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Privacy Policy

This privacy policy explains how Royal Swipe (Royal Swipe) on royelswipe.com collects, uses, discloses, and protects personal data of players and website visitors in connection with its UK-facing online casino services. It applies to all individuals who visit royelswipe.com, create an account, participate in games, use customer support channels, or interact with our marketing communications. Effective from 6 November 2025 and last updated in January 2026, this policy is designed to comply with UK data protection law (including the UK General Data Protection Regulation and the Data Protection Act 2018), as well as relevant international standards where applicable.

OBSERVE: This document focuses on how your personal data is handled when you use Royal Swipe (Royal Swipe) on royelswipe.com as a UK-targeted mobile casino operated on the ProgressPlay Limited platform.

EXPAND: Because we operate in a regulated gambling environment under the UK Gambling Commission and Malta Gaming Authority, we must meet enhanced requirements regarding anti-money laundering (AML), responsible gambling, and player protection, all of which affect how we collect and process your personal data.

REFLECT: By reading this policy before using royelswipe.com, you can make informed decisions about your data, understand your rights, and know how to contact us or supervisory authorities if you have questions or complaints.

Who We Are

OBSERVE: The controller responsible for personal data processed in connection with Royal Swipe (Royal Swipe) on royelswipe.com is:

  • Operator: ProgressPlay Limited (a limited company)
  • Registered / legal address: Soho Office, 3A, Punchbowl Centre, Elia Zammit Street, St. Julians, STJ3154, Malta
  • Primary licences:
    • UK Gambling Commission remote licence: account number 39335 (United Kingdom - UK-facing operation of Royal Swipe on the ProgressPlay platform)
    • Malta Gaming Authority licence: MGA/B2C/231/2012 (Malta / international for non-UK players on the international version of Royal Swipe)

EXPAND: ProgressPlay Limited manages the day-to-day operations, payments, and compliance for Royal Swipe (Royal Swipe) on royelswipe.com, using a shared technical infrastructure and game library across multiple sister brands. The UK-facing version is ring-fenced under the UKGC licence and integrates UK-specific controls such as GamStop, a credit card gambling ban, and GBP-only accounts. Company registration and tax identification details are not specified in the available data; however, the company is established and supervised in Malta and licensed in the UK and EU regulatory frameworks.

Data Protection Officer / data protection contact:

  • Email/contact: Via the customer support channels on royelswipe.com (live chat and email support). Please state that your query is "for the Data Protection Officer" or "for the data protection team".
  • Postal contact for data protection matters: Data Protection Officer, ProgressPlay Limited, Soho Office, 3A, Punchbowl Centre, Elia Zammit Street, St. Julians, STJ3154, Malta.

REFLECT: For all privacy-related questions, rights requests, or complaints about Royal Swipe (Royal Swipe) on royelswipe.com, you should first contact ProgressPlay Limited via the support channels described above, who act as the controller responsible for your personal data.

What Personal Data We Collect

OBSERVE: When you use Royal Swipe (Royal Swipe) on royelswipe.com, we collect and generate several categories of personal and technical data to comply with gambling regulations, provide our services, and protect both you and us from misuse.

Account and Identification Data

  • Personal identification data: Full name, date of birth, residential address, nationality, and copies or data from identity documents (e.g. passport, ID card, driving licence) required for Know Your Customer (KYC) checks.
  • Contact details: Email address, username, and, where provided, telephone number or other contact preferences.
  • Account data: Account ID, login credentials (stored in hashed form), security questions, and verification status.

Technical and Usage Data

  • Device and technical data: IP address, device identifiers, browser type and version, operating system, time zone, language settings, and basic connection diagnostics.
  • Log data: Login and logout times, session duration, error logs, security events, and system audit trails.
  • Behavioural and interaction data: Game selections, betting history, stakes and outcomes, time spent on site, clicks, page views, navigation paths, and responsible gambling tool usage (deposit limits, reality checks, self-exclusion, time-outs).

Financial and Transaction Data

  • Payment data: Deposits, withdrawals, payment method type (e.g. debit card, e-wallet, bank transfer), transaction identifiers, and partial card or account details processed via PCI DSS - compliant payment providers.
  • AML and affordability data: Information related to source-of-funds or source-of-wealth checks, enhanced due diligence information, and affordability assessments as required by UKGC rules and AML regulations.

Cookies and Similar Technologies

  • Cookies: Session cookies, persistent cookies, and third-party cookies used for essential site functions, security, analytics, and personalised marketing (where permitted by your consent choices).
  • Similar technologies: Tracking pixels, tags, and local storage used to measure performance, prevent fraud, and remember your preferences.

