Privacy Policy

Last Updated: June 2025

1. INTRODUCTION & SCOPE OF THIS PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) outlines how [Optival LTD] (“Company”, “we”, “our”, or “us”) collects, manages, and protects your Personal Data (as defined below).
This Privacy Policy applies to all our websites and digital properties (including landing pages, advertisements, etc. - collectively referred to as “website(s)”), where we share information and provide comparisons of third-party goods and services. Our platforms also help you connect directly with our business partners (“Business Partners”) and their websites (“Business Partner’s Website”) (collectively, “Services”).
Here, you’ll find full details about what Personal Data we collect when you visit, interact with, or use our websites and Services—including our other digital assets. We also explain why we collect data, how we use it, who we may share it with, and for what reasons. You’ll also learn about your rights and choices regarding your Personal Data.
This Privacy Policy is a key part of our Terms of Use (“Terms”). If you see capitalized terms here that aren’t defined, they carry the meaning assigned in the Terms.
While you’re not legally obligated to share Personal Data with us, please note that certain features of our Services require specific information to function—like your email address if you contact us, or cookies essential for website performance. Optional cookies that help enhance your experience or support our promotions can be opted out of, as explained in this Privacy Policy.
If you do not wish to provide the Personal Data necessary for certain Services, you are free to avoid using those features or to refrain from accessing our website.
By using our website and Services, you consent to this Privacy Policy and our data practices. If you disagree with any part of this Privacy Policy, please do not use our Site or Services.
For EU/UK residents:
This Privacy Policy also covers information we are required to provide under the General Data Protection Regulation (“GDPR”), including our lawful basis for processing your Personal Data, our Data Protection Representative, your GDPR rights, and how to exercise them.

2. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, at our discretion. The most recent version will always be available on our website, with the “Last Updated” date shown at the top. If any material changes are made, we’ll provide the notifications required under applicable laws, and if needed, request your consent. Changes will take effect seven days after the revised policy is posted. We encourage you to review this page regularly to stay informed about our latest privacy practices.

3. DATA CONTROLLER & CONTACT DETAILS

Your privacy matters to us. That’s why we’ve appointed Prighter Group and its local partners as our privacy representatives for:

a. The European Union (EU)

b. The United Kingdom

Prighter makes it simple to exercise your privacy rights (such as accessing or deleting your data). To contact us through our representative or to use your data rights, please visit: Prighter | Compliance Landing Page of Optival LTD

4. THE DATA WE COLLECT, WHY WE COLLECT IT & LAWFUL BASIS

Here, you’ll find details about the types of Personal Data we collect, the reasons for processing it, our lawful basis for doing so (where the GDPR applies), what’s considered “personal” and “non-personal” data, and how this information is processed.
Types of Data Collected
Under data protection law, “Personal Data” is any information that identifies, or could reasonably identify, an individual—such as your name, email, IP address, or cookies. This can also include insights drawn from your preferences, behaviors, or other linked information.
We also collect “Non-Personal Data,” meaning information that can’t identify any individual (e.g., aggregated site usage stats, technical device details). Data is only treated as Non-Personal when not combined with any identifier.
If we combine Personal Data with Non-Personal Data, we treat the whole dataset as Personal Data.
How We Collect Data
Depending on how you use our website and Services, we may collect information:

(i) Automatically, via tracking technologies like cookies, pixels, and tags (see “Cookies and Similar Technologies” below), either set by us or by service providers, Business Partners, or other third-party marketing partners. This also includes “tracking links” that help us and our partners identify if a user followed a link from our site to a partner’s site;

(ii) Directly from you, when you provide it voluntarily—for example, when you contact us; and

(iii) From Business Partners, especially when you engage with them after clicking through from our websites.
Personal Data Sets, Use & Lawful Basis
Here’s a summary of the types of data we collect, why we process them, and on what legal basis:
Online Identifiers: When you use our site, we collect things like your IP address, browser information, and Cookie ID. We may assign a unique user ID to track your activity, including if you click through to a Business Partner’s Website.
Location Data: We may determine your approximate location (country level) from your IP address.
Device Information: Details like your device type, browser, and operating system.
Usage Data: Information on how you interact with our website (e.g., pages viewed, time spent, links clicked), which we may store alongside online identifiers in our logs.

