Privacy Policy

This Privacy Policy explains how Throne Entertainment B.V. processes personal data when you visit or use the Hovarda version of the howarda.com website, register an account, place bets, use our casino products, or otherwise interact with us as a visitor, player, or affiliate contact. It is designed to help you understand what information we collect, why we collect it, how we use and share it, and what rights you have.

This Privacy Policy applies to all visitors and registered players accessing Hovarda through howarda.com from the United Kingdom and other permitted locations, and to any related online services, support channels, and marketing communications that refer to this policy.

Effective date: 6 November 2025.

Who We Are

The data controller responsible for your personal data in connection with the Hovarda services provided via howarda.com is:

Throne Entertainment B.V.
A private limited liability company (B.V.) incorporated and existing under the laws of Curaçao.
Registered jurisdiction: Curaçao, Kingdom of the Netherlands (Governor of Curaçao registry).
Gaming licence: Curaçao Interactive Licensing N.V. (C.I.L), Master Licence no. #5536/JAZ (sub-licence).
Registered region: Curaçao (exact registered address and company registration number are available on request).

For certain fiat payment methods, payment processing services may be provided on our behalf by a group or partner entity typically based in Cyprus, for example TPM Services Limited, a limited company incorporated in Cyprus, which may act as an independent or joint controller for some payment data as explained in the payment interface.

Contact for privacy matters (Data Protection Officer / Data Protection Team):
Email: dpo@howarda.com
Website: https://howarda.com (contact forms and live chat via your account).
Postal contact: "Data Protection Officer - Hovarda", Throne Entertainment B.V., Curaçao (full mailing details provided on request).

We do not currently operate a dedicated privacy telephone hotline; however, you can always contact customer support via live chat or email, who will escalate your request to our Data Protection Officer or data protection team.

What Personal Data We Collect

We collect and process different categories of personal data depending on how you use Hovarda via howarda.com. In each case, we limit collection to what is necessary for lawful and transparent operation of our services.

Identification and Contact Data

Account data: full name, username, date of birth, country of residence, language preferences, and unique player ID.
Contact details: email address, residential address, postcode, and (where provided) mobile or landline telephone number and preferred contact channel.
KYC/verification data: copies and details of identity documents (passport, national ID card, driving licence), proof of address (such as UK utility bills), selfies or video verification, and related metadata used to confirm authenticity.

Technical and Device Data

Usage and log data: IP address, approximate location derived from IP, device identifiers, browser type and version, operating system, access dates and times, pages and resources visited, error logs, and session IDs.
Security and integrity data: device fingerprints, login attempts, authentication tokens, and information generated by anti-fraud and anti-abuse tools.

Payment and Financial Data

Payment method data: selected payment provider, masked card details, card expiry date, card type, IBAN or bank details (where applicable), wallet identifiers (for example Jeton Wallet IDs or similar e-wallet accounts), and cryptocurrency wallet addresses (for example BTC, USDT, ETH, LTC).
Transaction data: deposits, withdrawals, bonuses, chargebacks, refunds, failed transactions, payment channel used (including Cyprus-based processors such as TPM Services Limited), timestamps, currency, and amounts.

Gaming and Behavioural Data

Betting and gaming history: games played, stakes, wins and losses, bonus usage, session duration, game preferences, and betting patterns.
Behavioural and risk data: responsible gaming indicators (for example, self-exclusion, deposit limits, session limits), dormant account status (including inactivity of 12 months and related dormant fee eligibility), anti-fraud signals, and risk scores generated by automated tools.
Support interactions: records of chats, emails, internal notes, feedback forms, and complaint correspondence.

Cookies and Similar Technologies

Cookie identifiers: unique identifiers stored in cookies, web beacons, and similar technologies to recognise your browser or device.
Online identifiers: advertising IDs, analytics IDs, and similar tokens assigned by us or our partners to measure usage, performance, and marketing effectiveness.

