PRIVACY POLICY – YESFUN® WEBSITE ( www.yesfun.app )

The purpose of this privacy policy is to inform you about the processing of personal data of users (“ Users ”) of the website ≪ www.yesfun.app ≫ (“ the Website ”) by the companies identified below (jointly referred to as “ Casinos ”) as joint controllers .

Such processing of personal data is carried out by Casinos in accordance with Regulation 2016/679 (EU) of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (“ GDPR ”) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (“ LOPD ”).

The processing of personal data of any user who downloads and browses the mobile application associated with the YESFUN® loyalty program will be carried out in accordance with the terms of the privacy policy of said application, accessible at the following link: ≪ www.yesfun.app/privacy-policy ≫.

1. Identification and contact details of the data controllers

The following entities act as joint controllers of the processing:

Casinos has appointed a Data Protection Officer (“ DPO ”), who may be contacted with any questions and/or doubts regarding any aspect of this privacy policy. For such purposes, you may send an email to the following email address: dpo@grupperalada.com , including, if possible, a mention of “YESFUN® – Data Processing” in the subject of the email.

2. Categories of data processed

In the context of the loyalty program offered by the Casinos (the “ Program ”), they will jointly process the following categories of personal data:

• Contact details : name and surname, email address.
• Browsing data : information relating to web pages and sections thereof that you visit, place and time of connection, the IP of your computer or the ID of your mobile device and online identifiers, depending on whether or not you have consented to the deployment of certain cookies and similar technologies that are not strictly necessary for the operation of the YESFUN® Website, in accordance with our cookie policy.

3. Basic information on the processing of personal data

Below, we inform you about the different purposes for which the Casinos may process the personal data that Users provide through this Website, indicating the legitimate basis for each processing:

4. Recipients

As a general rule, Casinos will not share Users’ personal data with third parties. However, in certain cases, such data may need to be shared with suppliers who need it to provide their services to Casinos, such as hosting providers and providers of services for the referral and management of commercial communications. These third parties will act as (sub)processors of Casinos and will provide appropriate guarantees to protect Users’ personal data, including the corresponding data processing contract in accordance with art. 28 GDPR.

5. International transfers

As a general rule, Casinos will not carry out direct transfers of personal data of Users outside the European Economic Area.

However, providers that provide services to Casinos, including in relation to hosting and/or data measurement services or subscription management and sending commercial communications, including newsletters , may process Users’ personal data outside the European Economic Area. In such cases, Casinos will contractually require such providers to guarantee the protection of Users’ personal data by adopting appropriate safeguards, in particular by subscribing to the standard data protection clauses approved by the European Commission in accordance with Article 46 of the GDPR.

6. Conservation periods

The data will be kept for the time strictly necessary to fulfil the purpose that justified its collection and processing. Before proceeding to its total deletion, the personal data will be kept blocked until the expiration of the limitation periods of the legal obligations or responsibilities that may be applicable to the Casinos.

7. User Rights

We inform you that all Users of the Website may exercise, at any time and free of charge, the following rights:

1. Right to be informed about the processing of your personal data by the Casinos and to access such data (“right of access”);
2. Right to obtain rectification of inaccurate personal data (“right to rectification”)

• Right to request the deletion of your personal data (“right to deletion”), or, in certain cases, to stop its processing (“right to restriction);

1. Right to request and, where applicable, obtain the portability of your data (“right to data portability”); and
2. Right to object and withdraw consent given for certain processing of personal data (“right to object”).
3. The right to withdraw your consent to the processing of your personal data for one, several or all of the purposes indicated above, which depend on such consent for processing. Please note that, where applicable, this may affect the way in which we provide the services to you or even lead to their termination.

You may exercise any of your rights or obtain further information regarding this privacy policy by sending an email to the following address: dpo@grupperalada.com , including a mention of “YESFUN® – Data Processing” in the subject of the email.

Likewise, if you consider that the Casinos have not treated your personal data in accordance with current regulations, you may file a claim with the Spanish Data Protection Agency.

