Midnight Wins Privacy Policy

Personal data collected

Midnight Wins may collect the following categories of personal data when users access the online services and create or use an account:

• Identification details, such as name, date of birth, nationality and verification documents
• Contact information, such as address, e-mail address and telephone number
• Account details, such as username, password, security questions and preferences
• Gambling and betting activity, such as games played, stakes, wins, losses and session details
• Payment and financial information, such as card or account details provided to payment processors, deposit and withdrawal history
• Technical data, such as IP address, device identifiers, browser type, operating system and log data
• Communication records, such as live chat logs, e-mails, support requests and complaints
• Information required for safer gambling, identity checks, fraud prevention and anti-money laundering controls

These data are collected to:

• Provide and administer online gambling services
• Verify identity and age
• Meet legal and regulatory duties in the United Kingdom
• Prevent fraud, money laundering and other unlawful activity
• Support safer gambling measures
• Maintain and improve the websites, platforms and user experience

Technical and organisational protection measures

Midnight Wins applies technical and organisational measures appropriate to the nature, scope and risks of the processing of personal data, including:

• Encryption of data in transit using suitable protocols
• Access controls based on roles and need-to-know principles
• Secure password and authentication procedures
• Regular security monitoring and logging of system access
• Segregation of data, backup routines and tested recovery procedures
• Staff training on data protection and confidentiality duties
• Careful selection and oversight of third-party service providers handling information

No internet-based service can guarantee absolute security, but Midnight Wins aims to maintain a level of protection that is appropriate to the risks.

User rights

Under United Kingdom data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018, users have the following rights in relation to their personal data, subject to legal limits:

• Right of access to a copy of personal data held and information about its use
• Right to rectification of inaccurate or incomplete personal information
• Right to erasure of personal data in certain circumstances
• Right to restriction of processing in defined cases
• Right to object to certain types of processing, including direct marketing
• Right to data portability in some cases, to receive data in a structured, commonly used and machine-readable format
• Right to withdraw consent where processing is based on consent, without affecting previous lawful processing
• Right to lodge a complaint with the Information Commissioner’s Office (ICO) in the United Kingdom

Requests can be made using the contact details provided on the websites. Proof of identity may be required before responding. Midnight Wins confirms that its handling of personal information aims to comply with United Kingdom data protection laws and applicable gambling regulatory requirements.

Purposes and legal bases

Personal information is processed only when there is a lawful basis and for specified, legitimate purposes. Uses of data include:

• Operating user accounts, enabling log-in and providing customer support
• Processing deposits, bets, wagers, withdrawals and account adjustments
• Carrying out identity, age, affordability and source-of-funds checks
• Monitoring play and behaviour to support safer gambling tools and interventions
• Meeting legal, regulatory and licensing duties, including anti-money laundering and counter-terrorist financing obligations
• Preventing, detecting and investigating fraud, abuse, security incidents and breaches of terms
• Providing service messages, transactional notices and changes to terms and policies
• Improving the performance, security and usability of the online services and websites
• Conducting analytics and statistics to understand how users interact with the services and to develop new features
• Providing, subject to consent or legitimate interest where permitted, marketing communications about products and services, including personalisation and profiling related to user preferences, activity and behaviour

Processing may be based on one or more of the following grounds:

• Performance of a contract for the provision of online gambling services
• Compliance with legal and regulatory obligations
• Legitimate interests of Midnight Wins in operating and protecting its business, provided such interests are balanced against the rights of users
• Consent, where required for marketing, cookies or specific optional features

Transparent and fair processing

Midnight Wins aims to ensure that data collection and use are:

• Limited to what is necessary for identified purposes
• Accurate and kept up to date where appropriate
• Kept for no longer than required for regulatory, legal and operational reasons
• Handled in a manner that respects confidentiality and data protection rights

Information about particular processing activities may be given at the point of collection or in supplementary notices where appropriate.

How users can access and update data

Users may request access to the personal data held about them, subject to legal restrictions. To do this, a request can be submitted through the contact channels provided on the websites. Reasonable steps may be taken to verify identity before releasing information.

Users can usually review and update core account details, such as contact information and preferences, by logging in to their account settings. For other updates or corrections, users can contact support and provide supporting documents where necessary.

Correction and deletion procedures

If any personal information is inaccurate or incomplete, users can request correction. Midnight Wins will take reasonable steps to check the accuracy of contested data and update it where needed.

Users may also request deletion of their personal data in certain circumstances. Requests will be assessed in line with United Kingdom data protection law and gambling regulations. Some information may need to be retained despite a deletion request, for example:

• To comply with anti-money laundering rules, licence conditions or record-keeping duties
• To establish, exercise or defend legal claims
• To demonstrate responsible gambling and self-exclusion measures

Where full erasure is not possible, data may be restricted or anonymised where lawful and practical.

Security checks and payment processing

By creating an account and using the services of Midnight Wins, users consent to:

• Security, identity and age checks
• Anti-money laundering and fraud prevention checks
• Ongoing monitoring of transactions, play patterns and behaviour for compliance and safer gambling purposes

Payment card and banking details provided for deposits or withdrawals are processed by approved payment providers and financial institutions. These third parties process information as independent controllers or processors, subject to their own security and privacy controls, and subject to applicable law and contract.

The online casino and sportsbook services are intended only for individuals aged 18 years or over who are legally permitted to gamble in the United Kingdom. Registration, deposits and betting by anyone under 18 are prohibited.

