PRIVACY AND COOKIE POLICY

Effective Date: 16.06.2025

IDENTIFICATION OF THE DATA CONTROLLER

Entity: Thelivering Ltd. (hereinafter referred to as “Casinobud” or “we”)
Head office: Level 4, Pendergardens Business Centre 44, St Andrew’s Road, STJ 9023, ST Julians, Malta
Email: info@thelivering.com
Data Protection Officer (DPO): dpo@casinobud.com

2. PURPOSE AND SCOPE

This Privacy and Cookie Policy aims to transparently inform users about how we process personal data in connection with their access to and use of our website (www.casinobud.com) and our related services. We are committed to complying with the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and other applicable laws, ensuring the protection of natural persons regarding the processing of personal data and the free movement of such data.

We only collect personal data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. This policy may be updated at any time to reflect changes in legal or operational requirements.

3. CATEGORIES OF PERSONAL DATA AND LEGAL GROUNDS FOR PROCESSING

The personal data we collect depends on your interaction with our platform and may include:

Identity and contact data (e.g., name, email, address, phone number, nationality, date of birth)
Account and login information (e.g., username, password)
Financial and transactional data (e.g., deposits, withdrawals, bank details)
Official documents (e.g., government-issued ID)
Gaming activity and preferences
Support interactions
Technical and device data (e.g., IP address, browser, operating system)
Marketing preferences

These data are processed for the following purposes and under the corresponding legal bases:

Legal Base	Purpose
Performance of a contract	Account creation, user identification, deposits and withdrawals, gameplay, support services
Legal obligation	Identity verification, anti-money laundering (AML), responsible gaming measures, tax reporting
Legitimate interests	Security, analytics, service improvement, fraud prevention
Consent	Marketing communications, optional surveys, cookies where applicable

4. HOW WE COLLECT PERSONAL DATA

We collect personal data through several means:

Directly from you, when you register an account, complete forms, provide identification documents, participate in promotions, or interact with costumer support via email, chat or phone.
Automatically, trough your use of our website and services, using cookies, session logs, IP tracking, device identifiers and other similar technologies. This includes behavioural data such as pages visited, login timestamps, clickstream data and geolocation (where permitted).
From third parties, such as identity verification providers (for KYC/AML compliance), payment service providers, marketing partners, fraud prevention services and social media platforms if you choose to log in using third-party credentials.
Publicly available sources, where applicable, to verify the accuracy of information provided or fraud detection purposes.

All data collection is carried out in accordance with the GDPR principles of lawfulness, fairness and transparency.

5. DATA RETENTION

We retain your personal data only for as long as necessary for the purposes for which it was collected, or to comply with legal and regulatory obligations. The general retention periods are:

RETENTION PERIODS
Transactional data	10 years (for tax and regulatory purposes)
Gaming and AML compliance	5 years after account closure
Support records	2 years from last interaction
Marketing	Until consent is withdrawn
Legal purposes	Duration of the applicable statute of limitations

After the expiration of retention periods, data is securely deleted or anonymised, unless further retention is required by law or necessary for the establishment, exercise or defence of legal claims.

6. DATA DISCLOSURE AND INTERNATIONAL TRANSFERS

Access to your personal data is strictly limited to those employees, contractors, and service providers who need it for the performance of their duties and who are bound by confidentiality obligations.

Typical categories of recipients include regulatory authorities, payment service providers, ID verification vendors, anti-fraud service providers, IT and infrastructure partners, and marketing or analytics platforms acting as processors under our instruction, with whom we may share your data only to the extent required for the purposes defined in this Policy.

In some cases, your data may be transferred outside the European Economic Area (EEA). Such transfers will only take place where adequate safeguards are in place, including but not limited to the use of Standard Contractual Clauses approved by the European Commission, under Article 46 GDPR.

7. DATA SUBJECT RIGHTS

As a data subject, you have the right to exercise the rights granted by Chapter III of the GDPR, which include the right to access your personal data; the right to rectify inaccurate or incomplete data; the right to erasure ('right to be forgotten'); the right to restrict the processing of your personal data; the right to object to the processing of data when based on legitimate interests or for direct marketing purposes; and the right to data portability, which allows you to receive your data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

You also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you, except where such processing is necessary for the performance of a contract, authorised by Union or Member State law, or based on your explicit consent.

Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of your rights, contact our DPO at dpo@casinobud.com.

8. USE OF COOKIES

This Cookie Policy is part of our Privacy and Cookie Policy and provides information about how Casinobud uses cookies and similar technologies through our website www.casinobud.com.

Cookies are small text files stored on your device when you visit a website. They help improve your experience, enable certain functionalities, and allow us to analyze usage.

Types of cookies we use:

Strictly necessary cookies: Essential for core website functions such as security, navigation, and user login.
Analytics cookies: Help us understand user behavior to improve performance and content.
Marketing cookies: Track user activity for advertising and audience targeting.

We may use both first-party and third-party cookies. Details about specific cookies used, their purpose, and duration are available upon request.

You can manage your cookie preferences using:

The cookie banner displayed when you first visit the website;
'Manage Cookies' button displayed on the website;
Your browser settings, where you can delete or block cookies.

For more information on managing cookies through browsers, visit:

You may withdraw your consent at any time via the 'Manage Cookies' button or your browser preferences. Disabling cookies may affect your experience on the website.

We use Google Analytics, a web analytics service provided by Google LLC, to collect statistical data about the usage of our website. This helps us understand user behaviour and improve our services. Google Analytics may collect data such as your IP address, browser type, and visited pages. These cookies are only used with your explicit consent. You can opt-out at any time using our cookie management tool or by installing the opt-out browser add-on available from Google at: http://tools.google.com/dlpage/gaoptout.

9. SECURITY MEASURES

We adopt appropriate technical and organisational measures to safeguard personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

These measures include encrypted connections (SSL/TLS), robust firewalls, physical access controls, role-based access management, pseudonymisation and encryption of data, logging and monitoring, and regular security training for all staff. While we strive to ensure a high standard of security, it is important to acknowledge that no system is entirely immune to cyber threats.

In the event of a data breach affecting your personal data, we will assess the situation without undue delay and, where legally required, notify the appropriate supervisory authority and data subjects. We maintain robust internal procedures to respond promptly and transparently in such scenarios.

We apply the principles of data minimisation and purpose limitation and ensure that Privacy by Design and Default are embedded into our systems and processes. Where required, we conduct Data Protection Impact Assessments to evaluate and mitigate any risks to data subjects.

10. SUPERVISORY AUTHORITY

If you believe that the processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with a supervisory authority. You may contact the authority in your country of habitual residence, place of work, or the place of the alleged infringement.

11. CHANGES TO THIS POLICY

We reserve the right to amend this Privacy and Cookie Policy to reflect legal, technical, or operational changes. Any significant modifications will be communicated through the website. The date of the last update will always be displayed at the top of this page.

For any questions about this policy or your data, please contact us at: dpo@casinobud.com.