Privacy policy

Last update: March 31, 2025

Please read this Privacy Policy carefully before using https://up-x.cc(Website).

1Win N.V. is a company incorporated under the laws of Curaçao with Company Number 147039 and registered address at Dr. H. Fergusonweg 1, Curacao, and licensed by the Curacao Gaming Authority to offer games of chance under license number OGL/2024/587/0621 in accordance with the National Ordinance on Games of Chance by means of access to various games on our platform. MFI Investments Limited, a company, whose registered office is at Agias Fylaxeos, 232, Flat/Office 102, 3082, Limassol, Cyprus with company number HE386738. MFI Investments Limited is providing payment services as an agent. By using our services, you trust us with your information. We understand that this is a big responsibility and we make every effort to protect your data and enable you to manage it. We are dedicated to maintaining the confidentiality and protection of your personal data in accordance with applicable data protection laws and regulations, including the data protection laws of your country and international regulations such as the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

This Privacy Policy describes what information we collect, for what purpose and how you can update, delete your data and manage it.

Information we collect

When you visit and use a Website you give us consent to collect and process your data for the purpose of providing services, performance of the contract, legitimate interest and in case of regulatory obligations.The types of personal information we collect:

1. nickname and password;
2. first name, maiden name, last name, marital status, title, date of birth and gender; 
3. passports and other photographic identification of the government issued forms of identifications that are collected to verify your identity, selfies; 
4. e-mail address;
5. phone number;
6. internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website;
7. numbers of wallets from which there were deposits and withdrawals;
8. bank account and payment card details; 
9. billing address, home address (if different to billing address); 
10. if you create an account through social networks, we will store your name, profile photo and link to the page on social networks.

If data is aggregated and anonymized, meaning you cannot be identified, this Privacy Policy is not applicable.

How we collect information

Information you directly provide to us.

In the course of using our services and interacting with us, you may provide certain information, including but not limited to when you create an account, subscribe to marketing materials, request customer support, participate in promotions, or communicate with us in other ways.

Additionally, we may collect information about your preferences and interests based on your use of our services.

Automatically collected information.

When you use our services, we automatically collect certain information, including:

• Log Information: Details about your use of the services, such as the IP address, system activity, and the date, time, and referrer URL of your request.
• Device Information: Information about the device you use to access our services, including the hardware model, operating system, version, unique identifiers, and network information. 
• Information Collected Through Cookies and Other Tracking Technologies: We use cookies, and similar technologies to track user activity and improve your experience. Cookies are small files stored on your device to help us analyze user behavior and understand which features are most popular. To know more about Cookies please refer to the corresponding section of the Privacy Policy.

Information we collect from other sources.

We may gather information about you from third parties, including publicly available sources or entities that have obtained your consent or are legally permitted to share your data. This information may be combined with data we collect directly through our services.

In some cases, we may collect device or network event data as part of a third-party integration, where you use a service within a third-party service. This data is typically non-personal but may include identifiers such as IP addresses or device IDs that can be used to track individuals or devices.

Third-Party Websites.

Our services may include links to external websites, including but not limited to payment providers, that are not under our control. We are not responsible for the privacy practices of these third-party sites. Before sharing personal information on any third-party website, we recommend reviewing their privacy policies and terms of service. 

Legal grounds to use your information

We will only process your personal data when we have a legal basis for doing so, as defined by applicable data protection laws. These legal grounds for processing include:

Contractual Necessity
We may process your personal data when it is necessary to fulfill a contract or take steps related to a contract. For instance, when you register on our website, you enter into agreements with us, or when we facilitate transactions that occur on the website.

Legal Obligation
There are certain laws and regulations that require us to process personal data in order to comply with legal obligations. For example, we may need to process your personal data to comply with anti-money laundering laws, responsible gaming requirements, or the terms of our gambling license.

Legitimate Interests
We may process your personal data when it is necessary for legitimate business interests, either for us or for other companies in our group, or even third parties. This can include processing for business or commercial purposes that are aligned with these interests.

Your Consent
In some cases, we may process your personal data based on your consent, such as when it is required for direct marketing activities or other specific purposes.

