PRIVACY POLICY FOR CAXINO.COM
Version 3.1 last updated July 7, 2025

At Rootz, we value transparency and take your privacy very seriously. We appreciate your trust when you share your personal information with us and want to be clear about how we use it.

Rootz LTD, as the data controller, undertakes to protect your personal data and to process it in accordance with applicable laws – in particular: the Malta Data Protection Act (Data Protection Act , Chapter 586 of the Laws of Malta) and related secondary legislation – “DPA”; Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – “GDPR”.

This Privacy Policy describes the privacy practices of Caxino Casino , our applications, software, websites, APIs , products and services (the “Services”). You will learn what information we collect, how we use it, what controls you have over your information and what steps we take to protect it.

If you have any questions, please feel free to contact us at [email protected] .

1. Who we are and how to contact us

If you are a resident of the European Economic Area (EEA) or Switzerland, Rootz LTD, a Maltese company, is the data controller and provides the Services to you. If you wish to exercise your statutory rights, please contact our Data Protection Officer at [email protected] . You can also reach us at:

Rootz LTD
Ewropa Business Center
Level 3 – 701, Dun Karm Street
Birkirkara BKR 9034
Malta

Email: [email protected]

If you wish to exercise your statutory rights, please contact our Data Protection Officer at [email protected] .

As Rootz is based in Malta, we are subject to the GDPR. This means that we always follow the GDPR principles when processing personal data:

• Legality, correctness and transparency
• Purpose limitation
• Task minimization
• Correctness
• Storage minimization
• Integrity and confidentiality
• Liability

If you have any questions, suggestions or concerns about this policy or our use of your information, please contact us at [email protected] .

2. Why we collect personal data

We need to process your personal data in order to provide our services. We always ask for the minimum amount of information possible and use it only for lawful purposes.

When you register an account with Caxino, you enter into an agreement with us according to our General Terms and Conditions. In order for us to fulfill the agreement and provide you with access to our services, we must process certain personal data about you. We always clearly state which data is mandatory and which you can refrain from providing. If you do not want to provide mandatory data, you cannot have an account with us or use our services. We use your data to:

• Help you create, operate and manage your personal profile and provide you with access to our games and services
• Manage loyalty points and rewards programs
• Protect your personal profile and account
• Process your bets and transactions, including the use of cards and online payment systems
• Provide customer support and service updates
• Analyze user trends and improve our services
• Monitor multiple account registration

Some information is also processed to comply with our legal and regulatory obligations as a gaming company, such as licensing requirements, responsible gaming and anti-money laundering (AML) regulations. This processing is done to:

• Conduct age and identity checks
• Verify source of wealth
• Performing duet due diligence checks
• Monitor and investigate transactions and gaming behavior to prevent and detect fraud, money laundering, problem gambling and other improper gaming activity
• Consult self-exclusion registers and manage problem gambling
• Manage registration of duplicate accounts and individuals from jurisdictions where gambling is prohibited

Caxino processes a limited amount of information about everyone who visits our website. This is to better understand our visitors and identify problems, security issues or errors. We use technical programs and functional cookies. Such processing is necessary for Caxino’s legitimate interest in offering a pleasant, safe and smooth customer journey and to protect the product against misuse that may affect other users’ ability to use the service. Read more in our Cookie Policy.

If we have your consent, Caxino will contact you about news, promotions and bonuses. We will only do this if you have given us your prior consent. You control whether and how we contact you via your account settings and can change these at any time.

Caxino will never ask you to provide sensitive personal information, such as health or racial/ethnic origin. Sometimes you may choose to tell us such information yourself, for example when contacting support. Chats and emails are linked to your account and if you disclose a health condition that may affect your ability to make rational decisions about gambling, we may block your access to our services for security reasons.

3. Where we get your information from

Most of the information comes directly from you. Sometimes we get information from other sources.

According to AML requirements, we must perform due diligence diligence checks to confirm information about you. In some cases, we need to verify your source of wealth. We work with reputable external companies operating in the gaming industry for these checks and receive reports with information about you and your background.

Payment service providers may in certain situations provide us with limited personal data in connection with a transaction so that we can link the transaction to you as a player.

4. Data we collect

When you use the Services, we collect the following types of information:

Information you provide to us

Account details
Certain information is required to create an account: name, address, email address, password, date of birth, gender, phone number and country of residence. This is important data for the KYC process according to AML regulations in Malta and the EU. This is the information you must provide to create an account.

Due to legal requirements, we also ask for your occupation and source of income. In some situations, you may need to submit documentation proving that you are using legitimate means.

Additional Information
To enhance your experience or enable certain features, you may choose to provide additional information, such as gaming preferences and payment/transaction history.

If you contact us or participate in a survey, competition or campaign, we collect the information you submit, such as name, contact information and message.

Data from third-party services
If you connect your account with us to an account with another service, we may receive information from that service.

