Privacy & Management of Personal Data

Overview

This Privacy Notice explains how Mmk121 collects, uses, stores and discloses your personal data in connection with our online betting, gaming and related services. The data controller responsible for your personal data depends on your geographic location and may include Mmk121 Limited or other entities within the Mmk121 group acting as data controllers. We update this notice when our processing changes and will notify you of material updates in accordance with applicable law.

Categories of personal data we collect

  • Identity data: username, account number, name, title, gender, date of birth.
  • Contact data: email address, postal address, telephone number.
  • Demographic data: age verification information where required.
  • Financial data: payment methods, transactions, bank account details, billing information.
  • Account activity data: betting and gaming activities, session timestamps, device identifiers, IP address.
  • Safety and compliance data: KYC information, source of funds, affordability data, self-exclusion, deposit limits, product blocks.
  • Communication data: records of support interactions, feedback, and complaints.
  • Marketing data: marketing preferences and responses to campaigns.
  • Health-related data for safer gambling: information provided in relation to safe gambling measures, where relevant and with consent or within permitted public interest grounds.
  • Third-party data: information obtained from verification providers, credit reference agencies and affiliates for identity, fraud prevention and risk assessment purposes.

How we process your personal data (legal bases)

  • To provide our services under a contract: account creation, topping up funds, placing bets, playing games and related account management.
  • To comply with legal and regulatory obligations: anti-money laundering, counter-terrorism financing, gambling regulation, and reporting to regulators.
  • To protect legitimate interests: fraud prevention, risk assessment, safeguarding against problem gambling, and the integrity of our services.
  • With your consent for processing such as direct marketing and certain health-related data for safer gambling interactions.
  • For purposes of research and product development on a legitimate interest basis, including testing new features and conducting surveys with appropriate safeguards.

Sharing and disclosure of personal data

  • Within the Mmk121 group and with service providers who perform services on our behalf (e.g., payment processing, IT support, customer service, data hosting, fraud prevention, and marketing operations).
  • With regulators, law enforcement or other authorities as required by law or to respond to lawful requests.
  • With third parties for identity verification, affordability assessments, and anti-fraud checks; we require these partners to protect your data consistent with this Notice.
  • For marketing with consent or where we have a legitimate interest, including tailored advertising and communications in accordance with your preferences.
  • In the event of a corporate transaction or restructuring, your personal data may be transferred to the acquiring entity pursuant to applicable law and with appropriate protections.

Transfers of personal data abroad

We may transfer your personal data to recipients located inside the United Kingdom, the European Economic Area and other jurisdictions as necessary to provide our services. Where transfers occur to countries outside the UK/EEA that do not provide an adequacy decision, we rely on standard contractual clauses or other approved transfer mechanisms to protect your data in accordance with applicable law. You may request further information about the transfer safeguards at any time.

Safeguarding your data

  1. Technical security: we implement encryption, access controls, and secure development practices to protect personal data.
  2. Organisational measures: we conduct regular staff training, policy reviews, and data minimisation practices to limit exposure.
  3. Data protection assessments: we perform Data Protection Impact Assessments where processing is likely to result in high risk to individuals’ rights and freedoms.

Data retention

We retain personal data only as long as necessary to fulfil the purposes described in this Notice and to comply with legal obligations. In general:

  • Account records and transaction history: retained for the duration of the active relationship plus six (6) years after account closure to satisfy AML/AML- and regulatory-reporting requirements.
  • Supporting documents for KYC, source of funds and affordability: retained for the duration of the relationship and for a period required by applicable law after termination.
  • Marketing data: retained until you withdraw consent or object to processing, after which we will stop marketing communications and retain only as necessary to demonstrate compliance with your preferences.
  • Aggregated/anonymised data: retained indefinitely for analytical purposes, and in such form no longer identifies individuals.

Your rights

  • Access: you may request a copy of your personal data in our custody or control.
  • Rectification: you may request correction of inaccurate or incomplete data.
  • Erasure: you may request deletion where processing is no longer necessary or unlawful, subject to legal exceptions.
  • Restriction of processing: you may request suspension of processing in certain circumstances.
  • Portability: you may request a structured, commonly used and machine-readable version of your data.
  • Objection: you may object to processing based on legitimate interests or for direct marketing, where applicable.
  • Withdrawal of consent: where processing is based on consent, you may withdraw consent at any time.
  • Complaint: you may lodge a complaint with a data protection authority if you consider our processing to be unlawful.

Automated decision-making and profiling

We may use automated processing, including risk scoring and behavioral profiling, to assess eligibility, detect fraud and manage safer gambling measures. You have the right to obtain human review of decisions that produce legal or similarly significant effects concerning you, and to challenge or request a reassessment where applicable.

Marketing and cookies

We may use personal data to deliver personalised content and direct marketing in accordance with your preferences and applicable law. You can update your marketing preferences in your account settings or contact our privacy team. We may use cookies and similar technologies to collect preference data and optimise our services; you can manage cookie settings through your device or browser.

Safer gambling and health information

We process health-related information only to support safer gambling interventions and with your explicit consent where required, or where processing is otherwise permitted by law in the interest of protecting your health and safety. We will limit such processing to the minimum necessary to achieve the safety objective and you may withdraw consent where applicable.

Children

We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected such data, we will take steps to delete the information promptly, where legally permissible.

Changes to this privacy notice

We may update this Privacy Notice from time to time. Material changes will be communicated to you in accordance with applicable law and, where required, will be brought to your attention in the service interface or by other appropriate means.

How to contact us

If you have questions about this Privacy Notice or wish to exercise your rights, you may contact our Data Protection Team at [email protected]. You may also lodge a complaint with the relevant data protection authority if you consider our processing to be unlawful.