Privacy Policy

Another Games Limited
(Trading as "Playmer")

Last Updated: 20 February 2026

1. Identity of the Data Controller

The data controller responsible for the processing of your personal data is:

Another Games Limited
Company Registration Number: C-97600
Registered Office: Level 2, Spinola Road, St Julians, STJ 3014, Malta
Email: support@playmer.com
Website: https://www.playmer.com

Another Games Limited (hereinafter referred to as the "Company", "Playmer", "we", "us", or "our") is the data controller within the meaning of Article 4(7) of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and Section 2 of the Data Protection Act, Chapter 586 of the Laws of Malta ("Cap. 586").

The Company is licensed by the Malta Gaming Authority ("MGA") under a B2B Critical Supply Licence and provides Type 1 Gaming Services.

2. Data Protection Officer

In accordance with Articles 37 to 39 of the GDPR and Section 28 of Cap. 586, the Company has appointed a Data Protection Officer ("DPO"). The DPO is responsible for monitoring the Company's compliance with applicable data protection legislation and serves as the primary point of contact for data subjects and the Information and Data Protection Commissioner ("IDPC").

You may contact the DPO as follows:

Data Protection Officer
Mr. Jeremy Mifsud
2, Spinola Road, St. Julians STJ 3014, Malta
Email: dpo@playmer.com

The DPO operates independently and reports directly to the highest management level of the Company, in accordance with Article 38(3) GDPR.

3. Scope of This Privacy Policy

This Privacy Policy explains how the Company collects, uses, stores, discloses, and protects your personal data in connection with your use of the website https://www.playmer.com, including any related products, services, sub-websites, and domains or subdomains owned or operated by the Company (collectively, the "Website").

This Privacy Policy applies to all individuals whose personal data is processed by the Company, including website visitors, business contacts, and any other data subjects whose personal data is processed in connection with the Company's operations.

This Privacy Policy is governed by and shall be interpreted in accordance with the GDPR, the Data Protection Act (Cap. 586 of the Laws of Malta), Subsidiary Legislation 586.01 (Processing of Personal Data (Electronic Communications Sector) Regulations), the Gaming Act (Cap. 583 of the Laws of Malta), and all other applicable data protection legislation.

4. Key Definitions

For the purposes of this Privacy Policy, the following definitions apply in accordance with Article 4 GDPR:

"Personal Data" means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

"Consent" means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

5. Categories of Personal Data We Collect

5.1 Contact Data (Provided by You)

When you submit a message via the contact form on our Website, or communicate with us by email, telephone, or other means, we may collect the following personal data:

Full name;
Age;
Email address;
Mobile phone number;
Any other information you voluntarily provide in your message.

The provision of this data is voluntary. However, if you do not provide the required information, we may be unable to respond to your enquiry or provide the requested service. The provision of personal data via the contact form is neither a statutory nor a contractual requirement, but is necessary for us to process your enquiry.

5.2 Data Collected Automatically (Technical Data)

When you access our Website, certain technical data is collected automatically through your browser or device. This may include:

Device type and unique device identifiers;
Browser type and version;
Browser language settings;
Operating system type and version;
Internet service provider or mobile network operator name;
IP address;
Referring website address (referrer URL);
Pages accessed, time spent on pages, and navigation patterns;
Date and time of access.

5.3 Cookie Data

We use cookies and similar tracking technologies on our Website. Cookies are small text files placed on your device when you visit our Website. We categorise cookies as follows:

Strictly Necessary Cookies: These cookies are essential for the Website to function and cannot be switched off. They do not require your consent under Article 5(3) of the ePrivacy Directive (Directive 2002/58/EC), as transposed into Maltese law by S.L. 586.01.
Analytical/Performance Cookies: These cookies allow us to analyse Website usage and improve performance. They are only placed on your device with your prior informed consent.
Functionality Cookies: These cookies enable enhanced functionality and personalisation. They require your prior informed consent.
Marketing/Advertising Cookies: If used, these cookies track your browsing activity to deliver targeted advertising. They require your explicit prior consent.

For detailed information about the specific cookies we use and how to manage your preferences, please refer to our Cookie Policy.

You may withdraw your cookie consent at any time by adjusting your browser settings or by using our cookie consent management tool on the Website.

5.4 Special Categories of Personal Data

We do not collect or process special categories of personal data as defined in Article 9 GDPR. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identification purposes, data concerning health, or data concerning a natural person's sex life or sexual orientation.

