Privacy Policy

1. Introduction

1.1. This Privacy Policy explains how Fortaluna Ltd ("we", "us", "our", or the "Company") collects, uses, stores, shares, and protects your personal data when you use the website www.pumpkings.com and related services (the "Website").

1.2. The Company is registered at Sea Urchin Street, San Pedro Town, Ambergris Caye, Belize under registration number 000048757 and is licensed by the Government of the Autonomous Island of Anjouan, Union of Comoros.

1.3. We are the data controller responsible for your personal data. By using the Website, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the Website.

1.4. This Privacy Policy should be read together with our Terms and Conditions.

2. Data Controller and Contact Details

For any privacy-related queries, or to exercise your rights, please contact:

3. Personal Data We Collect

We collect the following categories of personal data:

3.1. Information you provide directly:

• Identity data: full name, date of birth, gender, nationality.
• Contact data: email address, phone number, residential address.
• Account data: username, password, security questions, account preferences.
• Verification (KYC) data: government-issued ID, passport, driving licence, proof of address, selfies/live verification images.
• Financial data: cryptocurrency wallet addresses, payment method details, transaction history, source-of-funds information.
• Communications: correspondence with our support team, chat messages, survey responses.

3.2. Information collected automatically:

• Technical data: IP address, geolocation, device type, operating system, browser type, language settings.
• Usage data: pages visited, games played, bets placed, session duration, deposits and withdrawals, login times.
• Cookies and similar technologies (see Section 9).

3.3. Information from third parties:

• Identity verification, AML, fraud-prevention, and PEP/sanctions-screening providers.
• Payment and blockchain analytics providers.
• Affiliates and marketing partners (where lawful).
• Game and software providers.

4. How and Why We Use Your Data

We process your personal data for the following purposes and on the following legal bases:

4.1. Where we rely on consent (for example, certain marketing), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

5. Marketing Communications

5.1. We may send you marketing communications about our products, promotions, and offers where you have consented or where otherwise permitted by law.

5.2. You may opt out of marketing at any time via the unsubscribe link in our communications, through your Account settings, or by contacting us.

5.3. We will not send marketing communications to Players who have self-excluded or requested a break, for the relevant period.

5.4. Even if you opt out of marketing, we will continue to send service and transactional communications necessary to operate your Account.

6. Sharing Your Data

6.1. We do not sell your personal data. We may share your data with the following categories of recipients, only where necessary:

• Service providers and processors: hosting, payment and cryptocurrency processors, KYC/AML and fraud-prevention providers, customer support tools, analytics, and email providers.
• Game and software providers: to deliver the Games you play.
• Regulators and authorities: the Anjouan licensing authority, law enforcement, tax authorities, and courts, where required by law or to protect our legal rights.
• Professional advisers: lawyers, auditors, and consultants under confidentiality obligations.
• Corporate transactions: in connection with a merger, acquisition, sale, or restructuring of our business.

6.2. We require all third parties to respect the security of your data and to process it only on our instructions and in accordance with applicable law.

7. International Data Transfers

7.1. Your personal data may be transferred to, stored, and processed in countries outside your country of residence, including jurisdictions that may have different data protection standards.

7.2. Where we transfer data internationally, we take reasonable steps to ensure an appropriate level of protection, including through contractual safeguards with our service providers.

8. Data Retention

8.1. We retain your personal data for as long as your Account is active and for as long as necessary to fulfil the purposes set out in this Policy.

8.2. We retain certain data after Account closure to comply with legal, regulatory, AML, tax, and licensing obligations. KYC and transaction records are typically retained for a minimum of 5 years after the end of the business relationship, or longer where required by law.

8.3. When data is no longer required, we will securely delete or anonymise it.

9. Cookies and Tracking Technologies

9.1. We use cookies and similar technologies to operate the Website, remember your preferences, analyse usage, prevent fraud, and (where permitted) deliver relevant marketing.

9.2. Categories of cookies we use include:

• Strictly necessary cookies — required for the Website to function (including security and login).
• Functional cookies — remember your settings and preferences.
• Analytics cookies — help us understand how the Website is used.
• Marketing cookies — used to deliver and measure advertising.

9.3. You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect Website functionality.

10. Data Security

10.1. We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration, including encryption, access controls, and secure infrastructure.

10.2. While we take reasonable steps to protect your data, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10.3. You are responsible for keeping your login credentials confidential and for any activity carried out through your Account.

11. Responsible Gambling and Data

11.1. We process certain data to support responsible gambling, including monitoring play patterns, applying deposit and loss limits, and enforcing self-exclusion.

11.2. Where you self-exclude, we may share relevant data with self-exclusion schemes and partners to give effect to your exclusion, in accordance with our licence and applicable law.

12. Children

12.1. The Website is strictly for persons aged 18 or over (or the legal age of majority in your jurisdiction if higher). We do not knowingly collect data from minors.

12.2. If we become aware that a minor has registered or provided personal data, we will close the Account and delete the data, subject to any legal retention obligations.

13. Third-Party Links

The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review their privacy policies.

14. Automated Decision-Making

14.1. We may use automated systems to support fraud detection, AML monitoring, risk scoring, and responsible gambling. Where automated processing produces a legal or similarly significant effect, you may have the right to request human review, subject to applicable law and our legal and regulatory obligations.

15. Changes to This Privacy Policy

15.1. We may update this Privacy Policy from time to time. The most current version will always be published on the Website with an updated "Last updated" date.

15.2. Where changes are material, we will take reasonable steps to notify you. Your continued use of the Website after changes take effect constitutes acceptance of the updated Policy.

16. Contact Us