Privacy Policy

PRIVACY POLICY

In order to offer a safe, personalized and socially acceptable online gaming experience, protecting and respecting customers and/or visitors (hereinafter, "Users") privacy, Casinò Lugano adopts a privacy policy in accordance with the applicable legislation of personal data protection, in particular the Federal Act on Data Protection and the European Data Protection Regulation (GDPR).

This privacy policy applies to the online gaming website www.swiss4win.ch (hereinafter, the "Website") and to the complete range of games offered and associated services; and provides all useful information to understand how Casinò Lugano collects and processes the personal data of Users who interact with the Website.

1. Subject matter of Data processing

1.1 Casinò Lugano collects and processes the following personal data:

1. data provided to create an online account: name, surname, date and place of birth, nationality, language, gender, domicile/address, telephone, email, copy of a personal document allowing to identify the User; and other personal documentation for the purposes of managing the game account in compliance with the legislative obligations regarding gambling and casinos
2. data provided while making transactions to deposit sums and withdraw winnings: banking, economic/financial data
3. Website activity data: account data (player ID, password), device data (browser data, IP address, browsing history), game transactions (winnings and/or losses, deposits, withdrawals, bonuses and/or promotions)
4. Personal data processed in the context of communications and exchanges between Casinò Lugano and other casinos, carried out for purposes provided for by law.
5. any other information that may be exchanged between the User and Casinò Lugano, in particular, by email and/or live chat, during User registration or while using the Website.

In compliance with the FADP, the personal data processed and stored must be updated. Therefore, in the event that the aforementioned personal data undergoes changes, the User is responsible for updating their data via the appropriate section on the Website or by sending an email to customer service (customerservice@swiss4win.ch).

In the event of changes to the personal data Casinò Lugano becomes aware of through valid and updated documentation, the Casino reserves the right to independently update the same in its own systems, as required by regulatory obligations and in order to ensure the accuracy of the information processed.

2. Purpose and legal grounds for processing

2.1 Without specific User consent, in order to fulfill the legal and regulatory obligations required, in particular the following legal provisions:

1. Swiss Gaming Act
2. Swiss Gaming Ordinance (OGD)
3. FDJP Casinos Ordinance
4. Federal Act on Combating Money Laundering and Terrorist Financing (AMLA)
5. Federal Casinos Commission Ordinance on Gambling Due Diligence Requirements for Combating Money Laundering and Terrorist Financing (ORD-SFGB)
6. Communications and Directives by the Swiss Federal Gaming Board (SFGB)

Casinò Lugano will process personal data, including those worthy of special protection, to protect players from excessive gaming and to fight crime and money laundering (Art. 51 LGD).

2.2 Only with the User’s specific and distinct consent, Casinò Lugano will process his personal data for the following purposes:

1. awarding of points, prizes, invitation to tournaments, events and competitions
2. management of loyalty, marketing and promotion programs, by email, sms and social media

3. Methods of processing and storage of personal data

3.1 Casinò Lugano processes Users' personal data with partially or fully automated electronic tools, taking all measures reasonably necessary to ensure that data are securely processed, in accordance with the Federal Act on Data Protection and the GDPR. Any activities that can produce legal effects or that significantly affect the User, such as decisions based on profiling, always include human intervention and/or a final human decision.

3.2 Users' personal data are stored by Casinò Lugano at the Data Center located in Switzerland and the data center of the gaming platform and of the telecommunication services located in the EU. Limited to the purposes referred to in art. 2.1 lett. b) and c), also following a possible registration of the User in the black lists under Articles 52, 53 LGD (art. 42 OGD, art. 80 LGD), these personal data will be kept for a period of time which is strictly necessary and in any case not less than what is provided for by law. In all other cases, User's personal data will be kept for the time strictly necessary to pursuit the required purposes and, subsequently, safely deleted or, possibly, anonymized for statistical purposes.

3.3 For the purposes referred to in Art 2.2. the User may revoke the consent given for the processing of personal data at any time.

4. Disclosure of personal data

4.1 As part of the service offered and for the purposes indicated above, the User's personal data will be disclosed only to suppliers and partners of Casinò Lugano who have undertaken to sign adequate confidentiality agreements. In particular, Casinò Lugano cooperates with the following Third Parties:

1. game platform providers (online game management)
2. IT infrastructure providers (cloud-based services - software storage or hosting; and telecommunication services - chat, sms, telephone)
3. payment service providers to carry out gaming transactions (win and/or loss management service, deposits, withdrawals, bonuses and/or promotions).
4. telecommunication service providers (service for sending communications by chat, e-mail, sms, telephone)
5. providers of shipping services and delivery of giveaways, prizes and contest winnings acting on behalf of Swiss4win

Casinò Lugano monitors and ensures that each Third Party provides adequate guarantees regarding security, protection and confidentiality of personal data, as well as compliance with the Federal Data Protection Law and the GDPR.

