This Privacy Policy is last updated on August 16, 2019

This Privacy Policy describes the way in which FortuneJack deals with the information and data you provide to us to enable us to manage your relationship with FortuneJack.

We will process any personal information provided to us or otherwise held by us relating to you in the manner set out in this Privacy Policy. Information may be provided via the FortuneJack Website (the "Website"), telephone calls or any other means.

By accepting this Privacy Policy you agree that you understand and accept the use of your personal information as set out in this policy. If you do not agree with the terms of this Privacy Policy please do not use the Website or otherwise provide us with your personal information.

References in this Privacy Policy to “FortuneJack” (hereinafter referred as “We”, “us” or “our”) shall mean FortuneJack.com (the “Website” or “Site”) operated by Nexus Group Enterprises N.V., a limited liability company registered and established under the laws of Curaçao with registration number 139781. Nexus Group Enterprises N.V. is licensed by AntillePhone N.V. We offer and provide Internet-based and/or web-based mobile version interactive gaming services (hereinafter referred to as the “Gambling Service” or “Services”.) We control the ways your Personal Data is collected and the purposes for which your Personal Data is used by FortuneJack, acting as the “data controller” for the purposes of applicable data protection legislation.

• We protect, according to strict standards of security and confidentiality, all non-public personal information we collect about our customers;
• We maintain physical, electronic and organizational safeguards to protect this information;
• We require any party providing products to us or our customers on our behalf to protect the confidentiality of this information;
• We permit only authorized employees and contractors, including but not limited to Support and Fraud team to have access to non-public information of yours;
• We afford former customers the same protections as existing customers with respect to the use and sharing of their information;

Your Personal Data isn’t just protected by the quality, commitment and high standards of FortuneJack, it’s also protected by law. We can only process your Personal Data when there is a genuine reason to do so and it must meet one of the following:

• contractual relationship
• legal obligation
• your consent to process
• our legitimate interest
• public interest
• your vital interests

When We have a business or commercial reason to process your Personal Data this is referred to as a legitimate interest. Your Personal Data is still protected and We must not process it in a way that would be unfair to you or your interests.

If We do use legitimate interests as a reason to process your Personal Data We will tell you that We are doing so, what our legitimate interests are and provide you with a method to raise any questions or objections you may have. However, compelling grounds for processing such information may over-ride your right to object.

Considering legal obligations undertook to fulfill the contract signed between us and the customers, including and not limited to the legal obligations undertook to comply with laws or regulations that apply to us, and for to be efficient about how We fulfil our legal and contractual duties, We process your Personal Data in order to:

• Manage customer relationship
• Develop and manage our brands, new and existing products and Services for our customers, grow our business
• Create, develop, send and review marketing
• Learn from our customers’ behavior in relation to our product and Services
• To provide support for our products and Services
• To test new products, systems or Services
• To compare and manage our relationship with and the performance of other companies that provide Services to us and our customers
• Deliver quality products and Services to you
• Manage customer accounts, winnings, losses, payments and withdrawals
• Investigate, resolve and respond to any customer complaints
• Prevent and detect improper use of our systems
• Prevent crime happening
• Detect, investigate and report crime
• Managing risk for us and our customers
• Complying with any laws and regulations that apply to us
• Ensure corporate governance and compliance to all legal and regulatory obligations
• Fulfil our obligations as an accountable and responsible organization
• To exercise our rights set out in agreements or contracts

Internal reporting

If you choose not to provide your Personal Data it may prevent us from meeting legal obligations, fulfilling a contract, or performing Services required to run your account. Not providing your Personal Data may mean We are unable to provide you with products or Services.

The information and data about you which We may (Please, note that the scope of the information provided below is not mandatorily collected/stored/used/processed by us, FortuneJack reserves a right to collect/store/use/process data in certain cases when necessary for the various purposes stated in this Privacy Policy) collect, store, use and process may include but not exceed the following:

1.Personal Information:

1.1.  Account details: when you open an account and register to use the Services, you may be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth data, physical address, ID number, phone number, occupation, etc. In addition, We may collect certain information as required under various KYC and Anti-Money Laundering (AML) regulatory requirements, such as your source of funds, identity, connection to criminal authorities, utility bill copies and etc.

1.2.  Governmental-issued ID or Passport: in certain instances, you will be required to provide a copy of a governmental-issued ID or Passport, for identity verification process. Please, note that this information is required for certain features of our Services.

1.3.  Gaming information: in order to provide the Services, We may automatically record different information related to your account and use of our Services, including, with respect to your transactions, wallets, deposits, balances, bets, winnings, bonuses and withdraws.

1.4.  Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the live chat with the support team or the game chat (e.g. Dice game).

2.Non-personal Information:

2.1.  Log-in history and technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, We collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the Website from which you linked to the Services; etc.).

2.2.  Gameplay information: We record gameplay information including, which, amongst other things, may include information regarding your deposits, crypto-wallet balances, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms using your nickname or initials in cases if the user wins a sum worthy of publicity.

2.3.  Device and connection information: If you download the Software to your device, We may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, We may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, AI, etc.) or checking if the connection you are using is via a VPN or proxy.

2.4.  Analytic information: We may collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.

2.5.  Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and We may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

Where it is reasonable for us to do so and not detrimental to your rights and freedoms, We may also collect Personal Data from publicly available sources such as internet searches, social media or broadcast media.

Whenever your data is kept by FortuneJack We will ensure that it is appropriately protected and only for acceptable purposes.

We will keep your data for the period that you are a customer of FortuneJack. If you are no longer a customer of FortuneJack, We will keep your data for 10 years as required to comply with the purposes set out in this policy. Your personal records will be kept even if the customer account is blocked/deactivated/deleted/otherwise no longer active or cannot be deleted for technical reasons.

