Privacy Policy

Purpose / activity	Type of Data	Grounds for processing
To allow you to create and manage a user account on our website, including managing your public profile wish list products of interest, preferences, feedback, product reviews and survey responses, connecting with other website members and sharing games with your friends.	Identity and Contact Data Profile Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary for our legitimate interests of enabling users to create and develop personalised accounts, to facilitate purchases and recording of product and service preferences, for running our business and to develop new business.
To check your age eligibility to buy certain Codes, to process and deliver your order including managing payments, fees, charges and refunds; processing IG Credits and gift card credits; and collecting and recovering money owed to us.	Identity and Contact Data Profile Data Financial Data Transaction Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests to administer our services, to collect sums due to us and to keep our records updated.
To respond to queries submitted through the website, telephone, social media or other means and to manage our relationship with you including: (i) product and service support; (ii) notification of changes to our services, terms of sale, cookies policy, privacy notice or other policies; (iii) user feedback, product review and survey facilities; (iv) user complaints and disputes; (v) administering your marketing and communication preferences; (vi) administering your data protection, privacy and other rights.	Identity and Contact Data Profile Data Financial Data Transaction Data Technical Data Usage Data Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests for responding to user queries, attracting new users, affiliates and partners, running our business and to develop new business, keeping our records updated and to gauge consumer satisfaction with our services and/or the codes they purchase.
To administer and protect our business, products, services, networks, systems, the website and data and property hosted on or made available through the website including implementing and monitoring security measures, troubleshooting, data and usage analysis, testing, system maintenance, support, reporting and hosting of data.	Identity and Contact Data Profile Data Financial Data Transaction Data Technical Data Usage Data Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests for running our business, IT systems administration, network security, to identify and/or prevent fraud, to collate statistical business to enhance our services and business, and in the context of a business reorganisation or group restructuring exercise.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Identity and Contact Data Technical Data Usage Data Marketing and Communications Data	Necessary for our legitimate interests to study how users use our services, to develop them, to grow our business, to inform our marketing strategy and output and to conduct marketing.
To use data analytics to monitor usage of the website, to measure the performance of the website and to optimise the website, to improve our services, marketing strategy and output, user interactions, relationships and experiences.	Technical Data Usage Data	Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about products or services that may be of interest to you, including by way of news updates and other communications and to observe the readership of our news updates and other communications through the use of tracking technologies.	Identity and Contact Data Technical Data Usage Data Marketing and Communications Data	Necessary for our legitimate interests to develop our products and services, direct market and grow our business.
Instant-Gaming partners only: To register you as a new Instant-Gaming partner; to manage and administer our business relationship; to administer, collect and make payments, fees and charges relating to our business relationship; to comply with our legal obligations, including maintaining records; to comply with our insurance policies and to exercise or defend our legal rights, or to comply with court orders.	Identity and Contact Data Financial Data Transaction Data Technical Data Usage Data Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests to keep our records updated, manage sums payable by or to us, effectively manage and grow our business.

Generally, we do not rely on consent as a legal ground for processing your personal data although we will request your consent before sending direct marketing communications to you via email, text message or other electronic means.

Marketing: We would like to send you information about our services, upcoming game releases, preorders and offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email and/or by mobile push notifications.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by using the ‘unsubscribe’ link in emails, changing your notifications settings on your mobile device or by contacting us using the information set out in section 13 below. You can also manage your personal data associated with your user account via the settings page.

If you agree as part of our cookie’s framework, we will use certain technologies that allow us to see whether news updates and other communications we send to you have been viewed and read. As explained in section 6 above, we use this information for our legitimate interests to develop our products and services, direct market and grow our business.

Except as set out in this privacy notice, we do not disclose to any third-party personal data that we collect from you or you provide to us. We may have to share personal data with the parties set out below for the purposes set out in section 6 above.

 

Third parties: Companies assist us in providing our services. For example, our payment gateway provider(s), assists us with the processing of your payments (depending on your chosen method of payment for Codes), customer services, technical support, managing cancellation rights and where applicable issuing refunds or other payments.

 

External third parties: Companies that provide products and services to us such as professional advisors, IT systems suppliers and support, data storage, IT developers, analytics companies, website hosting providers and other service providers.

 

Public and government authorities: Entities that regulate or have jurisdiction over us. We will disclose personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities or in order to enforce a contract with you or to protect our rights, property or safety and/or that of our staff, website users and others.

 

Corporate activity: Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

We require all third parties who we disclose personal data which we collect under this privacy notice, to respect the security of personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent this sharing at the time that we notify you.

Data Processing and Transfer

Location of Data Processing

• Personal data of users accessing our website from Saudi Arabia may be processed for marketing and analysis purposes.

Data Transfer

• By accessing our website, you acknowledge and agree that your personal data may be transferred to and processed to third party partners.

Compliance with Laws

• We ensure that our privacy policy complies with all applicable laws and regulations in (CCPA & GDPR) regarding data protection and privacy.

Data Protection Measures

• Wasit Al Najah LLC implements appropriate technical and organizational measures to safeguard personal data processed on our behalf, in accordance with Saudi Arabian laws and regulations.

Data Sharing and Disclosure

• Personal data processed by Wasit Al Najah LLC may be shared with us for the purposes outlined in this Privacy Policy. Such sharing and disclosure will be conducted in compliance with applicable laws and regulations.

Contact Information

• If you have any questions or concerns regarding the processing of your personal data by Wasit Al Najah LLC, please contact us using the information provided in this Privacy Policy.

We are located in Dubai and so your personal data will be received and processed by us in Dubai. It may be necessary for us to disclose some of your personal data to our trusted suppliers or partners who provide us with products and services that assist us in providing our services to you. Our trusted suppliers and partners are located inside the European Economic Area and Saudi Arabia. We will ensure that any local/international transfers of your personal data are in accordance with applicable laws.

It is important that the personal data we hold about you is accurate and current. Please keep us informed, using your user account settings page, if any of your personal data changes during your relationship with us. You can also contact us using the information provided in section 13 below to update your personal data.

We have security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to obligations of confidentiality. You recognise that no entity can keep personal data fully secure. If you have reason to believe that any of your personal data is no longer secure, please notify us immediately by contacting us using the information provided in section 13 below.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a legal dispute in respect of our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Under certain circumstances, by law you may have the right to:

 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. This enables you to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you.

 

Right to withdraw consent: If you provide your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you wish to withdraw your consent, we will take steps to ensure we no longer process your personal data for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

In order to exercise one or more of your rights in respect of your personal data, please contact us in writing using the information provided below. We will need you to provide us with information to identify you on our records, we will also need proof of your identity and address, and the information to which your request relates.

Please note that the settings page of your user account enables you to update, manage and download certain of your personal data and to disable your user account and delete [all] personal data associated with your user account.

You have the right to make a complaint to the data protection supervisory authority. However, we would appreciate the chance to deal with your concerns before you contact the supervisory authority and therefore ask you, please contact us in the first instance using the information provided below.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us through the support and contact us links on the website or by logging into your user account and log. You can reach us by email to  support@neoplay.me

We will change this privacy notice from time to time and any changes will be contained in a revised privacy notice posted on the website. This version of the privacy notice was last updated on 1st July 2024 and historic versions can be obtained by contacting us using the information above.