6. Purposes and Legal Bases for Processing

In accordance with Articles 6(1) and 13(1)(c) GDPR, we process your personal data only where we have a valid legal basis. The following sets out the purposes of processing, the categories of data concerned, and the corresponding legal basis under Article 6(1) GDPR.

Responding to your enquiries via the contact form

Categories of Data: Name, email, phone number, message content
Legal Basis: Contractual necessity — Art. 6(1)(b): processing is necessary for the performance of a contract or pre-contractual steps at your request.

Providing, maintaining, and improving the Website and services

Categories of Data: Technical data, usage data
Legal Basis: Legitimate interests — Art. 6(1)(f): the Company has a legitimate interest in ensuring the proper functioning of its Website.

Analysing Website usage and performance

Categories of Data: Technical data, cookie data (analytical)
Legal Basis: Consent — Art. 6(1)(a): analytical cookies are placed only with your prior consent.

Personalising content and adapting the Website to your device and preferences

Categories of Data: Technical data, preferences
Legal Basis: Legitimate interests — Art. 6(1)(f): the Company has a legitimate interest in providing a tailored user experience.

Detecting and preventing fraud, unlawful activity, or security threats

Categories of Data: Technical data, usage data, IP address
Legal Basis: Legitimate interests — Art. 6(1)(f): the Company has a legitimate interest in protecting the security and integrity of its platform.

Compliance with legal and regulatory obligations (including gaming regulations, AML/KYC requirements)

Categories of Data: Contact data, identification data, transaction data (where applicable)
Legal Basis: Legal obligation — Art. 6(1)(c): processing is necessary to comply with the Gaming Act (Cap. 583), the Prevention of Money Laundering Act (Cap. 373), and other applicable legislation.

Sending direct marketing communications (where applicable)

Categories of Data: Name, email address
Legal Basis: Consent — Art. 6(1)(a): marketing communications are sent only with your explicit prior consent, which you may withdraw at any time.

Resolving disputes and enforcing the Company's legal rights

Categories of Data: Contact data, correspondence records
Legal Basis: Legitimate interests — Art. 6(1)(f): the Company has a legitimate interest in establishing, exercising, or defending legal claims.

Where processing is based on our legitimate interests under Article 6(1)(f) GDPR, we have conducted a legitimate interests assessment to ensure that our interests do not override your fundamental rights and freedoms. You have the right to object to processing based on legitimate interests at any time (see Section 8 below).

7. Data Sharing and Recipients

We do not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients, solely for the purposes described in this Privacy Policy:

IT and Hosting Service Providers: Companies providing server hosting, cloud infrastructure, and technical support services for the operation of the Website.
Web and Mobile Analytics Providers: Third-party analytics services (e.g., Google Analytics) that help us understand Website usage patterns. Data shared with these providers is pseudonymised where possible.
Payment Service Providers: Where applicable, payment processing companies that facilitate transactions.
Professional Advisors: Legal, accounting, and compliance advisors engaged by the Company.
Regulatory Authorities: The Malta Gaming Authority (MGA), the Information and Data Protection Commissioner (IDPC), and other competent authorities, where disclosure is required by law or regulatory obligation.
Law Enforcement: In response to lawful requests from government authorities, including subpoenas, court orders, or other legal processes, within the limits established by applicable law.
Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred as part of the transaction. We will notify you in advance of any such transfer and ensure appropriate safeguards are in place.

All third-party service providers acting as data processors on our behalf are bound by written data processing agreements in accordance with Article 28 GDPR. They are permitted to process your personal data only for the specific purposes instructed by us and are subject to strict confidentiality obligations.

8. Your Data Protection Rights

Under the GDPR and Cap. 586, you have the following rights in respect of your personal data. These rights are not absolute and may be subject to certain conditions and exceptions as provided by law.

Right of Access (Article 15 GDPR)

You have the right to obtain confirmation as to whether your personal data is being processed, and to request access to your personal data and information about the processing, including the purposes, categories of data, and recipients.

Right to Rectification (Article 16 GDPR)

You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data.

Right to Erasure ("Right to be Forgotten") (Article 17 GDPR)

You have the right to request the deletion of your personal data where, inter alia, the data is no longer necessary for the purposes for which it was collected, you withdraw your consent, or the processing is unlawful. This right is subject to certain exceptions, including where retention is necessary for compliance with legal obligations.

