PRIVACY POLICY

Version 31.01.2026

Why reading this information is important

We recommend that you read this information carefully, so that you know how your personal information is collected, processed and retained by NAPOLEONGAMES as well as why this is done. This privacy statement also contains more information about your privacy rights and how you can exercise them.

NAPOLEONGAMES may make changes to this privacy statement. The most recent version is always available via our website. NAPOLEONGAMES will also inform you of all substantive changes to this privacy statement by email in advance, provided that you have provided your email address to NAPOLEONGAMES.  

NAPOLEONGAMES processes your personal data conform the General Data Protection Regulation (“GDPR”) and other supplementary legislation regarding the protection of personal data. You can find more information about the Belgian privacy legislation on the website of the Belgian Data Protection Authority (previously called the Privacy Commission) at www.dataprotectionauthority.be.

Content

Clarification of meaningful terms
When do we collect your personal data?
What kind of personal data do we collect, why and on what legal basis?
Your rights in relation to your personal data
How to exercise your rights?
Transfer of personal data
Transfer of personal data to third countries
Protection of your personal data
Storage of personal data
Use of AI, automated decision making and profiling
More information, questions or complaints?

Clarification of meaningful terms

• Controller: The companies mentioned in the “General Conditions, Art. 1 - Publishers of NAPOLEONGAMES” are the controllers. Referred here-in as “NAPOLEONGAMES”.
• Data subject: you or any other natural personal NAPOLEONGAMES collects personal data of. 
• Personal data: any information relating to an identified or identifiable natural person (the “data subject”). A natural person shall be deemed “identifiable” if he or she can be identified on a direct or indirect basis, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Processing: the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure and/or destruction of your personal data.
• Processor: any natural or legal person that processes your personal data on our behalf and upon our instructions.

When do we collect your personal data?

We may collect personal data from you when you:

• visit our website (e.g. via cookies);

• create an account by registering on our website  (e.g. via Local Browser Storage);

• login to your account;

• upload documents;

• chat with us via the website;

• download and use our app;

• use our payment services;

• contact our customer service (e.g. via telephone or e-mail).

In addition, we may also collect personal data about you from other sources such as the Belgian Gaming Commission to check whether you are registered in the Excluded Persons Information System (“EPIS”) before you are allowed to use our gaming platform. 

What kind of personal data do we collect, why and on what legal basis? 

NAPOLEONGAMES shall only collect and use your personal data (1) when necessary to provide the services you have requested, (2) to comply with a legal obligation which we are subject to, (3) when you have consented that we do so, or (4) if we feel we have a legitimate interest to do so that is not detrimental to your right to privacy.

1. To provide the services you have requested

To become a NAPOLEONGAMES customer, you must create a player account and accept our Terms & Conditions. This means that you will enter into a contract with NAPOLEONGAMES. In order to enable NAPOLEONGAMES to execute certain obligations stated in that contract (e.g. to settle your winnings), we need your personal data.

In addition, we also need your personal data to reply to your requests (e.g. through our customer support service) or any other complaint(s) that you may have. In this regard it should be noted that your personal data might be passed on between the internal entities of NAPOLEONGAMES and/or to external third parties which handle these requests and complaints on our behalf.

We will also need your personal data for sending out service messages related to our services, such as warning messages. You can view these types of service messages in your personal preference page when you are logged in to your account.

The categories of personal data we collect to provide you with our services mentioned above are, but are not limited to:

• Identification and contact details (given name, name, email address, username, birthday and phone number);

• Transactional data from your account;

• Payment data (bank account number).

Please note that your failure to provide any of these personal data to us might result in NAPOLEONGAMES not being able to provide the requested services to you. 

2. To comply with our legal obligation

NAPOLEONGAMES is obliged to comply with a number of laws and regulations imposing the processing of your personal data. Below you can find an overview of the main ones: 

• Gambling Law: NAPOLEONGAMES is requested to collect personal data of all of its players (eg concerning the identification of its players). NAPOLEONGAMES is also obliged to transfer these data, if required, to the Belgian Gaming Commission (http://www.gamingcommission.be) and in accordance with all legal obligations included in the Gambling Law and its current and future implemention decrees.