We normally obtain data directly from you, from your use of Hovarda via howarda.com, and from third-party verification, payment, and analytics partners. In exceptional cases, we may receive information from anti-fraud databases, sanctions lists, or public sources where necessary to comply with law.

Legal Basis for Processing

We process personal data only where we have a valid legal basis under UK data protection law, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018, and - insofar as relevant for players or data subjects in other jurisdictions - under the EU GDPR and applicable Mexican data protection laws. Depending on the context, we rely on the following legal grounds:

Performance of a Contract

Account setup and operation: we need your identification, contact, and technical data to create and manage your Hovarda account on howarda.com, allow you to log in securely, process deposits and withdrawals (including via Cyprus-based payment processors), and deliver requested betting and casino services.
Customer support: we use your contact data, gaming history, and support records to answer questions, resolve complaints, process KYC verification (typically triggered on your first withdrawal and usually completed within 24 - 48 hours), and manage your account features such as limits and exclusions.

Compliance with Legal Obligations

KYC/AML obligations: our Curaçao gaming licence (#5536/JAZ) and anti-money-laundering ("AML") rules require us to verify your identity, monitor transactions, and retain certain data (often for up to 5 - 7 years after the relationship ends) to prevent money laundering, terrorist financing, fraud, and other offences.
Regulatory and tax requirements: we may need to process and retain data to comply with legal obligations imposed by regulators in Curaçao, by any applicable European or UK authorities, or by other competent authorities (for example, reporting obligations, responsible gambling requirements, sanctions screening).

Legitimate Interests

Service improvement and analytics: we analyse aggregated and pseudonymised data about how Hovarda is used to improve performance, game selection, user experience, and security. Where feasible, we do this with minimal personal data and strong safeguards.
Fraud prevention and security: we process technical, transactional, and behavioural data to detect suspicious behaviour, protect your account, prevent chargebacks, and secure our platforms, including by automated tools and risk scoring.
Business operations: we may process data for internal reporting, audits, and lawful business management, provided these interests are not overridden by your rights and freedoms.

Consent

Marketing communications: we use your contact details and marketing preferences to send promotional emails, SMS, or in-account messages about offers, bonuses, and news only where you have given your explicit consent, or where permitted by law. You may withdraw your consent at any time via your account settings or by using the unsubscribe links.
Non-essential cookies and advertising technologies: we rely on your consent for the use of analytics and advertising cookies (including third-party cookies) as described in our Cookies & Tracking Technologies section.
Certain special processing in other jurisdictions: for data subjects covered by Mexican law or EU GDPR, we may seek consent where local rules require additional authorisation beyond UK GDPR standards.

Purpose of Processing

We process personal data for clearly defined purposes aligned with the operation of Hovarda via howarda.com and with our legal and regulatory obligations.

Providing and Managing Our Services

Account creation and maintenance: to register you as a player, verify that you are eligible to use our services, maintain your profile, and manage your settings (including responsible gaming limits and self-exclusion status).
Gaming operations: to process your bets, display balances, manage bonuses, calculate winnings and losses, and provide game history and transaction records for your review.
Payments and withdrawals: to process deposits and withdrawals via accepted methods such as cryptocurrencies (BTC, USDT, ETH, LTC), e-wallets (for example, Jeton Wallet and similar providers, and potentially services such as MiFinity), and non-UK issued Visa/Mastercard, including any payment processing by Cyprus-based providers like TPM Services Limited.

Security, Compliance, and Risk Management

Verification and KYC: to confirm your identity and address (for example, using passport/ID and UK utility bills) and to perform checks required under gambling, AML, sanctions, and fraud-prevention regulations, typically in connection with your first withdrawal or where risk flags arise.
Responsible gambling: to monitor play, detect problematic patterns, apply limits, exclusions, and cooling-off periods, and to provide information or referrals to support services, including resources such as gamblingtherapy.org.
Account integrity and misuse prevention: to monitor for multiple accounts, bonus abuse, payment fraud, chargebacks, cyberattacks, and other misuse, using both human review and automated tools.