8. Cookies policy

Casinos will process the data collected through the use of cookies in accordance with the Cookies Policy available at the following link: ≪ www.yesfun.app/politica-cookies ≫.

9. Updates and modifications

Casinos may update and modify this Privacy Policy at any time in order to adapt it to any changes that may occur, whether in relation to the type of data processing carried out, or as a result of changes in the legislation, guidelines or jurisprudential criteria on the subject that are applicable.

Last updated: October 2024

PRIVACY POLICY – YESFUN® APP

(iOS & Android)

The purpose of this privacy policy is to inform you about the processing of personal data of users (“ Users ”) of the YESFUN® application (“ the APP” or “Application ”) carried out by the companies identified below (jointly referred to as “ Casinos ”) as joint controllers .

Such processing of personal data is carried out by Casinos in accordance with Regulation 2016/679 (EU) of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (“ GDPR ”) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (“ LOPD ”).

1. Identification and contact details of the data controller

The following entities act as joint controllers of the processing:

Casinos has appointed a Data Protection Officer (“ DPO ”), who may be contacted with any questions and/or doubts regarding any aspect of this privacy policy. For such purposes, you may send an email to the following email address: dpo@grupperalada.com , including, if possible, a mention of “YESFUN® – Data Processing” in the subject of the email.

2. Categories of data processed

In the context of the loyalty program offered by the Casinos (the “ Program ”), they will jointly process the following categories of personal data:

• Program registration data : name and surname, date of birth, access password and email address (which will act as your unique identifier). We will also be able to know if, once you have downloaded the Application, you have accessed it, in order to offer you the incentive or prize associated with said first access to the APP, if applicable.
• Data relating to user interactions with establishments participating in the Loyalty Program: record of visits to our establishments, including date and frequency of visits.
• Data on gaming activity, bets placed and consumption in our Casinos : data relating to gastronomy, leisure, events, slots, bets and/or promotions viewed and/or consumed by the User.
• Data relating to the allocation, exchange and consumption of points : number of points generated and accumulated and assigned to each player at any given time, as well as information relating to the exchange of said points for restaurant reservations, purchase of tickets for shows or consumption of other prizes and/or discounts, whether marketed by entities within the Peralada Group or by third-party companies on the VIP DISTRICT platform.
• VIP DISTRICT Data: Casinos may have access to information relating to the benefits viewed and/or consumed by each User, provided that the latter has expressly authorized this.
• Data on participation in VIP DISTRICT raffles/contests: Casinos may have access to data relating to the participation of Users in raffles and/or contests organised within the VIP DISTRICT environment.
• Invite a friend : name, surname and email address of both the User and the friend.

Additionally, to ensure the operation of certain functionalities of the APP, the following data will be processed:

• Device identification data : basic data of the device used to access the APP, including the model and operating system.
• App Activity : information about how the User interacts with the APP, based on whether or not the User has consented to the deployment of certain cookies and similar technologies that are not strictly necessary for the operation of the APP, in accordance with our cookie policy (≪ yesfun.app/cookie-policy ≫). Such data includes login, session reminders and push ID if push notifications have been enabled.
• Geolocation : If you provide your consent, we may track location-based information from your mobile device, for example, to send you personalized notifications informing you of your position on the waiting list of customers wishing to join a gaming table.

3. Basic information on the processing of personal data

Below, we inform you about the different purposes for which the Casinos may process the personal data of Users, indicating the legitimate basis for each treatment:

Any personal data processing activity not expressly mentioned in this policy will be the responsibility of third parties. In particular, any payment data processing that occurs within the VIP DISTRICT platform environment will be the responsibility of the payment gateway provider and/or, where applicable, VIP DISTRICT, as specified in the relevant privacy policy.

4. VIP DISTRICT

Those Program Users who voluntarily decide to register as “YESFUNNERS” will have access to the benefits and services that VIP DISTRICT offers through its loyalty platform.

