As a licensed operator in Italy, we obtain and safeguard personal and transactional data under stringent legal obligations https://it-richroyal.it/legal-and-affiliates/. This policy details exactly how long we keep different categories of information, the legal reasons behind those periods, and the security measures that safeguard your data at every stage. We regularly balance our duty to retain records for fraud prevention and financial audits with the privacy rights you maintain under Italian data protection law and the GDPR. Our schedules receive regular reviews so we remain fully compliant.
User Rights and Retention Management
When you submit an erasure request, our system automatically checks each data category against its retention schedule. All data past its mandatory window is erased without delay. For data still subject to a legal retention obligation, we secure it right away so it’s excluded from active use and stored only for compliance storage; we advise you which specific law applies and the date deletion becomes possible. Access requests are handled within thirty days and come with a breakdown of what we hold, why, and the scheduled deletion date. If you challenge accuracy, we add a note instead of altering the original record, so the audit trail stays intact. Portability requests are fulfilled in a structured, machine‑readable format even while data is still in its retention window.
Partner Program Data Retention
Affiliate partner information, including contact information, payout data and commission payment history, remains for the life of the active partnership plus a decade after the agreement terminates. That stems from tax requirements on commission transactions, which necessitate long‑term financial documentation. Affiliate performance metrics and aggregated player referral data get made anonymous after half a decade. We strictly forbid affiliates from independently collecting or keeping private data about referred users; they receive only anonymised, combined reports. Our affiliate agreements include review rights to ensure compliance, and any breach is cause for prompt contract ending and payout forfeiture.
Information Categories and Retention Periods
We organize all user data into distinct categories, each tied to a retention schedule that matches its use and legal context. That systematic approach keeps us from retaining things forever. Every year our Data Protection Officer examines these groupings and adjusts the timelines whenever new guidance arrives from the Garante per la protezione dei dati personali. Below you’ll find how long each data type stays in our live systems before being securely de-identified or erased. Archived backups follow a ninety‑day cycle because of technical constraints.
Identification and Monetary Records
Identity documents you provide during Know Your Customer checks, like passport scans, utility bills and tax ID numbers, are kept on file for ten years after you close your account, as anti‑money laundering law requires. Deposit and withdrawal logs, payment method tokens and wallet balance histories are retained for ten years from the date of each transaction, satisfying both AML requirements and Italian Civil Code limitation periods. We store these records in encrypted, access‑restricted vaults and tamper‑proof ledgers. Once the retention deadline expires, we remove all personal identifiers permanently; statistical trends may still be used but never in a way that traces to any individual.
Account Activity and Customer Support Interactions
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.
Ethical Play and Self‑Exclusion Data
Once you enable 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.
Information Protection In Retention
Retained data is safeguarded with AES‑256 encryption at rest, TLS 1.3 protocols in transit and isolated virtual private clouds. Access requires multi‑factor authentication plus just‑in‑time privilege elevation that expires 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 maintain 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 Control and Workforce Training
Only employees whose roles demonstrably necessitate 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.
Data Removal Procedures
When a data category hits the end of its planned retention period, our automated lifecycle engine kicks off a secure deletion workflow. First, the data gets virtually eliminated from production databases. Next, physical storage blocks are overwritten with random data patterns to stop forensic recovery. Finally, a digitally signed log lands in a regulatory record, giving traceable confirmation that purging happened on time. Backup copies rotate every ninety days, so any deleted data is removed from all media within three months. When a litigation hold applies, we suspend the deletion workflow only for the affected records, record the hold reason, and restart once the hold lifts.
Cross-border Data Transfers and Storage Periods
Our primary infrastructure resides within Italy and the wider European Economic Area. Some secondary services, like fraud detection platforms and customer relationship tools, may pass certain personal data to countries outside the EEA. In those cases, we guarantee an adequacy decision exists 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 choose vendors with Italian data centres. Geo‑fencing rules maintain Italian user data inside European boundaries, validated through yearly audits.
Popular Queries
Can I request deletion of my data before the retention period ends?
Absolutely, you may lodge an erasure request whenever you wish. We immediately check each data category against its legal retention obligation. When no legal hold exists, we remove it quickly. For any data we are required to retain, we limit it to storage‑only, inform you of the legal reason preventing immediate removal, and provide the anticipated deletion date. Additionally, you can see all your data categories along with their planned deletion dates via your account dashboard. Such a partial strategy respects your rights within the limits of Italian law.
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. This is a legal mandate designed to stop you from creating new accounts. Conversely, your gameplay and transaction records continue to adhere to the usual retention timelines and are erased when those durations expire. The self‑exclusion entry is isolated from all marketing and operational systems, thus it fulfills solely the protective purpose for which it was gathered. You will not receive any promotional messages.
What is your approach to data from inactive accounts?
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 fundamental retention timelines continue based on the initial collection dates, not the inactivity date. That means data from an inactive account is still held for the full statutory period that applies to its category and then deleted according to our standard procedures. If you return following a lengthy hiatus, you might have to finish a fresh Know Your Customer assessment to re‑enable your account. Your data dashboard displays the current status continuously.
Policy Revisions and Player Notification
We evaluate this Data Retention Policy every six months and whenever a major legal change affects Italian gambling operations. Minor clarifications are published silently with a revised effective date. Material changes that modify retention periods, add new data categories or alter the legal basis for processing are communicated directly to you by email at least thirty days before they come into force. You’ll also notice an in‑platform banner notification when you log in during the notice period. Historical versions are archived and available on request, each with a version number and a validity date range. If an earlier version provided a shorter retention period for certain data, we stick to that promise for data collected under that version and apply new terms only going forward.
Legal Basis for Information Storage
Our retention approach is based on several legal duties that apply to gambling operators targeting the Italian market. Anti‑money laundering regulations from the Italian Financial Intelligence Unit require us to keep activity logs, identity verification documents and suspicious activity reports for a fixed term after the business relationship ends. Meanwhile, tax rules enforced by the Agenzia delle Entrate require we preserve financial records that back up taxable gaming revenue and player winnings. These requirements override any general right to erasure during the mandatory period. For operational data that isn’t covered by a fixed legal window, we rely on legitimate interest assessments where a valid reason exists, and we allow an opt‑out unless a compelling legal obligation overrides it.
Consent‑Based Retention
Marketing preferences, newsletter sign‑ups and the behavioural analytics used for personalised offers stay only with your explicit consent. You can withdraw 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 do not use this data for anything beyond the activity you agreed to.