Service Improvement, Analytics, and Marketing

Analytics and performance: to analyse aggregated usage data so we can improve site performance, game offerings, user interface design, and general customer experience on Hovarda via howarda.com.
Personalised experience: to tailor content, promotions, and recommendations based on your account profile, language, and responsible gaming settings, respecting your consent and local legal requirements.
Marketing and communications: to send you promotional messages and to run campaigns, surveys, and competitions, in line with your marketing preferences and subject to your right to opt out at any time.

Automated Decision-Making and Profiling

Risk and compliance profiling: we use automated systems to help identify unusual betting patterns, payment anomalies, and other risk signals. These tools support responsible gambling and AML compliance and may affect your ability to make further deposits or withdrawals until additional checks are completed.
Marketing profiling: with your consent, we may use your activity and preferences to tailor offers and bonuses. You can object to this profiling for direct marketing at any time.

Disclosure & Sharing

We treat your personal data as confidential and only disclose it where necessary, proportionate, and lawful. When sharing data, we ensure appropriate contractual and technical safeguards are in place.

Group Companies and Payment Partners

Group and affiliated entities: we may share data with other entities under common ownership or control with Throne Entertainment B.V. (for example, related brands such as Jetbahis or Rexbet) where necessary for consolidated reporting, risk management, or shared infrastructure, subject to appropriate safeguards and strict access controls.
Payment processors: we share relevant payment and identification data with payment service providers, banks, e-wallet providers (for example, Jeton Wallet and similar services), card schemes, and cryptocurrency processors. For some fiat payments, this includes Cyprus-based processors such as TPM Services Limited, which may process your data as an independent or joint controller.

Service Providers and Professional Advisors

Technical and hosting providers: companies providing hosting, cloud infrastructure, content delivery networks, SMS/email delivery, customer support tools, and IT maintenance, including providers located inside and outside the UK/EEA.
Verification, anti-fraud, and analytics services: third parties that verify identity documents, perform sanctions and PEP checks, provide fraud detection systems, and deliver analytics or performance measurement tools.
Professional advisors: lawyers, auditors, consultants, and other professionals who require access to personal data to provide services to us, subject to confidentiality obligations.

Regulators, Authorities, and Dispute Resolution Bodies

Regulators and law enforcement: gaming regulators in Curaçao (including Curaçao Interactive Licensing N.V.), financial intelligence units, tax authorities, courts, law enforcement agencies, and other competent authorities where we are legally required or permitted to disclose data.
Dispute resolution and chargeback handling: banks, card schemes, and dispute resolution bodies involved in investigating chargebacks, fraud, disputes, or complaints.

Affiliates and Advertising Networks

Affiliate partners: we may share limited data (such as anonymised or pseudonymised IDs, registration and deposit events, and aggregated performance statistics) with approved affiliates for tracking and commission calculation, but we do not provide them direct access to your full account details.
Advertising and marketing partners: with your consent, we may share online identifiers and cookie data with advertising networks and social media platforms to measure, optimise, or deliver our marketing campaigns. We do not sell your personal data.

In the event of a proposed merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be shared with prospective counterparties subject to confidentiality obligations and, where required, your rights and applicable law.

International Transfers

Because Throne Entertainment B.V. is established in Curaçao and relies on infrastructure and service providers in several countries, your personal data may be transferred to and processed in countries outside the United Kingdom and the European Economic Area ("EEA"), including Curaçao, Cyprus, Turkey, and other jurisdictions where we or our service providers operate.

Countries and Regions Involved

Curaçao: core gaming operations, regulatory oversight under licence #5536/JAZ, and key corporate infrastructure.
Cyprus: payment processing and related support services (for example, TPM Services Limited or similar entities) for certain fiat transactions.
Other locations: technical hosting, support, and analytics providers may operate from or store data in the EEA, the UK, the United States, or other countries, always subject to appropriate transfer safeguards.

