INTERWETTEN GAMING LIMITED PRIVACY NOTICE

INTERWETTEN GAMING LIMITED PRIVACY POLICY


Last updated in October 2025

Welcome to https://www.interwetten.de (the “Website”).

This Privacy Notice explains how Interwetten processes, uses, stores, and protects personal data and describes your rights in relation to your personal data. Interwetten processes personal data for various purposes, which can be found in Section 6 of this Privacy Notice. This Privacy Notice applies to all scenarios demonstratively listed in Section 6.

1. About Us

1.1. The Data Controller of Your Personal Data is Interwetten Gaming Limited, a Maltese Company with registration number C-35736 having its registered address at The Centre, North Shore, Ground Level, Tigne' Point, Sliema TPO 0001, Malta (“Company” “We” “Us” “Our”).

1.2. By visiting our Website and using our services, you confirm that you have read this Privacy Notice and fully taken it into consideration.

1.3. The Company confirms that, when collecting your personal data, we are bound by Maltese law and will process your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation, “GDPR”) as well as the Federal Data Protection Act (“BDSG”). For further enquiries or questions about how we handle your personal data, you can contact us/our Data Protection Officer at the following email address: [email protected].

1.4. Any notices, requests, enquiries, or other communication with the Company must be sent either by registered mail with return receipt requested or by email. All notices sent by email are deemed received on the next business day after dispatch.

2. Definitions

Capitalized terms in this statement have the meanings assigned to them under the GDPR and shall be interpreted accordingly. In addition, the following definitions apply:

2.1. Account – an account provided to you by the Company upon your registration and acceptance of the General Terms and Conditions for the use of the services.

2.2. Services – the services offered by the Company via the Website, as defined in our General Terms and Conditions.

2.3. User – any person who creates an account on our Website or accesses and browses our Website (“you,” “your”).

3. Principles of Data Processing

3.1. We fully respect Your fundamental rights and consider the protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We respect the following basic principles:

3.1.1. We submit Your Personal Data only to lawful and fair processing, and We maintain full transparency vis-à-vis the way We handle Your Personal Data.

3.1.2. We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Notice, and We do not process it further in any manner incompatible with these purposes.

3.1.3. We process Your Personal Data only to the extent that it is necessary and appropriate to purposes for which it is collected.

3.1.4. We make reasonable efforts to ensure that Your Personal Data is accurate and updated, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.

3.1.5. We process Your Personal Data in a secure manner by using appropriate technical and organizational measures.

3.2. In general, We comply with all applicable laws and statutory obligations as Data Controller of Your Personal Data.

4. Personal Data We Process

In this Privacy Notice, “personal data” refers to any information relating to an individual who is directly or indirectly identifiable—particularly by reference to an identifier such as a name, an identification number, location data, or an online identifier. Personal data also includes one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a person.

Special categories of personal data include the following categories:

  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • genetic data
  • biometric data
  • physical or mental health or condition
  • sex life or sexual orientation
  • data relating to criminal convictions and offences

Special categories of personal data are not processed by Interwetten unless you provide them voluntarily. In such cases, they will be retained only as long as necessary, unless legal or regulatory reasons exist to retain them longer.

We collect and process the following personal data:

4.1. During your access to and use of the Website, technical data (including IP address, browser, etc.) is automatically captured by our system and temporarily stored in log files.

4.2. During your registration, “registration data” (including first and last name, email address, username, player ID, …) is processed.

4.3. During our business relationship, certain “Know Your Customer (KYC) data” (including identification or credit data) is processed. Depending on country-specific legal obligations, we may collect additional KYC data.

4.4. During the use of payment services, “payment data” (including credit card information or bank account information) is processed.

4.5. During communication with our customer service agents, “communication data” (including chat contents) is processed.

4.6. During our business relationship, “game-related data” (including, among other things, limits—comprising operator-specific and cross-operator limits (LUGAS), game scores and histories, gaming behavior, login and logout histories, details of the transactions you carry out, player exclusions (OASIS), etc.) are processed.

4.7. Any personal data that you provide to us directly and voluntarily during our interaction.

5. Purposes and Legal Bases of Data Processing

5.1. The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions, for the following purposes:

  • Enabling Your use of the Website;
  • Processing Your Account registration and maintenance (including checks made to age verify You and to guard against fraud);
  • Identification of dysfunctions and abuse of Our Services;
  • Performing payment services;
  • Enhancement of User experience, including the provision of personalized Services and improvement of the Website and the Services;
  • Administering the Website; and
  • Responding to Your requests.

When you visit our Website, we automatically collect certain personal data. The data we collect automatically includes, in particular, information such as your IP address, device type, unique device identifier, browser type, geographical location (e.g., country or city), as well as other technical information. We also record how your device has interacted with our Website, including the pages visited and links clicked. This provides us with more information about our Website visitors, their location, and which content is of interest to them. We use this information for internal analysis and to improve the quality and relevance of our Website for our visitors.

