Privacy Policy



    1. This Privacy Policy sets out the ways and the manner in which, we, Crossed Swords Studio Ltd., reg. no. 11392644 trading as Loot Masters Studio Ltd., LABS Holborn, 136 High Holborn, Hogarth House, WC1V 2PX, London, UK (we, us, our), collect and use personal data that we may obtain about you. The manner in which we process your personal data and steps we take to protect your personal data and how you can review and correct your personal data are covered here. We ask that you read this Privacy Policy carefully as it contains important information about what to expect as to how we collect and use personal data about you.
    2. Unless the context otherwise requires, capitalised terms not defined in this Privacy Policy shall be as defined in the T&Cs, which, for the avoidance of doubt, also apply and you will need to read and understand the General Terms in addition to this Privacy Policy.
    3. We may occasionally update this Privacy Policy. When we do, we will revise the “last updated” date at the bottom of the Privacy Policy. Please ensure that you frequently check this Privacy Policy for any updates.
    1. By visiting our site and/or using our app, registering to use our Services or contacting us this Privacy Policy will apply.
    2. The personal data we collect from you may include the following:
      1. information you provide to us when registering for our Services;
      2. information you provide to us in any correspondence and a record of any correspondence we have with you;
      3. details of transactions you carry out with us, as well as information about your bank account in the event of any payment from us to you;
      4. information about your use of our Services;
      5. any information you provide to us through any surveys you complete or any competitions you enter;
      6. information made available to us through any 3rd parties, including but not limited to Facebook (login through Facebook) and AppStore providers (Google, Apple);
      7. information about any possible fraudulent, criminal or anti-money laundering activity which our systems detect; and
      8. information about your usage history and patterns.
    3. You are not required to provide any information to us, but if you do not, we may not be able to provide you the requested Services.
    1. In accordance with data protection laws, we will only process your personal data where we have a lawful basis for doing so. In respect of your personal data, these bases are where it is necessary to provide Services to you under the performance of the contract we have with you; where we are required to do so in accordance with legal or regulatory obligations; where you have given your consent; and where it is in our legitimate interests to process your personal data provided that these do not prejudice your own rights, freedoms and interests.
    2. We will process your personal data for the following purposes and in accordance with the following lawful conditions:
      1. To enable us to set up and operate your account so that you can make full use of all of the features of the Services, including crediting your account with funds.
      2. To provide the Services to you.
      3. To link your online account and retail accounts where you have requested this.
      4. To enable us to receive questions and comments from you through our help centre, and for us to be able to respond to them (consent).
      5. To record telephone calls and retain communications to and from our customer services department for training purposes to allow us to improve our customer services as well as for security purposes to allow us to identify persons in subsequent communications (legitimate interests).
      6. To comply with relevant regulations regarding your registration and to verify the accuracy of the personal data you provide to us, including disclosure of such information to third parties (including financial institutions, age verification, and credit reporting agencies) in connection with such purposes (a record of the search will be retained and the third party may use the information to assist other companies for verification purposes) (necessary to comply with a legal obligation).
      7. To comply with our regulatory duties, obligations and responsibilities and under any other valid and applicable legislation and to any other competent authority (meaning any authority having any governmental, judicial or regulatory jurisdiction over us or any other company in our company group) and as more particularly described in paragraph 3.3 (necessary to comply with a legal obligation).
      8. Where you set deposit limits we will use automated means to track your deposit amounts to ensure that we comply with your request (consent).
      9. Preparing statistics, providing analytical reports and analysis relating to the use of the Services by you and other customers (legitimate interests).
      10. Periodically sending written communications to you to announce important service changes, technical issue updates and changes to the T&Cs, including this Privacy Policy (necessary for the performance of a contract).
      11. To send you offers and promotions which may be of interest to your (but only where you have consented for us to do so) (consent).
      12. To provide you with personalised use of our Services so that we can offer you and other players a better service (legitimate interests).
      13. To profile you so that we can better understand your preferences and which products and offers would be most suitable for you and customers similar to you (legitimate interests).
      14. When you choose to download software pursuant to our Services, notification software may also be downloaded onto your access device. This allows us to send notifications to you about our Services directly to your access device, for example to inform you about new features, updates, service communications, offers and promotions. By downloading such software, you consent to receiving notifications. If you would prefer not to receive these notifications, you will need to manually uninstall the notification software from your access device. Please note that these notifications are distinct from marketing which is addressed below.
