Privacy Policy

• This Privacy Policy (hereinafter, the “Policy”) aims to inform you about how Starscream Limited collects and manages your personal data to administer your relationship as a player at Locowin;
• All data processing activities carried out by Starscream Limited comply with EU Regulation (2016/679);
• The company has appointed a Data Protection Officer (DPO). For questions regarding this Policy or to exercise your rights, please contact the DPO at: dpo@starscreamltd.com.

• Access to our website is restricted to individuals who are 18 years of age or older;
• We will verify age using the information provided.

• The terms “Company”, “we”, or “our” refer to Starscream Limited;
• The terms “Player”, “end user”, “you”, and similar refer to any individual who accesses and plays at Locowin;
• “Games” or “Game” refers to the gaming products available on Locowin;
• “Data Controller” is the entity that determines the purposes and means of processing personal data;
• “Data Processor” is the entity that processes personal data on behalf of the Data Controller;
• “Personal data” refers to any information that can identify an individual;
• “GDPR” or “Regulation” refers to the General Data Protection Regulation (2016/679).

• Identity Data: Includes first name, last name, date and place of birth, residential address (city, postal code, country), nationality, identity card or passport reference number, and age;
• Contact Data: Includes username, phone number, postal address, and email address. We collect contact information, details of your gameplay or activity on the website, and your user ID number when you contact our support team;
• Account Limits: You can set limits on your accounts, such as playtime, bets, losses, and daily deposits;
• Financial Data: We may request details such as card number, expiration date, and security code;
• Self-Exclusion: You can choose to self-exclude to restrict your gaming activity or take a break from gaming;
• Account Freeze: You can freeze your account for 24 hours, 7 days, or 30 days. During this period, you will be unable to access your account;
• Know Your Customer (KYC): We collect data, including valid identification, proof of address, bank statements, information about the source of wealth, and political status, to verify your identity in accordance with anti-money laundering and counter-terrorism financing laws. We reserve the right to request additional information if necessary;
• Account Data: This includes activity logs, account balance, gameplay analysis, and technical data, such as your IP address, browser information, and cookies;
• Public Data: Information publicly available through internet searches;
• Marketing Communication Data: Includes your preferences for receiving marketing materials and promotions. You may opt out of receiving these materials without affecting your relationship with Locowin;
• Other Data: We do not collect sensitive data related to racial origin, political opinions, religious beliefs, union membership, health, sex life, or sexual orientation, unless you choose to share this information;
• We will update this Policy if there are changes in the information we collect;
• For inquiries regarding the processed data, please contact our Data Protection Officer.

• We collect and process data to provide a secure and personalized service, comply with legal requirements, and detect and prevent fraudulent activities. The data is used to:
  • Maintain a gaming history and apply measures to identify and manage gambling-related issues;
  • Conduct targeted marketing and improve our services;Confirm location and verify that no multiple accounts exist under applicable laws;
  • Assess personal aspects through profiling.

• Data is processed in accordance with applicable legislation and under the following circumstances:
  • To provide services under our contract with you;
  • For our legitimate interests, provided your rights do not override them;
  • To comply with legal obligations.
• We generally do not rely on consent as the legal basis for processing, except in relation to marketing;
• You may withdraw your consent at any time through the opt-out option or by contacting our Data Protection Officer.

• We do not store your credit card information or financial details, as payments are handled through our payment gateway providers that use secure server technology (SSL);
• We do not access details of your card or bank account, except for the information you provide for KYC verification, which we will process solely to comply with relevant legal obligations.

Locowin will only share your data with data processors or external consultants when legally permitted, in cases such as:

• To provide you with the requested service;
• To obtain third-party services necessary to deliver the service;
• To fulfill our legal obligations;
• To protect our legitimate interests in litigation or in defending our rights;
• To manage business risks;
• To comply with your instructions;
• To comply with legal requirements such as court orders or subpoenas;
• To report suspected fraud or money laundering;
• To act in emergencies that may endanger health, safety, or public welfare;
• To protect the rights and property of Starscream Limited, including the enforcement of our Terms and Conditions.

• Locowin will disclose your personal data to:
  • Regulatory and judicial authorities, as required by law;
  • Law enforcement agencies, governments, courts, dispute resolution bodies, regulators, and entities designated to audit or investigate our operations;
  • Entities within the Starscream Limited group, as previously described.
• We may share your information with external providers and third parties acting as data processors for Starscream Limited. These include:
  • MaxMind (for IP intelligence, relevant content and ads, analytics, and traffic routing);
  • Customer.io (email newsletter platform);
  • Payment IQ (payment gateway provider);
  • Professional advisors, such as lawyers and auditors.
• We may disclose your data in accordance with applicable laws and regulations regarding data privacy;
• In the event of disputes regarding payments or losses, we may share your KYC Data, Bank Account Data, Usage Data, and Account Data with your bank to resolve the issue;
• Relevant authorities and Starscream Limited employees handling customer support will have access to your data to perform their duties.

• Your data will only be transferred to the European Union or to countries that the European Commission has deemed to have an adequate level of protection for personal data;
• If we use providers in the U.S., data will only be transferred to those that comply with protections equivalent to those of the EU/EEA and are registered under the Privacy Shield (an agreement that allows data transfer between the EU and the U.S. in accordance with European data protection standards).

• Locowin may send you information about our services that may interest you;
• To opt out of marketing communications, you can:
  • Send an email to support@locowin.com indicating your wish to unsubscribe;
  • Select the “opt-out” option in your account profile;
  • Click “unsubscribe” in any marketing email you receive.
• Withdrawing your consent will not negatively affect your relationship with Locowin.

• We have implemented measures and procedures to prevent unauthorized access and maintain the confidentiality of the information you provide;
• Our site uses SSL to secure the transmission of your personal data;
• Access to your personal data is limited to employees, agents, and contractors who need it to perform their business functions, and they are required to maintain confidentiality;
• We have procedures in place to handle data breaches and will notify you and the relevant authorities as required by law.

• Locowin will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected;
• We will retain your data for the duration of your relationship with us;
• After the relationship ends, data will be retained for a minimum of five years, depending on the type of data.

• Right to Transparent Information: Be clearly informed about the personal data being processed;
• Right of Access: Request confirmation and access to the personal data we process;
• Right to Rectification: Request corrections of inaccurate personal data via:
  • Your profile: “Account Details” section;
  • Email: dpo@starscreamltd.com.
• Right to Erasure (“Right to be Forgotten”): Request immediate deletion of your personal data if processing was based on your consent or is no longer lawful;
• Right to Restrict Processing: Request restrictions on processing. Restricted data will only be stored and not processed unless we have your consent or it is required by law or the public interest;
• Right to Data Portability: Receive your personal data and transfer it to another controller without hindrance;
• Right to Object: Object to the processing of personal data based on legitimate interests, public interest tasks, direct marketing (including profiling), or scientific/historical/statistical research;
• Right to Withdraw Consent:
  • Email: support@locowin.com;
  • “Opt-out” option in your profile;
  • “Unsubscribe” link in marketing communications.

Withdrawing consent will not negatively affect your relationship with Locowin.

• When exercising your data protection rights, Locowin may require additional information to confirm your identity and verify your right to access your personal data;
• Locowin is legally obliged to keep your data up to date, so you may be asked to report any changes to your personal information;
• If you choose not to provide your data, we may be unable to establish or continue a relationship with you or comply with the applicable Terms and Conditions;
• Anti-money laundering regulations require us to verify your identity regularly. To fulfill this legal obligation, we may request necessary information and documents, and ask you to notify us of any changes to your business relationship;
• Our Terms and Conditions outline your commitment to provide specific personal data and documentation, as well as to notify us of any changes to such data. You are not obliged to provide data without a legal basis for processing beyond your consent.

• The data processing described above, except for marketing purposes, does not require your consent, as it is based on legal grounds;
• We may request your consent to process additional personal data. You are not obliged to grant this consent;
• You can withdraw your consent at any time (withdrawal does not affect the legality of processing carried out before the withdrawal) via: dpo@starscreamltd.com;
• Upon withdrawal of consent, we may identify another legal basis to continue processing your data, and we will inform you accordingly.