When necessary for the following purposes, We may share your Personal Data within the FortuneJack group and with other organizations stated below:

• Law enforcement agencies, regulators and other authorities
• Credit reference agencies
• Fraud prevention agencies
• Identity verification agencies
• Organizations that introduce you to us
• Third parties you ask us (or permit us) to share your data with
• Third parties necessary to provide products or Services which you have requested

The Site may use your Personal Information, including, but not limited to your name, email address or telephone number, ourselves or by using our third-party subcontractors/affiliates/game providers/joint marketing partners/business partners for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to you or interest you.  

• We may share and disclose said Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which We, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
• We may share any Personal information We collect from and about you with non-affiliated third parties. Information may be shared with or collected by third party service providers who provide us with Services such as information processing (e.g. under AML or KYC policy adopted by our Website and etc.). We require these providers to exercise reasonable care to protect your Personal Information and restrict the use of the data provided to the purposes for which it was provided to them.  

Your personal information may be transferred between the countries and disclosed to other companies within associated or subsidiary companies and to business partners, or successors in title to our business.

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information We collect online. These safeguards vary based on the sensitivity of the information that We collect and store.

We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

• Secure network topology, which includes intrusion prevention and Firewall systems;
• Encrypted communication;
• Authentication and Access Control;
• External and Internal audit tests, etc.

Although We take reasonable steps to safeguard information, however, due to the design of the Internet, We cannot be responsible for the acts of those who gain unauthorized access, abuse the Services or hacking and We make no warranty, express, implied or otherwise, that We will prevent such access.

The Site may contain hyperlinks to other websites that may have information policies and practices that are different from ours. The fact that We have provided a link to a site is not an endorsement, authorization, sponsorship, or affiliation by us with respect to such site, its owners, or its providers. Links to other websites are provided only as a convenience to you. We are not responsible for the content, validity, privacy policies or reliability of any website linked to this Site that is not within our family of properties. There are risks in using any information, products, software or Services found on the Internet, and you should make sure that you completely understand these risks before using, relying upon, or purchasing anything via the Internet.

Telephone or video calls to and from our Support office are recorded for KYC, training and security purposes along with the resolution of any queries arising from the Service you receive.

The Website uses cookies to deliver a better and more personalized Service to users.

Cookies are small text files containing minimum amounts of information which are sent to and stored on your computer, smartphone or other device when you access a Website. Cookies are then sent back to the originating Website on each subsequent visit or to another website that recognizes that cookie.

Cookies are generally used to improve and enhance the user experience. Some of the cookies We use are essential for the Website to operate.

FortuneJack’s use of cookies on the Website falls into the following categories:

• Session Management
• Functionality
• Fraud Prevention
• Tracking
• Analysis

Third party advertising companies/affiliates, that work with us, may also use cookies and related technologies to collect and store Information to provide you with advertisements that are likely to interest you.

You can find more information about cookies at www.allaboutcookies.org.

We will assist you if you choose to exercise any of your rights over your Personal Data, including:

• Withdrawing your previously granted consent (however, this will not invalidate any information processed under your previous consent)
• Lodging a complaint with any relevant Data Protection Authority
• Access to your Personal Data that We hold or process
• Correction of any Personal Data that is incorrect or out of date
• Erasure of any Personal Data that We process
• Please be noted, that upon your request We can delete any Personal Data after the account is blocked/deactivated/deleted/otherwise no longer active, except email and mobile number. We reserve the right to keep the email and mobile number to avoid unlawful registering using the same email and mobile number, even though, standalone email and/or mobile number is not considered as Personal Data
• Personal Data cannot be deleted when the account is temporarily suspended upon your request. We reserve the right to keep the Personal Data in order to match the information when the account is pending to be reopened.
• Asking us to provide you or another company you nominate with certain aspects of your Personal Data, often referred to as “the right to portability”
• The ability to object to any processing data where We are doing it for our legitimate interests
• The ability to contest a decision made entirely by automated processing, to express your point of view and to request that a human review the decision

For more information on these rights you can contact support@fortunejack.com

The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you. In the event that We become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us.

Over time, it may be necessary to modify or supplement our Privacy Policy. When We make changes, We will post the changes to our Websites and change the date at the top of the policy. The amended Privacy Policy will be effective upon posting on the site. We encourage you to visit our Website from time to time to review our Privacy Policy in the event it has changed. Your continued provision of information to us or use of our Websites following the posting of changes to the Privacy Policy means that you accept the changes and our use of your Personal Information in accordance with the revised Privacy Policy. If any material changes are made to this Privacy Policy We will use reasonable endeavors to inform you in advance by email, notice on the Website or other agreed communications channels.

Additionally, in relation to the Privacy Policy, We reserve right to amend, modify, update and change any of the terms and conditions of the Privacy Policy from time to time and you may be required to accept such changes to the Privacy Policy in order to continue using the online Services and products.

We will communicate the changes to you in advance, giving an appropriate amount of time for you to consider and understand the changes before they become effective. We will not enforce material changes to the Privacy Policy without your express consent. If you decline to accept the changes to the Privacy Policy, or otherwise do not accept the changes within the time period, We may not be able to continue to provide some or all products and Services.

Your use of our Site constitutes your acceptance of automatic use of cookies according to this Privacy Policy. This Privacy Policy is an integral part of Website’s Terms and Conditions and can be fully enforced as the Terms and Conditions are accepted by registering on our Website.

If you have any concerns, or would like more detail about how We process your Personal Data, you can contact us at support@fortunejack.com