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Privacy Policy

Step into the Legend, securely! GAMRFIRST is committed to protecting your personal information and privacy.

Below we explain which data are collected on GAMRFIRST and for what purposes.

As the Privacy Policy is an integral part of the GAMRFIRST General Terms and Conditions (GTUs), by using our gaming platform, opening a player account and logging into your player account, you agree to this Privacy Policy. We therefore invite you to read it carefully.

Scope of application

This privacy policy (the “Policy”) applies to all forms of data collection and processing performed by the establishments, subsidiaries and subcontractors of Casino de Montreux SA (collectively, “Casino de Montreux”, “GAMRFIRST” or “we”) and operated under the GAMRFIRST brand on the site https://www.gamrfirst.ch (the “Site”).

About Casino de Montreux

GAMRFIRST is the online casino of Casino de Montreux SA whose registered office is located at Rue du Théâtre 9, 1820 Montreux (Switzerland) and designates this company herein.

Casino de Montreux SA, UID: CHE-101.742.702 is a Barrière Group company that provides users (hereinafter “players”) with a secure, personalised and socially responsible online gaming offer. For this gaming offer and the associated services on its GAMRFIRST.ch site, Casino de Montreux undertakes to protect the privacy of players and their personal data that it has to process.

General

GAMRFIRST is attentive to the needs of its customers. It strictly complies with all applicable legal provisions, in particular the Swiss Federal Data Protection Act (the “LPD”). Accordingly, we have developed a privacy policy applicable to personal data collected in connection with these online casino activities (the “Services”).

Casino de Montreux is ISO/IEC 27001:2013 certified.

The privacy policy applies to the gaming platform, the entire gaming offer and the services associated with GAMRFIRST by Casino de Montreux.

It concerns the collection of data, in particular via our websites, whether your access is via a computer, tablet or mobile device.

Data Controller

The person responsible for the collection and processing of personal data is Casino de Montreux SA.

Should you have any questions or complaints about this privacy policy or about the processing of your data by Casino de Montreux, you may contact the Data Protection Officer by email or at the following postal address:

Casino de Montreux SA

DPO GAMRFIRST
Rue du Théâtre 9
1820 Montreux
Suisse
E-mail: [email protected]

In order to preserve the confidentiality and protection of your personal data, we ask you to enclose a copy of a valid official document (identity card, passport, driving licence) with your application. Your application will be processed as soon as possible and in accordance with the applicable legislation.

Modifications

We recommend that you consult this Policy regularly as we update and modify it regularly. You will be kept informed of the main changes.

Main legal bases for this privacy policy

  • Swiss Data Protection Act (LPD) and all related provisions
  • Swiss Gambling Act
  • Swiss Gambling Ordinance
  • Swiss FDJP Casinos Ordinance
  • Swiss Anti-Money Laundering and Financing of Terrorism Act (Anti-Money Laundering Act)
  • Ordinance of the Swiss Federal Gaming House Board concerning gaming house due diligence obligations in the fight against money laundering and terrorist financing (SFGB Anti-Money Laundering Ordinance, OBA-SFGB)

    • In order to fulfil its legal obligations, in particular with regard to protecting players from problem gambling and the fight against crime and money laundering, Casino de Montreux processes and may communicate the following data to its supervisory authorities:

  • Data collected at the time of each player's online registration;
  • Data concerning players’ gambling habits and financial transactions;
  • Data concerning players’ personal, professional and financial situation;
  • Data regarding player suspension.

    • The data are sent in pseudonymised form, via a data recording system located in Switzerland. Casino de Montreux retains this information for the period required by applicable laws, the data retention period.

    Data collected by GAMRFIRST

    Data provided by the player to GAMRFIRST

    Casino de Montreux collects the personal data which players make available to it in connection with the use of their account. To use the Montreux Casino GAMRFIRST gaming offer, players must have a player account on the gaming platform.

