
· Customer relationship data: conversations with customer support.
Processing takes place on the basis of the consent given at the time of registration.
2.1.4 Conducting marketing campaigns and optimizing marketing strategies
In order to promote our products and services, we run marketing campaigns through various communication channels (e-mail, SMS, phone calls). The content of the messages can be tailored to the interests, preferences, and behavior of users on the platform. In this context, for the planning, execution, and optimization of marketing campaigns, we collect the following categories of data:
· Identification data: first name, last name, player ID, username, gender;
· Contact details: email address and phone number;
· Geographic location data: used to personalize offers and content based on the area from which the user accesses the platform;
· Data on user preferences and interests: history of interactions with platform products;
· Marketing data: responsiveness to campaigns, participation in promotions, use of bonuses;
· Derived data: consolidated and anonymized information, processed for analytical purposes, to evaluate the performance of marketing campaigns (such as interaction level, access rate, or audience structure), as well as to identify general trends in user behavior and preferences
2.1.5 Surveys, market research, and internal analysis to improve products and services
In order to better understand user opinions and continuously improve the quality of the products and services offered, the operator conducts surveys, market studies, and internal analyses. To this end, the following categories of data are collected through surveys in order to gather feedback and inform development decisions:
· Identification data: first name, last name;
· Contact details: email address and phone number;
· Demographic data: age, gender;
· Customer value management data: user opinions about the products or services offered, their expectations and suggestions;
· Marketing and engagement data: survey responses, feedback on campaigns, and preferences.
Participation in these activities is optional. The decision not to provide the requested data or not to take part in surveys or market research will not affect the user's relationship with the operator or access to the products or services offered. However, the absence of certain information may limit the operator's ability to analyze the suggestions received or to customize offers and services according to the user's preferences.
2.1.6 User support and relationship management
In order to provide user support and efficiently manage the contractual relationship, the operator communicates with users by phone, email, online chat, or chatbot. In this context, the following categories of data are processed in order to resolve requests and improve the quality of support services:
· Identification data: first name, last name, IDNP;
· Contact data: email, phone number;
· Customer relationship data: information provided in customer support requests;
· Gaming behavior data: reported gaming habits or limits set at the user's request (daily, weekly, and monthly limits), history of self-exclusion requests, and account breaks/blocks.
2.1.7 Platform functionality
To ensure the efficient use of the platform, certain technical data is processed, including device information and cookie technologies. These enable the proper functioning of the services, the configuration of the interface and the content displayed, as well as the analysis of how the website is used. In this context, the data is used to resolve requests and improve the quality of support services, as well as to optimize the performance of the platform and identify any technical issues. In this regard, the following categories of data are processed:
· Device-related data: device type, operating system, browser type, language preference;
· Account activity data: IP address, history of games accessed and bets placed, history of platform access;
· Information obtained through cookies and related technologies: data is collected on how you interact with the platform, your chosen settings, browsing and usage patterns, as well as aggregated information, without direct identification, used exclusively for the purposes of analyzing and evaluating the performance of the services.
2.1.8 Winnings management
Personal data is used to manage participation mechanisms on the platform, including the recording of bonuses, free spins, and other facilities offered to users, as well as to validate and make payments related to winnings. At the same time, the processing of this information is necessary to comply with applicable legal obligations, including those of a fiscal nature. Thus, in the above context, we collect the following data:
· Identification data: first name, last name, date of birth;
· Financial data: amounts won, deposits, withdrawals, payment method information, applicable tax deductions;
· Account activity data: use of bonuses, betting history, wins/losses, compliance with promotional campaign conditions.
2.2 What happens if you do not provide us with your personal data?
You may choose not to provide us with the requested data; however, this decision may affect the functionality and quality of the services provided. For example, without providing your IDNP, it will not be possible to create an account on the SLOT.MD platform, and without the necessary identification information, we cannot process and release winnings, as they must be correctly and legally attributed to the entitled person. Also, refusing to provide contact details may limit access to offers, promotional campaigns, and information about available bonuses. At the same time, providing incomplete information may affect our ability to ensure the optimal functioning of the platform, personalize the user experience, and provide services tailored to individual requirements, which may impact the overall accessibility and efficiency of the platform.
3. Method of collecting personal data
Information is collected through several channels, including:
4. Disclosure of data to third parties
Your personal data will not be shared with third parties for commercial purposes without your explicit consent, except in the situations detailed below, where the transfer is carried out in a controlled manner and in compliance with applicable law.
