As a regulated operator in Italy, we gather and manage personal and transactional data under strict legal obligations https://it-richroyal.it/legal-and-affiliates/. This policy spells out exactly how long we retain different categories of information, the legal reasons behind those periods, and the security measures that shield your data at every stage. We constantly balance our duty to retain records for fraud prevention and financial audits with the privacy rights you hold under Italian data protection law and the GDPR. Our schedules get regular reviews so we remain fully compliant.
Policy Updates and Player Notification
We assess this Data Retention Policy every six months and whenever a major legal change hits 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 become effective. 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 offered 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.
Data Subject Rights and Retention Interactions
When you file an erasure request, our system automatically checks 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 restrict it right away so it’s taken out of active use and held only for compliance storage; we notify you which specific law is relevant and the date deletion becomes possible. Access requests are answered within thirty days and come with a breakdown of what we keep, why, and the scheduled deletion date. If you dispute accuracy, we append a note instead of changing the original record, so the audit trail stays intact. Portability requests are processed in a structured, machine‑readable format even while data is still in its retention window.
Data Deletion Procedures
When a information type hits the end of its designated storage time, our automatic lifecycle system 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 prevent forensic recovery. Finally, a digitally signed log lands in a compliance ledger, giving verifiable evidence that purging happened on time. Backup copies cycle every ninety days, so any deleted data is removed from all media within three months. When a litigation hold applies, we pause the deletion workflow only for the affected records, record the hold reason, and restart once the hold lifts.
Legal Basis for Data Retention
Our retention approach rests on several regulatory requirements that affect gambling operators targeting the Italian market. Anti‑money laundering regulations from the Italian Financial Intelligence Unit require us to keep transaction 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 demand we preserve financial records that substantiate taxable gaming revenue and player winnings. These obligations override any general right to erasure during the mandatory period. For operational data that doesn’t fall under 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 overrides it.
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 revoke 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 gets isolated 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 use this data for anything beyond the activity you agreed to.
International Data Transfers and Storage Periods
Our core infrastructure resides in Italy and the larger European Economic Area. Some ancillary services, like fraud detection platforms and customer relationship tools, may send some personal data to countries external to the EEA. In those cases, we make sure an adequacy decision exists or we implement Standard Contractual Clauses in place together with a transfer impact assessment. The retention periods we use to transferred data mirror those in this policy, and processors are contractually bound to delete 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 ensure Italian user data inside European boundaries, verified through yearly audits.
Data Categories and Holding Times
We sort all user data into distinct categories, each tied to a retention schedule that aligns with its function and legal context. That systematic approach stops us from holding on to things forever. Every year our Data Protection Officer assesses these classifications and modifies the timelines whenever new guidance arrives from the Garante per la protezione dei dati personali. Below you’ll find how long each data type remains in our live systems before being securely de-identified or destroyed. Archived backups operate on a ninety‑day cycle because of technical constraints.
Identity and Fiscal Records
Identity documents you provide during Know Your Customer checks, like passport scans, utility bills and tax ID numbers, stay on file for ten years after you terminate your account, as anti‑money laundering law requires. Deposit and withdrawal logs, payment method tokens and wallet balance histories are held for ten years from the date of each transaction, meeting 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 expires, we eliminate all personal identifiers permanently; statistical trends may still be utilized but never in a way that traces to any individual.
Account Activity 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
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.
Partner Program Data Retention
Affiliate partnership data, including contact details, payment information and commission transaction history, stays for the entirety of the current agreement plus a decade after the agreement terminates. That’s driven by tax duties on commission transactions, which necessitate long‑term financial archives. Affiliate performance statistics and combined referred-player data get anonymised after half a decade. We firmly disallow affiliates from independently collecting or retaining personal data about referred players; they get only anonymised, aggregated reports. Our partner contracts include review rights to check adherence, and any breach is grounds for immediate contract termination and commission forfeiture.
Common Questions
May I request data erasure before the retention period expires?
Absolutely, you may lodge an erasure request whenever you wish. We instantly examine each data category in relation to its legal retention duty. 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. That partial approach respects your rights as far as Italian regulations allow.
How is my data handled if I choose 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. No promotional communications will reach you.
What is your approach to data from inactive accounts?
An account becomes inactive after twelve straight months with no login. At that stage, we automatically disable marketing communications and transition the account to a dormant status with limited processing. The underlying retention periods remain active according to the original data collection dates, not the date of inactivity. 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. The current status is always visible on your data dashboard.
Data Safeguarding Throughout Storage
Stored information 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 terminates on its own. Every access event is recorded 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 Workforce 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 initiates 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.
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