• Anti-Money Laundering Law: Gambling providers must deploy all means to prevent and uncover money laundering and take part in the fight against terrorism. Therefore, NAPOLEONGAMES stores and verifies both personal identification data and financial transactional data of all of its players.  NAPOLEONGAMES is also obliged to report any suspicious transaction in terms of money laundering to the Belgian Financial Intelligence Unit (www.ctif-cfi.be)

The categories of personal data we collect to comply with legal obligations include but are not limited to: 

• Name and surname as mentioned on ID card;

• Date and place of birth;

• Nationality;

• National registration number;

• Copy of the ID card;

• Address;

• Profession;

• Picture;

• Signature;

• Financial information;

• EPIS verification.

Please note that providing us with abovementioned information is a statutory obligation.  Without this information, we will not be able to give you access to our gambling platform.  In addition, in case the EPIS verification we receive from the Gaming Commission excludes you from being able to gamble, we are legally obliged to refuse you access to our gambling platform.  This decision is taken in an automated way and cannot be undone by human interaction.

By using our services, you acknowledge that you are required to provide your actual, accurate and complete data as requested by NAPOLEONGAMES. Furthermore, you must inform us of any changes to your information to ensure it is kept up-to-date and accurate.

If you are found to be in breach of your obligations or if we have reasonable suspicion that the information you provide is false or incomplete or in any way contrary to Data Protection Law or this Notice, we retain the right to reject your application for registration or to suspend or terminate your account immediately without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.

3. When you have given consent 

We may occasionally ask you for specific permission to process some of your personal data for a specific purpose.  We will only process your personal data for this purpose if you agree us doing so in advance.

We will, for example, ask your consent to:

• Contact you via email with interesting information about our products and services; or

• Include your contact details in our Club-database; or
• If you are a Club-player of NAPOLEONGAMES, in order to contact you for special events.

You may withdraw the abovementioned consent at any time, without any need to give a reason.  An opt-out possibility is provided in every email message received from us.  In addition, you can also easily opt-out in your own preference center when logging on to your user account.  Once you have withdrawn your consent, we will no longer use your personal data for such purpose in the future. 

4. To act in our legitimate interest

We may process your personal data where it is in our legitimate interest to do so to be able to run a lawful business, provided that this does not outweigh your interests to protection of your personal data. 

Processing on the basis of our legitimate interests may, for example, include: 

• The processing of your email address to provide you, as a registered user, with information about our products and services that  you have shown an interest in;

• The collection of product-feedback aiming at enhancing our products and services. This concerns, for example, statistical data about the use of our website and services, recordings of conversations from customer support for training purposes or conducting a customer satisfaction survey.

• Processing of personal data to ensure the security and stability of our services and IT systems. This concerns, for example, scanning for third-party software in our games or other activities in violation of our conditions. We also monitor our IT systems and perform audits and investigations into our security and stability. 

Your rights in relation to your personal data

In order to give you more control regarding the processing of your personal data, you have various rights at your disposal under the GDPR:

1. You can access your data

You can view some of the data directly yourself when you sign in to your account. If you want a more detailed overview of the personal data we process or if you want further information on any of our processing activities, you can address an access request to us. 

2. You can correct your data

It may happen that your personal data is not correct (anymore). You can correct some of the data yourself when you sign in to your account. If you are of the opinion that other data should be corrected or completed, you can address a request for rectification to us.  

3. You can have your data deleted

You can ask us to delete the personal data we collected and hold on you. However, your request can only be granted under certain circumstances as defined in the GDPR.  Some data also needs to be kept by us due to the legal obligations we are under. 

4. You can object to your data being used for certain purposes

If you disagree with how NAPOLEONGAMES invokes its legitimate interests to process certain of your personal data, you can object to such processing. Objections will be respected unless there are overriding grounds not to do so (e.g. when we process data with the purpose of combating fraud or anti-money laundering).