· Service providers – partner companies that support us in operating the platform, including:
o National payment providers and IT solutions, including transaction security and fraud prevention;
o Online game providers;
o Digital marketing services (email, SMS);
o User support and relationship management services.
· Public authorities – in accordance with legal obligations, data may be transmitted to state institutions;
· In the event of mergers, acquisitions, or reorganizations – if our business is transferred, the data may be accessed by the new owners, in accordance with legal provisions;
· Anonymized data – we may share statistical information that does not allow personal identification.
All data transfers are carried out in compliance with the necessary security measures to protect your information.
4.1. International data transfers
International transfer takes place when storing and processing data for user support and relationship management, and for winnings management. Data is stored and processed on cloud infrastructures and on foreign partners' own infrastructures located only in European Union member states.
No personal data is transferred to third countries or international organizations outside the European Union, and processing is carried out in accordance with the player's consent and applicable European data protection legislation and standards.
5. User rights
At any time, you have the following rights regarding the personal data we process. Please note that these rights may be limited in certain circumstances, in accordance with applicable legal regulations, except for the right to object to processing for direct marketing and profiling for direct marketing purposes:
· Right to be informed: you have the right to receive clear information about the data controller, the purposes of the processing, and other details relevant to ensuring fair and transparent processing;
· Right of access: you have the right to request detailed information about your personal data and to receive a copy of it;
· Right to rectification: you may request the correction, completion, or deletion of incorrect personal data without undue delay;
· Right to erasure of data ("right to be forgotten"): you have the right to request the erasure of certain personal data. If this request conflicts with our legal obligations or if the data is necessary for the defense of legal claims, we will not be able to comply with the request, but we will inform you accordingly;
· Right to restriction of processing: you have the right to request the restriction of the processing of your personal data under certain conditions;
· Right to data portability: you may request to receive or transfer your personal data in a format that can be read by an automated system;
· Right to object: you may request that the processing of your data be stopped, including profiling, when the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority. You also have the right to object to the processing of data for direct marketing purposes;
· The right not to be subject to a decision based solely on automated processing, including profiling: you will not be subject to an automated decision that has legal effects or significantly affects you, unless it is necessary for the conclusion of a contract or authorized by law;
· Right to lodge a complaint: you have the right to lodge a complaint with the National Center for Personal Data Protection if you believe that the processing of your personal data does not comply with the applicable legal provisions:
Website: https://datepersonale.md/
Email: centru@datepersonale.md
Address: MD-2004, mun. Chişinău, str. Serghei Lazo, 48
Tel.: (022) 820 801
6. Data retention period
Your personal data is stored exclusively for the duration necessary to achieve the purposes for which it was collected, in compliance with the applicable legal provisions and regulations, including those specific to the field of gambling. Depending on the nature of the data and the purposes of the processing, storage periods may vary. The categories of data processed and the corresponding storage periods are presented below:
· Registration, authentication, and KYC documents: in accordance with applicable legislation, such as Law 308/2017, this type of data is retained for the duration of the business relationship. Upon termination of the business relationship or from the date of the last authentication, the data will be retained for 5 years.
· Transactional data: data regarding stakes, deposits, and withdrawals will be retained for the duration of the business relationship. Upon termination of the business relationship, transactional data will be retained for 5 years in accordance with applicable law.
· Marketing data: data used for marketing purposes, including contact details, information on consent and communication preferences, as well as data relating to interaction with promotional messages, is retained for the duration of the user's consent. After withdrawal of consent, data proving consent may be retained for up to 2 years, solely for the purpose of demonstrating compliance with applicable legal obligations
· Data related to support requests: support requests are stored for 120 days and then archived. Tickets remain in the archive for a period of 2 years and are then automatically deleted from our system.
At the end of the retention period, your information will be securely deleted or anonymized. If you wish to stop the processing of your personal data or discontinue our services, please contact us by email at datepersonale@slot.md.
7. Protection of minors
The services and products of the SLOT.MD platform are not intended for minors (persons under the age of 21). S.A. "Loteria Națională a Moldovei" has implemented measures to prevent the intentional collection of personal data from minors. To use our services and products, as well as to communicate with us, you must be 21 years of age or older.
