At Rise of Orpheus (https://riseoforpheus.org/), we understand that your trust is our most valuable asset. As a website dedicated to showcasing the slot game "Rise of Orpheus," we operate within an industry where financial security and user well-being are paramount. This Privacy Policy is not merely a legal document; it is our commitment to you, demonstrating how we responsibly manage your personal data, ensuring transparency, security, and compliance with the highest standards.
We are Orpheus Digital Solutions Ltd., a company registered in the United Kingdom at 123 Mythos Lane, London, W1A 0AA. We are the data controller for the personal data processed in connection with this website.
This policy outlines our practices in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other relevant UK and international data protection laws, as well as the specific requirements for online gambling-related sites, even as a game showcase. We aim to build and maintain trust, aligning with Google's Quality Rater Guidelines for YMYL (Your Money Your Life) content by demonstrating our Experience, Expertise, Authoritativeness, and above all, Trustworthiness.
1. Key Principles of Our Data Protection Approach
We are committed to:
- Transparency: Clearly explaining what data we collect and why.
- Purpose Limitation: Using your data only for legitimate, specified purposes.
- Data Minimisation: Collecting only data that is necessary and relevant.
- Accuracy: Keeping your data accurate and up-to-date.
- Storage Limitation: Retaining data only as long as necessary.
- Integrity & Confidentiality: Protecting your data through robust security measures.
- Accountability: Being responsible for our data handling practices and demonstrating compliance.
2. Data We Collect and Why We Collect It
As a website showcasing the "Rise of Orpheus" slot game, we collect various types of data to provide our services, improve your experience, and ensure the security and integrity of our site.
2.1. Information You Provide Directly
While we do not offer full player accounts, you may provide us with data through:
- Communications Data: If you contact us via email (e.g., [email protected]), contact forms, or other channels, we collect your name, email address, and the content of your message.
- Purpose: To respond to your enquiries, provide support, and improve our services.
- Lawful Basis: Legitimate Interests (responding to user queries) or performance of a contract (if applicable, e.g., providing support for a specific issue).
2.2. Information Collected Automatically (via Cookies and Tracking Technologies)
When you visit riseoforpheus.org, we automatically collect certain technical and usage information:
- Device and Technical Data: Your IP address, browser type and version, operating system, device type, screen resolution, language settings, and unique device identifiers.
- Purpose: To ensure our website functions correctly on your device, for security purposes (e.g., detecting malicious activity), and to understand our audience's technical needs.
- Lawful Basis: Legitimate Interests (ensuring site functionality and security).
- Usage Data: Information about how you interact with our website, including pages visited, time spent on pages, click patterns, and interactions with the "Rise of Orpheus" demo game (e.g., bet increments selected (0.30, 0.40, 0.50, 0.60, 0.80), number of spins, feature triggers like 'Orpheus feature' or 'Underworld Escape Free Spins' activation, and your preferences in the settings panel (e.g., 'Fast play', 'Auto adjust bet')).
- Purpose: To analyse website performance, understand user engagement with the game demo, improve content, and optimise the user experience.
- Lawful Basis: Legitimate Interests (website improvement, analytics) and, for non-essential tracking, your explicit Consent via our cookie banner.
- Cookie Data: Information collected through cookies and similar technologies. Please refer to our dedicated Cookie Policy for more details.
- Purpose: Essential site functionality, remembering your preferences, analytics, and marketing.
- Lawful Basis: Legitimate Interests (for strictly necessary cookies) and Consent (for all other cookies).
2.3. Analytics Data (Yandex.Metrica)
We utilise Yandex.Metrica, a web analytics service provided by Yandex LLC, to gain insights into website traffic and user behaviour.
- Data Collected: IP addresses (anonymised), user IDs (pseudonymous), device information, browser information, session data (pages visited, clicks, time on site).
- Purpose: To understand how users interact with our website, identify popular content, and improve site design and functionality.
- Lawful Basis: Your explicit Consent, obtained via our cookie banner, for the use of non-essential analytics cookies.
Important Note on Yandex.Metrica:
Yandex.Metrica is operated by a Russian company. The European Commission and the UK government have not issued an adequacy decision for data transfers to Russia, meaning that the legal framework in Russia is not deemed to provide an equivalent level of data protection to that in the UK. We acknowledge this risk and implement the following safeguards:
- IP Anonymisation: We configure Yandex.Metrica to anonymise IP addresses immediately upon collection.
- Consent-Based Processing: We only activate Yandex.Metrica for non-essential tracking purposes after obtaining your explicit consent.
- Data Minimisation: We only collect data necessary for analytics purposes.
We continuously monitor the legal landscape and available alternatives to ensure the highest level of data protection for our users.
3. How We Use Your Data
We use your personal data for the following purposes:
- To Provide and Maintain Our Website: Ensuring the "Rise of Orpheus" game demo is available and functions correctly.
- To Improve Your Experience: Analysing usage patterns to enhance website features, content, and the game demo itself.
- For Analytics and Research: Understanding user demographics and behaviour to inform strategic decisions and content development.
- For Security and Fraud Prevention: Detecting and preventing malicious activities, ensuring the integrity and safety of our website.
- To Communicate With You: Responding to your enquiries and providing customer support.
- For Compliance and Legal Obligations: Adhering to applicable laws, regulations, and industry standards, including those related to responsible gambling and anti-money laundering (AML), where relevant for a gambling-related site.
- For Affiliate Marketing (Commercial Transparency): As part of our business model, riseoforpheus.org may participate in casino affiliate programmes. This means we may earn a commission when users click on links to licensed gambling operators on our site and subsequently register or make a deposit. We use anonymised click data to track these referrals. This is disclosed transparently in line with Advertising Standards Authority (ASA) guidelines.
