Privacy Policy Notice

1. General Statement

MOBILE INCORPORATED Limited (the “Company”, “we”, “us”, or “our”) is committed to protecting the privacy and Personal Data of all individuals who use our Services.

This Privacy Policy Notice explains how Personal Data is collected, processed, stored, disclosed, and safeguarded when users access or interact with our websites, mobile applications, gaming platform, and related services (collectively, the “Services”).

By using the Services, you confirm that you understand and accept the practices described in this Policy, as well as the applicable legal and regulatory requirements governing data protection.

The Company processes Personal Data in accordance with:

  • Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR)
  • the Malta Data Protection Act (Chapter 586 of the Laws of Malta)
  • applicable Malta Gaming Authority (“MGA”) rules and directives relating to AML, responsible gaming, and player protection

2. Data Controller Details

MOBILE INCORPORATED Limited acts as the Data Controller in relation to Personal Data processed through the Services.

Registered Office:

Elite Business Centre, Trejqa Ta’ Box Box, Msida MSD1840, Malta

Company Registration Number: C 84149

Data Protection Officer (DPO)

Email: legal@tipclub.biz

Address: Elite Business Centre, Trejqa Ta’ Box Box, Msida MSD1840, Malta

The Data Protection Officer is responsible for overseeing compliance with data protection obligations and handling privacy-related enquiries.

3. Principles of Personal Data Processing

The Company applies the following GDPR principles when processing Personal Data:

  • Lawfulness, fairness, and transparency: data is processed in a lawful and transparent manner
  • Purpose limitation: data is collected for specified and legitimate purposes only
  • Data minimisation: only data necessary for operational and regulatory purposes is collected
  • Accuracy: Personal Data is kept accurate and updated where appropriate
  • Storage limitation: data is retained only for as long as necessary
  • Integrity and confidentiality: appropriate security safeguards are implemented
  • Accountability: compliance can be demonstrated at all times

4. Categories of Personal Data

We may collect and process the following categories of Personal Data:

Identity Information

  • full name
  • date of birth
  • nationality
  • gender

Verification Information

  • identity documents
  • proof of address
  • source of funds / source of wealth documentation (where required)

Contact Information

  • email address
  • telephone number
  • residential address

Account and Usage Information

  • account login credentials
  • gaming and betting activity
  • transaction history
  • account settings, limits, and preferences

Financial Information

  • payment methods
  • deposits and withdrawals
  • transaction records

Technical Information

  • IP address
  • device identifiers
  • browser and operating system details
  • usage logs and system activity

Communication Information

  • customer support messages
  • responsible gaming interactions
  • compliance-related communications

5. Purpose of Data Processing

Personal Data is processed for the following purposes:

  • account creation and management
  • identity and age verification
  • provision of gaming and betting services
  • processing payments, deposits, and withdrawals
  • compliance with AML, KYC, and regulatory obligations
  • fraud detection and prevention
  • responsible gaming monitoring and intervention
  • system security and operational integrity
  • customer support and communication
  • legal and regulatory reporting obligations
  • service improvement and analytics

6. Legal Basis for Processing

We process Personal Data under the following lawful bases:

  • Contractual necessity: to provide Services and manage user accounts
  • Legal obligation: to comply with AML, KYC, MGA, and other regulatory requirements
  • Legitimate interests: including fraud prevention, security, and business improvement
  • Consent: where required (e.g. marketing communications)

Consent may be withdrawn at any time where applicable.

7. Data Disclosure

Personal Data may be shared with trusted third parties where necessary, including:

  • payment processors and financial institutions
  • identity verification and AML/KYC providers
  • IT infrastructure, hosting, and cloud service providers
  • professional advisers (legal, audit, compliance)
  • regulatory authorities, including the Malta Gaming Authority and FIAU where required by law

We do not sell or rent Personal Data to any third party.

8. International Transfers

Where Personal Data is transferred outside the European Economic Area (EEA), the Company ensures appropriate safeguards, such as:

  • European Commission adequacy decisions, or
  • Standard Contractual Clauses (SCCs) or equivalent GDPR-approved mechanisms

9. Retention of Personal Data

Personal Data is retained only for as long as necessary to fulfil legal, regulatory, and operational requirements.

Retention periods are based on:

  • AML and gaming regulatory obligations
  • contractual and account requirements
  • dispute resolution and audit obligations

Once no longer required, Personal Data is securely deleted or anonymised.

Certain compliance-related records, including breach documentation, may be retained for at least five (5) years where required by law.

10. Security Measures

The Company implements appropriate technical and organisational measures to protect Personal Data, including:

  • encryption of sensitive data
  • access restriction controls
  • secure system architecture and monitoring
  • internal policies and governance procedures
  • staff training on data protection and security

Security controls are reviewed and updated on a regular basis.

11. Data Subject Rights

Subject to applicable law, individuals have the following rights:

  • right of access
  • right to rectification
  • right to erasure (where legally applicable)
  • right to restriction of processing
  • right to object to processing
  • right to data portability
  • right to withdraw consent (where applicable)

Requests should be submitted to the Data Protection Officer.

Individuals also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (Malta).

12. Personal Data Breach Management

In the event of a Personal Data breach, the Company will:

  • identify and contain the incident
  • assess potential risks to individuals
  • implement corrective and preventative measures
  • notify the relevant supervisory authority within 72 hours where required
  • notify affected individuals where the breach poses a high risk
  • maintain internal breach records for compliance purposes

13. Age Restrictions

The Services are strictly limited to individuals aged 18 years or older.

We do not knowingly collect Personal Data from minors. If such data is identified, it will be deleted and any related account will be closed where appropriate.

14. Cookies

We use cookies and similar technologies to:

  • enable core platform functionality
  • improve security and fraud prevention
  • analyse performance and usage
  • enhance user experience

Where required, cookie consent is obtained through an appropriate management tool.

15. Updates to This Policy

This Privacy Policy may be updated periodically to reflect legal, regulatory, or operational changes.

The most current version will always be published on the Company’s official website.

16. Governing Law

This Privacy Policy is governed by the laws of Malta and interpreted in accordance with the GDPR and applicable Maltese data protection legislation.