Privacy Policy

This Privacy Policy explains how Prima Play, operated via the online casino website at primaplay.bet, collects, uses, stores, shares, and protects your personal data. It applies to players, registered account holders, prospective customers, and visitors who access or use primaplay.bet and any related pages or services linked to this policy.

We are committed to processing personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the UK Data Protection Act 2018, and, where relevant, the EU GDPR and Mexican data protection legislation.

Effective date: 6 November 2025. Last updated: 6 November 2025.

Who We Are

The online casino service marketed as Prima Play for the UK Non-GamStop market is operated as Prima Play through the website primaplay.bet (together, the "Service", "we", "us", or "our").

The Service is part of a wider offshore online gambling group historically associated with Internet Gaming Services, which manages various Real Time Gaming ("RTG") powered casino brands (including sister site iNetBet Casino). The group has historically operated under a Curaçao eGaming sub-license, although the specific license number and validator are not publicly displayed in the footer as of November 2025 and may be subject to clarification.

Our operations are managed from offshore jurisdictions (including, historically, Curaçao and Belize-linked corporate structures) and we do not hold a licence from the UK Gambling Commission. For UK players, Prima Play operates as an offshore, Non-GamStop casino outside UKGC jurisdiction. This does not remove our obligations regarding the protection of your personal data under UK data protection laws, where they apply.

Data controller. For the purposes of this Privacy Policy, the primary data controller for personal data collected via primaplay.bet in connection with Prima Play is the operating company within the Internet Gaming Services group responsible for this brand. Precise legal-entity registration and postal address details are currently being updated and will be reflected in this Privacy Policy once formally published. Until then, you can exercise all your data protection rights using the contact channels below.

Contact details for privacy matters.

• Email (primary contact): [email protected] (please include "Data Protection" or "Privacy" in the subject line).
• Live chat: 24/7 customer support via live chat on the primaplay.bet website (widget available when logged in or on selected pages).
• Websites: https://primaplay.bet (current primary domain) and https://primaplay.eu (legacy/alternate domain and historical host for policy pages).

We do not currently provide a telephone contact number for privacy queries. All data protection requests and complaints should be submitted via email or live chat so that they can be logged and tracked efficiently.

What Personal Data We Collect

We collect and process different categories of personal data depending on how you interact with Prima Play and primaplay.bet. In particular, we may collect the following types of data:

• Identification and KYC data: full name, date of birth, nationality, username, account ID, copies of identification documents (such as passport, ID card, driving licence), proof of address (such as utility bill or bank statement), and other Know Your Customer ("KYC") and anti-money laundering ("AML") information required under applicable laws and industry standards.
• Contact details: email address (for example, the email used to register your account or contact support such as [email protected]), postal or billing address if provided, and any other contact information you choose to share with us.
• Account and gameplay data: account registration details, login history, game selections, play sessions, bets placed, wins and losses, bonuses claimed, wagering progress, reward points, and any restrictions or self-exclusion settings configured on your account.
• Financial and payment data: payment method details (such as partial card numbers, card issuer information, e-wallet details), deposit and withdrawal history, currency, payment verification records, and associated transaction identifiers. Full card details are handled and stored by our payment partners in accordance with their own security certifications and are not retained in full by us.
• Technical and device data: IP address, approximate location based on IP, device type, operating system, browser type and version, language settings, time zone, unique device identifiers, and technical event logs generated when you access or use primaplay.bet.
• Usage and behavioural data: clickstream data, pages visited, time spent on pages, navigation paths, links clicked, game performance statistics, interactions with promotions, marketing communications engagement (for example, email opens and clicks), and responses to surveys or feedback forms.
• Communications data: copies of emails, support tickets, live chat transcripts, complaint records, and any other communications between you and our customer support or dispute resolution services (including data that may be shared with Central Dispute System for game fairness matters).
• Cookies and similar technologies: data collected through cookies, web beacons, pixels, and similar technologies implemented on primaplay.bet and, where relevant, legacy domains such as primaplay.eu. This includes session identifiers, preferences, analytics identifiers, and advertising IDs, as described in the "Cookies & Tracking Technologies" section of this policy.
• Third-party data: information obtained from payment providers, fraud-prevention services, RTG and other technical providers, affiliates, marketing partners, and publicly available sources when necessary to verify account details, prevent fraud, or comply with legal obligations.