    When opening their player account, players must provide accurate information about themselves (first name, last name, date of birth, gender and nationality) as well as their address (street, postcode, city, country), a valid email address and a mobile phone number.

    When a provisional player account is switched to a permanent account, players are asked to provide a copy of an official identity document (such as passport or identity card) and proof of address (e.g. bank/postal account statement or electricity bill less than 3 months old) in order to verify the personal information and address provided.

    Casino de Montreux also collects the personal data which players make available to it for administration of the gaming platform, in particular for the processing of payment transactions.

    Players also make data available to the Casino de Montreux when they contact it, participate in activities organised by it or send it data in another way.

    GAMRFIRST has the right to demand proof of income or assets, proof of solvency or tax documents from players in order to fulfil legal obligations in relation to the fight against money laundering and the financing of terrorism or in the context of player protection measures according to the concept of social measures.

    Data collected by GAMRFIRST from other sources

    In addition to the data made available by each player, Casino de Montreux may collect and/or update personal data by third-party means (such as public registers, credit rating agencies or subcontractors).

    The data collected by GAMRFIRST by these third-party means include the following data:

  • Identification data such as surname, first name, date of birth and address data, which are used to verify that the data provided by the player are correct.
  • Data from game providers indicating whether a player has committed fraud or other violations of the terms and conditions, bonus conditions, gaming rules or applicable laws in the past. GAMRFIRST also collects data on players' gambling habits, including segmented data and profile data.
  • Data which GAMRFIRST is required by law to verify, for example to determine whether a player is a politically exposed person under the Anti-Money Laundering and Anti-Terrorist Financing Act.
  • Data that makes it possible to prevent fraud, offences and inappropriate behaviour towards GAMRFIRST and/or other players. This includes information (e.g. IP address) of devices connected to the Internet in order to assess the risk of fraud and to determine whether fraudulent behaviour has occurred in the past.

    • Data generated by the player using the gaming platform

    Casino de Montreux collects data resulting from the use of the gaming offer, including transactions to and from the player account. This means that GAMRFIRST stores and processes data on how players use the gaming platform. These data include, for example, the games the player has played, the services used, the promotions used, the events attended, the payment transactions made by/to external payment providers and correspondence between the player and GAMRFIRST.

    Purpose of processing personal data

    Casino de Montreux collects and processes the personal data of players to the extent necessary to comply with contractual and legal obligations. The table below provides information on the purpose of the collection and processing of personal data by GAMRFIRST and the corresponding legal basis. The table is not exhaustive insofar as the collection and processing of personal data is also necessary for GAMRFIRST to conclude the contract with a player and to fulfil its contractual and legal obligations.

    Purpose of collection

    Registering the player account

    Purpose of processing personal data

    Creating the player account

    Legal framework

    Persons wishing to access the online gambling service must create a player account in their own name with the information required by law (Art. 47 of the Swiss Gambling Act).

    Purpose of collection

    Identity/address verification

    Purpose of processing personal data

    Verification that the online gambling service offered by GAMRFIRST is intended for persons of legal age who are ordinarily resident in Switzerland.

    Legal framework

    Compliance with legal obligations regarding verifications (Art. 47 to 49 of the Swiss Gambling Ordinance).

    Purpose of collection

    Identification of banned gamblers, bans and exclusions

    Purpose of processing personal data

    Identification of banned players and recording of personal data when a player wishes to be banned or has to be banned from gambling. This list can be accessed and viewed by other Swiss casinos and lotteries. Use of the data submitted by players, to ensure that they are not listed in the National Register of Banned Players, and to exclude players who request it, or in the event of an imposed exclusion. The law imposes a ban on gambling for players who are potentially insolvent, do not meet their financial obligations or place bets that are unrelated to income/wealth.

    Legal framework

    Compliance with legal obligations, particularly with regard to due diligence (Art. 76 to 82 of the Swiss Gambling Act and Art. 87 to 91 of the Swiss Gambling Ordinance).

