1 Data protection at GCB
The processing of personal data by us is based on the provisions of Swiss law (Federal Data Protection Act DSG and the Ordinance VDSG) and, where applicable, the European General Data Protection Regulation (GDPR). jackpots.ch is also the first Swiss casino to be ISO 27001 (international standard for information security) certified since 2019.
2 Legal requirements for the operation of casinos
The operation of casinos is further subject to the following legal requirements, which require the casino to collect and process personal data:
- Federal Gaming Act (BGS)
- Ordinance on Money Games (VGS)
- Ordinance of the FDJP on casinos (SPBV-EJPD)
- Federal Law on Combating Money Laundering and Terrorist Financing (MLLA)
- Money Laundering Ordinance SFGB (GwV-ESBK)
3 The responsible
Responsible for the data processing described above is
GRAND CASINO BADEN AG
T +41 56 204 07 07
E-Mail: [email protected]
4 Data protection supervisory authorities
The competent data protection authority in Switzerland is the
Federal Data Protection and Information Commissioner
CH – 3003 Bern
Tel. +41 58 462 43 95
5 Rights of website users / data subject rights
Within the scope of the data protection law applicable to you, you have the right as a data subject to obtain information about your data stored by GCB. You can also assert your rights to rectification, deletion or restriction of processing or the right to object to GCB. To assert your rights against us, you can contact us at the address given in section 3 Responsible party.
You can also enforce your claims in court or complain to a data protection supervisory authority, listed in section 4 Data protection supervisory authorities, about the processing of your personal data by us.
If data processing by us is based on your consent, you can revoke this at any time without giving reasons for the future.
6 Purpose and scope of data processing of the internet presence
6.1 Website Logs
All accesses to websites operated by GCB in connection with jackpots.ch are logged and stored in the log files of the web servers used. In the log files, only that information is stored which your internet browser automatically transmits to the server. These are in particular:
- IP address,
- Time of the server request,
- operating system,
- browser type/version,
- language setting,
- name of your internet service provider,
- website from which you accessed our site, and
- Pages that you access on one of the websites operated by GCB.
The transmitted data is stored in server log files for a period of up to 4 weeks. The storage is done for data security reasons to ensure the stability and operational security of our website.
6.2 Contact forms
Our websites contain contact forms that can be used to contact us. The transmission of the data entered in the contact forms is encrypted (SSL encryption). The data entered in the contact forms will be stored for the purpose of processing your request or contacting the person making contact. The use of our contact forms takes place on an expressly voluntary basis and with your consent.
6.2.1 Contact by e-mail
When you contact us by e-mail, the data you provide (your e-mail address, your name, if applicable, your telephone number and the other information provided in the e-mail) will be stored by us in order to process your request or answer your questions. The use of contact via e-mail is on an expressly voluntary basis and with your consent.
6.3 Data collected by GCB
For personalized services or access-protected areas or for the processing of requests and administration of your subscriptions, your registration and thus the creation of a user account may be required. Registration requires the entry of certain personal data. This concerns your e-mail address, your date of birth, a user name and a password.
In addition to the information marked as mandatory, you can voluntarily enter and store further personal data. This data is then stored in our system. Furthermore, we store data in connection with the use of our offers and services, such as game progress and scores. For the use of additional services, further personal data may be required and will be requested from you in this case. This concerns, for example, first and last name, nationality, address (complete postal address, postal code, city), cell phone number, gender, preferred communication channels and language preferences.
GCB is also entitled to request wage statements, proof of income/assets or tax documents from you in order to fulfill its legal obligations under the money laundering laws and the regulations to combat money laundering and terrorist financing. In order to comply with legal requirements, GCB may additionally collect and/or update personal data through third parties (public registers, credit agencies, subcontractors).
We record all communication of the player with other players via the gaming platform, in particular via the chat function, as well as with jackpots.ch.
If you post contributions (comments, photos, videos, etc.) using the corresponding functions in order to share them with other users, these may be published by us and thus made available to the general public. This also applies to your user name. We refer you to our terms and conditions, which you explicitly agree to by opening a player account. We would like to point out that once such data has been published on the Internet, it may still be accessible to third parties, for example via search engines, even if you or we delete or anonymize it.
We collect, store, process and use your personal data exclusively for the purpose of providing our own services and for the delivery of marketing information.
6.4 Recipients of data and transfer to third parties
If we outsource certain parts of our data processing (e.g. IT service providers), we contractually oblige the contractor(s) to use personal data only in accordance with the requirements of applicable data protection law and to ensure the protection of the rights of the data subject. In addition, we also use (IT) services from our parent company Stadtcasino Baden AG. We also use IT service providers from the USA, with whom we conclude corresponding contracts (in particular based on the so-called standard contractual clauses of the European Commission) and ensure an appropriate level of protection by means of technical and organizational measures.
Within the scope of fulfilling their legal mandate, the Swiss Federal Gaming Board ("SFGB"; "Supervisory Authority") and authorities may request to inspect the data.
In order to fulfill our legal obligations, in particular to protect players from excessive gambling and to combat crime and money laundering, we process the following data and may disclose it to the supervisory authority:
- Data collected during the online registration of players.
- Data about players' gaming behavior and financial transactions.
- Data about players' personal, professional and financial situation.
