Privacy Policy

A. Introduction

CORTEX AK LIMITED 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 CORTEX AK LIMITED 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 (as specified herein) 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.

CORTEX AK LIMITED is an international group of companies which, with respect to corporate website operations, may act as controllers (jointly with other entities of the CORTEX AK LIMITED). For this website, the primary controller is:

CORTEX AK LIMITED
83 Ducie Street Manchester England M1 2JQ

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

Unless communicated otherwise by the relevant B2C licensed online gambling operators, who are EM’s own clients, if you are a customer to any of such operators, please address your queries relating to Data Protection and Privacy directly to them. In fact, the B2C operators act as controllers toward your personal data determining both the means and purposes of the processing activities involving your information. In such instances, CORTEX AK LIMITED, as a B2B online gambling 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.

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. 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 a 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;

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.

iii. “Website users”

As it is true for most of the 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, and gather broad demographic information that assists us in identifying visitor preferences.

CORTEX AK LIMITED 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 perform our 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 such third parties are as follows:

Marketing providers to perform certain marketing activities on our behalf and only with your consent;

IT/system support services;

Third parties assisting in investigations (such as AML investigations) for the purpose of detecting and preventing fraud or other security or technical problems;

Cloud services providers for provision of cloud-based services such as storage or hosting certain software;

Professional advisors acting as processors or joint controllers including lawyers, auditors and insurers who provide consultancy;

Service providers for the purpose of data analytics;

Service providers enabling communication with you from a technical standpoint (e.g. via email, chat).

You can always contact us to receive the applicable 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 insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Policy.

Kindly note the CORTEX AK LIMITED 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 GDPR.

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:

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

prevent processing likely to cause damage or distress;

prevent processing for purposes of direct marketing;

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

dispute an automated process of your personal data;

sue for compensation if you suffer any damage by any contravention of the applicable law;

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

request the supervisory authority to assess whether any provision of applicable law has been contravened;

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

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 to info@cortexak.com. 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.

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

info@cortexak.com

G. Filing a complaint with the supervisory authority

You have the right to make a complaint at any time to a supervisory authority:

The National Supervisory Authority for Personal Data Processing – Information Commissioner’s Office (ICO)

https://ico.org.uk

0303 123 1113

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF  

H. Validity

This Privacy Policy was lastly updated on 1th February 2025.

Cookies Policy

The Cookies Policy provides the conditions, procedures, and purposes of the use and storage of cookies by us.

Storage of Cookies

We make use of Cookies in order for the Website to function properly. Cookies are small bit record-keeping information that we store in Your computer/other equipment in order to associate and identify activity with You. Cookies do not include names and/or email addresses and/or other personal data; in fact, they typically contain anonymous information which is required for the better functionality of the Website.

Any use of the Website means that you are acquainted, and you agree with this Cookies Policy and unconditionally accept all its terms.

Usage of Cookies

We use cookies on this website to:

recognise you whenever you visit this website

count the number of times you have visited the website including when your first and last visit occurred

take note of the time you enter/stay on the site

track where you came from, including the search engine you use, the link you clicked on, the keyword you used and where in the world you are when you access the site

The information we obtain from our use of cookies will not contain your personal data.

Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other information, this will not usually identify you personally.

Other types of Cookies or third-party tools

Some of the services listed below collect statistics in aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.

Our website employs the use the various third-party services. Through the use of our website, these services may place anonymous cookies on the Visitor’s browser and may send their own cookies to the Visitor’s cookie file.

We use the following third-party services:

Google Analytics and Google Analytics tracking codes

Google AdWords and Google AdWords Conversion Tag

Facebook Pixel Code

LinkedIn Insight Tag

Twitter Universal Website Tag Code

If any third party operated services are listed among the tools above, these may be used to track Users’ browsing habits in addition to the information specified herein and without the Owner’s knowledge. In order to obtain complete information, consult the privacy policy for the respective third-party services listed in this document.

Managing the installation of Cookies

In addition to what is specified in this document, the user can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing them.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.

In the case of services provided by third parties, users can exercise their right to withdraw from the tracking activity by utilizing the information provided in the third party’s privacy policy, by clicking the opt-out link – if provided – or by contacting the third party.

Users can find information about how to manage Cookies in their browser by visiting Google Chrome, Mozilla Firefox, Apple Safari or Microsoft Windows Explorer websites. For further information about cookies and how to disable them you can visit www.aboutcookies.org or www.allaboutcookies.org

Information Security Policy

Information Security Objectives

CORTEX AK LIMITED objective of managing information security is to ensure its core and supporting business operations continue to operate with minimal disruptions.

CORTEX AK LIMITED shall ensure that all information that is used or stored by CORTEX AK LIMITED has absolute integrity and availability. CORTEX AK LIMITED shall guarantee that all relevant information is managed and stored with appropriate confidentiality procedures in place

Information Security Policy

The purpose of this Policy is to protect the organization’s information assets from all threats, whether internal or external, deliberate or accidental.

The CEO of CORTEX AK LIMITED has approved this Information Security Management System [ISMS] Policy.

It is the Policy of the organization to ensure that:

Information should be made available with minimal disruption to staff and the public as required by the business process. This will ensure that information and vital services are available to users when and where they need them;

The integrity of this information will be maintained. This means safeguarding the accuracy and completeness of information by protecting against unauthorized modification;

Confidentiality of information not limited to research, third parties, personal and electronic communications data will be assured. This will ensure the protection of valuable or sensitive information from unauthorized disclosure or unavoidable interruptions;

Regulatory and legislative requirements will be met. This will ensure that the organization remains compliant to relevant business, national and international laws;

A Business Continuity Management Framework shall be made available and Business Continuity Plans will be produced to counteract interruptions to business activities and to protect critical business processes from the effects of major failures or disasters. Business Continuity Plans are to be maintained and tested;

Information security education, awareness and training will be made available to staff and relevant external parties;

All breaches of information security, actual or suspected, will be reported to, and investigated by the relevant authorities not limited to Incident Response process;

Appropriate access control will be maintained and information is protected against unauthorized access.

ISMS Risks

Information security within CORTEX AK LIMITED is managed through the Risk Management Framework.

Policies, Procedures and Guidelines not limited to Information Security will be made available in both hardcopy and online format through an intranet system to support the ISMS Policy

Responsibilities

It is the responsibility of each member of staff to adhere to the ISMS Policy. All managers are directly responsible for implementing the ISMS Policy within their units, and for adherence by their staff.

The Management Representative is the Chief Security Officer and has direct responsibility for designing, planning, implementing and operating the ISMS within CORTEX AK LIMITED. He also is involved in writing and/or managing the development of relevant policies, procedures and guidelines not limited to information security

Internal Audit Unit has direct responsibility for verifying the effectiveness of the ISMS Policy.

This ISMS Policy is subject to review when significant changes occur in the organization.

Legal Disclaimer

CORTEX AK LIMITED does not guarantee the accurateness or validity of the content of this website. The information was provided as a guideline and should not at any time be interpreted as legal advice, it is therefore being given without warranty of any kind. We suggest that any information you derive from this website should be verified by your legal advisor. CORTEX AK LIMITED does not accept any responsibility or liability for the accuracy, content, completeness, legality, or reliability of the information contained on this website.

CORTEX AK LIMITED shall not be liable for any loss or damage of whatever nature which may arise as a result of your use of this website or the information found within it. Furthermore we shall at no time accept liability for any damage of whatever nature arising from the use of third party websites which are in any way linked to our website nor shall we be held responsible for the collection and use of personal information by any of these third party websites.

We cannot guarantee that the website is free from computer viruses or anything else which has destructive properties.