Effective Date: 28th June, 2018.



This Privacy Policy (“Policy”) outlines what personal data is collected by the Group, as defined below (“Company”, “we”, “us” or “our”), how we use such personal information, the choices you have with respect to such personal information, and other important information.

We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our services or as otherwise described in this Policy.



The Group includes the following companies all of which have an address at 601-701 Europort, Gibraltar:

• Virtual Global Digital Services Limited ;

• 888 UK Limited; 

• Virtual Digital Services Limited; 

• Sparkware Technologies SRL; 

• Random Logic Ltd.



Individuals that directly volunteer data: This Policy applies to Company's collection, use, and disclosure of the personal information of visitors to our website and any individual that directly volunteers information and (including any subdomains; the "Website"), such as job applicants and recruits (“Job Applicants”).

Visitors: In addition, when someone visits the Website (“Visitor(s)”), we collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the site. We do not make any attempt to find out the identities of those visitors to our website. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.



We do not knowingly collect or solicit personal information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”).  By accessing, using or interacting with our Website, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected personal information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.



Website Visitors and Job Applicants:

• Name, email address, telephone number, your resume (including any information available therein) and any other information you choose to provide. We ask for and—at your option—collect your contact data (such as name and email address) from you when you submit web forms on our Websites. We also may ask you to submit such personal information if you choose to use interactive features of the Websites, or otherwise communicating with us. 

• Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Websites, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.

• Cookies and Other Tracking Technologies. We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Websites and assisting us in our marketing efforts. You can control how websites use cookies by configuring your browser's privacy settings (please refer to your browser's help function to learn more about cookie controls). Note that if you disable cookies entirely, the Website may not function properly. We may also use cookies and similar technologies to provide you advertising on third-party sites based upon your browsing activities and interests. To learn more, please visit our Cookie Policy.

• When you visit or access our Websites (including when you interact or engage with our Embedded Items), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags and other technologies ("Tracking Technologies").

• These Tracking Technologies allow us and third parties to automatically collect information about you (such as your IP address, device unique identifiers and your online behavior), in order to enhance your navigation on our Websites, improve our Websites’ performance and customize your experience on our Websites, as well as for behavioral advertising and fraud prevention purposes. We also use this information to collect statistics about the usage of our Websites, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners. 



If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such information under applicable laws. 

In some cases, we may need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us through the contact details available below.



Company only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized.

 When you apply for a role with company: 

• We use the personal information that you submit to us on our recruitment portal to decide on your suitability for the role that you have applied for.

• If you are successful and accept the role we will use your personal information provided during the online application process to carry out pre-employment screening (further details of which will be provided to you at the time) and this information will also form part of your employment file.

We also use your personal information:

• To provide you with any other information, products and services that you request from us;

• To ensure that content from our Website is presented in the most effective manner for you and for your device and to fulfill other business purposes, such as product development and website administration;

• To allow you to participate in interactive features on our Website, when you choose to do so;

• For records keeping, statistical analysis, internal reporting, analytics and research purposes;

• To ensure data security and to provide you with access to any secure areas of our Website;

• To investigate any complaint you make;

• To train our staff;

• To provide evidence in any dispute or anticipated dispute between you and us;

• To support the effective operation of our Website and to make improvements to it;

• For business and disaster recovery, document retention/ storage, IT service continuity (e.g back-ups); and

• To protect the rights, property, and/ or safety of the company, our customers, and our personnel.

We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on a Company sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers.




We share your personal information with other companies for the purposes of:

• Potential recruitment opportunities within the company.

• Marketing and business winning purposes, either between the various business sectors or geographies, so that the most suitable people can follow-up on the opportunities;

• Internal and external audits;

• Data hosting; and

We also share your personal information with:

• Third party provider(s) who provide the following types of services to us: website hosting, support and maintenance, and pre-employment screening;

• Our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;

• Investors and other relevant third parties in in the event of an actual or potential sale or other corporate transaction related to an entity in the company;

• Relevant third parties for the purposes of doing what a court, regulator or government or crime prevention agency (including the police) requires us to do,  for example, complying with a search warrant or court order or acting as required or permitted by applicable laws or regulation; and

• Any other third parties, if authorized by you to do so in relation to a specific disclosure.


 The performance of services by a third party service provider may be subject to a separate privacy statement provided to you by such third party. You should read this statement carefully.



Please note that our businesses, as well as our trusted partners and service providers, are located around the world. Any information that we collect (including your personal information) is stored and processed in various jurisdictions around the world (including in the United States), for the purposes detailed in this Policy. Please note that some data recipients may be located outside the European Economic Area (the “EEA”). In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Whenever Company shares personal information originating in the EEA or Switzerland with a Company entity outside the EEA or Switzerland, it will do so on the basis of the EU standard contractual clauses or the Privacy Shield Framework.



Visitors and Job Applicants: If you reside in the EU (or in other jurisdiction that affords you with the below rights), you may request to:

• Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with certain supplementary information.

• Receive personal information you directly volunteer to us in a structured, commonly used and machine-readable format.

• Request rectification of your personal information that is in our control.

• Request erasure of your personal information.

• Object to the processing of personal information by us.

• Request to restrict processing of your personal information by us.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You also have a right to lodge a complaint with a supervisory authority



We will retain your personal information for as long as necessary to operate our Website and for the purposes listed above. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.



We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information.

While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Website, and you do so at your own risk. 



We reserve the right to change this Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Policy through our Website or we will send you an e-mail regarding such changes to the e-mail address that you volunteered (if you have volunteered it). Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Policy are effective as of the stated “Last Updated” date, and your continued use of the Websites after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.



We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business.



If you have any general questions about this Policy, please contact us by the following contact data:

Attn: Data Protection Officer

601-701 Europort, Gibraltar

By Emails