PRIVACY POLICY

(last updated 15.07.2026)

1. Purpose

The purpose of this Privacy Policy is to describe the information that the Company named Vargspire Ltd., registration number 2026-00017 (the “Company”), registered in Saint Lucia with its official address at Unit 1, La Place Creole Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia collect through the use of the website  https://moneymoon.casino/ (the “Website”) that we operate, how we use, disclose and protect your Personal Information, and the choices you can make about your Personal Information.

We strongly recommend that you carefully review the Privacy Policy and use it to make informed decisions. By accessing and using our Services, you agree to the terms outlined in this Privacy Policy, and your continued use of the Services signifies your ongoing acceptance of these terms.

1.1 Your Privacy Matters

The Company’s mission is to provide our players with a unique experience through innovation, high-quality products, transparency, and excellent player care. A core aspect of this mission is our commitment to being transparent about the Personal Information we collect, how it is used, and with whom it is shared.

This Privacy Policy applies whenever you use our Services (as described below).

 

1.2 Introduction

Our Players share their personal identities and other personally identifiable information in order to take part in our Services (enlisted below).

Services

This Privacy Policy applies tohttps://moneymoon.casino/the Company's branded applications, and related websites, apps, communications, and services. We are an online gaming company offering services such as Sportsbook and Casino.

Players use our Services for various activities, including placing bets, playing games, browsing our Website, depositing and withdrawing funds, connecting to social media, and more. Our Privacy Policy applies to all Players and Visitors who engage with our Services.

 

2. PI Collection

 

2.1 Personal Information

The first type of information we collect is personally identifiable information, also known as Personal Information, which can identify an individual or, with reasonable effort, identify an individual.

·     Account Information: When you create an account on our Services (whether directly through our website or via an affiliate’s landing page), you will be asked to provide Personal Information. This includes details like your full name, email address, home address, date of birth, phone number, payment methods (e.g., credit card number), and other financial information necessary to provide our Services.

·     Voluntary Information: We may also collect information that you voluntarily provide to us, such as when you communicate with us through email, live chat, or provide additional details about yourself via your use of the Services. Additionally, we may collect feedback, suggestions, complaints, or reports that you submit.

·     Device Information: We may collect Personal Information from your device, such as your IP address, geolocation, and unique device identifiers (e.g., MAC addresses, UUID, etc.).

The second type of information we collect is non-identifiable information, referred to as
2.2 Non-personal Information.

This data cannot be used to identify you and may be collected as you use our Services.

·  Usage Information: This includes aggregated data on your interactions with our Services, such as pages viewed, online browsing behavior, clicks, and other actions.

·  Technical Information: This may involve technical details transmitted by your device, such as the type of browser and operating system you use, language preference, access times, and the domain name of the website you were referred from.

Non-personal Information helps us improve the functionality of our Services.

 

2.3 If we combine Personal Information with Non-personal Information, the combined data will be treated as Personal Information for as long as it remains combined.

3. How we share information.

3.1 Our Services

 

3.1.1 Profile

Your profile is fully protected within our Services. We never publish your Personal Information publicly on the web or in any other public space. However, we may share certain Personal Information with third-party service providers based on legitimate interest or other lawful grounds.

Internally, we ensure that only authorized personnel have access to your Personal Information, and only when it is necessary for them to perform their professional duties. We take great care in handling your data to ensure its protection and privacy.

3.1.2 Third Parties We Use

Email Provider: We utilize a third-party email service to automate our email communications and enhance our analytical capabilities. The only personally identifiable information shared with this provider is your email address and The Company User ID.

We have ensured that our email provider complies with PIPEDA, FIPPA, and GDPR regulations, making it a secure and reliable third-party service. Your Personal Information will be deleted from their servers upon our request.

 

3.1.3 SMS Provider: We have verified that our SMS provider complies with FIPPA, PIPEDA, and GDPR regulations, ensuring that your data is handled in accordance with applicable laws.

The only Personal Information shared with this provider is your mobile phone number. Your Personal Information will be deleted from their servers upon our request.

If The Company utilizes this service to support internal marketing efforts, delivering relevant messages, offers, and product updates.

Additionally, we use this provider to verify Players during the registration process and to implement various security features.

 

3.1.4 Payment Providers: For the use of our Services, we offer a range of trusted third-party payment options. Your withdrawals and deposits will be processed through these third-party payment providers, and we share the following personal information with them: first name, last name, date of birth, email, address, zip code, city, country, phone number, and alias. This is necessary under the contract with The Company to facilitate the use of our Services.