Right to Restriction of Processing (Article 18 GDPR)

You have the right to request a temporary restriction on the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where the processing is unlawful but you oppose erasure.

Right to Data Portability (Article 20 GDPR)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance, where processing is based on consent or contractual necessity and is carried out by automated means.

Right to Object (Article 21 GDPR)

You have the right to object to the processing of your personal data where such processing is based on our legitimate interests (Article 6(1)(f) GDPR) or on the performance of a task carried out in the public interest (Article 6(1)(e) GDPR). You also have the right to object to processing for direct marketing purposes at any time.

Right to Withdraw Consent (Article 7(3) GDPR)

Where processing is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You may withdraw your consent by contacting us at the details provided in this Policy or by using any unsubscribe mechanism provided. Withdrawing consent is as easy as giving it.

Right Not to be Subject to Automated Decision-Making (Article 22 GDPR)

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for a contract, authorised by law, or based on your explicit consent.

8.1 How to Exercise Your Rights

To exercise any of the above rights, please contact us at:

Email: support@playmer.com or dpo@playmer.com
Post: Data Protection Officer, Another Games Limited, Level 2, Spinola Road, St Julians, STJ 3014, Malta

We will respond to your request without undue delay and in any event within one (1) month of receipt, in accordance with Article 12(3) GDPR. This period may be extended by a further two (2) months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

There is no fee for exercising your rights, unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request, in accordance with Article 12(5) GDPR.

8.2 Right to Lodge a Complaint with a Supervisory Authority

If you are not satisfied with our response to your request, or if you believe that your personal data has been processed in breach of applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority.

In Malta, the competent supervisory authority is:

Information and Data Protection Commissioner (IDPC)
Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta
Website: https://idpc.org.mt
Email: idpc@idpc.org.mt
Telephone: +356 2328 7100

You also have the right to lodge a complaint with the supervisory authority in the EU/EEA Member State of your habitual residence, place of work, or the place of the alleged infringement.

9. International Transfers of Personal Data

Your personal data is primarily processed within the European Economic Area ("EEA"). However, in certain circumstances, your personal data may be transferred to, stored in, or accessed from countries outside the EEA.

Where we transfer personal data outside the EEA, we ensure that appropriate safeguards are in place in accordance with Chapter V of the GDPR (Articles 44 to 49), including:

Adequacy Decisions: Transfers to countries that the European Commission has determined provide an adequate level of data protection (Article 45 GDPR);
Standard Contractual Clauses (SCCs): Transfers made under the European Commission's approved Standard Contractual Clauses (Article 46(2)(c) GDPR), supplemented by additional safeguards where necessary following the Court of Justice's Schrems II judgment (C-311/18);
Binding Corporate Rules: Where applicable, transfers within a group of undertakings covered by approved Binding Corporate Rules (Article 47 GDPR);
Derogations: In exceptional circumstances, transfers based on specific derogations under Article 49 GDPR, including your explicit consent (provided after you have been informed of the possible risks).

You may request further information about the specific safeguards applied to transfers of your personal data by contacting the DPO at dpo@playmer.com.

10. Data Retention

In accordance with the data minimisation and storage limitation principles under Article 5(1)(c) and (e) GDPR, we retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

Contact form data (name, email, phone, message)

Retention Period: 12 months from the date of the last communication, unless a longer period is necessary to resolve an ongoing enquiry.
Justification: Contractual necessity; legitimate interest in record-keeping.

Technical/usage data (IP address, browser data, access logs)

Retention Period: 6 months from the date of collection.
Justification: Legitimate interest in Website security and analytics.

Cookie data (analytical/functional)

Retention Period: As specified in the Cookie Policy (typically 12–24 months depending on the cookie).
Justification: Consent; legitimate interest in Website performance.

Regulatory/compliance data (AML, KYC, gaming records)

Retention Period: As required by applicable legislation — typically 5 years from the end of the business relationship (per Cap. 373).
Justification: Legal obligation under the Prevention of Money Laundering Act and Gaming Act.

Marketing consent records

Retention Period: For the duration of the consent and for 3 years thereafter as evidence of consent.
Justification: Legitimate interest in demonstrating compliance; legal obligation.

Correspondence and dispute records

Retention Period: 6 years from the date of resolution.
Justification: Legitimate interest in establishing, exercising, or defending legal claims (in line with Malta's prescription periods).