REFLECT: Some of this data is required by law or by our regulators (for example, identity and transaction data for AML), and without it we may not be able to provide you with access to Royal Swipe (Royal Swipe) on royelswipe.com or may have to restrict or close your account.

Legal Basis for Processing

OBSERVE: We process personal data for Royal Swipe (Royal Swipe) on royelswipe.com primarily under the UK GDPR and the Data Protection Act 2018. Depending on the context, we rely on one or more of the following legal bases.

Contractual Necessity

  • What it covers: Creating and managing your account, verifying your identity to open and operate the account, processing deposits and withdrawals, enabling gameplay, calculating bonuses and loyalty rewards, and providing customer support.
  • Why it is needed: These activities are necessary to perform the contract you enter into when you register and play on royelswipe.com as part of Royal Swipe (Royal Swipe).

Legal Obligations

  • Regulatory compliance: Compliance with UK Gambling Commission rules (licence number 39335), AML and counter-terrorist financing requirements, responsible gambling obligations (including GamStop integration and self-exclusion), tax and accounting rules, and record-keeping laws.
  • Reporting and cooperation: Responding to lawful requests from regulators, supervisory authorities, ADR bodies where appropriate, law enforcement, and courts in the UK and relevant jurisdictions.

Legitimate Interests

  • Fraud prevention and security: Monitoring for suspicious play, duplicate accounts, chargebacks, bonus abuse, and system attacks, and improving our security posture, including in light of previous UKGC scrutiny of AML and social responsibility controls.
  • Service improvement and analytics: Analysing gameplay and site usage in aggregate to enhance performance, user experience, and product offerings, while respecting your privacy and, where required, your consent preferences for analytics cookies.
  • Protection of legal rights: Establishing, exercising, or defending legal claims, handling disputes, and managing risk (including segregation of player funds at the UKGC "medium protection" level).

Consent

  • Marketing: Sending email or SMS marketing and personalised offers not strictly necessary for service provision, including third-party or affiliate offers, where you have given explicit consent and have not withdrawn it.
  • Non-essential cookies: Using advertising and certain analytics cookies and similar technologies, where local law requires consent.

REFLECT: Where we rely on consent, you can withdraw it at any time via your account settings, cookie management tools, or by contacting us. Where we rely on legitimate interests, we balance our interests against your fundamental rights and expectations and provide you with the right to object to certain processing.

Purpose of Processing

OBSERVE: We use personal data collected through Royal Swipe (Royal Swipe) on royelswipe.com for several distinct but related purposes.

  • Service delivery: To register and verify your account, enable deposits and withdrawals, provide access to the game library, calculate wagers and winnings, administer bonuses and loyalty schemes, and provide day-to-day customer support.
  • Regulatory and legal compliance: To meet obligations under UKGC and MGA licences, AML and counter-terrorist financing laws, responsible gambling rules (including GamStop, self-exclusion, and affordability assessments), and general tax and accounting requirements.
  • Risk management and fraud prevention: To detect and prevent fraud, money laundering, bonus abuse, and other misuse; to perform affordability and source-of-funds checks; and to manage financial and regulatory risks identified in our internal risk assessments.
  • Analytics and service improvement: To understand how players use royelswipe.com, improve usability and performance, test new features, and optimise game offerings, using aggregated or pseudonymised data where possible.
  • Marketing and personalisation: To send you promotional communications, tailor offers, and show relevant content, where permitted by law and your consent choices, including through cookies and similar technologies.
  • Security and incident management: To secure our systems, investigate and respond to incidents, maintain logs, and perform audits and quality assurance on our processes.

REFLECT: We do not use your personal data for purposes that are incompatible with those described here. If we wish to use your data for a new purpose, we will inform you and, where required, obtain your consent or rely on another appropriate legal basis.

Disclosure & Sharing

OBSERVE: To operate Royal Swipe (Royal Swipe) on royelswipe.com effectively and lawfully, we share personal data with carefully selected third parties and authorities under contractual and legal safeguards.

Service Providers and Partners

  • Payment processors and banks: Providers offering card payments, e-wallets, bank transfers, and other methods, operating under PCI DSS and other security standards to process your deposits and withdrawals.
  • Identity verification and AML providers: Vendors conducting KYC checks, sanctions and politically exposed person (PEP) screening, affordability assessments, and fraud monitoring, in line with UKGC and AML requirements.
  • Technical and hosting providers: Companies providing datacentres, hosting, content delivery networks, and security tools that support the ProgressPlay platform infrastructure.
  • Analytics and marketing partners: Providers of analytics tools, email and SMS delivery, and, where permitted, advertising networks that help us measure performance and deliver or personalise marketing communications based on your consent preferences.

