PRIVACY POLICY

Last updated: 4 Mar 2026

As we consider ensuring the right to the protection of personal data a fundamental commitment of ICONIC21, we dedicate all necessary resources and efforts to process your personal data in full compliance with Regulation (EU) 679/2016 (“General Data Protection Regulation” or “GDPR”), as well as with any other applicable legislation. The processing of personal data is carried out using mixed means (manual and automated), in compliance with legal requirements and under conditions that ensure security, confidentiality, the applicable principles, and respect for the rights of data subjects.

As transparency represents one of the essential principles of this legal framework, we kindly ask you to read this document, through which we inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to our products and services, including through our website. ICONIC21 Privacy Policy applies to any visitor/user of the website, as well as to any personal data processing activities.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Please also consult our pages regarding the Terms and Conditions for using the website http://www.smartree.com and the Cookie Policy, where we explain what types of cookies we use and how long we retain them.

1. Who we are and how you can contact us

For the purposes of data protection legislation, the controller of your personal data is ICONIC21, hereinafter referred to as “ICONIC21”.

We are an in-demand provider of iGaming content, offering a diverse and extensive portfolio designed to captivate and entertain.What sets us apart is our commitment to providing branded solutions tailored to each client’s unique needs, featuring dedicated studios and custom games that enhance the gaming experience.

With a client-centric philosophy, we excel at understanding the specific requirements of our partners, delivering solutions with speed and precision, and maintaining transparent communication.

This Privacy Policy applies to personal information for which we determine the purposes and means of processing, regardless of how such information is collected or stored, and describes, among other things, the types of information collected, how your information may be used, when it may be disclosed, how you can control the use and disclosure of your information, and how it is protected. This Policy covers information collected by ICONIC21 through various means of communication, including but not limited to the website https://www.iconic21.com/.

In case you have any questions regarding your personal data processing, please contact us at dataprotection@iconic-21.com.

1. Interpretation and Definitions 
2. i) Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1. ii) Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Company (referred to as either “the Company”, “ICONIC21”, “We”, “Us” or “Our” in this Agreement) refers to ICONIC21

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Romania

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Process, Processing or Processed means any operation performed on personal data, including but not limited to collection, recording, organization, structuring, storage, retrieval, use, disclosure by transmission, erasure or destruction of personal data.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to ICONIC21, accessible from https://iconic21.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

1. Processing Your Personal Data 

In general, we collect your personal data directly from You, meaning that You retain control over the type of information Youprovide to us. During the course of our business activities, we may have access to the following categories of personal data:

1. i) personal data provided during the recruitment process: first name, last name, telephone number, email address, professional experience, education and place of residence at the time of application;
2. ii) business-related personal data of contact persons representing our partners and suppliers: first name, last name, company name, position, department, business email address and business telephone number;

iii) information regarding your interactions with our online content or social media platforms (Facebook, LinkedIn, Twitter);

1. iv) records of any consent you have provided, including the type of activity requiring consent, the date and time of submission of such consent and any related information;
2. v) any comments or opinions you submit or publish in relation to ICONIC21 on social media platforms, including websites, forums and online communities;
3. vi) If you wish to apply for a position published by ICONIC21 on the careers page (https://www.iconic21/careers), we will collect all personal data you include in your CV, cover letter or any reference documents. Please do not send us sensitive or special category personal data. Any other information you provide that is not necessary for processing purposes will be deleted, where possible. We may request references from former employers only with your consent.

vii) It is also possible that third parties acting as providers of applications, tools, widgets and plug-ins on our website, such as social media tools, Google Analytics, Google AdWords and other Google tools, without limitation, may use automated means to collect data regarding your interaction with such platforms. In such cases, data is collected directly by those providers, who act as independent data controllers. We recommend that you consult the data protection policies and notices of such providers. Subject to applicable legislation, ICONIC21 is not responsible for the data protection practices of such providers.

viii) Usage Data – is collected automatically when using the Service.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

1. ix) Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies by reading our Cookies Policy here: iconic21.com/cookie-settings

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

1. x) CCTV recordings

In order to ensure the security of ICONIC21 buildings, employees and visitors, we have placed CCTV (close circuit television cameras) on ICONIC21 operating premises and areas.

The CCTV cameras capture your image, movements, and activities while you are visiting our locations.

Please note that you are informed about CCTV cameras placement with corresponding CCTV warning signs before entering the monitored area.

ICONIC21 complies with legal obligations and regulations towards CCTV placement; therefore, CCTV cameras are not placed in areas where you expect the total privacy (e.g., restrooms, kitchen, changing rooms, etc.).

ICONIC21 has placed CCTV cameras at all ICONIC21 operating sites for several business purposes such as:

• To ensure the physical security of our employees, customers, and service providers;
• To ensure the security of our premises and property;
• To detect and investigate any criminal activities and to act as a deterrent to crime;
• To use as evidence in legal claims or disputes, including disciplinary actions.
• To assist in day-to-day management, including ensuring the health and safety of staff.

This list is not exhaustive and other purposes may be or become relevant.