By registering on the SLOT.MD platform, you confirm that you are 21 years of age or older and that you have the capacity to accept, comply with, and be legally responsible in accordance with the terms and conditions set forth in this Privacy Policy. If it is found that a minor has provided us with personal data, it will be deleted immediately.
8. Cookie policy
Cookies are small files that are stored on the user's device when accessing the platform through a web browser. They allow the device used to be recognized, ensure the proper functioning of the platform, and improve the browsing experience. The cookies used can be session or persistent cookies and are classified, depending on the purpose of processing, into categories such as strictly necessary, functionality, analysis, or marketing cookies. The storage period is determined in relation to the role of each cookie and may, in certain cases, be up to 2 years, to the extent necessary to achieve the purposes described below.
8.1. Types of cookies used
Our platform uses different types of cookies, depending on the purpose for which they are needed, as detailed below.
8.1.1. Essential cookies
These cookies are essential for the platform to function and allow access to basic features such as logging into your user account, browsing the site, and using the services offered. Disabling them may result in the inability to use certain key features of the platform.
These cookies are generally session cookies and are automatically deleted when you close your browser.
Examples of use:
· ensuring the correct display of content depending on the device;
· keeping the session active while using the platform;
· remembering the selections made during an active session.
8.1.2. Functionality cookies
Functionality cookies allow the user to be recognized when returning to the platform and retain certain previously selected options or preferences. Their purpose is to facilitate the use of services and provide a personalized experience.
Disabling these cookies does not prevent access to the platform, but may limit the availability of certain features.
Examples of use:
· memorizing user preferences and settings;
· displaying relevant content based on previously selected options.
8.1.3. Analytics and performance cookies
These cookies are used to collect statistical information on how the platform is used and its performance. The data obtained is used exclusively for analysis and optimization and does not allow direct identification of users.
Some of these cookies may be provided by third parties, but the information collected is processed in an aggregated or anonymous form. Users can choose to disable them without affecting the basic functioning of the platform. The storage duration may vary, and cookies can be deleted at any time.
Examples of use:
· analyzing the number of page views;
· evaluating how the platform's features are used;
· improving the overall user experience.
8.1.4. Advertising and personalization cookies
These cookies are used to display relevant advertising content and to evaluate the effectiveness of promotional campaigns. They can track user interactions with the platform and can be used to display personalized ads, including on third-party websites.
The information collected through these cookies is processed in a form that does not allow direct identification of the user. Disabling them does not affect access to the platform, but may result in the display of ads that are not tailored to your interests.
Examples of use:
· personalizing advertising content;
· limiting the frequency of certain ads;
· evaluating the effectiveness of marketing campaigns.
8.2. Cookie management
You can control or change your cookie settings at any time using the options available in your browser. For more information on managing cookies, please refer to the "Help" or "Settings" section of your browser.
By using our services, you agree to the provisions of this Privacy Policy. If you have any questions or requests, please contact us at datepersonale@slot.md.
9. Security measures
To ensure the confidentiality, integrity, and availability of personal data processed through the platform, we implement a set of technical and organizational measures appropriate to the level of risk associated with the processing. These measures are designed to prevent unauthorized access, loss, disclosure, accidental or unlawful alteration or destruction of data, as well as to ensure the continuity and security of operations. The measures applied are reviewed periodically and adapted according to the evolution of risks, legal requirements, and best practices in the field of information security.
In this regard, we apply the following technical and organizational measures for data protection:
· SSL/TLS encryption for data transmission;
· Encryption of stored data (databases);
· Strict access control (two-factor authentication for staff);
· Regular monitoring and auditing;
We also have dedicated internal procedures for managing security incidents, including an incident response plan that sets out the steps necessary to identify, assess, and promptly remedy situations that may affect data security.
In the event of a security incident that may pose a high risk to the rights and freedoms of data subjects, users will be informed within 72 hours, in accordance with applicable legal requirements.
10. Provisions regarding the appointment of the person responsible for data protection
In order to ensure compliance with applicable legislation on the protection of personal data, a data protection officer has been appointed. This person is responsible for monitoring the compliance of processing operations, advising on the application of legal requirements, and mediating the relationship between the controller, data subjects, and the competent authorities.
The data protection officer can be contacted for any requests, clarifications, or complaints regarding the processing of personal data, including the exercise of the rights of data subjects, using the following contact details:
E-mail: datepersonale@slot.md
Address: str. Sprâncenoaia 1, MD-2028, mun. Chișinău, Republica Moldova