Regulators, Authorities, and ADR Bodies

  • Regulators: The UK Gambling Commission, Malta Gaming Authority, and other competent authorities may receive data when necessary for licensing, compliance checks, or investigations.
  • Law enforcement and public authorities: Police, courts, tax authorities, and other public entities, where required by law or to protect our legal rights or those of others.
  • Self-exclusion and safer gambling schemes: GamStop and similar national schemes, to implement self-exclusion and other responsible gambling measures for UK players.
  • ADR providers: Independent Betting Adjudication Service (IBAS) or other ADR entities may receive relevant account and transaction data in the context of dispute resolution, although they are not data protection regulators.

Group Companies and Affiliates

  • White-label and sister brands: Where necessary, limited data may be shared within the ProgressPlay Limited group and its white-label operations to manage risk, fraud, and platform-level services.
  • Marketing affiliates: Subject to your marketing preferences and consent, certain information may be shared with affiliates that promote royelswipe.com, under strict contractual controls.

REFLECT: We do not sell your personal data. Any sharing is done under data processing agreements, with appropriate security measures and, where applicable, international transfer safeguards as described below.

International Transfers

OBSERVE: Royal Swipe (Royal Swipe) on royelswipe.com is operated by ProgressPlay Limited in Malta and serves UK players under a UKGC licence, which naturally involves cross-border data flows between the UK, the European Economic Area (EEA), and occasionally other jurisdictions.

  • UK - EEA/Malta transfers: Personal data may be transferred between the UK and Malta/other EEA countries where our servers, support teams, or service providers are located. The UK Government currently recognises the EEA as providing an adequate level of protection, and the EU has adopted an adequacy decision for the UK, facilitating reciprocal data flows.
  • Transfers to other countries: Where we use service providers or partners located outside the UK and EEA (for example, certain payment, analytics, or email delivery providers), we implement safeguards such as the UK International Data Transfer Agreement (IDTA) and/or EU Standard Contractual Clauses, supplemented by risk assessments and additional technical and organisational measures where appropriate.
  • Regulatory and legal transfers: Data may be shared with regulators or authorities in other jurisdictions when required by law, court orders, or regulatory cooperation frameworks, subject to confidentiality and proportionality.

EXPAND: These mechanisms are designed to ensure that your personal data remains protected to a standard essentially equivalent to that under the UK GDPR, regardless of where it is processed. Our contracts with processors require them to process personal data only under our instructions and to maintain appropriate security levels.

REFLECT: If you would like more details about the specific transfer safeguards (such as copies of the relevant contractual clauses, with commercially sensitive sections redacted), you can contact our Data Protection Officer using the channels described in the "Who We Are" and "Complaints & Contacts" sections.

Data Retention

OBSERVE: We retain personal data collected via Royal Swipe (Royal Swipe) on royelswipe.com only for as long as necessary to fulfil the purposes described in this policy, including to meet legal, regulatory, accounting, and reporting requirements.

Category of data Typical retention period Main rationale
Account and identification data (KYC) Up to 5 years after account closure or last player interaction, whichever is later AML and KYC record-keeping obligations under UK and EU/Malta laws, and UKGC licence conditions
Transaction and betting history 5 - 7 years after the transaction, depending on applicable tax and accounting requirements Regulatory, accounting, and dispute resolution needs
Customer support communications Up to 5 years after resolution of the request Quality assurance, audit trails, and defence of legal claims
Technical logs and security data From a few months up to 2 years, depending on the log type Security monitoring, incident investigation, and fraud prevention
Marketing preferences and records of consent For as long as you remain subscribed plus up to 2 years after you opt out Proof of consent and compliance with marketing regulations

EXPAND: When data is no longer required, we either securely delete it or irreversibly anonymise it so that it can no longer be associated with you. Where we cannot fully delete data due to legal obligations (for example, AML records), we will restrict processing to storage only and implement appropriate access controls.

REFLECT: You may request more specific information about retention periods applicable to your personal data by contacting us. Where you exercise your rights to erasure or restriction, we will take these retention obligations into account when responding.

Your Rights

OBSERVE: As a user of Royal Swipe (Royal Swipe) on royelswipe.com, you have several rights in relation to your personal data under the UK GDPR and, where applicable, EU GDPR and Mexican privacy law.