In addition, you always have the right to withdraw your consent for any processing of your personal data based on your consent.  To exercise this right, you can opt-out via the link provided in each email message sent to you or via your account.

5. You can ask for a restriction of processing 

In some circumstances, you have the right to obtain the restriction of processing of your personal data.  In such case, your personal data will only be stored and not processed unless with your consent or for the establishment, exercise or defense of legal claims or to protect the rights of third parties or the public interest.

6. You can ask for your data to be transferred to another party

You are entitled to ask for personal data that you have provided to NAPOLEONGAMES yourself, to be transferred back to you or to a third party in a structured, commonly used and machine-readable format.

How to exercise your rights?

If you want to exercise any of your rights relating to your personal data that you cannot exercise directly yourself via your user account, please address your request by email to privacy@napoleongames.be . 

We invite you to formulate your specific request in as much detail as possible.

We will also need to verify your identity to guarantee that your rights are exercised by you and not by any other person. We therefore ask you to include the following identification elements in your email: your unique user code (which can be found when logging onto your account) and a copy of your ID card’s front. Without these identification elements we will not be able to accommodate your request. Depending on the circumstances or when any doubt, we may decide to request additional information to verify your identity with more certainty.   

For your convenience, in the table below, we have summarized how each of the abovementioned rights can be exercised:

Transfer of personal data

Your personal data may be transferred to or accessed by third party service providers that NAPOLEONGAMES works with in order to provide its services to you.  NAPOLEONGAMES shall ensure the necessary agreements are put in place with such third party service providers to guarantee the safe, respectful and cautious management and administration of your personal data by the third party. Categories of third parties are, but not limited to, gambling or licensing authorities, accountants, lawyers, auditors, potential purchasers, suppliers and contractors.

In addition, your personal data may also be transferred to third parties or organizations in accordance with NAPOLEONGAMES’ legal obligations (e.g. transfer to the Belgian Gaming Commission or the Financial Intelligence Unit) or  when you have provided us with your consent to do so.

Within our organization, we may transfer your personal data to different entities if this is necessary in function of the purposes of processing.  We shall ensure that all our employees and agents are bound by stringent contractual obligations to ensure the protection of your personal data at all times.

We see to it that your personal data shall only be accessible by our internal entities or by third parties who require access to the personal data in order to provide the requested services to you.

Transfer of personal data to third countries

Your personal data shall only be transferred or disclosed to processors or controllers in third countries in so far as we are legally authorized to do so.

In so far as such disclosure or transfer is necessary, we shall take appropriate measures to ensure that your personal data shall be significantly protected and that all disclosures or transfers of personal data outside of the EEA take place in a lawful and legitimate manner. In the event that a disclosure or transfer takes place to a country outside of the EEA, for which the European Commission has not determined that this country does not maintain an equivalent level of protection of the personal data, such disclosure or transfer shall always be subject to contractual or other legally binding instruments which under the terms and conditions for the transfer of personal data to third countries, such as the approved standard terms and provisions for the transfer of personal data to third countries as established by the European Commission.

Protection of your personal data

NAPOLEONGAMES ensures that your personal data is properly secured. We have taken all reasonable and suitable technical and organizational measures in order to protect your personal data as well as possible against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.

Your personal information will be treated as strictly confidential at all times. 

NAPOLEONGAMES secures your personal data in accordance with the international standard for information security ISO/IEC 27001 and is audited annually by an external party. NAPOLEONGAMES has an ISO/IEC 27001 certificate which is available on request

Storage of personal data

We shall in principle only retain your personal information for the length of time necessary for the intended purpose of data collection or for as long as legally required.  

In the event that no legal obligation to store your personal data exists, your personal data shall be erased on a routine basis once the purpose for which the personal data is collected has been achieved.  However, please note that we must take into account a number of (legal) retention periods which may oblige us to continue to store your personal data, even after the intended purpose of data collection has been achieved.

In accordance with our legal retention obligations, most of your personal information must be retained by us for a period of 10 years following the end of our customer relationship with you. 

