FOUNDATION Privacy Notice
Version 2.0
Effective Date: [Launch Date]
Last Updated: [Launch Date]
1. Introduction
This Privacy Notice explains how Golden Whale Productions GmbH (“Golden Whale”, “we”, “our” or “us”) processes personal data in connection with the registration for and use of the FOUNDATION platform (“FOUNDATION”).
This Privacy Notice fulfils the information obligations pursuant to Articles 13 and 14 of the General Data Protection Regulation (“GDPR”) and the Austrian Data Protection Act (Datenschutzgesetz – DSG).
This Privacy Notice applies exclusively to FOUNDATION. The processing of personal data when visiting the Golden Whale website is governed by our separate Data Protection Declaration available at:
2. Controller
Golden Whale Productions GmbH
Antonigasse 3/5
1180 Vienna
Austria
Email: dpo@goldenwhale.com
3. Roles and Scope of Processing
Depending on the processing activity, Golden Whale acts either as controller or processor under the GDPR.
User Account Data
Golden Whale acts as the controller for personal data relating to FOUNDATION users, including:
- account registration;
- authentication;
- subscriptions;
- billing;
- customer support;
- customer communications; and
- operation and security of the FOUNDATION platform.
Customer Data
FOUNDATION enables customers to upload operational gaming datasets for analysis, prediction and recommendation purposes.
Where Golden Whale processes such datasets solely on behalf of a customer, Golden Whale acts as a processor pursuant to Article 4(8) GDPR.
The respective customer remains responsible for:
- determining the purposes of processing;
- ensuring a lawful basis for processing;
- providing information to affected data subjects; and
- complying with applicable data protection legislation.
4. Processing of User Account Data
Categories of Personal Data
Depending on your use of FOUNDATION, we may process:
- name;
- business email address;
- company name;
- billing information;
- VAT number (where applicable);
- account credentials;
- subscription details;
- payment status;
- customer support requests;
- communication history;
- IP address;
- browser and device information;
- authentication logs; and
- security and audit logs.
Purposes
We process your personal data to:
- create and administer user accounts;
- authenticate users and manage secure access;
- provide FOUNDATION services;
- manage subscriptions and payments;
- provide customer support;
- communicate regarding the service;
- improve the usability and performance of FOUNDATION;
- protect the security of the platform;
- prevent fraud and misuse; and
- comply with legal obligations.
Legal Bases
Processing is based on:
- Article 6(1)(b) GDPR (performance of a contract);
- Article 6(1)(c) GDPR (legal obligations); and
- Article 6(1)(f) GDPR (legitimate interests including platform operation, security, fraud prevention and service improvement).
Where required by law, processing may additionally be based on your consent pursuant to Article 6(1)(a) GDPR.
5. Processing of Customer Data
FOUNDATION is designed according to the principles of Privacy by Design and Data Minimisation.
Customers are expected to upload pseudonymised operational gaming data only.
Typical datasets include:
- pseudonymised player identifiers;
- registration information;
- deposits and withdrawals;
- gaming events;
- bonus lifecycle events;
- campaign interactions;
- responsible gaming events;
- transactional information; and
- behavioural information.
Customers should not upload directly identifying personal information such as:
- names;
- email addresses;
- postal addresses;
- telephone numbers;
- payment card information;
- passwords;
- national identification numbers;
- passport numbers;
- IP addresses; or
- device fingerprints.
Golden Whale may reject or remove such information where technically feasible.
6. Recipients and Processors
Golden Whale uses carefully selected service providers to operate FOUNDATION.
Provider | Purpose |
Microsoft Azure | Hosting, cloud infrastructure and storage |
Auth0 (Okta) | User authentication and access control |
Stripe | Subscription management and payment processing |
HubSpot | Customer relationship management, onboarding and customer support |
Mixpanel | Product usage analytics and continuous improvement |
Golden Whale may engage additional processors for hosting, communications, monitoring, infrastructure and security services. This Privacy Notice will be updated where required by law.
7. International Data Transfers
Certain service providers may process personal data outside the European Economic Area.
Where necessary, Golden Whale relies on:
- adequacy decisions issued by the European Commission;
- the EU-U.S. Data Privacy Framework; and/or
- appropriate safeguards pursuant to Article 46 GDPR, including the European Commission’s Standard Contractual Clauses.
8. Retention
Personal data are retained only for as long as necessary for the purposes described in this Privacy Notice.
- User account data are retained for the duration of the customer relationship.
- Billing information is retained in accordance with applicable statutory retention requirements.
- Customer datasets are retained in accordance with the applicable contractual agreements.
- Security and audit logs are retained only as long as necessary to ensure the security and integrity of FOUNDATION.
9. Security
Golden Whale implements appropriate technical and organisational measures to protect personal data, including:
- access controls;
- role-based permissions;
- authentication mechanisms;
- encryption where appropriate;
- logging and monitoring;
- backup procedures; and
- regular security reviews.
10. Your Rights
Where Golden Whale acts as controller, you have the rights provided under the GDPR, including:
- access;
- rectification;
- erasure;
- restriction of processing;
- data portability;
- objection; and
- withdrawal of consent where applicable.
Requests may be sent to:
Where Golden Whale acts solely as processor, requests relating to customer datasets should generally be directed to the respective customer acting as controller.
11. Right to Lodge a Complaint
You have the right to lodge a complaint with the competent supervisory authority.
In Austria:
Österreichische Datenschutzbehörde
Barichgasse 40-42
1030 Vienna
https://www.dsb.gv.at
12. Amendments
Golden Whale may update this Privacy Notice from time to time to reflect legal, technical or operational developments.
The latest version will always be available through FOUNDATION.
