This Website collects some Personal Data from its Users. This document describes what data we collect and how we use it.
Personal Data collected for the following purposes and using the following services:
Access to third-party accounts
In case you connect one of the following third party accounts to your 91 Club account, this is the information that we collect. Data collected here is only used for enrichment purposes, to train our anti-fraud system and to prevent service abuse.
- Facebook account access
Account name; Email - Twitter account access
Account name - VK account access
Account name - Google account access
Account name; Email; Profile picture - Instagram account access
Account name - Discord account access
Account name - Steam
Account name, avatar, Steam ID
Voluntarily given: Steam API Key and Steam Trade URL
Analytics, Antifraud and KYC/AML
This is the information we collect from you by simply logging in to your account. Data collected here is used for enrichment purposes, to train our antifraud system, to prevent service abuse but also to comply with the legal requirements of the current legislation (for example, to monitor and prevent money laundering).
- Google Analytics
Cookies, Device data, Analytical data, Usage data
View the full Google Privacy Policy here - Seon
Transaction data, Device data, Geolocation data, Analytical data, Cross References and more.
View the full SEON Privacy Policy here - IPQS
Browser and device information; Various types of Data as specified in the privacy policy of the service - SumSub
Device Data, Geolocation data, Personal information according to the verification Tier you are choosing and more.
View the full SumSub Privacy Policy here
Displaying content from external platforms
- Google Fonts
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service - Gravatar
Personal Data: email address; Usage Data
Handling payments
- Fireblocks
- Unlimint
- Kinguin
Hosting infrastructure and DNS management
- Amazon Web Services (AWS)
Personal Data: various types of Data as specified in the privacy policy of the service - Cloudflare
Personal Data: Cookies; various types of Data as specified in the privacy policy of the service
Managing contacts, CRM, and marketing
- Sendgrid
E-mail address and more
View the full Sendgrid Privacy Policy here - FastTrack CRM
E-mail address, Device data, Geolocation data, Analytical data
Managing support, contact requests, and communication
- Intercom
Registration data, Device data, Service data, Third party data and more.
View the full Intercom Privacy Policy here
External Game Providers
- Hub88
IP Address, Country, Device Information - Pragmatic Play
IP Address, Country, Device Information, Geolocation data - Evolution Gaming
IP Address, Country, Device Information Geolocation data - No Limit Gaming
IP Address, Country, Device Information Geolocation data
Registration and authentication
- Steam
Registration and authentication provided directly by this Website
- Direct registration
Personal Data: Cookies; email address; password; User ID; username
Social features
- Public profile
Personal Data: picture; username
SPAM protection
- Google reCAPTCHA
Personal Data: Cookies; Usage Data
Traffic optimization and distribution
- Cloudflare
Personal Data: Cookies; various types of Data as specified in the privacy policy of the service
Further information about Personal Data
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Website to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
KYC information
According to AML laws and regulations, KYC documents and user submitted data are required to be kept for a period of minimum 5 years from the end of the relationship or from the completion of the occasional transaction.
This includes but is not limited to information provided in the verification forms, all of the verification documents and information submitted by the user or any other written correspondence with the user.
Sharing of Information
We may also share personally identifiable information and non-personally identifiable information externally with other entities for the purpose of preventing fraud or malicious intent in regards to payments, chargebacks, exploits, etc. Such entities can be our payment providers, their acquiring banks, our competitors, government entities or regulators, or any other third party service provider we have a working relation with.
Additionally, personal data may be shared with ESIC in accordance with an Information Exchange Agreement between 91 Club and ESIC.
ESIC shall be permitted to use the shared information in connection with its integrity related investigations and prosecutions if it deems necessary.
Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities (e.g. a court or a government agency).
Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Website may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Website adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Website, Users can check the relevant sections in this document.
Personal Data collected through sources other than the User
The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Pseudonymous use
When registering for this Website, Users have the option to indicate a nickname or pseudonym. In this case, Users’ Personal Data shall not be published or made publicly available. Any activity performed by Users on this Website shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on this Website, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.
Push notifications
This Website may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Website, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Website.
Push notifications based on the User’s geographic location
This Website may use the User’s geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Website.
Push notifications for direct marketing
This Website may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Website).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Website or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Website.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Data deletion
Users can request account data deletion by contacting Live Support or by e-mailing us at [email protected].
Upon account deactivation, personal data will be deleted, but some identifying information will be kept for a minimum of 5 years according to our anti money-laundering policy.
Please note that requesting the deletion of an account in order to bypass restrictions and limitations, or in order to create a duplicate account with the same identifying information is not allowed.
Contact information
Owner and Data Controller
The 91 Club is owned and operated by Perfect Storm B.V (registration number 150536) – Korporaalweg 10, Willemstad, Curaçao. “
91 Club is licensed and regulated by the Government of Curaçao, operating under license #8048/JAZ2021-088. It has passed all compliance regulations and is legally authorized to conduct gaming operations for all games of chance and wagering.
Payments and operational support services are handled by Nine Yards Limited (registration number HE407807) – Voukourestiou 25, Neptune House, 1st Floor, Flat 11, 3045, Limassol, Cyprus.