Rights Under UK and EU Data Protection Law

  • Right of access: To obtain confirmation as to whether we process your personal data and to receive a copy, along with information about how we use it.
  • Right to rectification: To have inaccurate or incomplete personal data corrected, for example updating your contact details or address.
  • Right to erasure: To request deletion of your personal data where there is no longer a legal basis for processing, subject to regulatory retention requirements (for example, we may need to keep certain AML or transaction records).
  • Right to restriction: To request that we limit processing of your data in certain circumstances, such as while we assess a challenge to accuracy or a processing objection.
  • Right to object: To object to processing based on legitimate interests (including certain profiling) and to opt out of direct marketing at any time.
  • Right to data portability: To receive certain data you have provided to us in a structured, commonly used, machine-readable format and, where technically feasible, to have it transmitted to another controller.
  • Right to withdraw consent: Where processing is based on your consent (for example, marketing or certain cookies), you can withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

Rights Under Mexican Privacy Law (Where Applicable)

  • ARCO rights: If you are in Mexico and interact with royelswipe.com, you may benefit from rights under the Mexican Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), including rights of Access, Rectification, Cancellation, and Opposition (ARCO), which are broadly aligned with the rights listed above.
  • Consent and revocation: You may have specific rights to grant, limit, or revoke consent in accordance with Mexican regulations and corresponding secondary rules and guidelines.

How to Exercise Your Rights

  • Submitting a request: Contact us via the support channels on royelswipe.com (live chat or email support) and clearly indicate that you are making a "data protection" or "privacy" request. You may be asked to verify your identity to protect your account.
  • Timeframe and cost: We aim to respond within one month (30 days) of receiving a complete request, in line with UK GDPR. This period may be extended by a further two months for complex or multiple requests, in which case we will inform you. We do not charge a fee unless a request is manifestly unfounded or excessive.
  • Limitations: Some rights may be restricted when necessary to comply with legal obligations, protect public interests (such as AML and responsible gambling), or defend legal claims.

REFLECT: If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority, as explained in the "Complaints & Contacts" section.

Cookies & Tracking Technologies

OBSERVE: Royal Swipe (Royal Swipe) on royelswipe.com uses cookies and similar technologies to provide core functionality, enhance the user experience, and support analytics and marketing, in accordance with UK and EU rules on electronic communications.

Types of Cookies We Use

  • Session cookies: Temporary cookies that are stored only while your browser is open and are deleted when you close it. These support essential functions such as login and navigation between pages.
  • Persistent cookies: Cookies that remain on your device for a defined period or until you delete them, used to remember your preferences, keep you logged in where chosen, and support performance and analytics.
  • Third-party cookies: Cookies set by third-party providers (for example, analytics services and advertising networks) that help us measure site performance or deliver personalised offers, subject to your consent where required.

Purposes of Cookies

  • Strictly necessary/functional: To enable secure login, account management, transactional workflows, and site security. These cookies are required for the site to function properly and cannot be switched off in our systems.
  • Analytics and performance: To collect anonymous or pseudonymised statistics about site usage, gameplay trends, and technical performance so we can improve royelswipe.com and address issues.
  • Advertising and personalisation: To deliver tailored promotions or offers and measure the effectiveness of marketing campaigns, where you have consented to such use.

Cookie Management

  • On-site controls: Where offered, you can manage your cookie preferences through a cookie banner or settings panel on royelswipe.com.
  • Browser settings: You may configure your browser to block or delete cookies, although this may affect site functionality or your ability to remain logged in.
  • REFLECT: Changes you make to cookie settings may not remove previously stored cookies immediately, but we will honour your preferences for future use to the extent required by law.

Data Security

OBSERVE: Protecting your personal data when you use Royal Swipe (Royal Swipe) on royelswipe.com is a priority for ProgressPlay Limited. We employ a combination of technical and organisational measures to safeguard confidentiality, integrity, and availability.