How we use information received from players

By becoming a player or otherwise providing us your personal information, you agree that we collect and use your personal information to provide the services.

You agree to provide a telephone number and / or email address to a third party for marketing purposes.

You agree to provide the game ID, your player’s name, bet, winning odds and winnings for publication on our social networks.

You agree that we have the right to disclose your personal information, but only for the purpose and in cases where such a requirement has been put forward by government bodies, in the manner prescribed by applicable law.

We receive information from the player so that the player can:

1. use our services, in particular, play games and place bets;
2. subscribe to the weekly newsletter;
3. create, manage, close an account.

In the profile settings on our website, a player can:

1. change nickname display on site;
2. change interface settings, including sound accompaniment and time zone settings.

We receive information from the player so that we can:

1. identify you as the player for safety and compliance with our legal obligations;
2. maintain the player account;
3. check the accuracy of the information provided by the player;
4. receive questions and comments from the player in order to respond to them and improve our services;
5. periodically send written messages about important changes in the service, technical update issues, etc;
6. study the suspicion of illegal, fraudulent activities related to our services;
7. report to the regulatory authorities on the commission of crimes or suspected crimes, including money laundering or fraud;
8. increase the safety and reliability of our service;
9. perform other tasks that are necessary to fulfill contractual obligations to the player.

Marketing

From time to time, we may use your personal information to inform you about our products or services, or about promotions that, in our opinion, may be interesting or useful to you. We can do this by email, SMS or phone or mail. If you no longer want to receive marketing or promotional materials from us in general, or in any specific form, you can contact our support team at any time with your request. We will respond and perform your request as soon as possible.

Access to personal information

You can access the personal information collected by us in your profile on the website or by contacting our support team by corresponding request.

We will provide you with access to your personal information as necessary, if possible, and within a reasonable period of time. If we deny access for such reasons, we will notify you in writing of the denial, the reasons and complaint mechanisms that are available to you.

You have the right to delete your data, we make sure that is safely and correctly deleted from servers or is retained only in anonymized form.

Data retention

Some of your data can be deleted at your discretion, while other data is automatically deleted, and certain data is retained for longer periods when required. When data is deleted, we ensure it is securely and completely erased from our systems or anonymized where necessary. Data will be retained until you decide to remove it.

We provide various tools that allow you to manage the data linked to your account. For instance, you can: Edit your personal details, delete a chat message, or delete your entire account.

We will retain your account data until it is closed, and for up to five years after closure, to fulfill our legal and regulatory obligations and to address any potential claims that may arise after your account is closed or following your last interaction with us.

Extended Data Retention for Specific Purposes

In some cases, business or legal obligations require us to retain certain information for an extended period. For example, when a user self-excludes from our services, we may retain their personal data for a longer period as part of responsible gaming practices.

There are several reasons we may retain some data longer than usual:

To prevent fraud, abuse, illegal activity, or unauthorized access. This includes cases where we suspect fraudulent actions, match-fixing, or money laundering.

To comply with financial regulations such as tax and anti-money laundering laws, as well as to manage accounting processes or facilitate dispute resolution. This may involve transactions such as deposits or payouts.

To meet legal, regulatory, or governmental requirements, or to enforce agreements, including investigating potential violations.

To ensure the continued operation of our services for you and other users.

If you have directly interacted with us, such as providing feedback or contacting customer support.

Your rights

You have several rights regarding your personal data. We are committed to ensuring transparency and giving you control over how your information is used. Your rights include:

1. Right to Access – You have the right to request a copy of the Personal Data we hold about you.
2. Right to Rectification – If any of your data is inaccurate or incomplete, you can request corrections.
3. Right to Erasure (Right to be Forgotten) – You can request the deletion of your data under certain circumstances, such as when it is no longer necessary for the purposes it was collected.
4. Right to Restrict Processing – You may ask us to limit the processing of your data in specific situations, such as while a dispute regarding its accuracy is being resolved.
5. Right to Data Portability – You can request to receive your Personal Data in a structured, commonly used, and machine-readable format or ask us to transfer it to another service provider where feasible.
6. Right to Object – You have the right to object to the processing of your data, including for direct marketing purposes. If you object, we will stop processing your data unless there are compelling legitimate grounds to continue.
7. Rights Related to Automated Decision-Making and Profiling – If we use automated systems to make significant decisions affecting you (e.g., fraud prevention measures), you have the right to request human intervention and to challenge the decision.
8. Right to Withdraw Consent – If we rely on your consent for processing, you may withdraw it at any time without affecting the lawfulness of processing based on consent before withdrawal.
9. Right to Lodge a Complaint – If you believe your rights have been violated, you can file a complaint with your local Data Protection Authority (DPA).