    3. We are required to implement measures to identify and investigate any suspected unlawful, fraudulent or improper activity connected with the Services, including possible money laundering, the use of proceeds of crime and fraud. We are also obliged to investigate and identify any possible integrity issues. Where we suspect such activities are taking place, we are required to disclose this information to the relevant authorities and/or governing bodies. In order to assist us in carrying out these obligations we will implement various manual and automated checks and balances to process your personal data and to flag any suspicious activity (necessary to comply with a legal obligation).
    1. We will appoint certain third parties to process your personal data on our behalf. These third parties will only process your personal data in accordance with our instructions and we will ensure that adequate measures are in place to ensure that your personal data is processed only in accordance with this Privacy Policy and kept secure at all times.
    2. In addition to any sharing listed in paragraph 3, we may disclose anonymized data (such as aggregated statistics) about the users of our Services in order to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will not contain your personal data.
    3. As listed in paragraph 3, we may occasionally be required by law, court order or governmental authority to disclose certain types of personal data.
    4. We may also share your information with third parties in the following situations, to the extent permitted by law:
      1. if we think doing so is necessary to protect the rights, property, security, or safety of us, our Service, our users, or the public;
      2. to enforce our T&Cs or any other agreements we have in place with you;
      3. to investigate and defend ourselves or others against any third-party claims or allgations; and
      4. while negotiating or in relation to a business transaction, such as a merger, change of control, sale of assets, or bankruptcy.
    1. It is important that the information we hold about you is accurate in order for us to comply with our legal and regulatory obligations and also to provide you with the best possible service. We therefore request that you ensure your personal data is up to data at all times. You may update your personal data at any time from within your account through your account or by contacting customer services.
    1. We strive to protect your personal data and our Services from unauthorised access to or alteration of your personal data. This includes use of various security measures to protect your personal data held by or on behalf of us and ongoing review of our information collection, storage and processing practices.
    2. Subject to the uses described in this Privacy Policy, we will endeavour to treat all of your personal data in strict confidence and endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. However, the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and will not hold us responsible for any breach of security unless this is due to our negligence or wilful default.
    1. You have the following rights in relation to your personal data:
      1. a right to access your personal data held by us;
      2. a right to receive certain personal data in machine-readable format;
      3. a right to object to processing where lawful basis is that it is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
      4. a right to have inaccurate personal data rectified;
      5. a right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 7.1.8, where you have objected pursuant to paragraph 7.1.3, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
      6. a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
      7. a right to complain to your national data protection regulator;
      8. where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on you have the right to withdraw this consent; and
      9. a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account section or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
    2. Any data held or used by us, is done so in compliance with all applicable regulations. If you are unsure about your rights or are concerned about how your personal data may be processed you should contact your national data protection regulator.
    3. If you would like to exercise any of your rights then you can do so by emailing us at Please be aware that whilst we will try to accommodate any request you make in respect of your rights they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
    4. Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests or have reason to believe requests are being made unreasonably we reserve the right not to respond.
    1. We may contact you in relation to promotions, products or services that you may be interested in from time to time, but only where you have consented to receive such marketing communications. You can update your marketing preferences and also opt-out at any time via your Account. We will also include unsubscribe features in our communications which you can utilise to opt-out of future marketing communications.
    2. We may also carry out certain profiling of you and your activity in relation to our Services in order to send you more relevant marketing communications. This profiling will be undertaken based on your use of our Services. You can update your preferences via your account.
    3. Where you have consented to receive direct marketing from us and also our retail business, we may send you direct marketing relating to joint online and retail offers.
    1. We will retain your personal data for the period necessary to provide you with Services. Accordingly, your personal data shall be maintained for up to 5 years following the closure of your account (if applicable) or the last contact with us emanating from you. Where it is no longer necessary to process your personal data we will delete it. Please note, however, that we may be subject to legal and regulatory requirements to keep personal data for a longer period, in particular pursuant to any applicable statutory limitation period.
    1. If at any time you believe that we have not adhered to the provisions set out within this Privacy Policy, please notify us by contacting customer services or at and we will use all commercially reasonable efforts to promptly determine and (where relevant) correct any issue.

This Privacy Policy is effective from 2018.06.18.