1. Subject matter of Data processing.
1.1 Casinò Lugano collects and processes the following personal data:
- 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
- data provided while making transactions to deposit sums and withdraw winnings: banking, economic/financial data
- 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)
- 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.
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:
- Swiss Gaming Act
- Swiss Gaming Ordinance (OGD)
- FDJP Casinos Ordinance
- Federal Act on Combating Money Laundering and Terrorist Financing (AMLA)
- Federal Casinos Commission Ordinance on Gambling Due Diligence Requirements for Combating Money Laundering and Terrorist Financing (ORD-SFGB)
- Communications and Directives by the Swiss Federal Gaming Board (SFGB)
Casinò Lugano will process Users' personal data for the following purposes:
- User's registration and identification for opening the player account and access to Casino games (articles 47 - 49 OGD)
- User registration, identification and financial verification (determination of the Beneficial Owner ) for anti-money laundering purposes (articles 3, 11 ORD-SFGB), in addition to the clarifications, communications and surveillance activities referred to in Articles 9, 12, 18 ORD-SFGB and the management of the relative documentation (art.21 ORD-SFGB)
- prevention of ludopathy and excessive gambling, applying social measures plan (articles 76 - 82 LGD, articles 81 - 91 OGD)
- fulfillment of legal and contractual obligations and protection of Casinò Lugano's rights such as, for example, prevention of improper use of the Website, investigations of possible violations against Casinò Lugano, exercise of the right of defense in court.
- statistical studies, trend analysis and market research.
2.2 Only with the User’s specific and distinct consent, Casinò Lugano will process his personal data for the following purposes:
- awarding of points, prizes, invitation to tournaments, events and competitions
- 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 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:
- game platform providers (online game management)
- IT infrastructure providers (cloud-based services - software storage or hosting; and telecommunication services - chat, sms, telephone)
- payment service providers to carry out gaming transactions (win and/or loss management service, deposits, withdrawals, bonuses and/or promotions).
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.
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 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 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 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
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 Stauffacher 1, CH-6901 Lugano
by sending an email to: [email protected]
by calling the number: 0919737111.
For further information on data protection, Casinò Lugano has appointed the Personal Data Protection Officer who can be contacted at the email address: [email protected]
If applicable, any changes will be notified to Users also through direct notice on the Website or communication via email.
These Terms and Conditions are published in different languages for information purposes and to facilitate User orientation. However, in the event of discrepancies between these T&C in other languages and the Italian version, the latter remains binding for both contractual parties.
Date: 4 February 2021