PRIVACY AND SECURITY

Privacy Policy for "PuzzlerBingo" (the "Brand") at www.puzzlerbingo.com (the "Website")

1. Introduction

1.1 The Brand is owned by Mark Jones of Puzzler Media Limited (the Brand Owner) and managed on the Brand Owners behalf by Cashcade Limited ("Cashcade"). Cashcade is a limited company registered under the laws of England and Wales with company number 03831781 whose registered office is 6-10 Valentine Place, London SE15 8QH.

1.2 This Website and the services offered on it are powered by software belonging to Brigend Limited ("Brigend") which is a wholly-owned subsidiary of Cassava Enterprises (Gibraltar) Limited ("Cassava"). As such, all personal data and customer funds are transferred to and stored by Cassava on its servers in Gibraltar. Both Cassava and Brigend are companies registered under the laws of Gibraltar to provide such services. Cassavas registered office is at Suite 601/701 Europort, Gibraltar. Brigends registered office is at 57/63 Line Wall Road, Gibraltar.

1.3 Cassava is happy to provide you with online bingo services under its remote gambling licence issued by the Government of Gibraltar to Cassava.

1.4 Cassava, the Brand Owner and Cashcade (we or us) are committed to preserving the privacy of all visitors to this Website. Please read the following privacy policy to understand how we collect, use and protect the information that you provide to us. By registering and using this Website, you consent to the collection, use and transfer of your information under the terms of this policy.

2. Information that we collect from you

2.1 Your personal information is collated and stored by Cassava primarily during the registration process on its servers in Gibraltar, but is also monitored when there is activity on your account and when you use this Website.

2.2 The personal information that Cassava collects may include information such as: contact information (including name, address, age, gender, telephone number and email address), billing information, transaction history, website usage preferences, and feedback regarding the Service. This information is held by Cassava on servers based in Gibraltar.

2.3 Cassava then permits Cashcade and third parties to access and use your data for the purposes further set out below. As with many other websites, we may use software known as 'cookies' to store information relating to your preferences to enable us to improve our service to you.

3. Use of your information

3.1 Personal data submitted by you to us will only be used to the extent that it is strictly necessary for one of the following purposes:

(a) assisting us in setting up and managing your account;
(b) building an accurate customer profile;
(c) send you emails and SMSs to provide you with news in relation to this Website and the services provided from it.
(d) publishing on this Website and in other promotional materials information relating to wins of 10 or more comprising the amount of the win and the abbreviated name, home town, state or province and country of the winner.

3.2 We reserve the right to conduct a security review at any time to validate your identity, age, the registration data provided by you and to verify your use of this Website and your financial transactions for potential breach of our terms and conditions and of applicable law. By accepting this Privacy Policy, you authorise us, our staff, affiliates, subsidiaries, agents and suppliers to use your personal data and to disclose your personal data to third parties for the purposes of validating the information you provide to us in the course of using this Website, including where necessary the transfer of information outside of your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third party databases. In addition, to facilitate these security reviews, you agree to provide such information or documentation as we may request.

4. Disclosure of your information

4.1 Please note that information that you provide will be disclosed to the following parties:-

(a) Cashcade, Cassava and the Government of Gibraltar have access to your account information for use in accordance with the rules and guidelines that govern this Website.
(b) to our reputable marketing partners so that we can send you emails and SMSs to provide you with news in relation to this Website and the services provided from it;
(b) any company or other entity to whom we may sell all or part of our business so that we may continue to operate this Website;
(c) any competent legal, regulatory or law enforcement authority including the Government of Gibraltar;
(d) our professional advisers or other appropriate third parties, if your use of our service, our Games or this website is in breach of Cassavas terms and conditions; and
(e) other users of this Website and persons receiving promotional materials, in each case pursuant to the information we provide about winners detailed above.

4.2 Please note that in respect of the Government of Gibraltar you may not be informed of any disclosure nor of any reasons for such disclosure and you hereby waive any and all rights that you may have, whether at law or otherwise, of any nature and in any jurisdiction, in connection with such disclosure.