*If any of the above (location, device info, usage data) is linked to an identifier, we treat it as Personal Data. When only used in aggregate, it’s Non-Personal Data.*
We use these datasets for purposes including: operating and securing our website, fraud prevention, debugging, analytics, marketing, and advertising (like retargeting). We may also use unique IDs to analyze how traffic moves from our website to partner sites for business, performance, and conversion tracking.
Essential cookies are used for website functionality (legitimate interests); other cookies (for marketing/analytics) are only set with your consent, which can be managed in your cookie preferences at any time.

Business Partners’ Engagement Data

If you click a Business Partner’s offer, a unique ID will be assigned to you, and we’ll record that action. In some cases, the partner may also share with us data about your engagement with their offer (e.g., if you register, make a deposit, or complete a transaction).
This is used for business operations, like calculating advertising fees and maintaining records, and may be aggregated to improve content and measure partner popularity. This processing is based on our legitimate interests.

Advertising Campaign Interactions

We use third-party providers and tools to manage and track advertising campaigns. These tools collect data such as your journey from an ad to our site, and whether you engage with a Business Partner. This helps us run and optimize our campaigns. Data is processed with your consent, which you can withdraw any time in your cookie settings.

Contact & Communications

If you reach out to us (e.g., by email), you may need to provide details such as your name and email, plus any information you choose to include. We keep these communications for support, record keeping, service improvement, or in case of future disputes.
We process this information with your consent when you contact us. For record keeping or service improvement, processing is based on our legitimate interests.
Actual data processing may involve various automated steps (collection, storage, use, erasure, etc.). Data transfers outside your region are also conducted according to the same legal basis described here.
We may also use Personal Data to prevent fraud or illegal activities, protect our users and Services, enforce our Terms, and defend our legal interests.

5. COOKIES & SIMILAR TRACKING TOOLS

We use cookies and similar tracking technologies (such as pixels, tags, and web beacons) on our websites and in connection with our Services. These small data files are a standard tool for website functionality, analytics, and advertising. Cookies help sites remember you, enable smooth navigation, collect stats, and personalize your experience. For details, visit: www.allaboutcookies.org.
You can also refer to our Cookies Settings banner for a list of all cookies in use on our website.

Managing Cookies & Opting Out
Except for essential cookies (needed for website functionality), you can adjust your cookie preferences or opt out of certain cookies anytime, using our cookie management tool or your browser settings. Please note, disabling cookies may affect how some site features work.

6. DATA SHARING – WHO WE SHARE YOUR DATA WITH

We may share your data with select third parties, including trusted partners and service providers who support and enhance our Services:

• Business Partners – Unique ID, Online Identifiers: If you click through to a Business Partner’s Website, we’ll share your unique ID and, if needed for fraud prevention, your IP address or similar details. This data is shared exclusively to operate our business and monitor conversions.

• Trusted agents and service providers – All relevant data: We work with a range of trusted agents (such as legal advisors) and service providers (including but not limited to cloud hosting, CRM systems, and security tech). These parties receive only the data necessary to deliver services on our behalf and are contractually required to use it solely for those services and to safeguard your data in line with all regulations. Some providers may use non-personal data for their own purposes.

• Subsidiaries, affiliates, or business acquirers – All data: Your data may be shared within our corporate group, or in connection with business changes like mergers, asset sales, or acquisitions. In these cases, affiliated or acquiring companies will uphold the commitments made in this Policy.

• Advertising Partners – Online Identifiers, Device, Location, and Usage Data: When we use third-party advertising tools (like Google or social networks), those partners may independently collect and combine your data—such as device and browsing info—across their platforms to improve ad targeting and analytics. They process this data according to their own privacy policies.