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised. Anonymised data (from which you can no longer be identified) may be retained indefinitely for statistical and analytical purposes.

11. Automated Decision-Making and Profiling

The Company does not currently engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, within the meaning of Article 22 GDPR.

If this position changes in the future, we will update this Privacy Policy to provide you with meaningful information about the logic involved, the significance of the processing, and the envisaged consequences for you, as required by Article 13(2)(f) GDPR. We will also provide you with the opportunity to exercise your rights under Article 22 GDPR, including the right to obtain human intervention, to express your point of view, and to contest the decision.

12. Data Protection by Design and by Default

In accordance with Article 25 GDPR, the Company implements appropriate technical and organisational measures to ensure that data protection principles are integrated into all processing activities from the design stage ("data protection by design") and that, by default, only personal data which is necessary for each specific purpose of processing is collected and processed ("data protection by default").

These measures include, but are not limited to:

Data minimisation — collecting only the personal data strictly necessary for each purpose;
Pseudonymisation and encryption of personal data where appropriate;
Access controls — limiting access to personal data to authorised personnel only;
Regular security testing and vulnerability assessments;
Staff training on data protection obligations.

13. Security of Your Personal Data

We implement appropriate technical and organisational security measures to protect your personal data against accidental loss, unauthorised access, use, alteration, or disclosure, in accordance with Article 32 GDPR. These measures include, but are not limited to:

Encryption of data in transit (TLS/SSL) and at rest;
Firewalls and intrusion detection systems;
Access controls and authentication mechanisms;
Regular security audits and penetration testing;
Incident response procedures and staff training.

While we take all reasonable steps to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.

14. Data Breach Notification

In the event of a personal data breach, the Company will act in accordance with Articles 33 and 34 GDPR and Section 30 of Cap. 586:

Notification to the IDPC: We will notify the Information and Data Protection Commissioner within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons (Article 33(1) GDPR).
Notification to Data Subjects: Where the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay (Article 34(1) GDPR), providing details of the nature of the breach, the likely consequences, and the measures taken or proposed to address it.

15. Children's Privacy and Age Restrictions

The Website and our services are not directed at, and are not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from children under the age of 18. In accordance with Article 8 GDPR and the Company's obligations under the Gaming Act (Cap. 583), if we become aware that we have collected personal data from a person under the age of 18, we will take immediate steps to delete that data.

If you believe that we may have inadvertently collected personal data from a minor, please contact us immediately at dpo@playmer.com.

16. Gaming-Sector-Specific Obligations

As a company licensed by the Malta Gaming Authority under a B2B Critical Supply Licence, the Company is subject to additional data protection obligations under the following legislation:

Gaming Act (Cap. 583): Obligations relating to responsible gaming, player protection, and self-exclusion mechanisms;
MGA Player Protection Directive (Directive 2 of 2018): Requirements for the protection of player data and responsible gaming practices;
Prevention of Money Laundering Act (Cap. 373): Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations requiring the collection and retention of identification and transaction data;
Proceeds of Crime Act (Cap. 517): Obligations relating to suspicious transaction reporting.

Where personal data is processed for gaming regulatory compliance purposes, the legal basis is Article 6(1)(c) GDPR (compliance with a legal obligation). You may not object to such processing, and the relevant data will be retained for the periods prescribed by law.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our processing activities, legal requirements, or regulatory guidance. Where changes are material, we will:

Notify you by email (where we have your email address) or by prominent notice on the Website;
Clearly indicate the date of the last update at the top of this Policy;
Where the changes relate to processing based on your consent, seek your renewed consent before implementing the changes.

We encourage you to review this Privacy Policy periodically. Your continued use of the Website after the effective date of any changes constitutes your acknowledgement of those changes. However, where consent is required for any new or changed processing activity, we will obtain your explicit consent before proceeding.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us at:

Another Games Limited
Level 2, Spinola Road, St Julians, STJ 3014, Malta
General enquiries: support@playmer.com
Data protection enquiries: dpo@playmer.com
Telephone: +38(068)731-61-82

Governing Law

This Privacy Policy is governed by and shall be construed in accordance with the laws of Malta, including the General Data Protection Regulation (EU) 2016/679, the Data Protection Act (Cap. 586 of the Laws of Malta), and all other applicable data protection legislation. Any disputes arising under or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Malta, without prejudice to your right to lodge a complaint with the IDPC or any other competent supervisory authority.

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