You can exercise your rights at any time by making adjustments to your account or by sending an email to support. We may require evidence of your identity before we take any requested action.

If you are not happy with how we are processing your personal information, please let us know by sending an email. We will review and investigate your complaint, and try to get back to you within a reasonable time frame.

Information management

We will take all reasonable measures to ensure the safety of the collected, used or disclosed personal information about the player.

Access to such information can only be provided to authorized persons.

We will destroy the personal information that we own after it is no longer needed to use, store, or disclose it, but not sooner than 5 years after its use.

Data sharing

From time to time we might be required to share your personal data. We might share it with:

Third parties, meaning other companies in the company group;

Third party service providers and partners who help us deliver the websites and services you have requested. This includes those who assist with website functionality, payment providers, service delivery, or marketing and promoting our websites and services; 

Regulatory bodies,law enforcement, government agencies, courts, fraud prevention organizations, licensing bodies, or other entities when necessary to comply with legal requirements or to protect, enforce, or defend our legal rights; 

Affiliates or any other parties referred you to us and other persons you consented to.

International data transfer

When we handle and share your data, it may be transferred to and processed in countries different from your own. These countries may have varying data protection laws. However, we take appropriate measures to ensure your Personal Data remains secure, regardless of where it is processed.

For individuals within the European Economic Area (EEA), this means your data may be transferred outside the EEA. In such cases, we ensure that adequate safeguards are in place, such as using legally recognized transfer mechanisms. Specifically, we implement the European Commission’s Standard Contractual Clauses in agreements with the receiving entities to maintain the protection of your data.

Security

You guarantee that you use all possible methods to preserve the information that you transmit to us, including but not limited to data encryption, limited access principles, network protection and security monitoring.

You are responsible for the security and access to your own computer, mobile device or any other device used to access the site.

You are solely responsible for maintaining the confidentiality of your username, password, and any other account information.

We will take all reasonable steps to protect your personal information from unauthorized use, loss and unauthorized access, alteration and disclosure, including using password-protected systems, databases and Secure Socket Layer (SSL) technology.

Our employees, agents and contractors are required to maintain the confidentiality of player personal information.

Cookies 

Cookies are small text files stored on your device when you visit our website. They help us improve your experience by remembering your preferences, analyzing site traffic, and enabling certain functionalities. Types of Cookies we use:

1. Essential Cookies – Necessary for the operation of our website, including login authentication and security.
2. Performance Cookies – Help us analyze website traffic and optimize our platform for a better user experience.
3. Functionality Cookies – Remember user preferences such as language and game settings.
4. Marketing and Advertising Cookies – Used to deliver personalized advertisements based on your browsing behavior.
5. Third-Party Cookies – Set by external providers (e.g., analytics, payment processors, or advertising networks).

You can manage or disable cookies through your browser settings. However, restricting cookies may affect website functionality, including access to certain games and services.

We may allow third-party analytics providers and advertisers to place cookies to collect data about user interactions. These third parties have their own privacy policies governing their data usage.

Changes to this policy

We change this Privacy Policy from time to time, but do not limit your rights described in it without your explicit consent. We always indicate the date of publication of the latest changes.

Complaints and applicable law

In case of disputes and disagreements, our decision is final and you fully agree with him. All disputes and disagreements arising out of or in connection with this policy are resolved through negotiations. If it is not possible to reach an agreement through negotiations, disputes, disagreements and claims arising from this policy shall be resolved in accordance with the applicable laws of Curacao.

If you have any questions, requests for access, or complaints related to the processing, you can contact our support team (support@up-x.cc) with a corresponding request.