The recordings may be shared between us and our affiliates only if an adequate security level is ensured, and all legal requirements are met.

ICONIC21 will not disclose this data to any third parties without legal grounds. We might share the recordings with the police or other public institutions, if necessary. In case of legal claims or disputes, including disciplinary actions, we may share the recordings with third parties (e.g., lawyers, insurance companies).

We have implemented appropriate technical, physical and organizational measures to protect CCTV recordings from unauthorized or accidental destruction, alteration or disclosure, misuse, damage, theft or accidental loss, or unauthorized access. The physical, technological infrastructure and recordings are stored and backed-up internally.

Generally, the CCTV footage is kept for a period of up to 30 days from the time of recording unless otherwise required by local legislation or legal requirements. Certain areas, namely our game floors and back-office operations, may have a longer general storage period of 90 days, namely due to the higher sensitivity and vulnerability of those areas.

In the event of an incident, potential or ongoing investigation or claim, the CCTV recording may be retained for a period until the incident, or the claim is finalised or if it is required to be stored by legal obligations.

Due to legal requirements, you have several rights towards your personal data. You have right to request access, correct, erase, transfer your personal data and restrict personal data processing.

Please note that due to CCTV processing specifics, certain rights such as right to rectify, and right to erase your personal data are limited.

General disclaimer: ICONIC21 is not responsible for personal information you voluntarily disclose on public social media pages or through quotation requests submitted by telephone, email or via the website. This policy does not cover the practices of third parties that may provide personal information about ICONIC21.

If you would like to exercise your rights or in case you would like to receive additional information regarding CCTV personal data processing please contact us as indicated within this Policy.

1. Use of Your Personal Data 

ICONIC21 may use Personal Data for the following main purposes:

1. i) To provide and maintain our Service, including to monitor the usage of our Service.
2. ii) For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

iii) To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

1. iv) To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
2. v) To manage Your requests: To attend and manage Your requests to Us.
3. vi) For other purposes: We may use Your information for other purposes, such as but lot limited to data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

vii) To analyze and improve our Services and communications.

viii) To ensure security and manage access to our premises, IT and communication systems, online platforms, websites and other systems.

1. ix) To monitor and evaluate compliance with our policies and standards.

We expressly state that we do not collect or process sensitive personal data included by the General Data Protection Regulation within special categories of personal data. We also do not collect or process personal data of minors under the age of 21.

1. Legal Grounds for Processing Activities

In accordance with Article 6(1) of the GDPR, ICONIC21 processes personal data based on the following legal grounds:

1. a) the existence of a contract (service agreements, purchases, invoices, delivery notes or other documents with contractual value);
2. b) the existence of a legal obligation of a commercial or legal nature associated with certain activities (Labor Code, accounting and commercial legislation);
3. c) processing is necessary for the purposes of our legitimate interests in providing high-quality solutions and services, except where such interests are overridden by your interests or fundamental rights and freedoms;
4. d) the existence of informed, freely given consent related to the processing of personal data for direct communication activities or for any other processing activity for which no other legal ground applies.
5. Sharing your personal data

ICONIC21 may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to contact You.

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

With Your consent: We may disclose Your personal information for any other purpose with Your consent.

1. Retention of Your Personal Data 

ICONIC21 will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

1. Transfer of Your Personal Data 

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

ICONIC21 will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

1. Your rights 

You have several rights towards your personal data: to request access, rectify, erase, object, restrict personal data processing, withdraw consent if given and transfer your personal data. In addition, you have the right to contact Data Protection Supervisory authority in the country where you are located.

We will respond to all individual requests wishing to exercise their data protection rights. We may request to verify your identity or ask for additional information in order to help us respond efficiently to your request and to protect personal data from unauthorized disclosure.

In case you would like to exercise your rights related to our developed games, we kindly ask you to contact the Casino you played with, as we do not process information of players by which the person can be identified directly. This action is done by online casinos as they are Data Controllers of the players personal data.

You also have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may exercise your rights at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

If you wish to exercise your data protection rights, please contact us as stated in the preamble of this Policy.

1. Disclosure of Your Personal Data 
2. i) Business Transactions

If ICONIC21 is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

1. ii) Law enforcement

Under certain circumstances, ICONIC21 may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

iii) Other legal requirements

ICONIC21 may disclose Your Personal Data in the good faith belief that such action is necessary to:

1. iv) Comply with a legal obligation
2. v) Protect and defend the rights or property of ICONIC21
3. vi) Prevent or investigate possible wrongdoing in connection with the Service

vii) Protect the personal safety of Users of the Service or the public

viii) Protect against legal liability

1. Security of Your Personal Data 

We ensure that all necessary appropriate security measures are in place to keep and process your personal data securely. In support of this commitment, we have implemented appropriate technical, physical, and organizational measures to protect your personal data against unauthorized or accidental destruction, alteration or disclosure, misuse, damage, theft or accidental loss, or unauthorized access.

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

1. Children’s Privacy 

Our Service does not address anyone under the age of 21. We do not knowingly collect personally identifiable information from anyone under the age of 21. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 21 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

1. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

1. Changes to this Privacy Policy 

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.