This file describes the information collection and disclosure practices of the Web Site, possessed by the
Maritime Enterprise Group. (separately and jointly referred to as "the Operator").
1.2 Your use of the Website and any content or programs accessible on it'll be called the
"Services".
2.1 Your private information (ie, info about you by which you may be personally identified,
such as name, address, phone number or email address, understood in this Privacy Policy as "Your
Information"), will be processed by the Operator (including their representatives and workers), and (as
appropriate) by our associates and subcontractors in order to supply a broad variety of services. Your
advice will be gathered when you register to start an account with us, or when you send a written question
to us.
2.2 2 While the Web sites may include links to other Web sites operated by third parties, the
Operator isn't responsible for the practices relating to the privacy or content of any such
websites.
2.3 By using any of the Services, you agree that you've read and agree with the conditions of
this Privacy Policy and, by supplying your advice (including, for the avoidance of doubt, your a query
through one of the web sites, or if you've finished the enrollment procedure of your account just somewhat),
you consent to the use of such advice by the Operator (and our associates and subcontractors) for the goals
set out in paragraph 3 of this Privacy Policy.
2.4 If you don't want to supply your information under the provisions of this Privacy Policy,
you shouldn't enter the applicable information in the spaces provided for such purpose in the accompanying
section in any of the Websites, or supply any private information over the telephone. But unless such advice
is provided by you, you may not be permitted to use in full the applicable part of the Services.
2.5 As part of the enrollment procedure for your account, we additionally offer visitors filing
with us the chance to choose not to be kept informed about future events, offers and promotions from the
Operator. Visitors wishing to elect with this choice must "assess" the proper box on the enrollment
procedure. It is possible to update your marketing preferences at any time under "My Account / Update
Marketing Preferences" (or similar) on the Web Site (if that choice is available) or by contacting the
Customer Service. If, when the choice is available, you've got chosen for information regarding forthcoming
events, offers and promotions by text messages to mobile phones, you are going to have the choice to
discontinue receiving such information anytime by replying with the word "STOP ".
2.6 We can, in the usual course of our business and for the purposes of payment processing,
share your Personal data with the relevant personnel within the company, or with our duly authorized banking
partners / processors, contractors/subcontractors, to ensure continuity of business process and maximize the
quality and efficiency of our services.
2.7 We may also be obliged to disclose Personal data to regulatory authorities, courts, and
government agencies where required by law, regulation or legal process, or to defend the interests.
Otherwise, we will not share your Personal data with other parties unless you request it or have given us
prior approval to such sharing.
3.1 The Operator will gather your information in order to:
3.1.1 Be able to start Your Account for you to use all the features of our Services, including,
among others, add fund to your account, place bets and play games;
3.1.2 Receive your questions and comments through our Online Support Centre, and reply
them;
3.1.3 Comply with all relevant regulations affecting Your enrollment, for example, confirmation
of age; and
3.1.4 (Provided you don't choose to be excluded from this choice), keep you informed about
future events, offers and promotions from the Operator.
3.2 In addition to a comprehensive thing identified in paragraph 3.1 above, the Operator will
only use Your Information, including sharing Your Tips with our associates and subcontractors who process
data (including, where appropriate, Your Information) on our behalf, to:
3.2.1 open, run and manage Your Account;
3.2.2 Supply all the services that you request and for any other function related to the supply
of such services;
3.2.3 Check the correctness of your info, including the disclosure of such information to third
parties, including financial institutions and age verification bureaus and credit reports, to that function.
We are going to maintain an archive of the confirmation and such third parties may use the advice to help
other companies for verification purposes);
3.2.4 compile data regarding use of the Services by you and other customers;
3.2.5 develop and exhibit material and proper personalized advertising content;
3.2.6 occasionally send to bill holders written communications to announce important service
changes, upgrades on specialized problems and shifts to the Terms of Use (including this Privacy
Policy);
3.2.7 Execute our duties, obligations and regulatory responsibilities under the Gambling Act
2001, before the Regulatory Authority of Curacao, and in accordance with relevant law and with appropriate
regulatory agencies in other jurisdictions where the Operator develops a controlled activity;
3.2.8 Satisfy legal requirements, or to take measures to protect the interests of sporting
bodies or other related agencies;
3.2.9 investigate the suspected unlawful, fraudulent or improper actions in relation to the
Services;
3.2.10 report a criminal violation or feeling, including money laundering or fraud of any sort,
and
3.2.11 all other functions essential to meet our contractual obligations to you.
3.3 The Operator will not send you unsolicited advice regarding commercial offers or third
party marketing.