4. Lawful Basis for Processing Your Data
Under UK GDPR, we must have a valid lawful basis to process your personal data. We rely on the following bases:
- Consent: Where you have given us explicit permission to process your data for a specific purpose (e.g., for non-essential cookies via our cookie banner, or for marketing communications). You can withdraw your consent at any time.
- Legitimate Interests: Where processing is necessary for our legitimate interests, provided these do not override your fundamental rights and freedoms. This includes website improvement, security, analytics (where consent is not required), and responding to your queries.
- Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., responding to lawful requests from authorities, maintaining records for compliance).
- Performance of a Contract: Where processing is necessary for the performance of a contract with you, or to take steps at your request before entering into such a contract (e.g., if we were to offer specific services that require user accounts).
5. How We Share Your Data
We may share your personal data with the following categories of recipients:
- Service Providers: Third-party companies that perform services on our behalf, such as website hosting, analytics (Yandex.Metrica), security services, and customer support tools. These providers are contractually bound to protect your data and only use it for the purposes we specify.
- Game Provider (Play'n GO): While we are a showcase site, limited, aggregated, and anonymised data about demo game engagement may be shared with Play'n GO to help them understand player interaction with "Rise of Orpheus."
- Affiliate Partners: When you click on an affiliate link on our site and are redirected to a licensed gambling operator, certain anonymised or pseudonymous data (e.g., a unique tracking ID) may be shared to track the referral for commission purposes. We do not share your direct personal identifiers with these partners without your explicit consent.
- Regulators and Law Enforcement: We may disclose your data if required by law or in response to valid requests by public authorities (e.g., gambling regulators like the UKGC, or law enforcement agencies), or to protect our rights or the safety of others.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your data may be transferred as part of that transaction. We will ensure appropriate safeguards are in place.
6. International Data Transfers
As detailed in Section 2.3, we use Yandex.Metrica, which involves the transfer of data to Russia.
- The UK and EU have not made an adequacy decision regarding data protection in Russia. This means that, from a UK GDPR perspective, Russia does not provide an equivalent level of data protection.
- Safeguards: To mitigate these risks, we implement IP anonymisation, rely on your explicit consent for non-essential tracking, and strive to minimise the data collected.
- We continuously monitor the legal and geopolitical landscape concerning data transfers to Russia and will adapt our practices as necessary to ensure compliance and protect your data. By consenting to the use of Yandex.Metrica, you acknowledge and accept these transfer risks.
For any other international transfers (e.g., with other service providers located outside the UK/EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA), along with supplementary measures where necessary.
7. Data Security
We take the security of your personal data very seriously. We implement a range of technical and organisational measures to protect your data from unauthorised access, disclosure, alteration, and destruction. These include:
- Encryption: Using SSL/TLS encryption for data in transit (https://riseoforpheus.org/).
- Access Controls: Restricting access to personal data to authorised personnel only.
- Regular Security Audits: Conducting periodic reviews of our systems and processes.
- Data Minimisation: Only storing data that is necessary for our purposes.
- Employee Training: Ensuring our staff are aware of their data protection responsibilities.
While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.
8. Your Data Protection Rights
Under UK GDPR, you have the following rights regarding your personal data:
Right to Be Informed
To receive clear, transparent, and easily understandable information about how we use your data (which this Privacy Policy aims to do).
Right of Access
To request a copy of the personal data we hold about you.
Right to Rectification
To request that we correct any inaccurate or incomplete data we hold about you.
Right to Erasure
To request that we delete your personal data in certain circumstances.
Right to Restrict Processing
To request that we limit the way we use your data in certain situations.
Right to Object
To object to our processing of your data based on legitimate interests or for direct marketing.
Right to Data Portability
To request that we transfer your data to another organisation or to you, in a structured, commonly used, and machine-readable format.
Right to Withdraw Consent
Where we rely on your consent to process your data, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to your request within one month, in accordance with UK GDPR requirements.
9. Cookies and Similar Technologies
Our website uses cookies and similar technologies to enhance your browsing experience, provide necessary functionality, and gather analytics data. For detailed information on the types of cookies we use, their purpose, and how you can manage your preferences, please refer to our dedicated Cookie Policy.
10. Responsible Gambling
Even as a showcase site for a slot game, we are deeply committed to promoting responsible gambling. We understand the risks associated with gambling and believe in empowering users with information and support.
- Information: We aim to provide accurate information about the "Rise of Orpheus" game in a responsible manner.
- Age Restriction: This website is intended for individuals aged 18 and over. We do not knowingly collect data from or market to individuals under this age.
- Support Resources: If you or someone you know is struggling with gambling, please seek help from reputable organisations:
- GamCare: Freephone 0808 8020 133 or visit www.gamcare.org.uk
- BeGambleAware: Visit www.begambleaware.org
- National Gambling Helpline: Freephone 0808 8020 133
11. Children's Privacy
Our website and services are not directed at, nor intended for, individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have inadvertently collected personal data from a child under 18, we will take immediate steps to delete such information from our records.
12. Third-Party Links
This Privacy Policy applies solely to riseoforpheus.org. Our website may contain links to third-party websites, including licensed gambling operators, game providers, and other resources. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory landscape. Any changes will be posted on this page with an updated "Effective Date." We encourage you to review this policy periodically to stay informed about how we are protecting your information. For significant changes, we may notify you via email or a prominent notice on our website.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please do not hesitate to contact us: