Privacy Policy

We will always treat your information with the utmost care and respect.

A. Introduction

EveryMatrix Group takes the privacy of its clients and visitors seriously into account. The purpose behind this policy (the “Privacy Policy”) is to inform you of how the EveryMatrix Group protects the privacy of your communications and processes your Personal Data as well as the rights you have with regard to your access to and use of this website as well as other services provided by us (hereinafter the “Services”). We are committed to comply with the European General Data Protection Regulation 2016/679 (the “GDPR”).

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

Any reference in this Privacy Policy to “EveryMatrix Group”, “EM”, “us”, “we” or “our” is a reference to the Controller.

We refer to you, the visitor and/or the user of our website, as “you” and derivatives of the word “you”.

If you are a customer to any of our B2C clients which offer online entertainment to individuals across different channels (e.g. websites, apps), please address your queries relating to Data Protection and Privacy directly to the relevant operators. In fact, the latter act as controllers toward your personal data determining both the means and purposes of the processing activities involving your information. In such instances, EveryMatrix Group, as a B2B service provider, caters for a number of technical solutions to such operators and it is not in the position to influence the processing of your personal data.

On the other hand, as far as any sites owned by EveryMatrix Group are concerned, some of the entities part of the EveryMatrix Group act as Controllers (jointly, or separately with other entities of the EveryMatrix Group).

With respect to this domain, the primary responsible entity of the EveryMatrix Group acting as Controller is EveryMatrix Software Limited, bearing Reg. Number: C51832, and having its registered office at Piazzetta Business Plaza, Office 12, Level 10, Ghar il – Lembi, Tas-Sliema, Malta.

By using and/or visiting any section of this website as well as agreeing to use our Services, you agree to be bound by the Privacy Policy.

B. Information we collect about you and the way we use it

i. “Contact Us”

When you contact us through the form for General Enquiries or Sales Enquiries, we ask you to provide us with certain pieces of information, including your full name, email, phone number, Skype ID. Please note that all the required pieces of information are mandatory and conditional to obtaining a response from us in such contexts.

We process this data for the purposes of:

a. allowing you access and use of the website’s functionalities;

b. providing you a support and information service;

c. contacting you;

d. website administration and monitoring;

e. maintaining accurate records of the information that we receive from website’s users;

f. improving the website and our users’ experience;

g. taking the first step for entering into a contract with you;

h. statistical analysis and research;

i. research and development;

j. marketing and market research;

k. customisation of the products and Services;

l. exercising and defending legal claims;

m. detection and prevention of fraud and other fraudulent activities.

We will only use your personal data for the purposes for which it was obtained, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

EM has a legitimate interest in understanding how customers and potential customers use its website. This assists EM with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet customer needs.

Please note that, depending on the circumstances, you might be asked to provide further information. For example, when you approach us or have been approached by us either as our partner or client with regards to the provision of our Services as well as services provided to us by you, and upon entering into contract with us, you shall be prompted to provide us KYC data (by filling in the applicable form(s)). In this instance we collect data you have provided us with, by submitting the applicable forms, and such data may include:

· personal details of directors;

· personal details of UBO’s;

· account signatory personal details (if applicable);

· additional information such as personal information on PEPs;

· any additional information as may be set out in the respective form(s), or privacy notices that will be issued and provided to you.

In any case, please get in touch with our Group DPO at in order to know for how long we keep the data you supply to us and to answer any other privacy related queries you might have.

ii. “Careers – Open Positions”

When you apply for a job through the Application Form in our career section, we collect the data you provide us with by submitting this form (that includes your name, e-mail address, telephone number, Skype id). We can also obtain personal information that you supply to us within the “Message Box” of the Application Form along with that information which is disclosed to us through the uploading of your Cv.

Kindly note that the above mentioned is just a preliminary information that is required in order for you to trigger (should that be the case) the whole recruiting process with us. Please be aware that further documentation and information will be required after the submission of the Application Form, during the recruitment process (in accordance with its stages) until final onboarding (if any). This information is necessary to carry out the recruitment process in order to take steps to possibly enter into a contract with you.

Notwithstanding the foregoing, kindly address any query you might have with respect to how we process, for what purposes, and for how long we retain your personal data within the recruiting process by emailing our Group DPO at

iii. “Website users”

As is true of most other websites, please note that our website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

EveryMatrix Group has a legitimate interest in understanding how users, customers and potential customers use its website. This assists us with providing more relevant products and services, with communicating value to our sponsors, and with providing appropriate staffing to meet customer needs.

As a general remark, please note that if you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry; to notify you of other Services; or to keep a record of your complaint, or similar concern.

Note: if you ask us not to contact you by email at a certain email address, we will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.