    Purpose of collection

    Administration of the gaming offer

    Purpose of processing personal data

    To make the GAMRFIRST gaming service possible, in particular for the transfer of credits between the player’s account, the accounts of external payment organisations and the GAMRFIRST bank account. This processing is essential for maintaining the commercial relationship between the player and GAMRFIRST.

    Legal framework

    Performance of the contract and performance of legal obligations, particularly with regard to due diligence (Art. 50 of the Swiss Gambling Ordinance and Art. 3 and 13 of the SCC’s Anti-Money Laundering Ordinance).

    Purpose of collection

    The provision of high-quality customer service, an individual and personalised gaming offer and promotions.

    Purpose of processing personal data

    To make it possible to contact Customer Service by instant messaging, contact form, email, telephone or any other means made available to the player. GAMRFIRST records its Customer Service conversations with players for quality control purposes. To make it possible to provide the player with an individualised experience through personalised content on GAMRFIRST, and specific offers and promotions. Players can choose the communication channels through which they wish to receive personalised communications and opt out of certain types of communications.

    Legal framework

    In performance of the contract; user consent.

    Purpose of collection

    Preventive measures and investigations in the event of suspected fraud or breaches of contractual or legal obligations against GAMRFIRST or players

    Purpose of processing personal data

    The purpose of the processing is to ensure fair play and to intervene in the event of a suspected infringement. The processing is necessary for secure gaming, continuous improvement of IT security and prevention of attacks/intrusions into players’ accounts.

    Legal framework

    Compliance with contractual and legal obligations (art. 42 of the Swiss Gambling Act and art. 41 and 42 of the Swiss Gambling Ordinance); legitimate interest in fair play in the gaming community.

    Purpose of collection

    Responsible gaming, prevention and protection of players under the Social Measures programme

    Purpose of processing personal data

    Regulation of gaming behaviour (in particular with deposit/bet/loss limits, temporary gambling suspensions, self-assessment questionnaire for gambling behaviour). Processing of data generated by the use of the gaming offer, in particular for the analysis of gambling habits, in order to prevent, detect and combat risky gambling behaviour, or even to pronounce exclusions (see above). GAMRFIRST may request that players provide financial and/or tax documents attesting to their financial capacity.

    Legal framework

    Compliance with legal obligations regarding due diligence (art. 76 to 81 of the Swiss Gambling Act, art. 87 to 91 of the Swiss Gambling Ordinance) and processing based on the legitimate interest of all parties and the community in socially responsible gaming.

    Purpose of collection

    GAMRFIRST Communications

    Purpose of processing personal data

    GAMRFIRST communicates using various channels: email, telephone, notifications on the gaming platform. GAMRFIRST messages may include information about GAMRFIRST, as well as game availability and security. Players can change certain preferences from their player account. Players may unsubscribe from communication that does not contain security instructions or legal information.

    Legal framework

    Legitimate interest in being able to communicate with any player; legal and contractual obligations to be able to contact the player for any issues relating to player protection, security, and any other overriding interest.

    Processing for other purposes

    Personal data are processed only for the purposes for which they were collected. However, they may also be processed for other purposes, provided that these are fully compatible with the original purpose and that required by law.

    Data retention time

    Casino de Montreux does not store data for longer than necessary to achieve the specified purposes. GAMRFIRST stores personal data for 5 years after the end of the financial year during which the customer relationship was terminated, in compliance with legal requirements. The data are then deleted or anonymised so that they can no longer be associated with a player's person.

    GAMRFIRST must therefore retain certain personal data for longer in order to satisfy certain legal or regulatory conditions and/or conditions imposed by the concession. GAMRFIRST is, for example, required to keep part of the personal data indefinitely, if they relate to a voluntary or ordered gambling ban.

    In such cases, GAMRFIRST processes only the part of the personal data required for these specific purposes.

    GAMRFIRST may also process personal data for a longer period of time if so required in ongoing legal proceedings.