 

3.1.5 Casino Providers: We collaborate with various casino providers to deliver our Services to our Players.

 

3.1.6 Player support: We use several providers in order to service our Players' requests. By contacting our support team, you acknowledge that the communication will be shared with these 3rd parties. This is necessary under the contract with The Company, in order to use our Services. We use the following providers:

 

Using social media: We allow you to share content related to you and our services on various social media platforms (e.g Facebook). We want to emphasize that you control where you want to post or share this content and that it is under your control to keep or delete this content under your social media provider's settings. Moreover, you should be aware that anything that is posted on social media platforms, can be redistributed or re-shared by anyone.

3.2. Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing, and development), including but not limited to sports governing bodies, payment services providers, and financial institutions. They will have access to your Personal Information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. We take great care in the selection of the providers that we choose to work with and make sure that they are committed to protecting your data at all times.

3.3 Legal Disclosures

It may be necessary for us to disclose your Personal Information if required by law, subpoena, or other legal processes, or if we have a good faith belief that such disclosure is reasonably necessary to:

• Investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
• Enforce our agreements with you;
• Investigate and defend ourselves against any third-party claims or allegations;
• Protect the security or integrity of our Services (including sharing information with entities facing similar threats);
• Exercise or protect the rights and safety of The Company, our members, personnel, or others.

 

When appropriate, and unless prohibited by law, court order, or emergency circumstances, we strive to notify Members of legal demands for their personal data. We may challenge such demands if we believe they are overly broad, vague, or lack proper authority, but we do not guarantee that we will contest every request.

 

3.4 Change in Control or Sale

We may also disclose your personal data in connection with a sale, merger, acquisition, or other change in control, including during the preparation stages of such events. Any entity that acquires us or a portion of our business will have the right to continue using your data in accordance with this Privacy Policy, unless you provide consent for different terms.

 

4. Your Choices and Obligations (Rights)

 

4.1 Data Retention

We retain your Personal Information as long as your account remains active or as required by law, legitimate interest, or operational necessity. This includes data you provide, data generated from your use of our Services, and any necessary records. Even if you do not use our Services for an extended period, we will keep your Personal Information until either you or we decide to close your account. Additionally, we follow internal guidelines to prompt you about account closure after prolonged inactivity. Regardless of account closure, we may retain necessary data as required by law or deemed critical, with a clear retention timeline. For risk management and compliance purposes, we may store your personal details for up to 5 years.

 

Below we have described our data retention procedure:

The Company will retain data about you in the following way: based on legitimate interest, legal requirement, based on the contract with us, and by consent.

 

4.2 Rights to Access and Control Your Personal Data

You have the option to choose the type of communication you receive from us or opt out entirely. Additionally, you can modify or update certain personal data, subject to applicable laws, our internal policies, and the information necessary to fulfill our Service obligations.

 

4.3 Account Closure

If you choose to close your The Company account, your personal data will be removed from our communication channels, ensuring that you are not included in any further processing or profiling within 72 hours.

However, we may retain your personal data even after account closure if necessary to:

• Comply with legal obligations (including law enforcement requests)
• Meet regulatory requirements
• Address legitimate business interests
• Resolve disputes
• Maintain security
• Prevent fraud and abuse
• Enforce our Terms and Conditions, Privacy Policy, or other service-related agreements
• Fulfill your request to unsubscribe from future communications

We will retain de-personalized information after account closure. This data is irreversibly anonymized and cannot be restored or decrypted.

Personal data will be depersonalized after 5 years from the date of account closure or inactivity. However, complete deletion is not possible due to compliance with Applicable Law, PCMLTFA, and related regulations, which require data retention for:

• Player due diligence
• Fraud prevention
• Responsible gaming obligations
• Operational purposes such as sportsbook risk management, fraud detection/prevention, and player segmentation/communication.

 

4.4 Keeping the Information Accurate and Current

4.4.1 Operator responsibility

We will ensure that your Personal Information is kept as accurate, complete, and up-to-date as possible. We will not routinely update your Personal Information unless such a process is necessary. We expect you, from time to time, to supply us with updates to your Personal Information, when required.

4.4.2 Player responsibility

You can contact us at any time to review, correct, update, or modify the Personal Information we hold about you. To do so, please provide clear details regarding the information you wish to change or specify if you want your Personal Information removed from our servers.