5. Security and Data Retention

5.1 We are committed to the security of all personal details entered onto this Website and employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires.

5.2 Our systems are rigorously tested and have been developed with encryption software and secure socket layer technology. All banking details and transactions are also protected by firewalls with a view to ensuring the security of all personal information and your complete peace of mind.

5.3 It is only necessary to enter your debit/credit card details once when they are stored in our secure servers using a proprietary encryption algorithm. After that your debit/credit card details will only be used when you make a deposit or withdrawal and are then transmitted between our secure servers and the secure servers of one of the UK's leading e-commerce payment companies which in turn has secure encrypted links between itself and all the major banks.

5.4 Our employees do NOT have access to your full debit/credit card details.

6. Accessing and Updating

6.1 To make data corrections or to obtain access to the data we have about you, you must send us a written request that should be addressed to the Director of Customer Services for Cashcade. We will disclose to you your personal data held by us, we shall correct or delete inaccurate details, and notify any third party recipients of the necessary changes. Changes to certain parts of your account information can also be made by accessing the 'My Account' section on this Website.

6.2 We regularly delete data that is no longer required. For further information on what data is held about you can be obtained by contacting us as follows:-

Address:
Cashcade Limited
10, Valentine Place
London
SE1 8QH

Telephone Number: UK: 0845 456 3044; Outside UK: +44 845 456 3044

Email:

6.3 You may also "opt-out" of receiving any promotional communications either by choosing to opt-out where such option is made available on this Website or by contacting us at the details set out above.

7. Cookies

Cookies are small amounts of information which we store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to this Website. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalise the content of this Website for you. You may set up your computer to reject cookies although, in that case, you may not be able to use certain features on our Website. If you do not wish to receive cookies in the future, please let us know.

8. Changes to this Privacy Policy

Any changes to our privacy policy in the future will be posted to this Website and, where appropriate, through e-mail notification.

9. Protection of Children

The Service is not intended for or directed to persons under the age of 18. Any person who provides their information to us through any part of the Service represents to us that they are 18 years of age or older. If we become aware that a minor has attempted to or has submitted personal information via this Website, we will not accept this information and will take steps to remove such information from our records. This may involve us having to access and verify your personal information.

10. Ownership

With the exception of your personal details, all other information, including, but not limited to, ideas, submissions, emails, suggestions, concepts, graphics, chatroom contents including material and statements, posted on this website or submitted to us will become our property and we shall not be subject to any obligation of confidentiality and will be free to reproduce, modify, edit, adapt, publish, translate, distribute and display by us or anyone we designate in any and all media now known or in the future created.

11. Third-Party Practices

We cannot ensure the protection of any information or images that you provide to a third-party online site that links to or from this website or any information collected by any third party administering our affiliate program or any other program, since these third-party online sites are owned and operated independently of us. Any information collected by these third parties is not governed by this Privacy Policy but by the privacy policy, if any, of such third party. If you have questions about a third partys information practices, please read its privacy policy. We assume no responsibility or liability whatsoever for the practices, actions or policies of such third parties, and is not responsible for the content or privacy practices of such online sites.

12. Legal Disclaimer

13. Legal Compliance, Governing Laws and Disputes

13.1 We use our best endeavours to materially comply with the UK Data Protection Act 1998, the UK Privacy and Electronic Communications (EC Directive) Regulations 2003 and Gibraltan gaming and data protection/privacy laws.

13.2 This Privacy Policy forms part of Cassavas terms and conditions governing your use of this Website and as such shall be governed by and construed in accordance with the laws of England. You irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to resolve any dispute or claim of whatever nature arising out of or relating to this policy and consent or otherwise to the use of your personal data, and that the laws of England shall govern such dispute or claim. However, we retain the right to bring legal proceedings in any jurisdiction where we believe that infringement of our intellectual property rights or breach of those terms is taking place or originating.

13.3 You are responsible for compliance with any applicable laws and regulations of the jurisdiction from which you are accessing this Website.

Last amended: 14th July 2008