Privacy policy – clickplayzone.com
Last updated: 1 July 2025

1. Who We Are
Monterizo LTD ("Monterizo LTD", "we", "our" or "us") operates the website https://clickplayzone.com (the "Website"). Monterizo LTD is a company incorporated in Cyprus (registration no. HE 409253) with its registered office at A.G. Leventi 5, The Leventis Gallery Tower, 13th Floor, Flat/Office 1301, 1097 Nicosia, Cyprus. We hold the Romanian affiliate advertising licence Class II ONJN – Decision No. 979 of 27 June 2024, allowing us to promote licensed iGaming brands in Romania.

For questions about this Policy or your personal data, contact us:
• General enquiries: ceo@monterizo-cyprus.com
• Privacy enquiries: ceo@monterizo-cyprus.com
• Data Protection Officer (DPO): ceo@monterizo-cyprus.com
• Postal address: see registered office above

2. Which Laws Apply
• Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”);
• Romanian Law 190/2018 implementing the GDPR;
• Romanian Law 506/2004 on privacy and electronic communications (cookies & direct marketing);
• Guidance and decisions issued by the Romanian Data Protection Authority (ANSPDCP).

3. What Personal Data We Collect
• Technical & usage data (IP address, cookie ID, browser, device information, pages visited, interactions).
• Regulatory compliance data (age verification or self‑exclusion status, if provided by operators).
We do not intentionally collect special‑category data, nor do we knowingly collect data from anyone under 18 years old.

4. Why We Use Your Data & Our Legal Bases
• To operate and secure the Website – legitimate interest (Art. 6 (1)(f) GDPR).
• To respond to enquiries and provide affiliate services – contract performance or steps at your request (Art. 6 (1)(b)).
• To comply with gambling‑advertising, AML and consumer‑protection rules – legal obligation (Art. 6 (1)(c)).
• To defend legal claims or fulfil requests from ONJN, ANSPDCP or other regulators – legitimate interest / legal obligation.
Where processing relies on consent, you may withdraw that consent at any time without affecting the lawfulness of processing already carried out.

5. Cookies & Similar Technologies
We use the following categories of cookies, placed only after you have given consent via our cookie banner in accordance with Law 506/2004:
• Strictly necessary – e.g., to remember language preference and verify age (18+ gate);
• Analytics – e.g., Google Analytics 4 to understand aggregated user behaviour;
• Marketing / affiliate tracking – e.g., unique sub‑ID parameters and post‑back pixels that allow us to recognise a referral source and attribute conversions.

You can change or withdraw your cookie preferences at any time via the “Cookie Settings” link in the footer of every page.

6. How We Share Your Data
• Service providers – hosting, CDNs, analytics platforms, CRM and e‑mail services, each bound by data‑processing agreements.
• Licensed online casino operators whose brands we promote (limited to traffic‑validation and commission‑payment data).
• Regulators and public authorities (e.g., ONJN, ANSPDCP) where required by law.
• Group companies within the EEA (operational subsidiaries and auditors).
• Potential acquirers in the context of a merger or acquisition, under appropriate safeguards.
We do not sell or rent your personal data.

7. International Transfers
Our main servers are located in the European Economic Area (currently Germany). Should we transfer data outside the EEA (for example, to a U.S. SaaS provider), we will rely on safeguards permitted by Chapter V GDPR, primarily the European Commission’s Standard Contractual Clauses.

8. Security Measures
We implement appropriate technical and organisational measures, including HTTPS with HSTS, server‑side firewalls, stringent access controls, encryption of data at rest and in transit, regular penetration testing, and the “need‑to‑know” principle for employee access.

9. Your Rights
• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erase data (“right to be forgotten”) in certain circumstances;
• Restrict processing;
• Object to processing based on legitimate interests or to direct marketing;
• Data portability (receive your data in a structured, commonly‑used, machine‑readable format);
• Withdraw consent at any time (where processing is based on consent);
• Lodge a complaint with the Romanian Data Protection Authority (ANSPDCP).
To exercise any of these rights, please contact us at ceo@monterizo-cyprus.com.

10. Children & Age Restrictions
This Website targets only persons aged 18 years or older. We actively block under‑18 users through our age‑gate mechanism. If we learn that we have collected personal data from a minor, we will delete it promptly.

11. Automated Decision‑Making
We do not use your personal data for decisions that produce legal or similarly significant effects solely based on automated processing (within the meaning of Article 22 GDPR).

12. Links to Third‑Party Sites
Our Website may contain links to third‑party content (e.g., licensed casino operators). We are not responsible for the privacy practices of those websites. Please read their privacy notices before submitting any personal information.

13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect legal, technical or business changes. The latest revision date appears at the top. If changes are material, we will provide prominent notice (e.g., by e‑mail or banner).

14. Contact Us
Monterizo LTD – Privacy Office
A.G. Leventi 5, The Leventis Gallery Tower, 13th Floor, Flat/Office 1301, 1097 Nicosia, Cyprus
E‑mail: ceo@monterizo-cyprus.com
We aim to respond to all legitimate requests within one month.

By continuing to browse or interact with https://clickplayzone.com you acknowledge that you have read and understood this Privacy Policy.