If you demonstrate that the Personal Information, we have is inaccurate or incomplete, we will update our records accordingly. However, please note that:

• Certain data may need to be retained for recordkeeping purposes.
• Residual information may remain in our databases and archives, which cannot be fully removed.
• We will make commercially reasonable efforts to update third parties that have access to your Personal Information, if necessary.

4.5 Complaints Management

If you have a complaint, please refer to clause 10 in our Terms and Conditions

 

5. Other Important Information.

5.1 Security

The Company implements strict security standards to safeguard your Personal Information. Our security measures include:

• Regular system monitoring for vulnerabilities and potential attacks
• Annual penetration testing to identify and address security risks
• Employee training by security professionals
• Proportionate security measures for network and infrastructure protection

Access to your Personal Information is restricted to personnel who have a legitimate business need to process it.

However, despite these efforts, no system is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, disclosure, alteration, or destruction will never occur due to potential breaches of physical, technical, or managerial safeguards.

 

5.2 What can you do in order to mitigate risks

5.2.1 Use strong password protection.

Using strong, complex passwords can help stop cyberthieves from accessing your Personal Information. Simple passwords can make access easy. If a cybercriminal figures out your password, it could give them access to your Personal Information. Creating unique, complex passwords is essential.

A strong password contains at least 10 characters and includes numbers, symbols, and capital and lowercase letters. Also, it’s essential to change your passwords on a regular basis. Changing and remembering all of your passwords may be challenging. A password manager can help.

5.2.2 Protect your Personal Information

To protect your Personal Information, it's important to follow best practices and stay vigilant, especially in an online environment. Here are some steps to take:

• Install anti-virus software and ensure that all computer software, including your operating system and applications, is regularly updated.
• Log off public computers and avoid leaving sensitive information open on shared devices.
• Be cautious of pop-ups, unknown emails, and suspicious links. Avoid clicking on anything that seems suspicious, even if it appears to come from a trusted source.
• Limit social network information sharing, and be mindful of the personal details you post online. Cybercriminals can use this information for fraudulent activities.

Remember, cybercriminals can fake legitimate sources like emails, phone calls, and websites, so staying alert and cautious is key to protecting your information.

5.3 Lawful Bases for Processing

We will only collect and process your Personal Information when we have a lawful basis to do so. The lawful bases for processing include:

• Consent (when you give us your permission to process your information)
• Contract (when processing is necessary for the performance of a contract between you and us, such as providing the services you have requested)
• Legitimate Interests (when processing is necessary for our legitimate interests or the legitimate interests of third parties, provided that such processing does not outweigh your rights and freedoms)

We may process your Personal Data for the purposes of our legitimate interests or for the legitimate interests of third parties (e.g., email or SMS service providers), as long as this processing does not violate your rights and freedoms.

Examples of how we may process your Personal Data for legitimate interests include:

• Protecting you, us, or others from threats (e.g., security threats or fraud)
• Complying with applicable laws
• Enabling or managing our business operations (e.g., quality control, consolidated reporting, segmentation for product offerings, and player services)
• Managing corporate transactions (e.g., mergers or acquisitions)
• Understanding and improving our business or player relationships
• Personalizing offers and your experience on our site

Definitions of the lawful bases:

·       Consent: For activities such as direct mail, SMS, electronic email, and phone calls, we will always ask for your explicit consent before processing your information.

·       Contract: This includes using third-party providers essential for providing our core services, such as payment providers, casino providers, player support providers, and service notifications.

·       Legitimate Interest: This includes essential internal routines necessary for our day-to-day operations and compliance with our terms and conditions.

When we rely on your consent to process your Personal Information, you have the right to withdraw your consent at any time. If we rely on legitimate interests, you have the right to object to such processing.

If you have any questions about the lawful basis on which we may collect and use your personal information, please contact our Player Support by emailing [email protected].

6. Changes to our Privacy Policy

6.1 We may update this Privacy Policy from time to time. Any changes will take effect from the date they are published on the Site. We encourage you to review this Policy frequently to stay informed about any updates.

6.2 If any material changes are made to this Policy, we will take all reasonable steps to inform you in advance. This may include sending an email, providing a notice on the Website, or using other communication channels to notify you of the changes.

7. Contacting Us

If you have any questions or concerns regarding this Privacy Policy, or if you would like more details about how we process your Personal Data, you can contact us in writing at any time at privacy@moneymoon.casino