Legal Basis for Processing

We process personal data only when we have a valid legal basis under applicable data protection laws, including UK GDPR, the UK Data Protection Act 2018, EU GDPR (where applicable), and relevant non-UK laws (such as Mexican privacy legislation). The main legal bases we rely on are:

• Performance of a contract: We process your personal data when it is necessary to enter into and perform our contract with you, including:
  • creating and managing your player account;
  • verifying your eligibility to use the Service;
  • processing deposits, wagers, and withdrawals;
  • providing games and related services (through RTG and other providers); and
  • providing customer support and resolving operational issues.
• Compliance with legal obligations: We process certain data to comply with laws and regulations applicable to offshore online gambling and financial transactions, including:
  • KYC/AML and counter-terrorist financing obligations;
  • responsible gambling and risk assessments;
  • record-keeping, audit, tax, and regulatory reporting duties; and
  • responding to lawful requests from courts, law enforcement bodies, or regulators (for example, in Curaçao or other relevant jurisdictions).
• Legitimate interests: We process data where it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your rights and freedoms. These legitimate interests include:
  • operating, maintaining, and improving primaplay.bet and our gaming services;
  • preventing fraud, abuse, chargebacks, bonus misuse, and other unlawful or suspicious activities;
  • protecting the security and integrity of our systems and RTG-powered platform;
  • personalising your experience and tailoring offers to your profile (subject to your marketing preferences); and
  • defending and exercising legal claims, including disputes handled via Central Dispute System.
• Consent: In some cases we rely on your explicit consent, for example:
  • sending electronic marketing communications (email, SMS, push notifications) where required by law;
  • using certain non-essential cookies or similar technologies for analytics or advertising purposes; and
  • processing special categories of data where applicable and permitted (for example, information relating to problem gambling or self-exclusion, where it may have health-related implications).
  You may withdraw your consent at any time, as described in the "Your Rights" section, without affecting the lawfulness of processing based on consent before its withdrawal.
• Vital interests and legal claims: In rare circumstances, we may process data to protect your vital interests or those of another person (for example, where we identify serious problem gambling indicators and need to take urgent protective steps), or where necessary to establish, exercise, or defend legal claims.

Purpose of Processing

We use personal data for clearly defined purposes that are consistent with applicable law and this Privacy Policy. In particular, we process your data for the following purposes:

• Providing and managing the Service: to create and administer your player account, provide RTG-powered casino games, enable deposits and withdrawals, process bets and winnings, maintain account settings, and provide customer support and dispute handling.
• Compliance and risk management: to perform identity verification and KYC/AML checks, monitor transactions and gameplay for fraud or suspicious activity, prevent chargebacks and abuse, and meet our legal and regulatory obligations in Curaçao and other relevant jurisdictions.
• Improving our products and services: to analyse gameplay patterns, website performance, game popularity, and customer feedback, allowing us to optimise primaplay.bet, fix technical issues, and develop new features or promotions tailored to our player base.
• Personalisation and marketing: to provide you with personalised content, bonuses, and offers; to send you marketing communications (where permitted and subject to your consent or lawful interests); and to measure the effectiveness of campaigns and affiliate programmes.
• Analytics and statistics: to use aggregated and pseudonymised data for statistical analysis, performance monitoring, business reporting, and service optimisation, ensuring that individual players are not identifiable in these aggregated datasets.
• Security and integrity of the Service: to detect and prevent security incidents, protect user accounts, enforce our Terms and Conditions, monitor for misuse of bonuses or multiple-accounting, and safeguard the RTG platform and our infrastructure against cyber threats.
• Dispute resolution and legal claims: to investigate and resolve complaints and game fairness disputes, including those escalated to Central Dispute System, and to establish, exercise, or defend legal claims in any relevant jurisdiction.
• Corporate governance and business continuity: to support internal management, audits, compliance reviews, and potential corporate transactions (such as reorganisation, merger, or asset transfer) involving the Prima Play brand.

