Privacy Policy

Privacy Policy

1. General

This Privacy Policy explains how personal data is processed in accordance with the General Data Protection Regulation (GDPR) and applicable data protection laws.

1. General

This Privacy Policy explains how personal data is processed in accordance with the General Data Protection Regulation (GDPR) and applicable data protection laws.

2. Data Controller

The data controller within the meaning of Article 4(7) GDPR is:

MENSIS CAPITAL FZCO
Freezone Company
United Arab Emirates
License No.: 10957
Contact email: christophe@zap.win

2. Data Controller

The data controller within the meaning of Article 4(7) GDPR is:

MENSIS CAPITAL FZCO
Freezone Company
United Arab Emirates
License No.: 10957
Contact email: christophe@zap.win

3. Role of the Company

MENSIS CAPITAL FZCO acts as a technology provider and intellectual property holder.

The Company does not operate consumer-facing gaming services, does not accept wagers, and does not process player funds.

Where licensed gaming services are operated using the Company’s software, personal data processing related to such services is conducted by the respective licensed operators as independent data controllers.

3. Role of the Company

MENSIS CAPITAL FZCO acts as a technology provider and intellectual property holder.

The Company does not operate consumer-facing gaming services, does not accept wagers, and does not process player funds.

Where licensed gaming services are operated using the Company’s software, personal data processing related to such services is conducted by the respective licensed operators as independent data controllers.

4. Personal Data Processed

Depending on use of the website, the following data may be processed:

  • Technical data such as IP address, browser type, device information

  • Usage data such as pages accessed and timestamps

  • Contact data submitted via email or contact forms

No unnecessary personal data is collected.

4. Personal Data Processed

Depending on use of the website, the following data may be processed:

  • Technical data such as IP address, browser type, device information

  • Usage data such as pages accessed and timestamps

  • Contact data submitted via email or contact forms

No unnecessary personal data is collected.

5. Purpose of Processing

Personal data is processed solely for:

  • Operating and securing the website

  • Responding to inquiries

  • Improving functionality and performance

  • Complying with legal obligations

5. Purpose of Processing

Personal data is processed solely for:

  • Operating and securing the website

  • Responding to inquiries

  • Improving functionality and performance

  • Complying with legal obligations

6. Legal Basis

Processing is based on:

  • Article 6(1)(b) GDPR – performance of a contract or pre-contractual measures

  • Article 6(1)(c) GDPR – legal obligations

  • Article 6(1)(f) GDPR – legitimate interests, including website security and operation

6. Legal Basis

Processing is based on:

  • Article 6(1)(b) GDPR – performance of a contract or pre-contractual measures

  • Article 6(1)(c) GDPR – legal obligations

  • Article 6(1)(f) GDPR – legitimate interests, including website security and operation

7. International Data Transfers

Personal data may be processed outside the European Union, including in the United Arab Emirates.

Where such transfers occur, appropriate safeguards are implemented in accordance with Articles 44–49 GDPR, including standard contractual clauses or equivalent legal mechanisms.

7. International Data Transfers

Personal data may be processed outside the European Union, including in the United Arab Emirates.

Where such transfers occur, appropriate safeguards are implemented in accordance with Articles 44–49 GDPR, including standard contractual clauses or equivalent legal mechanisms.

8. Data Retention

Personal data is stored only for as long as necessary for the stated purposes or as required by law.

8. Data Retention

Personal data is stored only for as long as necessary for the stated purposes or as required by law.

9. Your Rights

You have the right to:

  • Access your personal data

  • Rectify inaccurate data

  • Request erasure

  • Restrict processing

  • Data portability

  • Object to processing

  • Withdraw consent at any time

Requests may be sent to christophe@zap.win

9. Your Rights

You have the right to:

  • Access your personal data

  • Rectify inaccurate data

  • Request erasure

  • Restrict processing

  • Data portability

  • Object to processing

  • Withdraw consent at any time

Requests may be sent to christophe@zap.win

10. Supervisory Authority

You have the right to lodge a complaint with a competent supervisory authority in your country of residence or place of work.

10. Supervisory Authority

You have the right to lodge a complaint with a competent supervisory authority in your country of residence or place of work.

11. Data Security

Appropriate technical and organizational measures are implemented to protect personal data against unauthorized access, loss, or misuse.

11. Data Security

Appropriate technical and organizational measures are implemented to protect personal data against unauthorized access, loss, or misuse.

12. Updates

This Privacy Policy may be updated to reflect legal or technical changes. The current version is always available on the website.

12. Updates

This Privacy Policy may be updated to reflect legal or technical changes. The current version is always available on the website.