Transfer Safeguards

Standard contractual clauses and UK-approved mechanisms: where data is transferred from the UK or EEA to a country without an adequacy decision, we rely on appropriate safeguards such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to EU Standard Contractual Clauses, or equivalent EU Standard Contractual Clauses, as updated from time to time.
Additional technical and organisational measures: we implement encryption, strict access controls, data minimisation, and internal policies to reduce transfer risks and protect your privacy, including layered security for cross-border processing.
Recognised frameworks: where our partners are certified under any recognised international data transfer frameworks applicable in 2025 (for example, EU - US or UK - US arrangements that may replace or succeed earlier programmes), we will consider these in our risk assessments, but will not rely solely on obsolete mechanisms.

Where local laws require, including for data subjects in Mexico, we will ensure that international transfers involve contractual commitments consistent with the EU GDPR, UK GDPR, and Mexican data protection standards, and we will provide further details upon request.

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, to comply with legal and regulatory requirements, and to resolve disputes or enforce our agreements. Retention periods may vary depending on the type of data and applicable law, but the following principles generally apply:

Account and Identification Data

Active accounts: we keep your identification, contact, and account data for the duration of your active relationship with Hovarda via howarda.com.
After account closure: we usually retain core account and KYC data for up to five (5) years after account closure, or longer where required by AML, gaming, tax, or other laws (in some cases up to seven (7) years). This includes copies of identity documents and address verification records.

Transaction and Gaming Data

Financial and transaction records: deposit, withdrawal, and betting history are typically retained for at least five (5) years from the date of the relevant transaction, and may be kept longer where needed for legal claims, regulatory audits, or AML obligations.
Dormant accounts: if your account is inactive for 12 months, it may be designated as dormant under our Terms & Conditions and may be subject to a monthly maintenance fee (currently approximately €5 until the balance reaches zero). We will retain the data necessary to administer dormant accounts and to demonstrate compliance with applicable rules.

Marketing and Communication Data

Marketing preferences: we keep records of your marketing consents and opt-outs for as long as needed to demonstrate compliance with consent requirements and to ensure we respect your choices.
Marketing content: emails and messages themselves may be stored for shorter periods, generally not longer than two (2) years, unless required for legal or evidential purposes.

Technical and Security Data

Logs and security data: technical logs and security-related records are usually retained for six (6) to twenty-four (24) months, depending on the sensitivity and purpose, and may be extended in case of active investigations or incidents.
Cookies: cookie lifetimes vary by type; session cookies usually expire when you close your browser, while persistent cookies may remain on your device for a period typically ranging from a few days up to two (2) years, unless you delete them earlier.

When data is no longer required, we will delete it or irreversibly anonymise it. Where complete deletion is not technically feasible (for example, backups), we will ensure that the data is securely stored and isolated from further active processing until it can be removed.

Your Rights

Under UK GDPR and the Data Protection Act 2018, and where applicable under EU GDPR and Mexican data protection laws (including the Federal Law on Protection of Personal Data Held by Private Parties in Mexico), you have a number of rights in relation to your personal data. These rights may vary slightly depending on your location, but we apply them in a broadly consistent and user-friendly way.

Core Data Protection Rights

Right of access: you can request confirmation of whether we process your personal data and obtain a copy of the data we hold about you, together with information about how we use it.
Right to rectification: you can ask us to correct inaccurate or incomplete personal data. In many cases, you can update certain details directly via your Hovarda account dashboard on howarda.com.
Right to erasure ("right to be forgotten" / cancellation): you can request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where processing is unlawful. We may need to retain certain information to comply with legal obligations (for example, AML rules or regulatory retention requirements).
Right to restriction of processing: you can ask us to restrict processing of your data, for example while we verify its accuracy or assess your objection, or where processing is unlawful but you prefer restriction to deletion.
Right to object: you can object at any time to processing based on our legitimate interests, including profiling. We will stop processing unless we have compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for legal claims.
Right to data portability: where processing is based on your consent or on a contract and is carried out by automated means, you can request that we provide your personal data in a structured, commonly used, machine-readable format, or that we transmit it directly to another controller where technically feasible.
Right to withdraw consent: where we rely on your consent (for example, for marketing or certain cookies), you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Mexican ARCO Rights and Additional Protections

ARCO rights (Access, Rectification, Cancellation, Opposition): if Mexican law applies to you, you may exercise the specific ARCO rights recognised under Mexican data protection regulations. These broadly correspond to access, correction, deletion, and objection rights described above.
Consent and revocation: where Mexican law requires express consent for particular processing activities, you may revoke such consent in accordance with local rules, subject to legal and contractual limitations.

