As a licensed operator in Italy, we gather and manage personal and transactional data under stringent legal obligations https://it-richroyal.it/legal-and-affiliates/. This policy spells out exactly how long we retain different categories of information, the legal reasons behind those periods, and the security measures that protect your data at every stage. We regularly balance our duty to retain records for fraud prevention and financial audits with the privacy rights you maintain under Italian data protection law and the GDPR. Our schedules get regular reviews so we keep fully compliant.
Individual Rights and Retention Handling
When you send an erasure request, our system automatically reviews each data category against its retention schedule. Anything past its mandatory window is removed without delay. For data still subject to a legal retention obligation, we restrict it right away so it’s taken out of active use and kept solely for compliance storage; we inform you which specific law is relevant and the date deletion becomes possible. Access requests are responded to within thirty days and provide a breakdown of what we keep, why, and the scheduled deletion date. If you dispute accuracy, we add a note instead of altering the original record, so the audit trail is preserved. Portability requests are honoured in a structured, machine‑readable format even while data is still in its retention window.
Policy Updates and User Notifications
We assess this Data Retention Policy every six months and whenever a major legal change impacts Italian gambling operations. Minor clarifications go up silently with a revised effective date. Material changes that modify retention periods, add new data categories or shift the legal basis for processing are communicated directly to you by email at least thirty days before they come into force. You’ll also find an in‑platform banner notification when you log in during the notice period. Historical versions are archived and available on request, each with a version number and a validity date range. If an earlier version offered a shorter retention period for certain data, we follow that promise for data collected under that version and apply new terms only going forward.
Data Security In Preservation
Retained data is safeguarded with AES‑256 encryption at rest, TLS 1.3 protocols in transit and isolated virtual private clouds. Access demands multi‑factor authentication plus just‑in‑time privilege elevation that terminates on its own. Every access event is logged into an immutable audit trail. We run quarterly penetration tests through CREST‑certified firms and continuous vulnerability scans to maintain our storage tight. Backups are encrypted and spread across Italian data centres, with strict controls that block accidental restoration of data past its deletion date. A dedicated lifecycle dashboard identifies every dataset as it nears expiration.
Access Governance and Employee Education
Only employees whose roles demonstrably necessitate access to retained personal data get permissions, and those permissions go through monthly recertification audits. Any access to dormant user records prompts a managerial review within one business day. Every staff member who handles personal data completes mandatory annual training on Italian data protection law and our internal retention policies, including hands‑on exercises on spotting valid erasure requests and distinguishing the difference between data we must keep under a legal hold and data we can delete straight away.
Regulatory Foundation for Record Keeping
Our data management policy relies on several legal duties that apply to gambling operators targeting the Italian market. Anti‑money laundering regulations from the Italian Financial Intelligence Unit oblige us to keep transaction records, identity verification documents and suspicious activity reports for a fixed term after the business relationship ends. Meanwhile, tax rules administered by the Agenzia delle Entrate oblige us to preserve financial records that support taxable gaming revenue and player winnings. These obligations override any general right to erasure during the mandatory period. For operational data that doesn’t fall under a fixed legal window, we base our approach on legitimate interest assessments where a valid reason exists, and we provide an opt‑out option unless a compelling legal obligation overrides it.
Consent‑Based Retention
Marketing preferences, newsletter sign‑ups and the behavioural analytics utilised for personalised offers remain only with your explicit consent. You can retract consent anytime through your account dashboard; once you do, we stop that processing immediately and delete the connected profiles within thirty days. Data processed lawfully before withdrawal gets isolated from active systems to block further use, but it is not removed retroactively. Consent records themselves are kept for six years as proof of compliance. We never employ this data for anything beyond the activity you agreed to.
Cross-border Data Transfers and Retention
Our primary infrastructure is located within Italy and the wider European Economic Area. Some ancillary services, like fraud detection platforms and customer relationship tools, may pass certain personal data to countries outside the EEA. In those cases, we guarantee an adequacy decision is available or we implement Standard Contractual Clauses in place together with a transfer impact assessment. The retention periods we use to transferred data match those in this policy, and processors are contractually bound to remove or return data when the service ends. We maintain a public register of sub‑processors, updated within fourteen days of any change, and we choose vendors with Italian data centres. Geo‑fencing rules maintain Italian user data inside European boundaries, confirmed through yearly audits.
