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Privacy Policy

1. General Information

MOBILE INCORPORATED Limited (the “Company”, “we”, “us”, or “our”) is committed to safeguarding the privacy and personal information of individuals who use our services.

This Privacy Policy explains how Personal Data is collected, used, disclosed, stored, and protected when users interact with our websites, gaming platform, mobile applications, and any associated services (together referred to as the “Services”).

By accessing or using the Services, you acknowledge that your Personal Data will be handled in accordance with this Policy and applicable legal requirements.

The Company processes Personal Data in compliance with:

  • the General Data Protection Regulation (EU) 2016/679 (“GDPR”);
  • the Malta Data Protection Act (Chapter 586 of the Laws of Malta); and
  • applicable Malta Gaming Authority (“MGA”) requirements, including obligations relating to player protection, AML controls, and responsible gaming standards.

2. Data Controller Information

For the purposes of data protection law, MOBILE INCORPORATED Limited acts as the Data Controller in relation to Personal Data processed through the Services.

Registered Office:

Elite Business Centre, Trejqa Ta’ Box Box,

Msida MSD1840, Malta

Company Registration Number: C 84149

Data Protection Officer (DPO)

Email: legal@sunwin.navy

Address: Elite Business Centre, Trejqa Ta’ Box Box, Msida MSD1840, Malta

The Data Protection Officer is responsible for overseeing compliance with applicable privacy laws, supporting internal governance processes, and serving as the primary contact point for data protection matters.

3. Core Data Protection Standards

The Company applies the core GDPR principles when handling Personal Data, ensuring that:

  • Lawfulness, fairness, and transparency: data is processed in a lawful and transparent manner;
  • Purpose limitation: data is collected only for specified, legitimate purposes;
  • Data minimisation: only necessary data is collected and processed;
  • Accuracy: Personal Data is kept accurate and updated where appropriate;
  • Storage limitation: data is retained only for as long as required;
  • Integrity and confidentiality: appropriate security safeguards are implemented; and
  • Accountability: the Company maintains evidence of compliance with its obligations.

4. Personal Data We Process

Depending on your interaction with the Services, we may collect and process the following categories of Personal Data:

Identity Information

  • full name
  • date of birth
  • nationality
  • gender

Verification and Compliance Data

  • identity documents issued by government authorities
  • proof of address documents
  • source of funds or source of wealth information (where legally required)

Contact Details

  • email address
  • telephone number
  • residential address

Account and Gaming Information

  • username and login credentials
  • gameplay and betting activity
  • account limits, balances, and preferences

Financial Information

  • deposit and withdrawal history
  • payment method details
  • transaction records

Technical Data

  • IP address
  • device identifiers
  • browser and operating system details
  • system logs and usage data

Communication Data

  • customer support interactions
  • responsible gaming communications
  • compliance-related correspondence

Certain types of data may be treated as higher-risk and are subject to enhanced protection and access controls.

5. How We Use Personal Data

Personal Data is processed for clearly defined and legitimate purposes, including:

  • registering and managing user accounts
  • verifying identity and age eligibility
  • enabling deposits, withdrawals, and payments
  • complying with AML, KYC, and regulatory obligations
  • monitoring and preventing fraud or misuse
  • supporting responsible gaming and player protection measures
  • maintaining system security and integrity
  • responding to user enquiries and support requests
  • fulfilling legal reporting obligations
  • improving and maintaining platform performance

6. Legal Grounds for Processing

We rely on one or more of the following legal bases under GDPR:

  • Contract necessity: to provide Services and manage user accounts
  • Legal obligation: to comply with AML, KYC, MGA, and other regulatory requirements
  • Legitimate interests: including fraud prevention, security, and service improvement
  • Consent: where required, such as for marketing communications

Where processing is based on consent, users may withdraw it at any time.

7. Sharing of Personal Data

Personal Data may be shared with carefully selected third parties where necessary, including:

  • payment processors and financial institutions
  • identity verification and AML service providers
  • hosting, IT infrastructure, and cloud service providers
  • professional advisers such as auditors, legal counsel, and compliance consultants
  • regulatory and enforcement bodies, including the Malta Gaming Authority and FIAU where required by law

We do not sell or rent Personal Data to third parties.

8. Transfers Outside the EEA

Where Personal Data is transferred outside the European Economic Area, the Company ensures appropriate safeguards are in place, such as:

  • adequacy decisions issued by the European Commission; or
  • Standard Contractual Clauses (SCCs) or equivalent safeguards under GDPR

9. Data Retention

Personal Data is retained only for as long as necessary to meet operational, legal, and regulatory obligations.

Retention is determined by:

  • AML and gaming regulatory requirements
  • contractual obligations
  • dispute resolution and audit requirements

Once data is no longer required, it is securely deleted or anonymised.

Records relating to Personal Data breaches are retained for a minimum of five (5) years in accordance with regulatory expectations.

10. Security and Protection Measures

The Company implements appropriate technical and organisational measures to protect Personal Data, including:

  • encryption of sensitive information
  • access controls based on user roles
  • secure infrastructure monitoring
  • internal security policies and procedures
  • employee training and awareness programmes

These measures are regularly reviewed and updated to address evolving risks.

11. Your Rights Under GDPR

Users may exercise the following rights, subject to legal limitations:

  • access their Personal Data
  • correct inaccurate or incomplete information
  • request deletion of data (where permitted)
  • restrict processing
  • object to processing
  • data portability
  • withdraw consent for marketing

Requests should be submitted to the Data Protection Officer.

Users also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (Malta).

12. Personal Data Breach Procedures

If a Personal Data breach occurs, the Company will:

  • take immediate steps to contain and assess the incident
  • investigate and implement corrective actions
  • notify the supervisory authority within 72 hours where required
  • inform affected individuals if there is a high risk to their rights and freedoms
  • maintain internal breach documentation for compliance purposes

13. Age Restrictions

The Services are strictly limited to individuals aged 18 years or older.

The Company does not knowingly collect data from minors. If such data is identified, it will be deleted and the associated account will be closed where applicable.

14. Cookies and Tracking Technologies

Cookies and similar technologies are used to support the functionality, security, and performance of the Services.

They may be used to:

  • ensure core website functionality
  • analyse usage and performance
  • enhance user experience
  • support fraud prevention

Where legally required, cookie consent is obtained through a dedicated management tool.

15. Updates to This Policy

This Privacy Policy may be revised from time to time to reflect legal, regulatory, or operational changes.

The most current version will always be published on the Company’s website and will replace any previous version.

16. Governing Law

This Privacy Policy is governed by the laws of Malta and shall be interpreted in accordance with the GDPR and applicable Maltese data protection legislation.