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Privacy Policy

1. Introduction

MOBILE INCORPORATED Limited (“Company”, “we”, “our”, or “us”) respects your right to privacy and is committed to protecting your Personal Data.

This Privacy Policy describes how we collect, process, store, and protect Personal Data when users access our website, gaming platform, mobile applications, and related services (collectively, the “Services”).

All Personal Data processing is carried out in accordance with:

  • the General Data Protection Regulation
  • the Malta Data Protection Act
  • regulatory obligations imposed by the Malta Gaming Authority relating to player protection, anti-money laundering and responsible gaming.

By using the Services, you confirm that you have read and understood this Privacy Policy.

2. Data Controller

MOBILE INCORPORATED Limited acts as the Data Controller for the Personal Data processed through the Services.

  • Registered Office: Elite Business Centre, Trejqa Ta’ Box Box, Msida MSD1840, Malta
  • Company Number: C 84149

Data Protection Officer (DPO)

  • Email: legal@zowin.vet
  • Address: Elite Business Centre, Trejqa Ta’box Box, MSIDA, MSD1840, Malta.

3. Data Protection Principles

Personal Data is processed according to the principles set out under the GDPR:

Lawfulness, Fairness and Transparency

Data is processed lawfully and transparently.

Purpose Limitation

Data is collected only for legitimate and specified purposes.

Data Minimisation

Only the necessary data required to provide the Services is collected.

Accuracy

Personal Data is kept accurate and updated where required.

Storage Limitation

Data is retained only for the period necessary for regulatory or operational purposes.

Integrity and Confidentiality

Appropriate technical and organisational security measures are applied.

Accountability

The Company is responsible for demonstrating compliance with these principles.

4. Categories of Personal Data

We may collect the following categories of Personal Data.

Identity Data

  • Full name
  • Date of birth
  • Nationality
  • Gender

Verification (KYC) Data

  • Government-issued identification
  • Proof of residential address
  • Source of funds or source of wealth (where required)

Contact Data

  • Email address
  • Telephone number
  • Residential address

Gaming and Account Data

  • Username and login credentials
  • Account activity and gameplay history
  • Account limits and balances

Financial Data

  • Payment method details
  • Deposit and withdrawal transactions

Technical Data

  • IP address
  • Device and browser information
  • System logs and platform usage data

Communications Data

  • Customer support communications
  • Responsible gaming interactions

Certain categories of data may be treated as sensitive or high-risk data and are subject to enhanced security controls.

5. Legal Basis for Processing

Personal Data is processed on one or more of the following legal bases:

  • Contractual Necessity – to create and manage user accounts and provide gaming services
  • Legal Obligation – compliance with AML, KYC, responsible gaming and regulatory reporting obligations
  • Legitimate Interests – fraud prevention, system security, and service improvement
  • Consent – where required, including marketing communications

6. Purpose of Processing

Personal Data may be processed for the following purposes:

  • Account registration and management
  • Identity and age verification
  • Payment processing and transaction monitoring
  • Compliance with AML and responsible gaming obligations
  • Fraud detection and prevention
  • Monitoring player behaviour for player protection
  • Communication of regulatory or operational updates
  • Improvement of platform functionality and security

7. Data Sharing

Personal Data may be disclosed to trusted third parties including:

  • Payment service providers
  • Identity verification and AML providers
  • IT infrastructure and hosting providers
  • Professional advisers (legal, compliance, auditors)
  • Competent authorities where legally required, including the Malta Gaming Authority

The Company does not sell Personal Data to third parties.

8. International Transfers

Where Personal Data is transferred outside the European Economic Area, appropriate safeguards will be implemented including:

  • Transfers to jurisdictions recognised by the European Commission as providing adequate protection
  • Standard Contractual Clauses (SCCs) or equivalent legal mechanisms

9. Data Retention

Personal Data is retained only for as long as necessary for regulatory, contractual, and operational purposes.

Retention periods are determined based on:

  • gaming regulatory requirements
  • AML legislation
  • dispute resolution obligations

Where data is no longer required it will be securely deleted or anonymised.

Personal Data breach documentation must be retained for at least five (5) years.

10. Security Measures

The Company maintains appropriate technical and organisational measures including:

  • encryption of sensitive information
  • role-based access controls
  • secure system monitoring
  • internal security procedures and staff training

11. Data Subject Rights

Users have the following rights under the GDPR:

  • right of access
  • right to rectification
  • right to erasure (subject to legal limitations)
  • right to restrict processing
  • right to object to processing
  • right to data portability
  • right to withdraw consent for marketing communications

Requests may be submitted to the Data Protection Officer.

Users also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta.

12. Personal Data Breaches

In the event of a Personal Data breach the Company will:

  • take immediate containment measures
  • investigate and remediate the incident
  • notify the competent supervisory authority within 72 hours where required
  • notify affected users where the breach presents a high risk to their rights and freedoms

13. Minors

The Services are strictly limited to individuals 18 years of age or older.

The Company does not knowingly collect Personal Data from minors.

Any such data identified will be deleted and the relevant account terminated.

14. Cookies

The website uses cookies and similar technologies to:

  • ensure website functionality
  • analyse usage and performance
  • improve user experience

Where required, consent is obtained through a cookie management tool.

15. Governing Law

This Privacy Policy is governed by the laws of Malta.

16. Policy Updates

This Privacy Policy may be updated periodically to reflect regulatory or operational changes. The latest version will always be available on the website.