How to Exercise Your Rights

Submitting a request: you can exercise your rights by contacting us at dpo@howarda.com or via the secure contact options available in your howarda.com account (for example, live chat or support form). Please clearly indicate which right you wish to exercise and provide sufficient information to verify your identity (we may require additional KYC information where necessary to prevent unauthorised access).
Response timeframe: we aim to respond to all valid requests within one (1) month / thirty (30) days of receipt. In complex cases, or where you have submitted multiple requests, we may extend this period by up to a further two (2) months, in which case we will inform you of the extension and reasons.
Cost: we provide responses to rights requests free of charge. If a request is manifestly unfounded or excessive (for example, repeated requests), we may charge a reasonable fee or refuse to act, in line with applicable law.
Limitations: we may not be able to fully comply with a request where doing so would conflict with legal obligations (for example, AML retention rules, regulatory reporting, or our need to establish, exercise, or defend legal claims). In such cases, we will explain the reasons and the residual processing that continues.

Cookies & Tracking Technologies

We use cookies and similar technologies to operate Hovarda on howarda.com, to improve performance and security, and - where you consent - to personalise content and measure marketing campaigns. Cookies are small text files stored on your device when you visit our site.

Types of Cookies We Use

Strictly necessary cookies: session and persistent cookies that are essential for site operation and security (for example, enabling login, remembering your language and region, and protecting against fraud). These cookies are required for the site to function and cannot be switched off in our systems.
Functional cookies: cookies that remember your preferences and choices (such as interface settings or responsible gaming configurations) to provide an enhanced, personalised experience.
Analytics and performance cookies: first- and third-party cookies that collect aggregated information about how players and visitors use Hovarda (for example, pages visited, device types, time spent). We use this information to improve our services and user experience. Where required, these cookies are used only with your consent.
Advertising and targeting cookies: third-party cookies and similar technologies used, with your consent, to deliver and measure personalised advertising for Hovarda, to limit the number of times you see an advert, and to help us understand campaign effectiveness.

Managing and Disabling Cookies

Cookie banner and preferences: on your first visit and periodically thereafter, you will see a cookie banner allowing you to accept, reject, or customise non-essential cookies. You can adjust your preferences at any time via the cookie settings link on howarda.com.
Browser settings: you can configure your browser to block or delete cookies, or to alert you when cookies are being set. Each browser provides help pages explaining how to manage cookies; please note that blocking strictly necessary cookies may affect site functionality.
Third-party choices: for certain analytics or advertising cookies, you may be able to opt out directly through our partners' tools or industry opt-out platforms, subject to their terms.

For more details about cookies used on Hovarda via howarda.com, including specific providers and cookie lifetimes, please consult the cookie information available through our cookie banner or settings panel.

Data Security

We take the protection of your personal data seriously and implement a combination of technical, organisational, and procedural measures designed to keep your data secure, confidential, and resilient against unauthorised access, loss, or misuse.

Technical Measures

Encryption in transit and at rest: data transmitted between your device and howarda.com is protected using up-to-date encryption (for example, TLS 1.2+). Where feasible, sensitive data (such as passwords and certain financial details) is additionally protected by hashing, tokenisation, or encryption at rest.
Access controls and authentication: access to systems holding personal data is restricted based on job role and necessity. Multi-factor authentication, strong password policies, and network segmentation are used to reduce the risk of unauthorised access.
Secure development and testing: we follow secure coding practices, perform vulnerability assessments, and apply regular updates and patches to our systems and applications.