We use cookies and similar tracking technologies to collect this information, as explained in the Cookie Policy.

Our Website uses Google Analytics (“Google”) to provide reports, visualizations, and analyses of data. Google processes the following types of personal data: your IP address (to create geosegmentation reports and to identify internal and external users accessing our Website) as well as user IDs, email addresses, names, and passwords to the extent these are directly provided by Website visitors. Your personal data is processed by Google for the following purposes: (i) to capture web metrics about user journeys within our site (e.g., pages viewed and links clicked), (ii) to analyze and understand general information about Website traffic, (iii) to enable us to make informed decisions about our Website, and (iv) to authenticate users and enable their access to our Website.

Interwetten Gaming Limited is the data controller. Google Analytics is provided to us by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes the website usage data on our behalf and is contractually committed to measures that ensure the security and confidentiality of the processed data. No personal data such as name, address, or contact details is transmitted to Google Analytics. This data is transferred to Google servers in the United States. We point out that the same level of data protection as within the EU cannot be guaranteed in the United States.

Google Analytics stores cookies in your web browser for a period of two years from your last visit. These cookies contain a randomly generated user ID that can recognize you on future Website visits. The recorded data is stored together with the randomly generated user ID, which enables the analysis of pseudonymous user profiles. This user-related data is automatically deleted after 14 months. Other data remains stored indefinitely in aggregated form. If you do not agree with this data collection, you can prevent it by installing the browser add-on to deactivate Google Analytics once, or by rejecting cookies via our cookie settings dialog.

Our website also uses various social media plugins. The purposes for which we process your personal data when you visit our website include:

  • Providing and ensuring the security and stability of our website
  • Managing our website, including verifying and authenticating your identity, and preventing unauthorized access to secure areas of our site
  • Personalizing our website to your needs by displaying content that may be relevant and of interest to you
  • Analyzing data from our website visitors
  • Identifying the company, organization, institution, or authority you work for or are otherwise associated with
  • Expanding our business and services
  • Conducting benchmarking and data analysis (e.g., regarding website usage and demographic analyses of our visitors)
  • Analyzing usage of our website’s offerings and features
  • Monitoring and ensuring compliance with applicable terms of use
  • Reviewing quality and risk management
  • Any other purposes for which you have provided Interwetten with information

The processing of personal data of our website visitors is based on the following legal grounds:

  • Our legitimate interest in providing you with information and services effectively and in carrying out our business activities efficiently and lawfully
  • Our legitimate interest in developing and optimizing our website and your user experience

5.2. The Company may process Your Personal Data to comply with its legal obligations, for the following purposes:

  • Detection, investigation and prevention of money laundering and the financing of terrorism;
  • Protection of minors; and
  • Implementation of responsible gaming measures.

5.3. The Company may process Your Personal Data based on Our legitimate interest to promote Οur Services and develop Our business, for the following purposes:

  • Commercial communication, marketing and advertising of Our Services;

5.4. The Company may process Your Personal Data only with Your lawful consent for the following purposes:

  • Commercial communication, promotional campaigns, and advertising.

5.5. You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Notice. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your Data prior to its revocation.

6. Social Media Plugins

6.1. We use various social media platforms, for example for recruitment or marketing purposes. We use social media to inform about our job vacancies and events, to present our services, and to increase our brand awareness.

6.2. We are responsible for the content we publish via social media platforms, but not for the operation of the social media platforms (for example, the creation of user statistics or the placement of cookies). By using social media platforms, you agree to comply with the legal and data protection provisions of the providers of these platforms. These providers collect personal data about you, including data about your use of the social media platforms, for the creation of statistics and analyses. These include, for example, a list of pages you have visited, your “likes,” recent visits, as well as posts you have published or found interesting.

6.3. If you wish to access this data or exercise any of your other rights (for example the right to object to the processing of your data), you should contact the provider of the social media platform. Some social media providers make aggregated data relevant to our websites available to us, such as the number of “likes” clicked in relation to our content or the number of posts, visitors to our websites, downloaded photos, or clicked links.

6.4. We implement so-called plugins on our Website. When you access a webpage that displays one or more such buttons, your browser establishes a direct connection to the server of the relevant social network and loads the buttons from there. At the same time, the social media operator is informed that the relevant page of the Website has been accessed. We have no influence over which data is collected by the social media operators using these buttons. To avoid this, please log out of your social media accounts before visiting our Website. Social media operators also use cookies unless you have disabled the acceptance and storage of cookies in your browser settings.