Disclosure & Sharing

We do not sell your personal data in the sense of directly exchanging it for money. We do, however, share your data with carefully selected third parties where necessary for the operation of Prima Play, for compliance, or with your consent. These recipients may include:

• Payment service providers and financial institutions: banks, card processors, e-wallet providers, and other payment intermediaries that process deposits, withdrawals, and refunds and that apply their own KYC/AML checks.
• Gaming platform and software providers: Real Time Gaming (RTG) and associated technical providers that supply and host games, random number generators, and related services for the Prima Play brand. These providers may receive gameplay, transaction, and technical data necessary to deliver their services.
• Dispute resolution services: Central Dispute System (CDS) or similar fairness mediation services used to investigate game outcomes and disputes. For such purposes, we may share account identifiers, gameplay logs, transaction records, and relevant correspondence. CDS is an RTG-affiliated mediator, not a government regulator.
• IT, hosting, and security providers: third-party vendors that provide data hosting, cloud services, content delivery, security monitoring, incident response support, logging, analytics tools, and other IT solutions. Some of these providers may maintain certifications such as ISO 27001 or SOC 2.
• Marketing and affiliate partners: email service providers, SMS and push notification platforms, affiliate networks, and advertising partners that help us promote the Service or track campaign performance, subject to your marketing preferences and, where required, your consent.
• Professional advisers: lawyers, auditors, consultants, and other professional advisers who require access to specific data to provide their services and who are subject to confidentiality obligations.
• Regulators, law enforcement, and authorities: courts, law enforcement agencies, tax authorities, gaming regulators (such as Curaçao eGaming where applicable), and other public bodies when we are legally required or permitted to share data, or when disclosure is necessary to protect our rights or the rights of others.
• Corporate transactions: prospective or actual purchasers, investors, or other parties in the context of a merger, acquisition, asset sale, restructuring, or similar corporate transaction involving the Prima Play brand or Internet Gaming Services group. In such cases, data will be shared subject to appropriate confidentiality and data protection safeguards.

Where we engage third parties to process personal data on our behalf, we enter into written data processing agreements requiring them to process data only in accordance with our instructions, implement appropriate security measures, and comply with applicable data protection laws.

International Transfers

Because Prima Play is operated by an offshore group serving UK players and other international markets, your personal data may be transferred to and processed in countries outside the United Kingdom and the European Economic Area ("EEA"). These locations may include, for example, Curaçao, other Caribbean or Latin American jurisdictions, the United States, and other countries where our group entities, RTG platform infrastructure, payment providers, or service vendors are based.

Some of these countries may have data protection laws that are different from, and potentially less protective than, the laws in your country of residence. Where we transfer your personal data outside the UK or EEA, we implement appropriate safeguards to ensure a level of protection essentially equivalent to that required under UK GDPR and EU GDPR. These safeguards may include:

• Standard contractual clauses (SCCs): using standard data protection clauses adopted by the European Commission or their UK equivalents, along with any necessary supplementary measures, for transfers of data to countries without an adequacy decision.
• Data transfer impact assessments: assessing the legal and practical risks associated with transfers to particular countries and implementing technical and organisational measures (such as strong encryption and access controls) to mitigate those risks.
• Reliance on adequacy decisions or similar frameworks: where applicable, transferring data to countries or providers that operate under adequacy decisions or comparable approved mechanisms under EU and UK law.
• Contractual and organisational measures: restricting access to data to those who need it, limiting the data transferred to what is strictly necessary, and applying strong security practices across our international infrastructure.

You may contact us at [email protected] if you would like further information about the specific transfer mechanisms or safeguards we rely on for a particular transfer, where permitted by law.

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, including to meet legal, accounting, and reporting requirements, and then securely delete or anonymise it. Retention periods depend on the type of data and the context in which it was collected. In general:

• Account, KYC, and AML records: kept for the duration of your active relationship with us and, after account closure, typically for a period of up to five (5) years (or longer if required by applicable KYC/AML or financial regulations) to comply with legal obligations, handle disputes, and maintain records.
• Transaction and gameplay data: retained for as long as necessary to administer your account, resolve disputes, support responsible gambling measures, and comply with regulatory and tax requirements, generally aligned with the retention of KYC and AML records.
• Customer support communications: emails, live chat transcripts, and complaint records are usually stored for up to five (5) years after resolution, to allow us to review past interactions, defend legal claims, and improve our services.
• Technical logs and security data: server logs, security alerts, and similar technical records are typically retained for shorter periods (for example, six (6) months to two (2) years), unless longer retention is necessary to investigate incidents or comply with legal obligations.
• Marketing data: information used for marketing purposes is retained for as long as you remain subscribed to our marketing communications and, after you opt out, for a short period necessary to record your preferences and demonstrate compliance (for example, maintaining a suppression list).
• Cookies: cookie data is retained in accordance with the lifespan of each cookie as described in our cookie-related notices on primaplay.bet and in your browser settings.