Organisational and Procedural Measures

Policies and training: our staff are subject to confidentiality obligations and receive regular training on data protection, information security, and responsible handling of player data.
Vendor management: we carefully select third-party providers and require them to implement appropriate security measures, including through data processing agreements and periodic reviews where appropriate.
Incident response: we maintain incident response and breach notification procedures. In the event of a data breach likely to result in a risk to your rights and freedoms, we will take appropriate steps to mitigate the impact and, where required by law, notify the relevant supervisory authority and affected individuals without undue delay.

We aim to align our security controls with recognised international standards, such as ISO 27001 and SOC 2, where proportionate for an online gambling operator, even if we are not formally certified under these specific frameworks as of 2025.

Complaints & Contacts

If you have questions, concerns, or complaints about how we handle your personal data in relation to Hovarda on howarda.com, we encourage you to contact us first so we can try to resolve the issue directly.

Contacting Us

Data Protection Officer / Data Protection Team: dpo@howarda.com
Website: secure messaging and live chat via your howarda.com account, marked for the attention of the "Data Protection Officer".
Postal: "Data Protection Officer - Hovarda", Throne Entertainment B.V., Curaçao (full postal details available upon request or through our customer support).

Internal Complaint Procedure

Step 1 - Customer support: contact our customer support via live chat or email and explain your privacy concern or complaint. Many issues can be resolved quickly at this level.
Step 2 - Escalation to DPO: if you are not satisfied with the initial response, or if your concern relates directly to data protection rights, ask for your case to be escalated to our Data Protection Officer or data protection team at dpo@howarda.com. We will review your complaint thoroughly and provide a considered response.
Timeframe: we aim to acknowledge complaints within a few working days and to provide a substantive response within thirty (30) days. In complex cases or where we handle multiple complaints, this may be extended; if so, we will inform you of the extension and the reasons.

Escalation to Supervisory Authorities

United Kingdom - Information Commissioner's Office (ICO): if you are located in the UK and are not satisfied with our response, you have the right to lodge a complaint with the ICO:
Website: https://www.ico.org.uk
Telephone (UK): +44 303 123 1113.
European Union / EEA: if EU/EEA data protection law applies to you, you may lodge a complaint with your local data protection authority. Contact details of national authorities are available at: https://edpb.europa.eu/about-edpb/board/members_en.
Mexico - INAI: if Mexican privacy law applies to you, you may lodge a complaint with the Mexican data protection authority, the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI):
Website: https://www.inai.org.mx.
Other jurisdictions: depending on your place of residence, you may have the right to complain to other supervisory authorities or regulators, such as the gambling regulator in Curaçao. We can help you identify the relevant authority if you contact us.

We encourage you to contact us first so we can address your concerns promptly, but you may approach a supervisory authority at any time, without first contacting us.

Updates

We may update this Privacy Policy from time to time to reflect changes in our services, our processing activities, our corporate structure, or applicable laws and regulatory guidance affecting Hovarda and howarda.com.

How We Will Inform You

Website notice: we will publish the updated Privacy Policy on howarda.com and indicate the date of the latest revision at the end of the document.
Email and in-account notifications: where changes are material or significantly affect how your data is processed, we will provide additional notice, for example by email, in-account messages, or prominent banners when you log in to Hovarda.

Advance Notice and Your Choices

Advance notice: for significant changes that materially impact your rights or our processing of your data, we will, where reasonably practicable, give you at least thirty (30) days prior notice before the changes take effect.
Your options: if you do not agree with the updated Privacy Policy, you may close your account with Hovarda on howarda.com and cease using our services. Continued use of the services after the effective date of an update will constitute your acknowledgement of the changes, to the extent permitted by law.

Last updated: November 2025. We intend to review this Privacy Policy at least annually and, in any event, no later than November 2026, to ensure ongoing compliance with UK GDPR, applicable EU standards, and relevant Mexican data protection regulations.