• Government authorities or legal requirements: We may need to disclose data in response to lawful requests from government or law enforcement, to comply with legal obligations, or to protect our rights in legal proceedings.

7. INTERNATIONAL DATA TRANSFER

Because our operations and some service providers are global, your Personal Data may be transferred to—and processed in—countries outside your own. Any such transfers are made in accordance with applicable data protection laws. We take appropriate steps to ensure your data remains protected, such as using approved legal agreements (like Standard Contractual Clauses). Where required, your use of our Services is deemed consent to these international transfers.

8. DATA RETENTION

We retain Personal Data only as long as necessary for the reasons it was collected, which can include legal, administrative, or financial requirements. Our retention period depends on:

(i) The type of Personal Data and its purpose—considering sensitivity, purpose, and the risk if accessed unlawfully.

(ii) Legal obligations—sometimes, we’re required by law to retain data for a specific period, or to comply with binding legal orders.

(iii) Disputes or claims—we may retain data to protect our interests or manage disputes until fully resolved.
When we no longer have a legitimate reason to keep your data, it will be deleted or anonymized so it can’t be linked to you.
Unless required by law, we’re not obliged to retain Personal Data for any set time and may delete it at our discretion, without notice.

9. SECURITY

We take your data security seriously and employ technical and organizational measures to protect your information from unauthorized access, loss, or misuse, as required by law. However, no security system is completely infallible. While we work to safeguard your Personal Data, there’s always some inherent risk in digital data processing, and we cannot guarantee absolute protection from threats such as unauthorized access, cyberattacks, or technical failures. Please take steps to keep your own devices and networks secure.

10. YOUR PRIVACY RIGHTS & CHOICES

You have a range of rights and choices regarding your Personal Data, depending on your location and the applicable laws. These may include the following principal rights, along with instructions on how to exercise them. Some rights can be managed directly (such as cookie preferences), while others may require you to contact our privacy team at contact@top10everydayslot.com. EU and UK residents can also contact our Data Protection Representative via Prighter | Compliance Landing Page of Optival LTD.

When making a request, please specify which right you’re exercising and provide any details we need to confirm your identity. Additional verification may be required.

• Right to be Informed: You have the right to know how and why we process your Personal Data. This Privacy Policy covers those details, but if you need more information, just ask.

• Right of Access: You’re entitled to know if we process your Personal Data and to receive a copy of it.

• Right to Correction/Rectification: You can request correction of incomplete or inaccurate data.

• Right to Erasure/Be Forgotten: In certain circumstances, you may request the deletion of your data. Note: some exceptions apply if we must keep data for legal or legitimate reasons.

• Right to Restrict Processing: In some cases, you can ask us to limit how we use your data (for example, while a dispute over accuracy is resolved).

• Right to Data Portability: You may request your data in a portable, machine-readable format for transfer to another service.

• Right to Withdraw Consent/Object/Opt-Out: If you’ve given consent, you can withdraw it at any time. You may also object to certain data uses, particularly if based on our legitimate interests. We will stop processing unless we have overriding reasons, or need to defend a legal claim.

• Right to Appeal or Complain: If we deny your request, we’ll tell you why. Under GDPR, you have the right to lodge a complaint with the relevant Data Protection Authority in the EU or with the UK’s Information Commissioner.

11. ELIGIBILITY AND CHILDREN PRIVACY

Our Services are not designed for children (defined as anyone below the age specified by relevant laws), and we do not knowingly collect or process personal data from minors. If we discover that we have inadvertently received information from a child, we will promptly delete that data from our records.

12. LINKS TO EXTERNAL SITES

Our websites and Services may feature links to external sites, including those of our Business Partners. By clicking these links or accessing such sites, you may allow third parties to gather or share your data. Please note that we do not control these third-party websites or their privacy policies, and we are not responsible for their data practices. To exercise your privacy rights regarding data collected by Business Partners, you should contact them directly.