Partner Program Data Retention
Affiliate partner information, including communication data, payout data and commission transaction history, stays for the life of the active partnership plus a decade after the agreement terminates. That stems from tax obligations on commission payouts, which necessitate long‑term financial documentation. Affiliate performance metrics and combined referred-player data get anonymized after five years. We strictly forbid affiliates from autonomously collecting or keeping private data about referred players; they receive only anonymous, combined statements. Our affiliate contracts include inspection rights to check adherence, and any violation is reason for prompt contract ending and payout forfeiture.
Frequently Asked Questions
Is it possible to ask for data deletion prior to the retention period’s conclusion?
Absolutely, you may lodge an erasure request whenever you wish. We promptly review every data category against its mandatory retention requirement. If no legal obligation applies, we erase it promptly. Regarding items we must preserve, we confine them to storage‑only, explain the legal basis blocking instant erasure, and share the projected deletion date. You may also review all your data categories and their scheduled deletion dates from your account dashboard. Such a partial strategy respects your rights within the limits of Italian law.
What occurs with my data when I opt for permanent self‑exclusion?
Upon enrolling in permanent self‑exclusion, your identity information is transferred to a specialized exclusion register that remains active indefinitely under strictly controlled access. It is a legal obligation intended to block you from establishing new accounts. Your gameplay and transaction history, on the other hand, still follow the standard retention schedules and get deleted once those periods run out. The self‑exclusion entry is isolated from all marketing and operational systems, thus it fulfills solely the protective purpose for which it was gathered. You will not receive any promotional messages.
How do you handle data belonging to inactive accounts?
An account becomes inactive after twelve straight months with no login. At that point, we automatically switch off marketing communications and move the account to a dormant state with reduced processing. The underlying retention clocks keep ticking based on the original collection dates, not the inactivity date. This implies that data from a dormant account is still retained for the complete legal period relevant to its category and subsequently erased following our standard protocols. If you come back after a long break, you might need to complete a fresh Know Your Customer check to reactivate. Your data dashboard displays the current status continuously.
Data Types and Storage Durations
We organize all user data into clear categories, each linked to a retention schedule that matches its use and legal context. That organized approach keeps us from holding on to things forever. Every year our Data Protection Officer reviews these classifications and updates the timelines whenever new guidance comes from the Garante per la protezione dei dati personali. Below you’ll find how long each data type stays in our live systems before being securely anonymized or erased. Archived backups operate on a ninety‑day cycle because of technical limitations.
Personal and Financial Records
Identity documents you submit during Know Your Customer checks, like passport scans, utility bills and tax ID numbers, are kept on file for ten years after you end your account, as anti‑money laundering law mandates. Deposit and withdrawal logs, payment method tokens and wallet balance histories are held for ten years from the date of each transaction, fulfilling both AML requirements and Italian Civil Code limitation periods. We hold these records in encrypted, access‑restricted vaults and tamper‑proof ledgers. Once the retention deadline expires, we strip away all personal identifiers permanently; statistical trends may still be used but never in a way that links back to any individual.
User Activity and Help Desk Messages
Comprehensive records of game sessions, bets placed, outcomes and session lengths are kept for five years after each gaming event, matching the statute of limitations for civil disputes. Customer service transcripts, email threads and call recordings stay for three years from your last interaction, covering the typical complaint‑handling window. After those periods, raw logs and case attachments get permanently deleted. Aggregated, anonymised datasets can be kept indefinitely for product improvement and service quality analysis. All of this data lives in case management systems with role‑based access restrictions.
Responsible Gambling and Self‑Exclusion Data
When you activate self‑exclusion, your identity data must be stored permanently in a locked‑down register to stop you from opening new accounts, a measure Italian gambling regulations explicitly permit. Other safer‑gambling markers, like expired voluntary deposit limits, are deleted two years after the limit lifts. We never use self‑exclusion register data for anything other than enforcing the exclusion. The register is completely walled off from marketing and operational systems, so it serves only its protective purpose.
Information Erasure Procedures
When a information type hits the end of its scheduled retention, our automatic lifecycle system kicks off a protected erasure procedure. First, the data gets digitally detached from production databases. Next, physical storage blocks are replaced with random data patterns to prevent forensic recovery. Finally, a digitally signed log lands in a audit trail, giving traceable confirmation that purging happened on time. Backup copies rotate every ninety days, so any deleted data is removed from all media within three months. When a litigation hold applies, we suspend the deletion workflow only for the affected records, document the hold reason, and restart once the hold lifts.