Midnight Wins relies on information provided by users and on verification checks to confirm age, but it cannot in all cases identify the age of a person who accesses the websites without supporting documents. If it is discovered that personal data relate to a minor, steps will be taken to close any related account and to delete the personal information where lawful and practical.

Parents or legal guardians who believe that a minor has provided personal data or has an account should contact the operator promptly. After appropriate verification, Midnight Wins will:

• Investigate the circumstances
• Close any unauthorised account
• Arrange deletion or anonymisation of the minor’s personal information, except where retention is legally required

Information from age verification checks may be retained where it is needed to demonstrate compliance with legal obligations and licensing duties.

Personal data may be processed in, or transferred to, locations outside the United Kingdom and the European Economic Area, for example where technology providers, payment processors, support teams or other partners are based or host their systems.

By using the websites and services of Midnight Wins and providing personal information, users consent to such international transfers, subject to applicable data protection law.

Where personal data are transferred to countries that do not have the same level of protection as the United Kingdom, Midnight Wins takes steps to protect the information, which may include:

• Using standard contractual clauses or equivalent safeguards approved under data protection law
• Selecting providers that commit to robust privacy and information security standards
• Limiting transfers to what is necessary for the provision of services, compliance checks and other specified purposes

All partners handling personal data are expected to respect confidentiality obligations and to protect information using appropriate technical and organisational measures.

This Privacy Policy is intended to explain how personal data and information are handled when users engage with the online services of Midnight Wins. In some situations, a legal disclaimer or specific terms may clarify, limit or extend the application of certain rules described in this document.

Any disclaimers or additional terms published on the websites, or included in account registration or service-specific notices, form part of the overall legal framework governing use of the services and the processing of information. Where there is a conflict between those terms and this Privacy Policy, the more specific or later version may prevail, to the extent allowed by law.

The provisions described in this section apply when users indicate acceptance of this Privacy Policy and related terms, for example by signing a document provided electronically, ticking an acceptance box, continuing to use the online services after being provided with the policy, or otherwise confirming agreement or accession under applicable law.

Nothing in this Privacy Policy limits any non-excludable rights granted to users under United Kingdom law or removes any duties that cannot be excluded by contract.

Cookies are small text files stored on a user’s device when visiting websites or using online services. Similar technologies, such as pixels and local storage, may also be used for related purposes.

Midnight Wins uses cookies and similar tools to:

• Enable core site functions, such as log-in, session management and security
• Compile statistics and aggregated data about traffic, usage and performance
• Analyse behaviour on the websites to understand how services are used
• Remember preferences, such as language, settings and display options
• Personalise content and features based on account information and user activity
• Support marketing, including measurement of campaign effectiveness and, where permitted, tailoring of messages

Cookies are generally kept for up to 1 year, after which they are deleted or refreshed. Some session cookies may expire sooner when a browser is closed.

Users can control cookies through browser settings, for example by blocking certain types or deleting existing cookies. However, blocking or deleting some cookies may affect the functioning of the websites and the availability of certain features. Additional information on cookie categories and choices may be provided in a separate cookie notice.

By accessing or using the websites and services of Midnight Wins, creating an account, or providing personal data, users confirm that they have read, understood and accepted this Privacy Policy, as updated from time to time.

The version of the Privacy Policy published on the websites at the time of use is the version that applies. If the policy is updated, the revised document will replace previous versions for future processing and continued use of the services after the update will be treated as acceptance of the current policy, where permitted by law.

Users who do not agree with the handling of personal information described in this document should not use the online services or should stop using them and request closure of their account.

Sharing of personal data

Personal information may be shared with third parties in limited circumstances, such as:

• Where required by law, regulation or a court or regulatory order
• Where necessary to comply with licence conditions or requests from gambling regulators or law enforcement bodies
• To payment providers, banks and financial institutions for handling deposits, withdrawals and fraud checks
• To identity verification, credit reference and anti-money laundering service providers
• To analytics, security and hosting providers that support the operation of the websites and services
• To advisers, such as lawyers, auditors and consultants, where needed for legal, compliance or business reasons
• In relation to disputes, chargebacks, claims or enforcement of agreements

Details of key third-party categories and partners may be listed on the websites or provided on request. Where specific third parties are not listed, users will be informed of the purpose and scope of sharing where required by law.

Responsibility of third parties

Each third party handling personal information is responsible for its own privacy practices and compliance with applicable data protection law. Midnight Wins uses reasonable efforts to select partners that protect personal data and enter into suitable contracts where required, but it does not control how independent controllers use data once it has been lawfully shared.

By providing personal information and using the services, users consent, where such consent is required by law, to the sharing and processing of their data for the purposes described in this Privacy Policy and any related notices.

The websites and online services of Midnight Wins may contain links to third-party websites, platforms or services that are not operated or controlled by the operator.

If users follow a link to another site, that third party’s privacy policy and terms will govern how personal data and other information are collected, used and stored on that site. Midnight Wins is not responsible for, and does not endorse, the privacy practices, content, security or services of external websites.

Users are encouraged to:

• Review the privacy policy, cookie notice and terms of any third-party site they visit
• Consider how their personal data, payment information and behaviour data may be collected and used by that third party
• Exercise caution before providing personal information, making payments or sharing account details on external websites

Use of any third-party site is at the user’s own risk, and this Privacy Policy applies only to the services and websites operated under the Midnight Wins brand.