As a licensed operator in Italy, we obtain and safeguard personal and transactional data under stringent legal obligations it-richroyal.it. This policy spells out exactly how long we hold different categories of information, the legal reasons behind those periods, and the security measures that protect your data at every stage. We continuously balance our duty to retain records for fraud prevention and financial audits with the privacy rights you possess under Italian data protection law and the GDPR. Our schedules get regular reviews so we keep fully compliant.
Regulatory Foundation for Information Storage
Our retention approach rests on several legal duties that govern gambling operators operating in 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 specific duration after the business relationship ends. Meanwhile, tax rules imposed by the Agenzia delle Entrate require we preserve financial records that substantiate taxable gaming revenue and player winnings. These duties override any general right to erasure during the mandatory period. For operational data that falls outside 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 stops us.
Consent‑Based Retention
Marketing preferences, newsletter sign‑ups and the behavioural analytics utilised for personalised offers are kept only with your explicit consent. You can retract consent anytime through your account dashboard; once you do, we cease that processing immediately and delete the connected profiles within thirty days. Data processed lawfully before withdrawal is removed 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.
Information Erasure Procedures
When a data class hits the end of its scheduled retention, our automated lifecycle engine kicks off a safe removal process. First, the data gets digitally detached from production databases. Next, physical storage blocks are rewritten with random data patterns to hinder forensic recovery. Finally, a digitally signed log lands in a compliance ledger, giving traceable confirmation that purging happened on time. Backup copies rotate every ninety days, so any deleted data disappears 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.
Data Subject Rights and Retention Handling
When you file an erasure request, our system automatically reviews each data category against its retention schedule. Everything beyond its mandatory window gets deleted without delay. For data still under a legal retention obligation, we restrict it right away so it’s taken out of active use and held only for compliance storage; we advise you which specific law applies and the date deletion becomes possible. Access requests are answered within thirty days and provide a breakdown of what we keep, why, and the scheduled deletion date. If you question accuracy, we add a note instead of changing the original record, so the audit trail remains intact. Portability requests are fulfilled in a structured, machine‑readable format even while data is still in its retention window.
Information Protection During Retention
Held data is protected with AES‑256 encryption at rest, TLS 1.3 protocols in transit and isolated virtual private clouds. Access necessitates 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 ensure 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 marks every dataset as it nears expiration.
Access Governance and Staff Training
Only employees whose roles demonstrably need 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 telling the difference between data we must keep under a legal hold and data we can delete straight away.
Affiliate Program Data Retention
Partner relationship data, including communication data, payment details and commission transaction history, remains for the duration of the active partnership plus ten years after the contract ends. That’s driven by tax duties on commission transactions, which necessitate long‑term financial documentation. Affiliate performance metrics and aggregated player referral data get anonymised after five years. We strictly forbid affiliates from independently collecting or retaining private data about referred users; they obtain only anonymized, combined reports. Our affiliate agreements include audit rights to ensure compliance, and any breach is grounds for immediate contract termination and commission loss.
International Data Transfers and Retention
Our primary infrastructure resides in Italy and the broader European Economic Area. Some ancillary services, like fraud detection platforms and customer relationship tools, may pass some personal data to countries outside the EEA. In those cases, we make sure an adequacy decision is in place or we establish Standard Contractual Clauses in place together with a transfer impact assessment. The retention periods we apply to transferred data reflect those in this policy, and processors are contractually bound to delete or return data when the service ends. We keep a public register of sub‑processors, updated within fourteen days of any change, and we prefer vendors with Italian data centres. Geo‑fencing rules maintain Italian user data inside European boundaries, confirmed through yearly audits.
Information Categories and Holding Times
We sort all user data into distinct categories, each linked to a retention schedule that aligns with its use and legal context. That organized approach prevents us from holding on to things forever. Every year our Data Protection Officer examines these groupings and updates the timelines whenever new guidance emerges from the Garante per la protezione dei dati personali. Below you’ll see how long each data type is kept in our live systems before being securely anonymised or deleted. Archived backups follow a ninety‑day cycle because of technical constraints.
Personal and Fiscal Records
Identity documents you provide during Know Your Customer checks, like passport scans, utility bills and tax ID numbers, remain on file for ten years after you close 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 elapses, we eliminate all personal identifiers permanently; statistical trends may still be utilized but never in a way that connects to any individual.
Account Actions and Support Communications
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.
Policy Changes and Player Notification
We review 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 change the legal basis for processing are communicated directly to you by email at least thirty days before they take effect. You’ll also see an in‑platform banner notification when you log in during the notice period. Historical versions are kept and available on request, each with a version number and a validity date range. If an earlier version gave a shorter retention period for certain data, we adhere to that promise for data collected under that version and apply new terms only going forward.
Common Questions
Can I request deletion of my data before the retention period ends?
Yes, you can file an erasure request any time. We promptly review every data category against its mandatory retention requirement. If there’s no legal hold, we delete it fast. 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 can also view all your data categories with their scheduled deletion dates through your account dashboard. That partial approach respects your rights as far as Italian regulations allow.
What occurs with my data when I opt for permanent self‑exclusion?
If you sign up for permanent self‑exclusion, your personal data is shifted to a dedicated exclusion register that operates indefinitely with highly restricted access. It is a legal obligation intended to block you from establishing new accounts. Your gaming and transaction history, however, still complies with standard retention schedules and is removed after those periods conclude. The self‑exclusion record is cut off from all marketing and operational systems, so it serves only the protective function it was collected for. No marketing communications will be sent to you.
How is data from dormant accounts managed?
After twelve uninterrupted months of no login, an account is considered inactive. 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. Consequently, data from an inactive account is kept for the entire statutory duration applicable to its type and then removed in line with our usual processes. Should you return after an extended absence, you may be required to undergo a new Know Your Customer verification to reactivate. Your data dashboard shows the current status at all times.