- Data about the blocking of players. GCB is required by law to make the identity of persons affected by a gambling ban available to other casinos in Switzerland. In addition, the date of issue, the type of ban and the name of the casino that imposed the ban will be disclosed. This information obligation is carried out by means of storing the information in a central database to which all Swiss casinos have access.
GCB cooperates with an addiction prevention center and a therapy facility in the implementation of the social concept (Art. 37 CDBG). During the cooperation, personal data is exchanged on a case-by-case basis.
In the event that a gambling ban is lifted, jackpots.ch is entitled to pass on the player's data, which is necessary to verify the lifting, to a cantonally recognized specialist or specialist office. If there are indications of money laundering, financing of terrorism, funds of criminal origin or criminal organizations, GCB is authorized to forward all necessary data to the Money Laundering Reporting Office.
GCB will disclose the personal data required to open your player account (cf. section 2 of the GTC) to third parties in Switzerland and abroad, in particular in the event of suspicion of fraud, money laundering or other criminal conduct, for the purpose of clarifying the suspicion, initiating criminal, civil or administrative proceedings and complying with government orders during and outside pending proceedings, insofar as this is permitted under Swiss data protection law.
jackpots.ch maintains a data recording system for the money games offered on the gaming platform in Switzerland, which records the above-mentioned player data and makes it available to the supervisory authority. For the duration of data retention, see section 6.5.
6.5 Storage period and data deletion
We process and store your personal data for the duration of the fulfillment of our contractual and legal obligations, for as long as it is necessary to achieve the purposes pursued with the processing, and for as long as we are legally obliged to store and document it. We may retain personal data for as long as claims may be brought against our company or as long as we are otherwise required to do so by law or legitimate business interests so require. If your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as a matter of principle and to the extent possible.
GCB uses so-called cookies on the website www.jackpots.ch to recognize multiple use of the offer by the same user/Internet connection owner. Cookies are small text files that your Internet browser stores on your computer. They are used to optimize the GCB website and offers. These are mostly so-called "session cookies", which are deleted after the end of your visit. These cookies are used to make our ads more relevant and interesting for you.
In some cases, however, these cookies provide information to automatically recognize you. This recognition is based, for example, on the IP address stored in the cookies.
We use analysis cookies to evaluate the use of our website. With the information obtained in this way, we can optimize our offers and provide you with easier access to the GCB website. The use of analysis cookies is based on your consent.
We also use marketing cookies. The use of marketing cookies is based on your consent.
6.7 Cookie setting and consent
6.8 Google Tag Manager
For more information on the Google Tag Manager, see: https://www.google.com/intl/de/tagmanager/use-policy.html
6.9 Web analytics - Google Analytics
We also use some services and technologies from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
We use Google Analytics, a web analytics service provided by Google Inc ("Google"), for the purpose of designing, analyzing and improving our websites in line with demand.
Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the websites will be transmitted to and stored by Google on servers in the United States. However, due to the activation of IP anonymization on our website, your IP address will be shortened by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and only shortened there.
Google will use this information for the purpose of evaluating your use of the websites and GCB applications, compiling reports on website activity and providing other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
6.10 Google Ads Conversion
Our websites use the Google conversion tracking. If you have reached one of our websites via an ad placed by Google, Google Ads will set a cookie on your computer. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of our websites and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies can therefore not be tracked through the website of Ads customers. The information obtained using the conversion cookie is used to create conversion statistics for Ads customers who have opted in to conversion tracking. Clients learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, you will not receive any information that can be used to personally identify users.
For more information on the purpose and scope of data collection and processing, as well as further information on your rights in this regard and settings options for protecting your privacy, please contact: Google Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
6.11 Google Remarketing
In addition to Google Ads Conversion, we use the Google Remarketing application. This is a procedure with which we would like to address you again. Through this application, our advertisements can be displayed to you during your further internet use after visiting our websites. This is done by means of cookies stored in your browser, which are used by Google to record and evaluate your usage behavior when visiting various websites. In this way, Google can determine your previous visits to our websites. According to its own statements, Google does not combine the data collected in the course of remarketing with your personal data, which may be stored by Google. In particular, according to Google, pseudonymization is used in remarketing.
If you do not wish to participate in remarketing, you can refuse the setting of a cookie required for this, see section 6.7.
6.12 Google Optimize
6.13 Facebook Custom Audience (Facebook Pixel)
Our websites use the visitor action pixel from Facebook, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland ("Facebook") for conversion measurement.
This makes it possible to track the behavior of site visitors after they have been redirected to the corresponding website of the provider by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimized.
You can also deactivate the "Custom Audiences" remarketing function in the settings section for advertisements at https://www.facebook.com/help/109378269482053/?helpref=hc_fnav . To do this, you must be logged into Facebook.
If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: https://www.youronlinechoices.com/ch-de/praferenzmanagement .
7 Data security
We take appropriate technical and organizational measures to protect your personal data from unauthorized access and misuse, such as issuing directives, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization or anonymization and controls.
8 Changes to this data protection information
GCB reserves the right to change this policy at any time in compliance with applicable and valid data protection regulations. Changes will be published on GCB's website (www.jackpots.ch) and will become effective when posted. The current status is August 2022.
If you have any questions regarding the processing or security of your personal data, you can contact the GCB data protection officer directly in accordance with section 3 above.