VIP DISTRICT will act as the data processor for the personal data of “YESFUNNERS” users who access the platform. Casinos has entered into the corresponding data processing contract with VIP DISTRICT, in accordance with the provisions of the applicable data protection regulations, in order to ensure that the processing of user data is carried out with the application of appropriate security measures to protect its integrity and confidentiality.

For additional information on the processing of personal data within the framework of the VIP DISTRICT platform, users can consult the privacy policy available through the following (≪ https://yesfun.ventajasvip.com/privacy-policy.action ≫).

5. Recipients

As a general rule, Casinos will not share Users’ personal data with third parties. However, in certain cases, such data may need to be shared with:

• Suppliers: Access to personal data will be granted to those suppliers who need it to provide their services to Casinos, such as loyalty service providers (VIP DISTRICT), hosting providers, and providers of referral and management of commercial communications. These third parties will act as (sub)processors of Casinos and will provide appropriate guarantees to protect the Users’ personal data, including the corresponding data processing contract in accordance with art. 28 GDPR.

• Others: Casinos may share personal data of Users with third parties if required to do so by a regulation, by an administrative or judicial authority or for the good purpose of public interest or order, including compliance with tax obligations.

Finally, in the event of a corporate restructuring, merger, spin-off or sale, Casinos may transfer all personal information about Users to the third party arising from said transaction, based on the legitimate interest of the company in accordance with article 21 of the LOPD.

6. International transfers

As a general rule, Casinos will not carry out direct transfers of personal data of Users outside the European Economic Area.

However, providers that provide services to Casinos, including in relation to hosting and/or data measurement services or subscription management and sending commercial communications, including newsletters , may process Users’ personal data outside the European Economic Area. In such cases, Casinos will contractually require such providers to guarantee the protection of Users’ personal data by adopting appropriate safeguards, in particular by subscribing to the standard data protection clauses approved by the European Commission in accordance with Article 46 of the GDPR.

7. Conservation periods and security measures

The data will be kept for the time strictly necessary to fulfil the purpose that justified its collection and processing. Before proceeding to its total deletion, the personal data will be kept blocked until the expiration of the limitation periods of the legal obligations or responsibilities that may be applicable to the Casinos.

Casinos will implement the necessary technical and organizational measures to ensure the security of the personal data being processed, in order to prevent the loss, destruction, access, alteration or unauthorized disclosure thereof.

8. User Rights

We inform you that all Program Users may exercise, at any time and free of charge, the following rights:

1. Right to be informed about the processing of your personal data by the Casinos and to access such data (“right of access”);
2. Right to obtain rectification of inaccurate personal data (“right to rectification”)

• Right to request the deletion of your personal data (“right to deletion”), or, in certain cases, to stop its processing (“right to restriction);

1. Right to request and, where applicable, obtain the portability of your data (“right to data portability”); and
2. Right to object and withdraw consent given for certain processing of personal data (“right to object”).
3. The right to withdraw your consent to the processing of your personal data for one, several or all of the purposes indicated above, which depend on such consent for processing. Please note that, where applicable, this may affect the way in which we provide the services to you or even lead to their termination.

You may exercise, free of charge, any of your rights or obtain more information in relation to this privacy policy by sending an email to the following address: dpo@grupperalada.com , including a mention to “YESFUN® – Data Processing” in the subject of the email.

Likewise, if you consider that the Casinos have not treated your personal data in accordance with current regulations, you may file a claim with the Spanish Data Protection Agency.

9. Cookies policy

Casinos will process the data collected through the use of cookies in accordance with the Cookies Policy available at the following link: ≪ www.yesfun.app/cookie-policy ≫.

10. Updates and modifications

Casinos may update and modify this Privacy Policy at any time in order to adapt it to any changes that may occur, whether in relation to the type of data processing carried out, or as a result of changes in the legislation, guidelines or jurisprudential criteria on the subject that are applicable.

Last updated: November 2024