6.4.1 Facebook

Our website includes plugins for the social network, Facebook. The Facebook plugins can be recognized by the Facebook logo or by the like button on our websites. For an overview of Facebook plugins, click here.

When you visit our website, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our website from your IP address. If you click on the Facebook “like button” while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our website with your user account. If you are not yet logged into your Facebook account, clicking a Facebook button will show you the Facebook login page for you to enter your login credentials. Please note that we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook’s privacy policy.

6.4.2 X

Functions of the X service have been integrated into our website. When you use X and the “retweet” function, the websites you visit are connected to your X account and made known to other users. If you are not yet logged into your X account, clicking the X button will show you the X login page for you to enter your login credentials. In doing so, data will also be transferred to X. We would like to point out that we have no knowledge of the content of the data transmitted or how it will be used by X. 

For more information, see X Privacy Policy.

6.4.3 Instagram

Our website contains functions of the Instagram service.

If you are logged into your Instagram account, you can click the Instagram button to link the content of our pages with your Instagram profile. This means that Instagram can associate visits to our pages with your user account. If you are not yet logged into your Instagram account, clicking an Instagram button will show you the Instagram login page for you to enter your login credentials. We expressly point out that we receive no information on the content of the transmitted data or its use by Instagram.

For more information, see Instagram’s privacy policy.

6.4.4 YouTube

Our website uses plugins from YouTube, which is operated by Google.

If you visit one of our pages featuring a YouTube plugin, it is a connection to the YouTube servers. Here, the YouTube server is informed about which pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. If you are not yet logged in, clicking a YouTube button will show you the YouTube login page for you to enter your login credentials.

For more information, see Google’s privacy policy.

7. Suppliers

We process personal data about our suppliers (including subcontractors, and individuals associated with our suppliers and contractors) in order to manage our contract and to receive services from our suppliers.

The personal data we process is generally limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).

Legal grounds for processing personal data of our suppliers are:

  • Performance of a contract
  • Compliance with a legal or regulatory obligation
  • Our legitimate interest in managing payments, fees and charges, and to collect and recover money owed to us

8. Data Recipient

8.1. For the execution of the purposes set out in this Privacy Notice, we may disclose or transfer your Personal Data to the following third-party recipients (“Data Processors”):

  • Processors such as technical service providers
  • Group companies for operational purposes
  • Game providers for gameplay purposes
  • Payment service providers to facilitate payments
  • Information technology providers for the operation of the website
  • Statistics and reporting providers for data analysis and regulatory/supervisory purposes
  • Credit reference agencies and operators of companies for identity verification and age verification
  • Customer support providers
  • Sales and marketing partners for marketing-related purposes
  • Supervisory authorities
  • Courts and public authorities, in particular in connection with the enforcement of claims for performance under contracts
  • Legal and tax advisers

Recipients include, among others, the following companies:

  • Schufa Holding AG, Kormoranweg 5, 65201 Wiesbaden
  • IDNow GmbH, Auenstraße 100, 80469 Munich
  • Insic GmbH, Brookweg 6a, 22941 Jersbek
  • AUTHADA GmbH, Julius-Reiber-Straße 15a, 64293 Darmstadt
  • Sofort GmbH, Theresienhöhe 12, 80339 Munich
  • Card Complete Service Bank AG, Lassallestraße 3, 1020 Vienna
  • Unzer Austria GmbH, Kolumbusplatz 7–8, 1100 Vienna
  • Paysafe Prepaid Services Ltd., 4 Grand Canal Street, Upper, Dublin, Ireland

Should it be necessary to verify your identity or creditworthiness as part of our business relationship, we will transmit the required data to CRIF GmbH, Rothschildplatz 3/Top 3.06.8, 1020 Vienna, which, as an independent controller, will process the transmitted data for its own purposes as a credit reference agency and address publisher, as described at https://www.crif.at/datenschutz/.

8.2. We transmit your Personal Data to operators of government databases (OASIS and LUGAS) for regulatory supervisory purposes. The operator of the cross-state blocking system OASIS is the Regierungspräsidium Darmstadt, Wilhelminenstraße 1–3, 64283 Darmstadt. Further information on the OASIS blocking system can be found at https://rp-darmstadt.hessen.de/sicherheit-und-kommunales/gluecksspiel/spielersperrsystem-oasis

The cross-state gambling evaluation system LUGAS is administered by the Joint Gambling Authority of the Länder and operated by Dataport, a service provider to the public administration of the State of Saxony-Anhalt. Further information on LUGAS can be found at https://www.gluecksspiel-behoerde.de/de/aufsichtssysteme/verpflichtende-it-systeme-fuer-veranstalter-und-vermittler-von-gluecksspielen.

8.3. We transfer your personal data to third parties outside the European Union only if:

  • you have given your explicit consent, or
  • it is necessary for us to fulfill a contract you have entered into with us, or
  • to comply with a legal duty or obligation.