  • Encryption in transit: royelswipe.com uses 128-bit SSL encryption (Sectigo RSA certificate) and TLS 1.2+ protocols to protect data transmitted between your device and our servers, as last verified in January 2025.
  • Payment security: Payment processing is carried out via PCI DSS - compliant providers, reducing exposure of card details and enforcing strict access controls around financial data.
  • Access controls and authentication: Access to personal data is restricted to authorised personnel on a need-to-know basis, protected by strong authentication mechanisms, role-based permissions, and logging of administrative actions.
  • Data protection by design: Our platform and processes are designed with privacy and security in mind, including segregation of player funds in line with UKGC "medium protection" standards and system-level controls to support responsible gambling tools (deposit limits, time-outs, self-exclusion and GamStop integration).
  • Monitoring, audits, and training: We conduct regular security monitoring, vulnerability assessments, and internal audits. Staff receive training on data protection, AML, and responsible gambling requirements, including lessons learned from past regulatory actions involving ProgressPlay Limited.
  • Incident response: Incident response procedures are in place to detect, investigate, and remediate security events. Where required by law, we will notify affected individuals and supervisory authorities of data breaches within the prescribed timeframes.

EXPAND: Our security framework aims to align with recognised international best practices and standards (such as ISO 27001 and SOC 2 principles), even where we may not hold formal certifications for all such standards. We periodically review and enhance our controls in response to emerging threats, regulatory expectations, and industry developments.

REFLECT: While no system can guarantee absolute security, these measures significantly reduce risks to your personal data. You also play a role in security by maintaining strong, unique passwords, not sharing account details, and promptly contacting support if you suspect unauthorised access.

Complaints & Contacts

OBSERVE: If you have questions, concerns, or complaints about how your personal data is handled in connection with Royal Swipe (Royal Swipe) on royelswipe.com, you have multiple channels to contact us and, if necessary, escalate the matter.

How to Contact Us

  • Live chat: Available via royelswipe.com, typically from 8:00 AM to 12:00 AM GMT. Tests in December 2025 indicated an average wait time of about 4 minutes, though times may vary.
  • Email support: Accessible via the email channel indicated on royelswipe.com. Observed response times were approximately 26 hours in December 2025, but may be shorter or longer depending on volume.
  • Postal address for privacy matters: Data Protection Officer, ProgressPlay Limited, Soho Office, 3A, Punchbowl Centre, Elia Zammit Street, St. Julians, STJ3154, Malta.

Complaint Procedure

  1. Step 1 - Contact support: Start by contacting customer support via live chat or email, explaining that your issue relates to privacy or data protection and providing relevant details (for example, account ID, dates, and a description of the problem).
  2. Step 2 - Escalation to DPO: If your issue is not resolved or requires specialist handling, request that it be escalated to our Data Protection Officer or data protection team. We will review your complaint and aim to provide a substantive reply within 30 days.
  3. Step 3 - Further clarification: If the matter is complex or requires additional information, we may ask you for clarification and may extend the response period by up to two further months, in line with legal requirements, notifying you of any extension and reasons.

Escalation to Supervisory Authorities

  • United Kingdom - Information Commissioner's Office (ICO): If you are located in the UK or your issue concerns our UK-facing operations, you have the right to lodge a complaint with the ICO:
    • Website: www.ico.org.uk
    • Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
  • European Union: If you interact with our services from within the EEA and EU law applies, you may raise the matter with your local data protection authority in the EU, particularly in the country where you live or work or where the alleged infringement occurred.
  • Mexico - INAI: Where Mexican privacy law applies to your use of royelswipe.com, you may lodge a complaint with the National Institute for Transparency, Access to Information and Personal Data Protection (INAI) under the Federal Law on Protection of Personal Data Held by Private Parties:
    • Website: www.inai.org.mx

REFLECT: You are not required to contact us before approaching a supervisory authority, but we encourage you to give us the opportunity to address your concerns directly, as many issues can be resolved more quickly through our internal processes.

Updates

OBSERVE: This privacy policy for Royal Swipe (Royal Swipe) on royelswipe.com may be updated from time to time to reflect changes in law, regulatory guidance, our services, or our internal practices.

  • Last updated: January 2026.
  • Version control: We maintain an internal record of policy versions and material changes, including the effective date (currently 6 November 2025 for this core version, as adapted and reviewed through 2025 - 2026).
  • Notification methods: For significant changes, we will provide notice via one or more of the following:
    • Email notifications sent to the address registered in your royelswipe.com account.
    • Prominent notices or banners on the website.
    • Alerts or messages in your account dashboard.
  • Advance notice: Where legally required or where changes materially affect your rights or obligations, we will aim to provide at least 30 days' advance notice before the changes take effect.
  • Your options: If you do not agree with a material change, you may close your account and request that we restrict or delete your personal data, subject to retention obligations described in this policy.

REFLECT: Continued use of Royal Swipe (Royal Swipe) on royelswipe.com after the effective date of an updated policy will be taken as your acknowledgement of the changes, so we encourage you to review this page periodically to stay informed about how we handle your personal data.