Payment and Card Information
For payouts, you will be required to provide certain identification and verification information: name, card number (credit/debit/other), card expiration date and CVV code. The information is encrypted and sent to the card network, which upon approval returns a token (random numbers) for transactions without exposing the card number. For your convenience, we store the last four digits of the card number as well as the card issuer’s name and contact information.

Location information
We can derive approximate location from your IP address.

Usage Information
When you use the Services, we receive usage data: interactions, such as when you view/search content, log in, play games, receive/redeem bonuses or loyalty points.

We also collect data about the devices/computers you use for access: IP addresses, browser type, language, operating system, referring website, pages visited, location and cookie information.

Cookie Information
Our websites use “cookies”, which are software that can be sent to your device. Cookies allow us to collect information about how our websites and services are used and to operate them more effectively.

See our updated Cookie Policy .

5. How we use data

We use collected data for the following purposes:

Providing and maintaining the Services
The information helps us deliver the Services and fulfill our agreement with you. For example, we need to use your information to provide your player dashboard , provide game suggestions and relevant marketing campaigns.

Improve, customize and develop the Services
We use the information to improve and customize the Services and develop new ones. Examples: troubleshooting and protection against errors; data analysis and testing; research and surveys; development of new features. We also segment players based on behavior to understand usage and develop our marketing, including bonuses/promotions.

If you allow location collection, we use it to improve features, such as showing favorite games or games you may be interested in at the top, based on your preferences, country, and game data.

We must comply with AML/CTF and anti-fraud regulations . We therefore use software that monitors player behavior and warns of suspicious/ fraudulent transactions. If the system flags anything, we escalate it to the relevant regulatory and law enforcement authorities.

As part of our license, we also have obligations around responsible gambling. We use a system that flags patterns of gambling that may indicate problem gambling. When an account is flagged, our RG team makes an assessment and, if necessary, contacts the player for discussion and information/advice.

Third Party Websites
Our websites may occasionally contain links to local/international third party websites (with their permission). Such links do not constitute an endorsement of the information, products or services there. We are not responsible for the content, availability, privacy practices or otherwise of those websites. When you leave our website, the privacy policy of the respective website applies.

No third party may link another website to ours without our written consent.

6. How we communicate with you

We use your information as needed to send you service notifications and to respond to you when you contact us. We also use your information to market new features/products that may be of interest to you. You can control marketing and most service notifications through the notification settings in your account or via the “Unsubscribe” link in emails.

Use of Email for Communication
All emails are routinely scanned for viruses . We may reject, delay or delete email content due to content/attachments that may interfere with our systems or pose a security risk (e.g. viruses). We may also filter emails with certain content (e.g. offensive or spam). Unfortunately, this can sometimes affect “innocent” emails, but we try to minimize this.

Please note that data sent over the Internet can technically cross national borders even if the sender and recipient are in the same country. This means that personal data about you may be transferred through countries with a lower level of protection than in your home country.

7. How data is shared

External Processing
In some cases, we need to share your information with recipients outside of Caxino in order to provide the Services. When we share with third parties, we always ensure that appropriate agreements are in place, that the transfer is secure, and that only the minimum information necessary is shared.

Third parties we work with include payment and gaming providers, analytics services, identity and AML services, social platforms, website performance and security systems, affiliates and other partners who process data on our behalf in accordance with our instructions, this policy and adequate privacy and security measures. These partners provide global services such as customer support, IT, payments, marketing, data analytics, research and surveys.

When you consent or instruct us to share
You may ask us to disclose information, such as when you use community features such as “Races.” For some information, we offer privacy settings and other tools in your account to control visibility to other users. Please note that if you participate in a “Race,” information such as your first name may be visible to all participants.

Analytics and advertising services from others
We work with partners who provide analytics and advertising services. This helps us understand how the Services are used, serve ads to us across the web, and measure their effectiveness. These companies may use cookies, pixels, and similar technologies to collect information about your interactions with the Services and other websites/ apps .

We may share non-personal information that has been aggregated or de-identified so that an individual cannot reasonably be identified. Such information may be used for research/statistics.

We do not transfer your personal data to third parties for marketing purposes or purposes other than those stated above.

For legal reasons or to prevent harm
Without prejudice to anything else in this policy, we are obliged to disclose personal data about you to third parties if necessary, including to:

• prevent, detect or prosecute fraud or other crime,
• when required by national/public security,
• for budgetary, monetary or fiscal interests,
• protect and defend our or users’ rights and property,
• protect against misuse/unauthorized use of the Services,
• protect the safety or property of individuals (e.g. in the event of false information or attempts to impersonate someone else), and
• fulfill agreements you have entered into with us or when required by law.

Our policy is to notify you of any legal process requesting access to your information (e.g., search warrant, court order, subpoena), unless we are prohibited by law. If a court imposes a confidentiality period, we will provide delayed information after the period has expired.