When personal data is no longer required for any lawful purpose, we will either delete it securely or irreversibly anonymise it so that it can no longer be associated with you. In some cases we may retain anonymised or aggregated data for analytical purposes for a longer period, without identifying any individual.

Your Rights

Depending on your place of residence and on the legal basis for processing, you may have a range of rights over your personal data. For UK and EEA players, these rights primarily arise under UK GDPR and EU GDPR. For Mexican residents, similar rights are provided under Mexican data protection laws, such as the Federal Law on Protection of Personal Data Held by Private Parties and its Regulations. Subject to applicable law and certain exceptions, your rights may include:

• Right of access: to obtain confirmation as to whether we process your personal data and, if so, to receive a copy of the data together with information about how we use it.
• Right to rectification: to have inaccurate or incomplete personal data corrected or completed. You can also update certain details directly through your account settings on primaplay.bet.
• Right to erasure ("right to be forgotten" / cancellation): to request deletion of your personal data where there is no valid reason for us to continue processing it, subject to legal or regulatory retention obligations (for example, we may be required to retain some KYC/AML records and transaction data for a statutory period).
• Right to restriction of processing: to request that we restrict the processing of your data in certain circumstances (for example, while we verify its accuracy or in the context of a disputed legal claim).
• Right to object: to object at any time to processing based on our legitimate interests, including profiling, on grounds relating to your particular situation. You also have an absolute right to object to direct marketing at any time.
• Right to data portability: to receive certain data that you have provided to us in a structured, commonly used and machine-readable format, and to have that data transmitted to another controller where technically feasible and where the legal basis is consent or contract.
• Right to withdraw consent: where we process data based on your consent (for example, receiving promotional emails or non-essential cookies), you may withdraw that consent at any time. This will not affect the legality of processing conducted before withdrawal.
• Rights under Mexican law (ARCO): for Mexican residents, additional rights such as Access, Rectification, Cancellation, and Opposition ("ARCO rights") apply under relevant Mexican data protection legislation. These rights largely correspond to the rights described above and can be exercised using the same contact channels.

How to exercise your rights. To exercise any of these rights, please contact us by email at [email protected] or via live chat, clearly stating that your request concerns data protection and specifying which right you wish to exercise. We may need to request additional information to verify your identity and ensure the security of your account and data.

Response times and fees. We aim to respond to all valid requests within one (1) month (30 days) of receipt. In complex cases or where we receive numerous requests, this period may be extended by a further month, in which case we will inform you of the extension and reasons. We generally handle requests free of charge, but may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive, in line with applicable law.

Please note that these rights are not absolute and may be limited by legal obligations (for example, AML laws), our need to defend legal claims, and the rights and freedoms of others.

Cookies & Tracking Technologies

primaplay.bet uses cookies and similar technologies to ensure the website functions correctly, to enhance your experience, to perform analytics, and, where permitted, to support marketing activities. Cookies are small text files stored on your device when you visit a website. They may be set by us ("first-party" cookies) or by third parties ("third-party" cookies).

We use, in particular, the following categories of cookies:

• Strictly necessary (session) cookies: essential for the operation of the website and the provision of services you request, such as maintaining your logged-in session, securing transactions, and enabling basic navigation. These cookies are typically session-based and expire when you close your browser.
• Functional (persistent) cookies: used to remember your preferences and settings (for example, language selection, saved login preferences where allowed, site layout choices). These cookies may remain on your device for a longer period or until you delete them.
• Analytics and performance cookies: first- or third-party cookies that help us understand how visitors use primaplay.bet (for example, which pages are visited most often, how long sessions last, whether error messages appear). The information collected is aggregated and used to improve website performance and user experience.
• Advertising and affiliate cookies: cookies used to track the effectiveness of our marketing campaigns and affiliate relationships, and, where applicable and permitted, to show relevant offers to you. These may be set by us or by our advertising and affiliate partners.

Managing cookies. On your first visit (and periodically afterwards), you may be presented with a cookie banner or settings panel that allows you to manage your non-essential cookie preferences. You can also control cookies through your browser settings by blocking, limiting, or deleting cookies. However, disabling certain cookies may impact site functionality and your ability to use some features (such as remaining logged in, viewing games, or completing transactions).

For detailed information about specific cookies used on primaplay.bet, their purposes, and lifespans, please refer to the cookie-related information provided on the website or within the cookie settings panel, where available.

