PRIVACY POLICY

1. Who We Are

Pinateros.com is the official website for the "Pinateros" slot game, developed by Swintt. This website is operated by:

This website primarily serves as an informational hub for the "Pinateros" slot game, offering details about its features, mechanics, and providing access to a demo version. While we may direct you to licensed online casinos where you can play "Pinateros" for real money, we do not directly process real-money transactions or hold your gambling account funds on this site.

2. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data: Includes first name, last name, username or similar identifier, date of birth (if provided for age verification for demo access or newsletter sign-up).
• Contact Data: Includes email address, telephone numbers (if provided for support or newsletter).
• Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Includes information about how you use our website, such as pages visited, time spent on pages, game features interacted with in the demo version (e.g., number of spins, bets placed in demo mode, bonus features triggered in demo), referring website, and search terms.
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
• Aggregated Data: We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences directly. However, please note that when you proceed to licensed casinos for real-money play, they will have their own privacy policies that may cover such data in the context of their regulatory obligations (e.g., AML, responsible gambling).

3. How We Collect Your Data

We use different methods to collect data from and about you, including through:

Direct interactions:

You may give us your Identity, Contact, and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

• Sign up for our newsletter.
• Contact us with an enquiry or to request support.
• Participate in surveys.
• Provide feedback.

Automated technologies or interactions:

As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies (including Yandex.Metrica).

Third parties or publicly available sources:

We may receive personal data about you from various third parties, such as:

• Analytics providers (e.g., Yandex.Metrica, as detailed below).
• Affiliate partners (e.g., if you click on a link from an affiliate site to ours, or from ours to a casino, they may pass anonymised tracking data).
• Technical, payment and delivery service providers.

4. How We Use Your Data and Our Legal Basis

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Purpose/Activity	Type of Data Collected	Lawful Basis for Processing
To provide and manage your access to our website and the Pinateros demo game.	Identity, Contact, Technical, Usage	Performance of a contract with you (e.g., allowing you to use the demo game); Legitimate Interests (to ensure our website functions correctly and efficiently).
To manage our relationship with you, including notifying you about changes to our terms or privacy policy.	Identity, Contact, Marketing and Communications	Performance of a contract with you; Legal Obligation (to inform you of changes); Legitimate Interests (to keep our records updated and to study how customers use our services).
To send you newsletters, updates, and marketing communications about Pinateros or other related games and promotions (if you have opted in).	Identity, Contact, Marketing and Communications	Consent (where required by law); Legitimate Interests (to promote our services to existing customers, where consent is not required, with clear opt-out options).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).	Technical, Usage, Identity	Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring); Legal Obligation (e.g., for security audits).

5. How We Share Your Data

We may share your personal data with the parties set out below for the purposes described in this policy:

Internal Third Parties:

Other companies within our corporate group (if applicable) who provide IT and system administration services and undertake leadership reporting.

External Third Parties:

• Service Providers: Such as IT and system administration services, hosting providers, analytics providers (e.g., Yandex.Metrica), and email communication services.
• Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Regulators and Other Authorities: Including the UK Gambling Commission (UKGC), Information Commissioner's Office (ICO), and other relevant authorities who require reporting of processing activities in certain circumstances.
• Affiliate Partners: We may share anonymised or pseudonymised data (e.g., unique click IDs) with our affiliate partners to track referrals and commissions. This data does not directly identify you.
• Game Provider: Swintt, the provider of the Pinateros game, for technical support, game performance monitoring, and ensuring fair play.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party 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.

6. International Transfers of Your Data

Your personal data may be transferred to, and stored at, a destination outside the UK or European Economic Area (EEA).

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

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 litigation in respect to 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.

9. Your Legal Rights

Under certain circumstances, you have rights under UK GDPR in relation to your personal data. These include 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• 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 to continue to process it.
• 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in specific scenarios.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

10. Cookies and Other Tracking Technologies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please refer to our dedicated Cookie Policy.

11. Responsible Gambling

As an operator in the online gambling ecosystem, we are deeply committed to promoting responsible gambling. While Pinateros.com itself does not offer real-money gambling, we acknowledge the risks associated with it. We strive to be a trustworthy resource by:

• Age Verification: We take steps to ensure that access to our demo game and marketing materials is not available to individuals under the legal gambling age (18+ in the UK).
• Informational Resources: We provide clear information about the nature of the "Pinateros" game, including its RTP (Return to Player) of 96.17%, to help users make informed decisions.
• Signposting Support: We strongly encourage anyone concerned about their gambling habits or those of a loved one to seek help. We provide links to reputable organisations that offer support and advice.
• Transparency in Game Mechanics: We clearly detail the game's features, betting options, and potential outcomes, reinforcing fairness and clarity.

12. Commercial Transparency: Affiliate Disclosure

Pinateros.com may participate in casino affiliate programs. This means that if you click on a link to a casino or gambling operator from our site and subsequently register an account, make a deposit, or engage in other specified actions, we may receive a commission from that operator.

This comes at no additional cost to you. Our participation in these programs helps us to maintain and improve Pinateros.com, providing you with high-quality content and resources about the "Pinateros" slot game. We are committed to transparency and will only recommend licensed and reputable gambling operators.

13. Changes to This Privacy Policy

We keep our Privacy Policy under regular review. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy. This policy was last updated on the Effective Date stated at the beginning of this document.

14. How to Contact Us

For any questions regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer (DPO):

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.