

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.