Alternatively, the disclosure of personal data to third parties will take place only with User explicit consent.

4.2 Without explicit consent, User's personal data may be communicated to the administrative or judicial authority on the basis of a request from the same or a legal and/or regulation obligation.

5. Users' rights

Each User can exercise the rights under the Federal Act on Data Protection and if applicable to the GDPR. Specifically, in relation to the processing of its personal data, the User has the right to ask Casinò Lugano for confirmation of the existence or not of a processing of his or her personal data and, in relation to them, he/she can exercise the following rights.

5.1 Right of access

• The User has the right to request access to data to obtain information on the purposes pursued with the treatment, on the recipients to whom the data may be communicated, the duration of processing (where possible) and any consequences of a processing based on profiling.

5.2 Right to rectification and integration

• The User has the right to rectify or integrate its personal data whether these are incorrect or incomplete.

5.3 Right to cancel

• The User has the right to delete its personal data whether they are no longer required by the Data Controller for the purposes of the processing envisaged, are inadequate with respect to the purposes of the processing, the User has revoked his/her consent or the data have been processed in an unlawful way.

5.4 Right to limit processing

• The User has the right to limit the processing of their personal data in specific situations. This may be the case, for example, in which the User disputes the accuracy of personal data or the processing is unlawful and the interested party opposes the deletion of personal data, requesting instead that their use be limited.

5.5 Right to object

• The User has the right to object to the processing of his personal data and, specifically, has the right to object to decisions that concern him/her if based solely on automated processing of his/her data, including profiling.

5.6 Right to withdraw consent

• The User has the right to withdraw consent to the processing of their personal data at any time, without prejudice to the lawfulness of the treatment based on the consent given before the withdrawal. The processing that the Casinò is required to carry out pursuant to the legal rules referred to in point 2.1 above remain reserved.

5.7 Right to data portability

• The User, limited to the data processed in an automated manner, has the right to retrieve their personal data processed by Casinò Lugano in a standard format, in order to transmit them to a third party.

6. Cookies

Cookies are small text files downloaded on User's device when the latter accesses the Website. Cookies allow to simplify and improve the user experience of Users when they interact with the Website; they are used, for example, to track preferences during navigation, pages viewed, average time spent on the Website and other statistics.

The Website uses various types of cookies, each of which has a specific function.

Technical Cookies

• Technical cookies are essential for the proper functioning of the website and to provide the service requested by the User. Technical cookies are used, for example, to make navigation and use of the web faster, display content on the device by recognizing the language or to recognize the country from which the User has connected.

Analytical cookies

• Analytical cookies collect information, usually anonymously, on how users of the website navigate, to see how visitors move around the site and to record the contents that are displayed. This helps us determine how often certain pages are visited and therefore what are the most popular areas of the website.

Profiling cookies

• Profiling cookies are aimed at creating profiles related to the User and are usually used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.

First and third-party cookies

• First-party cookies are created directly from the Website visited by the User and, consequently, only the owner of the Website can consult the information collected. Third-party cookies are, however, installed by a third party other than the owner of the Website with the aim of collecting certain information about the User such as, for example, behavior, preferences, habits and other characteristics.

6.1 Consequences of refusing cookies

• The user can choose whether or not to consent to the use of cookies. However, disabling some or all cookies, could result in the compromise of one or more features necessary to correctly display the information on the website or use some functions intended to improve navigation.

6.2 Cookies management

• Most browsers are set up to automatically accept cookies. The user can change the browser settings in such a way as to block or disable the use of some or all cookies or so that a consent message is presented to the user for the installation of the related cookie.

Here is a list of links that describe how to change cookies settings within the main browsers: CHROME, CHROMIUM, FIREFOX, SAFARI, EXPLORER, OPERA, TOR, SRWARE.

7. Contact information

In case of need and/or question relating to the collection and processing of personal data, as well as for the exercise of Users’ rights, Casinò Lugano can be contacted

• by sending a written request to: Casinò Lugano SA, Via Chiarina Stauffacher-Vedani 1, CH-6901 Lugano
• by sending an email to: info@casinolugano.ch
• by calling the number: 091 973 71 11

For further information on data protection, Casinò Lugano has appointed the Personal Data Protection Officer who can be contacted at the email address: dpo@casinolugano.ch

8. Changes to the terms of this privacy policy

Casinò Lugano reserves the right to modify or simply update the content of this Privacy Policy, in full or in part, also in relation to changes in applicable legislation. The changes are considered binding from the moment they are published on the Site. After publication, access and/or use of the services by the User shall be deemed as acceptance of the new content of the Privacy Policy. Casinò Lugano therefore invites the User to regularly visit this section to be informed of the most recent and up-to-date version of the Privacy Policy and to be always aware of the data collected and the manner, purpose and aim of its processing by Casinò Lugano

Last update: 07.01.2025 – versione 1.6