We shall only disclose Your Personal Data to third parties located outside of the European Union in cases where:

  • The recipient is located in a jurisdiction which is subject to an Adequacy Decision issued by the European Commission.
  • The recipient guarantees a standard of data protection comparable to that in place in the European Union, through the implementation of the Standard Contractual Clauses issued by the European Commission.

In some cases, we may be required by law to disclose your personal information to third parties and may have limited control over how it is protected by that party.

8.4. Upon indication of transactions and/or activities that may raise suspicions of criminal activities, We will report to the relevant authorities, sporting bodies and associations (e.g. police, sporting bodies/associations, private associations aiming at the prevention of criminal and fraudulent activities in sports betting and/or games of chance). In this context, Your Personal Data may be disclosed.

8.5. In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that We are legally bound to do so, We may transfer Your Personal Data to public authorities to the extent required by law.

8.6. In certain instances (e.g. for AML, KYC and Due Diligence checks) We may transmit Your Personal Data to credit rating agencies that conduct creditworthiness assessments and suppliers for identity verification checks (e.g. Verify, Sonio).

9. Data Security and Confidentiality

9.1. In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, the Company applies internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.

9.2. The processing of Your Personal Data by the Company is conducted in a secure and confidential manner, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.

9.3. In particular, payment information will always be encrypted. Whereas sensitive information is protected online by SSL encryption, We strive to ensure the protection of players' Data in all other areas. Only authorised employees, or employees of third parties contractually bound to confidentiality, have access to players' information. At regular intervals, all employees are given training on the applicable security and data protection standards. All relevant servers are located in a secure environment.

9.4. In order to protect players' Personal Data during communication with the web browser, We use encryption technology of Our certification partners. In addition, online transactions are shielded by the security system of a worldwide-accredited partner. In addition, all player Data is protected from unathorised access by firewall and intrusion prevention systems.

10. Retention of Personal Data

10.1. We retain your personal data for as long as necessary to fulfill the processing purposes explained in this statement, in accordance with the principles of data minimization and storage limitation. We point out that retention periods differ from country to country and are set in accordance with local statutory retention obligations.

10.2. To meet legal requirements, assert, exercise, or defend our legal claims, as well as for archiving and traceability purposes, we must retain information for a longer period.

10.3. Retention periods vary in length, and in justified individual cases (for example, preservation of evidence), the retention period may be longer. If the affected data is subject to different retention periods, the longest retention period applies.

10.4. After the retention period expires, your personal data will be deleted from our databases and systems.

10.5. For more information on the conditions of data retention in relation to specific personal data, please contact us at [email protected].

11. Your Rights

11.1. You have the right:

  • You may object to receiving marketing communications at any time.
  • You may request that the processing of your personal data be restricted or stopped, or that your personal data be deleted (under certain circumstances and in accordance with applicable law).
  • You may request the restriction of the processing of your personal data in cases explicitly provided for by law.
  • You have the right (under certain circumstances and in accordance with applicable law) to receive a copy of the personal data you have provided to Interwetten in a structured, commonly used, and machine-readable format (known as data portability). You may also request the transfer of your personal data to another data controller in such a format.
  • You may object to the processing of your personal data in cases explicitly provided for by law.
  • You may object to a decision made solely on the basis of automated processing, including profiling, that affects you or significantly impacts you.
  • If you have voluntarily provided personal data or otherwise consented to its use, you have the right to withdraw your consent at any time.
  • You have the right to lodge a complaint with a data protection authority (see Section 13 “Complaints”).

11.2. Any requests relevant to the above Section 10.1 must be addressed in writing to [email protected].

12. Complaints

If you suspect that Interwetten may have violated data protection laws or other legal regulations, you can contact the Data Protection Officer at [email protected]. They will investigate your complaint and inform you about the next steps.

In addition, you have the right to file a complaint with the relevant data protection authority.

13. Minors

Our Website is not intended for use by minors under 18 years of age. We do not knowingly collect, disclose, or sell the personal data of minors under 18 years. If you are under 18 years old, please do not provide any personal data, even if prompted to do so. If you believe you have inadvertently provided personal data, please ask your parents or guardians to inform us, and we will delete your personal data.

14.Your Obligations

By using our Website and submitting your personal data, you acknowledge that you are obliged to provide your true, accurate, and complete data as requested by the Company. Furthermore, you must inform us of any changes to your data so that we can ensure it is current and correct.

15. Changes to the Privacy Notice

This Privacy Notice will be updated from time to time to reflect changes to our services. When changes are made to this Privacy Notice, the date indicated at the top of this statement will also be updated to show when the update took place. If material changes are made to the way personal data is collected, used, and disclosed, a clear notice of the changes will be provided on the Website.