As a licensed operator in Italy, we obtain and safeguard personal and transactional data under rigorous legal obligations. This policy outlines exactly how long we keep different categories of information, the legal reasons behind those periods, and the security measures that shield your data at every stage. We regularly 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 receive regular reviews so we keep fully compliant.
Information Categories and Retention Periods
We categorize all user data into clear categories, each connected to a retention schedule that aligns with its use and legal context. That systematic approach stops us from keeping things forever. Every year our Data Protection Officer assesses these groupings and modifies the timelines whenever new guidance emerges 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 anonymised or deleted. Archived backups follow a ninety‑day cycle because of technical limitations.
Personal and Monetary Records
Identity documents you upload during Know Your Customer checks, like passport scans, utility bills and tax ID numbers, remain on file for ten years after you terminate your account, as anti‑money laundering law mandates. Deposit and withdrawal logs, payment method tokens and wallet balance histories are kept for ten years from the date of each transaction, meeting both AML requirements and Italian Civil Code limitation periods. We keep these records in encrypted, access‑restricted vaults and tamper‑proof ledgers. Once the retention deadline expires, we eliminate all personal identifiers permanently; statistical trends may still be utilized but never in a way that connects to any individual.
User Activity and Support Communications
Detailed logs 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
Upon activating 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.
Data Transfers Abroad and Storage Periods
Our primary infrastructure resides within Italy and the wider European Economic Area. Some ancillary services, like fraud detection platforms and customer relationship tools, may send some personal data to countries beyond the EEA. In those cases, we make sure an adequacy decision is in place or we implement Standard Contractual Clauses in place together with a transfer impact assessment. The retention periods we assign to transferred data reflect those in this policy, and processors are contractually bound to remove or return data when the service ends. We publish 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.
Information Erasure Procedures
When a information type hits the end of its designated storage time, our self-running lifecycle mechanism kicks off a safe removal process. First, the data gets logically removed from production databases. Next, physical storage blocks are replaced with random data patterns to hinder forensic recovery. Finally, a cryptographically timestamped entry lands in a compliance ledger, giving traceable confirmation that purging happened on time. Backup copies refresh 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 resume once the hold lifts.
Policy Changes and Player Notification
We evaluate this Data Retention Policy every six months and whenever a major legal change impacts Italian gambling operations. Minor clarifications are posted silently with a revised effective date. Material changes that alter 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 find 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 follow that promise for data collected under that version and apply new terms only going forward.
Individual Rights and Retention Interactions
When you submit an erasure request, our system automatically reviews each data category against its retention schedule. All data past its mandatory window gets deleted without delay. For data still subject to a legal retention obligation, we lock it down 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 responded to within thirty days and include a breakdown of what we store, why, and the scheduled deletion date. If you challenge accuracy, we attach a note instead of altering the original record, so the audit trail is preserved. Portability requests are processed in a structured, machine‑readable format even while data is still in its retention window.
Data Security In Storage
Stored information is secured with AES‑256 encryption at rest, TLS 1.3 protocols in transit and isolated virtual private clouds. Access demands 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 keep 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 flags every dataset as it nears expiration.
Permission Management and Staff Training
Only employees whose roles demonstrably require access to retained personal data get permissions, and those permissions go through monthly recertification audits. Any access to dormant user records triggers 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 distinguishing the difference between data we must keep under a legal hold and data we can delete straight away.
Legal Grounds for Data Retention
Our retention approach is based on several regulatory requirements that apply to gambling operators targeting 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 fixed term after the business relationship ends. Meanwhile, tax rules administered by the Agenzia delle Entrate oblige us to preserve financial records that substantiate 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 provide an opt‑out option unless a compelling legal obligation stops us.
Storage with Consent
Marketing preferences, newsletter sign‑ups and the behavioural analytics used for personalised offers stay only with your explicit consent. You can revoke consent anytime through your account dashboard; once you do, we stop that processing immediately and delete the connected profiles within thirty days. Data processed lawfully before withdrawal gets isolated from active systems to block further use, but it isn’t retroactively deleted. 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.
Affiliate Programme Data Retention
Affiliate partner information, including contact information, payout data and commission payment history, stays for the entirety of the current agreement plus ten years after the partnership concludes. That’s driven by tax requirements on commission transactions, which demand long‑term financial documentation. Partner performance data and aggregated player referral data get anonymized after half a decade. We strictly forbid affiliates from independently collecting or storing personal information about referred users; they receive only anonymous, consolidated statements. Our affiliate contracts include inspection rights to verify compliance, and any infringement is cause for prompt contract ending and commission forfeiture.
Common Questions
Can I request deletion of my data before the retention period ends?
Certainly, you can submit a deletion request at any moment https://it-richroyal.it/legal-and-affiliates/. We immediately check each data category against its legal retention obligation. When no legal hold exists, we remove it quickly. Regarding items we must preserve, we confine them to storage‑only, explain the legal basis blocking instant erasure, and share the projected 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 happens to my data if I self‑exclude permanently?
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. 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. No marketing communications will be sent to you.
What is your approach to data from inactive accounts?
After twelve uninterrupted months of no login, an account is considered inactive. At that stage, we automatically disable marketing communications and transition the account to a dormant status with limited processing. The fundamental retention timelines continue based on the initial 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. If you come back after a long break, you might need to complete a fresh Know Your Customer check to reactivate. Your data dashboard shows the current status at all times.