Data Security

We take the security of your personal data very seriously and implement technical and organisational measures designed to protect it against unauthorised access, loss, misuse, alteration, or destruction. While no system can guarantee absolute security, we maintain safeguards in line with industry standards and the sensitivity of the data processed. These measures include, among others:

• Encryption in transit and at rest: data transmitted between your browser and primaplay.bet is protected using modern cryptographic protocols (such as TLS 1.2 or higher). We also use encryption, pseudonymisation, and other security controls to protect stored data where appropriate.
• Access controls and authentication: personal data is accessible only to authorised personnel and service providers who require it for legitimate purposes. Administrative access to systems is protected by strong authentication mechanisms, and multi-factor authentication is implemented for sensitive accounts where feasible.
• Network and infrastructure security: firewalls, intrusion detection and prevention systems, secure configurations, and monitoring tools are used to help safeguard our infrastructure and the RTG-powered platform against cyber threats and unauthorised access attempts.
• Security policies and training: staff are subject to confidentiality obligations and receive training on data protection, information security, and responsible handling of player data.
• Vendor due diligence: when selecting third-party providers (including hosting, payment, and security vendors), we assess their security practices and certifications. Where appropriate, we work with providers that maintain recognised security certifications such as ISO 27001 or SOC 2, or equivalent measures.
• Incident response: we maintain procedures for detecting, investigating, and responding to potential security incidents and data breaches. Where a breach results in a high risk to your rights and freedoms, we will notify you and relevant supervisory authorities in accordance with applicable law.

We encourage you to also play your part in keeping your data safe by using a strong, unique password, keeping your login details confidential, and promptly informing us if you suspect any unauthorised use of your account.

Complaints & Contacts

We aim to resolve all privacy-related queries and concerns promptly and fairly. If you have any questions about this Privacy Policy or how we handle your personal data, or if you wish to make a complaint, you can contact us using the following channels:

• Email: [email protected] (please clearly state that your message concerns data protection or privacy).
• Live chat: 24/7 support via the primaplay.bet live chat interface.

Internal complaint procedure.

1. Stage 1 - Initial contact: Submit your question or complaint via email or live chat, including relevant details (account ID, dates, and description of the issue).
2. Stage 2 - Acknowledgement: We will acknowledge receipt of your complaint as soon as reasonably practicable and usually within seven (7) days.
3. Stage 3 - Investigation and response: We will investigate your complaint, which may include reviewing account records, transaction data, communication logs, and, where relevant, consulting with RTG or Central Dispute System. We aim to provide a substantive response within thirty (30) days.
4. Stage 4 - Extended review (if necessary): If your complaint is particularly complex or involves external parties, we may require additional time. In such cases, we will inform you of the extension and provide an updated timeframe, which should not normally exceed an additional thirty (30) days.

Escalation to supervisory authorities. If you are not satisfied with our response or believe that we are processing your personal data in breach of applicable laws, you have the right to lodge a complaint with a data protection authority:

• United Kingdom: Information Commissioner's Office ("ICO"). Up-to-date contact details are available at https://ico.org.uk/global/contact-us/.
• Mexico: For Mexican residents, the relevant authority is the National Institute for Transparency, Access to Information and Personal Data Protection ("INAI"). Contact details are available at https://www.inai.org.mx/.
• European Union / EEA: If EU or EEA data protection law applies to you, you may also lodge a complaint with your local data protection authority. A list of supervisory authorities and their contact details is available via the European Data Protection Board.

We encourage you to contact us first so that we have the opportunity to address your concerns directly. This internal process does not affect your right to approach a supervisory authority at any time.

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, technology, or the operation of Prima Play and primaplay.bet. When we make changes, we will revise the "Last updated" date at the top of this policy and, where the changes are material, provide additional notice.

Notification methods. For significant changes that materially affect your rights or how we process your data, we will take appropriate steps to inform you in advance, which may include:

• showing a prominent notice on the primaplay.bet website (for example, a banner or pop-up);
• displaying an alert in your account dashboard when you next log in; and/or
• sending an email to the registered email address associated with your account.

Unless otherwise required by law, material changes will normally take effect no earlier than thirty (30) days after notification. If you do not agree with the updated policy, you may choose to close your account and stop using the Service before the changes become effective. Continued use of primaplay.bet after the effective date will constitute your acceptance of the updated Privacy Policy.

For historical or previous versions of this Privacy Policy (including versions hosted on legacy domains such as primaplay.eu), you may contact us at [email protected] and we will provide copies where reasonably available.