8. Your rights to access and control your personal data

We provide account settings and tools for accessing and controlling your personal information, no matter where you live.

Access and export of data
You have the right to:

• access the information we have about you,
• correct incorrect information,
• in very limited cases, have data deleted,
• in some cases, limit or “pause” use,
• have the data in digital format and, where possible, transferred to another organization.

By logging in, you can access much of your information, including your dashboard .

If you want to exercise your rights, email [email protected] from your registered email and state:

• Your name
• Contact details
• Your registered email
• Full description of your request

In some cases, we may request ID documents to verify identity. We will fulfill your request to the extent possible.

Editing and deleting data
In the account settings you can change personal data. For example, you can update profile information or request deletion of the account via [email protected] .

Please note that it may take up to 30 days to delete transaction data (e.g. game data) due to the scale/complexity of the systems.

We recognize the right to be forgotten, but according to AML regulations, we are required to retain all account data collected for Know Your Customer (KYC) purposes, such as name, address and all documentation from registration and payment processes, for 5 years after you close the account. This period may be extended for a further 5 years if deemed necessary for the prevention, detection, analysis and investigation of money laundering or terrorist financing by the FIAU, regulatory authorities or law enforcement agencies.

Customize or limit the use of your data
Your account has settings to control data usage. For example, you can limit visibility to other users or control notifications.

You have the right to object to use for direct marketing. Use the notification settings to control marketing communications about new games/products. See also our Cookie Policy for how to control our and our partners’ use of cookies and similar technologies for advertising.

If you need further assistance regarding your rights, please contact our Data Protection Officer at [email protected] . You can also file a complaint with your local data protection authority or the Malta Data Protection Authority (our lead supervisory authority).

9. Data storage

We retain account information – such as name, email and password – for as long as the account exists because it is needed to operate the account. For information on retention periods, please contact [email protected] .

10. Promote safety and security

We use collected information to enhance the security of the Services, our users, and others. For example: authenticate users, enable secure payments, protect against fraud/abuse, respond to legal requests, conduct audits, and enforce our terms/policies.

For personal data, we support processing on several legal grounds: your consent (which can be withdrawn via account settings), when processing is necessary to perform the contract with you (e.g. General Terms and Conditions), and our legitimate interests (e.g. improving/developing the Services, marketing relevant features/products, and promoting security).

Information Security
We work hard to keep your information secure and make reasonable efforts to protect the confidentiality of the personal information we process. We regularly review and improve our technical, physical and organizational procedures: access control, authentication, logging, monitoring, alarms, data storage/backup and transfer standards – to prevent unauthorized access, alteration, misuse, disclosure or unlawful destruction/accidental loss.

Our security policies, rules and technical measures are aimed at protecting the personal data we control. All employees and data processors who have access to and are involved in the processing are bound by confidentiality and must comply with privacy principles .

However, the Internet is by its nature not a completely secure medium and data can potentially be exposed to unauthorized actions. No method of transmission or storage is completely secure. If you have any security-related questions, please contact Customer Support.

11. International operations and data transfers

Caxino will retain your information within the EEA as much as possible. However, in some cases, data must leave the EEA, e.g. when collaborating with third parties. Caxino always ensures that transfers outside of Europe are legal and secure.

We use multiple legal bases for global transfers of personal data, including your consent, the EU-US and Swiss-US Privacy Shield (to the extent relevant/replaced), as well as the European Commission’s Standard Contractual Clauses which require certain privacy and security protections. Copies of the Standard Clauses can be obtained by contacting us.

12. Compliance with privacy legislation

Our privacy policy complies with the Malta Data Protection Act (Cap. 586) as well as future data protection legislation, including the GDPR and other applicable law.

Filing a complaint
If you are dissatisfied with how Caxino has handled your information, first contact Support at [email protected] .

If you are unable to resolve the issue with Support, please contact our Data Protection Officer (DPO) at [email protected] and provide:

• Your name
• Your contact details
• Your registered email
• Full description of the complaint

The DPO investigates whether your data has been handled correctly in accordance with this policy, our legal obligations and internal procedures, and provides feedback with the outcome and any actions taken.

If you are still dissatisfied after the DPO’s response, you can complain to our lead supervisory authority:

Office of the Information and Data Protection Commissioner
Level 2, Airways House, High StreetSliema, SLM 1549, Malta
Telephone : (+356) 2328 7100
Email: [email protected]

Translations of this Privacy Policy
We have translated the policy from English into the official languages of the countries in which we operate to ensure clarity. In the event of any conflict or discrepancy between translated versions, the English version shall prevail.

Changes to this policy
This privacy policy may change at any time, particularly in the event of new legal requirements or for security reasons. Any changes will be published here so that you are always aware of how and why we process your data.

We will notify you before we make any material changes and give you the opportunity to review the revised policy before deciding whether to continue using the Services.