Furthermore, we may store your personal data if you have given us your consent to do so or where such storage is necessary for the establishment, exercise or defense of legal claims. In this last instance, certain personal data may be used for evidence purposes.

Use of AI, automated decision making and profiling

We use certain artificial intelligence (“AI”) and other automated tools in our products and/or services to personalise your gaming experience, to help us manage operational and integrity risks in a consistent way and to better understand the way you interact with our products and services, in accordance with our legitimate interests and legal obligations applicable to us. These systems are designed to support and enhance your experience and the integrity of our services; they do not replace human decision-making where this could affect your rights or ability to use the platform.

As an example, such AI tools could be used to offer or support the following services:  

• Make recommendations and personalise sections like as “Because You Played” or “Recommended for You”; 
• Help us understand changes in player activity over time;
• Support our efforts to detect and manage potentially abusive or fraudulent behaviour;
• Detect players that are struggling or have issues with gambling as part of our Responsible Gaming activities;
• AI-powered chatbot solutions that can answer questions and assist you with support, product and responsible gaming queries.

Depending on the specific objectives, the underlying models process behavioural, transactional and interaction data linked to the use of our gaming and betting products and your contact with us. This may include information about your gameplay (f.e. games you play, spins, navigation paths, how frequent you are active, your betting and ticket history, your deposits and withdrawals). Responsible gaming tools may analyse your activity to detect patterns (f.e. increase in intensity, chasing losses) to protect you. AI chatbot solutions process the content of your conversations with the chatbot, together with technical identifiers and basic account context, so that they can provide relevant answers and guide you to appropriate features or human support. For these AI use cases we link events only to an internal player identifier and technical identifiers; we do not use your name or contact details as direct input. The purpose of processing is to understand game and content preferences so we can present more relevant, personalized service, to identify patterns that may indicate abuse or fraud, and to provide faster and more consistent support.

We implement data-minimisation and quality controls for these AI tools. The data used comes from our own data platforms and from chatbot interactions and is modelled using standardised processes. We include only the information necessary for the aimed purposes. Personalisation is based on your interactions with games, content, features and support, rather than personal characteristics. Risk and responsible gaming systems focus on behavioural and transactional indicators that are relevant to platform integrity and safer gambling, rather than “you as a person”. 

These systems involve a degree of “profiling” in the sense of analysing behaviour and interactions to detct preferences, risk levels or potential signs of gambling-related harm. Depending on your query AI-driven chatbots use your account information and decide which information, options or self-service tools to present to you. They have limited impact: they do not restrict your access to games or make changes to your contractual terms. You decide freely to ignore recommendations; browse any content; decline promotions; or follow chatbot suggestions. Responsible gaming related tools provide internal scores only. Decisions that may negatively affect how you can use the platform (f.e. applying limits, contacting you about your game play) always involve human review and judgement.

We take measures to promote fairness, non-discrimination, accuracy, robustness and security in connection with the used AI systems. The models are designed to work on game transactional data, chatbot interactions and internal identifiers. They are not intended to use attributes such as gender, ethnicity or other personal characteristics. We monitor performance over time and use feedback from our internal teams to refine the systems where necessary. The data used and the outputs generated by these tools are processed in secure, access-controlled environments in line with our information-security standards. We maintain logging, monitoring and incident-response processes so that any issues can be investigated. Data processed through these AI tools are subject to the same retention, access and security standards as other player data. 

Where applicable law grants you specific rights in relation to automated processing (including the right to obtain human intervention, to express your point of view, or to question a decision), you may exercise these rights as described in  this Privacy Notice.

More information, questions or complaints?

If you have a question about our privacy statement or a complaint about the way in which NAPOLEONGAMES processes your personal data, you can address this by:

• sending an email to our Data Protection Officer via DPO@napoleongames.be; or 

• writing a letter addressed to the attention of NAPOLEONGAMES’ DPO, Korte Keppestraat 23/6, 9320 Aalst, Belgium. 

Alternatively, you also have a right to address your complaint to the Belgian Data Protection Authority.  Please visit the website of the Belgian Data Protection Authority at https://www.dataprotectionauthority.be/ for further information.