C. Cookies and third parties’ plug-ins and links

This website may include links to third-party websites, plug-ins, applications and cookies. Clicking on those links or enabling those connections or cookies may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the applicable privacy notice of every website you visit.

For information on what cookies are and how we use them please refer to our full Cookie Policy.

D. Sharing and disclosure

In certain circumstances we may share and disclose your personal data as described below.

Compliance with the law, responding to legal requests, preventing harm and protection of our rights

We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability.

Third-party service providers

We can use third-party service providers to help us provide services related to the website and the payment services. Service providers may be located inside or outside of the European Economic Area (“EEA”).

These providers have limited access to your information and are contractually bound to protect and to use it on our behalf only for the purposes for which it was disclosed and as well as to provide the same level of data protection and be consistent with this Privacy Policy. The categories of the such third parties are mainly the following:

  1. Marketing providers to perform certain marketing activities on our behalf and only with your consent;
  2. IT/system support services;
  3. Third parties assisting in investigations (such as AML investigations) for the purpose of detecting and preventing fraud or other security or technical problems;
  4. Cloud services providers for provision of cloud-based services such as storage or hosting certain software;
  5. Professional advisors acting as processors or joint controllers including lawyers, auditors and insurers who provide consultancy;
  6. Service providers for the purpose of data analytics;
  7. Service providers enabling communication with you from a technical standpoint (e.g. via email, chat).

You can always contact us to receive the full list of our service providers which process your data.

Corporate affiliate

We may share your information, including personal information, to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Policy.

Kindly note the EveryMatrix Group is present in different jurisdictions globally, therefore your personal data may be transferred outside of the EU/EEA in accordance with the conditions laid down below within the Section “Overseas transfer of your information”.

Aggregated data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

Business transfers

If we undertake or are involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence).

Overseas transfer of your information

To facilitate our global operations, we may transfer, store, and process your information within our family of companies or share it with service providers based outside of the EU/EEA area for the purposes described in this Privacy Policy.

If we do transfer your personal data to other group entities or business partners/providers which are outside of the EU/EEA area, and there is no possibility to rely on a transfer of personal data based on adequacy decision (Art. 45 of the GDPR), we will take all reasonable steps to ensure that adequate measures are in place by relying on the use of EU Commission’s standard contractual clauses in accordance with Art. 46 of the GPDR.

You can always contact us to receive the full details over the jurisdictions to which your personal data is sent to and the details of the extra-EU/EEA entities involved in such overseas processing activities. You can also obtain visibility over the standard contractual clauses and stipulations in place within the context of a transfer of personal data to third countries.

E. Data subject rights

Under the GDPR, you have the right to:

o make subject access requests regarding the nature of information held and to whom it has been disclosed;

o prevent processing likely to cause damage or distress;

o prevent processing for purposes of direct marketing;

o be informed about the mechanics of automated decision-taking process that will significantly affect them;

o have significant decisions that will affect them taken solely by automated process;

o sue for compensation if you suffer damage by any contravention of the GDPR;

o take action to rectify, block, erased, including the right to be forgotten, or destroy inaccurate data;

o request the supervisory authority to assess whether any provision of the GDPR has been contravened;

o have personal data provided to you in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller; and

o object to any automated profiling that is occurring without consent.

You may exercise any of the rights described in this section before by sending an email Please note that we may ask you to verify your identity before taking further action on your request.

Particularly, please note that:

Withdrawing consent. Where we have specifically requested your consent to process your personal data, and you are no longer interested in keeping that consent, you can withdraw your consent at any time. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

Objection to processing. In certain circumstances, individuals have the right to object to the processing of their personal data at any time. This effectively allows you to stop or prevent us from processing your personal data.

By way of illustration, an individual can object to the processing of their personal data for direct marketing at any time. This includes any profiling of data that is related to direct marketing.

This is an absolute right and there are no exemptions or grounds for us to refuse. Therefore, when we receive an objection to processing for direct marketing, we will not process your data for this purpose.

However, please note that, besides the above mentioned, the right to object to processing of personal data is not absolute and can only be exercised upon the preconditions as set out by applicable law.

F. Contact us

If you have questions about this Policy or our information handling practices, or If you are seeking to exercise any of your rights under GDPR, please contact our Data Protection Officer at:

i.; or

ii. EveryMatrix Software Ltd. (to the attention of the Group DPO), Reg. no: C51832, Address: Piazzetta Business Plaza, Office 12, Level 10, Ghar il – Lembi, Tas-Sliema, Malta.

G. Filing a complaint with the supervisory authority

You have the right to make a complaint at any time to a supervisory authority. The Information and Data Protection Commissioner (IDPC) in Malta is the Lead Supervisory Authority:

Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta

+356 2328 7100

H. Validity

This Privacy Policy was lastly updated on 1st October 2021.