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Privacy Policy

This Privacy Policy describes Jettogg Limited policies and procedures on the collection, use, and disclosure of Your information (including personal data) when You use the marketplace styled marketing platform created for informational purposes through the website https://jokerclub.win (hereinafter the "Website"), and/or other Our services and tells You about Your privacy rights and how the law protects You.

This Privacy Policy is an integral part of the Terms of Use.

The information You provide is jointly collected and processed by Jettogg Limited, a company registered under the laws of Hong Kong under the registration number 76280610 with the registered address at: No. 5, 17/F, Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong providing access to the Platform.

We assure You that We take all measures necessary to ensure the confidentiality of the personal data that You provide to Us.

We encourage You to carefully read this Privacy Policy. By registering on the Website, You fully and unconditionally agree to its terms. Should You disagree with any part of this Privacy Policy, You will not be authorized to receive our Services and must cease using this Website immediately.

Definitions

For the purposes of this Privacy Policy the terms have the following meanings:

  • Account means a unique account created for You to access Our Service or parts of Our Service.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Jettogg Limited, a company registered under the laws of Hong Kong under the registration number 76280610 with the registered address at: No. 5, 17/F, Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong. The Company acts as the Data Controller.
  • Data Controller refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Website such as a computer, a cell phone, smartphone or a digital tablet.
  • Personal Data means any information that relates to an identified or identifiable individual. For the purposes of the present Privacy Policy, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  • Service refers to the services provided by Us to You.
  • Service Provider means any natural or legal person who processes the Personal Data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing how the Services are used. For the purpose of the PDPO, Service Providers are considered “Data Processors”.
  • Usage Data refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
  • Website refers to the website accessible via https://jokerclub.win.
  • You means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. You can also be referred to as the “Data Subject” or as the “User” as You are the individual using the Services.
  • Cookies means small files that are placed on Your computer, mobile device, or any other device by a website, which contain the details of Your browsing history on that website.
  • Payment System Provider is a company that provides online services for conducting electronic payments.

Collecting and Securing Your Personal Data

What types of Personal Data are collected:

While using Our Service, We may ask You to provide Us with certain personally identifiable information (Personal Data) that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

1. For individuals:

  • First name and last name;
  • E-mail;
  • Phone number;
  • Full Address (State, Province, City, Street, ZIP/Postal code);
  • Passport/ID document details;
  • Picture with a passport/ID document;
  • Payment card details (of the card that is used for making deposits).

2. For legal entities:

  • Company name, number and registered address;
  • Company structure chart;
  • Directors’ and Shareholders data;
  • License information.

Furthermore, while You're using the Service, Your Usage Data is collected automatically. Usage Data includes such information as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique Device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through the Device.

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. However, We shall strive to use all legally and commercially acceptable means to protect Your Personal Data.

Use of Your Personal Data

1. The information You provide to Us

1.1. Cookies

Like most websites, We use Cookies.

Some Cookies are necessary for the normal operation of the Website and are used without obtaining Your additional permission. These files include the following:

  • Cookies needed to identify the source from which the transition was made to the Website;
  • Cookies containing Your session ID on the Website.

We also collect and process data about Your device, including the IP address (Internet Protocol address), browser type, browser version, browser configuration (hereinafter the "Usage Data").

We respect all applicable registration and allow you to manage your preferences and You have control over the optional cookies that we use.

1.2. Email Address for Registration

When registering on the Website, We ask You to provide Us your email address.

1.3. Full Registration

If You prefer to register on the Website using all opportunities of the Website, You provide Us with access to Your name, phone number and email address.

1.4. Payment Details

When crediting an Account in Joker Wallet, Our partners (technical platforms, financial institutions or Payment Service Providers) receive and process information containing Your payment details, including the bank card number, information on the credit/financial institution and/or the issuer, and other data depending on the means of payment, as well as Your first and last name. Also, upon the request of the Payment Service Providers, We may request additional information.

Payment Service Providers process such information during the period of Your use of the Company's services and delete it upon achieving their processing goals, unless the law requires or allows for the establishing of a longer period for the storing of such personal data.

A prerequisite for Our cooperation with Payment Service Providers is that they fulfill the requirements of personal data protection laws. Therefore we may conduct verification procedures.

1.5. Verification Documents

As part of verification, We request You to provide:

  • a photograph of Your passport or ID-card;
  • a photograph of Your bank card/screenshot of Your e-wallet;
  • a photograph of You with the documents specified above in Your hand.

In order to comply with laws aimed at countering the legalization of illegally obtained funds, the Company may require You to submit additional documents, such as:

  • a utility bill;

1.6. Website Activity Data

We collect and store data on Your activity and other actions on the Website, as well as information contained in web server reports (including the interface language, browser type, and date and time of the last visit).

1.7. Promotion Winners

If You become a winner in Our promotions, We may ask You provide Us Your first and last name, address, and phone number, so We can send You a prize if applicable to a specific promotion.

1.8. Questionnaires

From time to time, We may ask You to fill out questionnaires in order to improve Our quality of service, for statistical purposes, or to comply with applicable laws.

Sometimes when filling out a form You will be asked to provide Your name and email address.

1.9. Promotional Gifts

Anytime, We may send You presents or promotional gifts in order to promote our services. In such cases, You will be asked to provide Us Your first and last name, address, and phone number.

1.10. Support Service Contact

When contacting the Company's Support Service, We ask You to include Your first and last name, and email address.