    All data relating to a money laundering report are retained for a period of five years from the date of the report, then destroyed.

    For data relating to the fight against money laundering and the financing of terrorism (Art. 21 of the SCC’s Anti-Money Laundering Ordinance), the retention period is 10 years after the end of the customer relationship. These data include:

  • The list of all players identified.
  • Copies of identity documents.
  • Documents regarding recorded transactions.
  • Player statements regarding beneficial ownership.
  • Documents including notes on the results of specific clarifications.
  • Documents including notes on risk classification and results of applying risk characteristics.

    • Recorded telephone conversations with a player are stored by GAMRFIRST for 180 days and then destroyed.

    Where the player does not wish to receive information about GAMRFIRST's marketing activities or withdraws consent, GAMRFIRST will cease processing personal data for this specific purpose.

    Automated processing

    In order to comply with legal requirements, Casino de Montreux may verify all or part of the personal data by automated means. Access to GAMRFIRST’s gaming offer may depend on this processing.

    This automated processing also concerns responsible gaming, which may lead to the suspension of players or transactions on the player account. The purpose of this processing is to immediately prevent potentially problematic gambling behaviour, identify gambling problems and subsequently alert players to their gambling habits.

    Transmission and transfer of personal data

    Transmission of personal data

    Casino de Montreux processes personal data confidentially and only transmits them to third parties in accordance with this privacy policy. Data will only be transmitted to persons who are authorised to process personal data and who are subject to confidentiality under the same rules as those set out in this Policy. Otherwise, GAMRFIRST shall only transfer personal data to third parties if the player has consented to the transfer.

    GAMRFIRST must transmit personal data if it is obliged to do so by law, and at the request of an authority (e.g. police, public prosecutor, administrative authority, judge). This may include spontaneous transmission of data in cases where GAMRFIRST suspects that an offence has been committed.

    Data processors

    In order to provide certain components of the gaming offer, GAMRFIRST collaborates with “data processors”, i.e. companies that process personal data on behalf of GAMRFIRST in accordance with its instructions. GAMRFIRST collaborates with the following data processors:

  • Game providers, to be able to offer a wide range of games.
  • IT companies providing IT solutions for the operation, technical support and customer service, as well as for the maintenance of GAMRFIRST's gaming offer and other activities.
  • Companies providing payment solutions, such as banks, buyers and other payment service providers, to the extent that these companies do not act as independent data controllers.
  • Companies providing services to combat and detect fraud, violations and/or other unlawful behaviour.
  • Marketing companies, such as communication and advertising agencies and affiliated companies.

    • The provision of personal data to data processors only takes place for purposes compatible with those for which GAMRFIRST has collected the personal data according to the contract with the player and this Policy, and only to the extent that it is necessary for the professional services of these processors.

    GAMRFIRST checks and guarantees that each data processor provides guarantees similar to those of GAMRFIRST regarding the security, protection and confidentiality of personal data. GAMRFIRST is bound to all data processors by written agreements that regulate their obligations. These agreements oblige the data processors to respect the same level of confidentiality, data protection and security as that applicable to the relationship with players.

    Within Barrière Group

    Personal information may be transferred to the parent company and to sister companies and subsidiaries of GAMRFIRST, exclusively for the purposes described in this Privacy Policy. The transmission of personal data within the GAMRFIRST Group is mainly used to manage personal data and to address issues relating to the gaming offer. This information is not transferred to third parties.

    Other companies (independent data controllers)

    GAMRFIRST provides certain personal data - strictly within the limits of necessity - to other companies with which it works, which do not act as data processors. In other words, these companies, as independent data controllers, can decide autonomously how personal data are processed. However, GAMRFIRST only provides personal information to the following independent data controllers for the purposes described here:

  • Companies providing payment solutions, such as banks, buyers and other payment service providers, solely to facilitate payment traffic.
  • Companies awarding prizes to players for their participation in a GAMRFIRST event or activity, and solely for this purpose.
  • GAMRFIRST will only address anonymised data to the providers of the games available on the gaming platform, in order to continuously improve the offer, and solely for this purpose.
  • GAMRFIRST only passes on anonymised data to research institutes in order to contribute to research into the prevention of gambling addiction, and solely for this purpose.