3.4 The Operator may use your username and / or first name and area for marketing or
promotional goals.
3.5 Phone calls made or received by our Customer Service Department may be recorded for
training and security functions.
3.6 We may transfer Your advice in case of transfer or sale of our company or part of it,
including in the event of insolvency.
3.7 If at any time you want to discontinue our task processing your advice for the goals listed
above, please contact us and we will take the proper measures to comply with your request. You should bear
in mind the determination may affect the closing of Your Account.
4.1 Within the context of the supply of services, the Operator may need to transfer
information (including, Your Advice) to:
4.1.1 Other firms within the same group of firms as the Operator, and
4.1.2 our associates and subcontractors found in their home countries
5.1 You may update or delete your information at any time from your account using the "My
Account / Update my account" option (if available), or by contacting the Customer Service Section.
5.2 You may get a copy of Your info held by the Operator by contacting the Customer Service. We
require to be notified in advance of up to thirty (30) days to satisfy your request.
6.1 OBJECTIVE OF THE POLICY
6.1.1 Funclubcasino.com is fully committed to be constantly vigilant to prevent money
laundering and combat the financing of terrorism in order to minimize and manage risks such as the risks to
its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent
serious crime and not to allow its systems to be abused in furtherance of these crimes.
6.1.2 Funclubcasino.com will endeavour to keep itself updated with developments both at
national and international level on any initiatives to prevent money laundering and the financing of
terrorism. It commits itself to protect, at all times, the organization and its operations and safeguards
its reputation and all from the threat of money laundering, the funding of terrorist and other criminal
activities
6.2 OBLIGATIONS
6.1.1 In order to adhere to the requirements of the Prevention of Money Laundering Act, the
regulations and any guidance notes Funclubcasino.com shall as a minimum:
(i) Appoint one of its senior officers as the designated Money Laundering Reporting Officer
(MLRO) whose responsibilities will include the duties required by the laws regulations and guidance
notes.
(ii) Take reasonable steps to establish the identity of any person for whom it is proposed to
provide its service. For this purpose, the process for the registration of Players provided for under the
General Terms and Conditions provides for the due diligence process that must be carried out before the
opening of a User Account.
(iii) keep at all times a secure online list of all registered Players.
(iv) Retain identification and transactional documentation as defined in the laws regulations
and guidance notes.
(v) Provide initial and ongoing training to all relevant staff so that they are aware of their
personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity,
record-keeping and reporting any unusual/suspicious transactions.
(vi) Ensure that this policy is developed and maintained in line with evolving statutory and
regulatory obligation and advice from the relevant authorities.
(vii) Examine with special attention, and to the extent possible, the background and purpose of
any complex or large transactions and any transactions which are particularly likely, by their nature, to be
related to money laundering or the funding of terrorism.
(viii) Report any suspicion or knowledge of money laundering of terrorism financing to the
Curacao Gaming Commission and relevant authorities from the country the transaction was initiated.
(ix) Cooperate with all relevant administrative, enforcement and judicial authorities in their
endeavour to prevent and detect criminal activity.
6.3.1 Not accept to open anonymous Accounts or Accounts in fictitious names such that the true
beneficial owner is not known.
6.3.2 Not accept cash from Players. Funds may be received from Players only by any of the
following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other
method.
6.3.3 Not register a Player who is under eighteen (18) years of age.
6.3.4 Only register a single account in the name of a particular person: multi-account
practices are strictly prohibited.
6.3.5 Transfer payments of winnings or refunds back to the same route from where the funds
originated, where possible.
6.3.6 Not accept a wager unless a User Account has been established in the name of the Player
and there are adequate funds in the Account to cover the amount of the wager.
6.3.7 Not accept a wager unless the funds necessary to cover the amount of the wager are
provided in an approved way.
6.3.8 Not accept Players residing or playing from non-reputable jurisdictions.
6.3.9 Not make a payment in excess of two thousand (US$/AU$2,000) out of a User Account to a
Player until the Player's identity, age and place of residence have been verified.
6.3.10 Where it deems necessary, verify creditworthiness of the Player with third parties who
previously provided any information on the Player.
6.3.11 If it becomes aware that a person has provided false information when providing due
diligence documents, not register such person. Where that person has already been registered,
Funclubcasino.com shall immediately cancel that person's registration as a Player with the company.
7.1 If at any time you believe that the Operator hasn't complied with the principles included
in this Privacy Policy, you can contact the Customer Service, and we will use all commercially reasonable
efforts to discover and correct the issue as soon as possible.
7.2 Effective Date of this Privacy Policy: 1st of July, 2016