1.11. AML/KYC Compliance

In order to comply with international legislation aimed at countering the laundering of proceeds from crime (Anti-Money Laundering laws), and adhering to the principle of KYC, We are entitled to ask You for other additional information and data required by law.

We collect and process Your personal data only in the following situations:

  • it is necessary in order to conclude the agreement on the provision of services (Terms of Use) in accordance with Your request and its further execution; or
  • You have given Us Your consent to the collection and processing of such data, including through the acceptance of the terms of the Terms of Use and the Privacy Policy when registering on the Website; or
  • such collection and processing are necessary in order to comply with the requirements of applicable law; or
  • such collection and processing are in Our legal interests, while We always strive to maintain a balance between Our legal interests and the confidentiality of Your personal data.

Kindly note that in most cases, if You do not provide the necessary information, We cannot provide You with the Service You have requested.

1.12. Communication

To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted Services, including the security updates, when necessary or reasonable for their implementation.

1.13. Marketing

To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

1.14. Business Transfers

We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service Users is among the assets transferred.

1.15. Other Purposes

We may use Your information for other purposes, such as data analysis, identifying Usage Data trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and Your experience.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers, web servers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your personal data may be transferred. We will provide You with notice before Your personal data is transferred and becomes subject to a different privacy policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your personal data if required to do so by applicable law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other Legal Requirements

The Company may disclose Your personal data in the good faith belief that such action is necessary to:

  • comply with a legal obligation; and/or
  • protect and defend the rights or property of the Company; and/or
  • prevent or investigate possible wrongdoing in connection with the using of the Trading Platform; and/or
  • protect the personal safety of Our clients; and/or
  • protect against legal liability.

Disclosure to Third Parties

Third parties to whom We may transfer Your personal data process them on Our behalf and strictly in accordance with Our requirements, instructions, and this Privacy Policy. Such third parties may include:

  • a limited number of Our employees and employees of Our affiliates;
  • professional auditors;
  • professional dispute resolution organizations;
  • payment systems;
  • Payment Service Providers;
  • verification service providers;
  • service providers that significantly affect the performance and operation of the Website.

To verify You and Your payment details, We engage Finchecker SIA, to which We transfer the personal data provided by You.

For more information on the handling of personal data by Finchecker SIA, please see their Privacy Policy: https://finchecker.eu/terms-and-conditions

For promotional purposes, as well as for statistics generation, We provide information that does not contain Your personal data to the following:

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data they collect to track and monitor the use of Our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Zendesk

Zendesk is a service (system) that tracks, prioritizes, and executes tickets assigned to requests. Therefore, if You contact Our Support Service, the Zendesk service gets access to the personal data You provided upon request.

For more information on the privacy practices of Zendesk, please visit the Zendesk Privacy web page: https://www.zendesk.com/company/agreements-and-terms/privacy-policy/

Customer.io

Customer.io is a customer engagement and marketing automation platform that enables businesses to personalize communication with their customers across multiple channels. It focuses on using real-time behavioral data to trigger personalized messages via email, SMS, push notifications, and in-app messages. We use this service with Your previous consent. For more information on the privacy practices of Customer.io, please visit the Customer.io Privacy web page: https://customer.io/legal/privacy-policy

Vendors

With your consent we may transfer your personal details to the Vendors advertised in the Website.

Our partners in such jurisdictions are always bound by contractual obligations to maintain an adequate level of protection of any transmitted data, and We take all possible measures to ensure the confidentiality of the information You provide.

In the event the Company participates in mergers or acquisitions, it may be necessary to transfer Your personal data to Our future partners, and We guarantee the confidentiality of that data.

Protecting technical information

To ensure the security of the information You provide, We have implemented special rules and technical measures to protect that information.

We use a Secure Sockets Layer (SSL) encryption system for transmitted data. Accordingly, all operations carried out on the Website are well protected.

Mandatory AML/CTF requirements

In order to conduct verification, affordability checks, and fraud detection purposes, We may transfer Your Personal Data to third parties. For more information about our AML, please, visit AML Policy.

Other legal requirements

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may disclose Your Personal Data in order to defend Our legal rights as well.

Provision of Our Services

We may share Your Personal Data with service providers to enable Us to provide Our Services, such as companies that help Us with technology services, storing and combining data, and processing payments or providing relevant online advertising for Our Services. We may use third-party service providers to monitor and analyze the use of Our Services.

Other requirements

We may disclose Your Personal Data in other cases when being in the good faith belief that such action is necessary provided that You have given Your consent.

Your Personal Data Retention Period

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Personal Data for internal analysis purposes. Personal Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).

Your Rights in regards to Your Personal Data

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

The present Privacy Policy establishes Your right to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your Account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities or Services of the Website.

Governing Law

All aspects related to your Personal Data collection, processing and protection that are not regulated in the present Privacy Policy shall be governed by the current legislation of Hong Kong on data protection (PDPO).

Changes to the present Privacy Policy

We may update Our Privacy Policy periodically in order to comply with the applicable law. We will notify You of any amendments to the present Privacy Policy by posting the new version of the document on Our Website.

We will let You know via email and/or a prominent notice on the Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are also advised to review this Privacy Policy from time to time to be informed about any changes.

Contact Us

If You have any questions about this Privacy Policy, You can contact Our Data Protection Officer at: support@jokerclub.win.