    • Transfer of personal data abroad

    GAMRFIRST places the utmost importance on protecting data transferred. The processing of personal data takes place primarily in a data centre in Switzerland, otherwise within the European Union (EU) and the European Economic Area (EEA). Should it become necessary to transfer personal data outside Switzerland and the EU/EEA, for example to a data processor, GAMRFIRST will take all necessary legal, technical and organisational measures to ensure a level of protection equivalent to that guaranteed in Switzerland. In the event of personal data being transferred outside Switzerland, reference will be made to the list of countries of the Federal Data Protection and Information Commissioner, which includes countries with legislation ensuring an adequate level of protection (Art. 6, 1st para. of the Swiss Data Protection Act).

    The provisions applicable in the country of destination, if they ensure an even higher level of protection, are also respected.

    Rights

    In accordance with the Data Protection Act, you have the following rights as a data subject in compliance with the legal requirements:

    Access rights

    Players have the right to access their personal data processed by Casino de Montreux, provided that:

  • such personal data do not affect the rights and freedoms of third parties
  • access to personal data is not prohibited by legal provisions, such as the act against money laundering and the financing of terrorism, and
  • the information does not jeopardise the outcome of a criminal investigation or proceedings.

    • Note: In cases where it receives an access request, GAMRFIRST may ask the player for additional information to ensure that the request is processed efficiently and that the data are forwarded to the correct person.

    Right of correction and completion

    The player has the right to correct incorrect personal data and to complete incomplete personal data for the specified purposes. To do so, players must contact GAMRFIRST’s Customer Service Department and request the appropriate correction or completion.

    Right to be forgotten

    Players have the right to require Casino de Montreux to delete or remove personal data pertaining to them, in whole or in part, when it is no longer required for the purposes for which it was collected or processed.

    Casino de Montreux may deny the request for deletion or anonymisation of personal data if legal obligations preclude it, such as those resulting from the gambling act or the anti-money laundering and terrorism financing act.

    Right to restrict processing

    Players have the right, under certain conditions, to demand that the processing of their personal data be restricted. This may be the case for a certain period of time, should a player deny the accuracy of the personal data, or if the processing is unlawful and, rather than requesting the deletion of the personal data, the player instead demands a restriction of their use.

    Right to object

    Players are entitled to object to certain types of processing, for example for direct marketing purposes. Players can also choose communication channels via their player account settings. Should the player not wish to receive advertising communications, GAMRFIRST will cease to send such information and to process personal data for this purpose.

    GAMRFIRST may nevertheless continue the processing of personal data in the presence of a significant reason or if there are interests that outweigh those of the player, until the situation is legally clarified. In the event of an objection from the player, GAMRFIRST may process only the personal data for the purpose of establishing, asserting or defending its position in this context.

    Revocation of consent

    If GAMRFIRST bases the processing of personal data on the player’s consent, the player may revoke this consent at any time, free of charge, by contacting GAMRFIRST’s Customer Service Department or via its player account on GAMRFIRST.ch.

    The revocation of consent does not affect the legality of the processing previously carried out. It may result in the termination of the contractual relationship, at GAMRFIRST's discretion.

    Data security

    Casino de Montreux implements - and ensures that its service providers and subcontractors implement - appropriate means to preserve the security and confidentiality of data, through physical and logical protection procedures, including data encryption. Casino de Montreux supervises the operation of the GAMRFIRST Online Casino through an Information Security Management System (ISMS), in accordance with the provisions of standard ISO/IEC 27001:2013.

    All means are implemented and all measures are thus taken, including with service providers, to secure your personal data.