Privacy & Cookies Policy

Domain: swissonlinegambling.com
Last updated: 2025

This Policy explains how MORNING STAR (“we”, “us”, “our” or “the Company”) processes the personal data of visitors on swissonlinegambling.com in accordance with:

revised Swiss Federal Act on Data Protection (revDSG) – for users in Switzerland
EU General Data Protection Regulation (GDPR) – where it applies to EU/EEA users

1. Data Controller and Representatives

Data Controller

MORNING STAR
Laulii Vaimauga Sasae
A'ana, 9617, Samoa
Email (privacy / opt-out): info@swissonlinegambling.com

1.1 Swiss Representative (revDSG Art. 14)

For users in Switzerland, we have appointed the following representative under Art. 14 revDSG:

Mediaconsulting Fohrmann
Hauptstrasse 163
4466 Ormalingen
Switzerland
Email: mediaconsulting@swissonlinegambling.com

The Swiss representative acts as a point of contact for Swiss data subjects and for the Swiss Federal Data Protection and Information Commissioner (FDPIC) in connection with our processing of personal data of individuals in Switzerland. The representative does not become a separate controller but forwards and supports handling of requests directed to the controller MORNING STAR.

1.2 EU Representative (Art. 27 GDPR)

For users in the EU/EEA (where GDPR applies), our representative under Art. 27 GDPR is:

Gustum
C/O Niels Bo Lund
Rundholtsvej 28, st. 3
Denmark

2. What Personal Data We Collect

Technical and log data: IP address (shortened where possible), date and time of access, requested pages, referrer URL, user-agent (browser, operating system, device type), basic geo-region (e.g. country), and technical identifiers generated by our security and hosting services.
Cookies and similar technologies: identifiers associated with your browser or device, such as consent-status cookies, security cookies and affiliate tracking identifiers (see Section 4).
Contact data: if you contact us by email, we process your email address and any other information you include in your message.

Sensitive data

We do not request or intend to collect sensitive data (e.g. health data, religious beliefs, political opinions, trade union membership, biometric data, information on criminal convictions), nor do we require financial data or government-issued IDs on this Website.

Please do not send such information to us via email or forms. If we become aware that we have inadvertently received sensitive data, we will delete or sufficiently restrict it and will not use it for any profiling or decision-making.

3. Purposes of Processing and Applicable Legal Frameworks

3.1 Purposes

We process personal data only to the extent necessary for the following purposes:

Operating and securing the Website – delivering content, ensuring availability, load balancing, preventing misuse and attacks.
Basic analytics – using Cloudflare Web Analytics to understand aggregated visits, page views and technical performance (see Sections 4 and 5).
Affiliate marketing – tracking when a user clicks an affiliate link (e.g. to Swiss4Win) via Gambling-Affiliation.com in order to attribute commissions.
Communication – answering inquiries that you send to us by email.
Compliance and defence of legal claims – logging access for security, preventing abuse and complying with legal retention requirements.

3.2 Processing under Swiss law (revDSG)

For users in Switzerland, our processing must comply with the principles of revDSG, in particular:

Lawfulness and proportionality – we process data only for the purposes listed above and only to the extent necessary.
Transparency – this Policy explains what data is processed, for what purposes, who receives it and where it is processed.
Purpose limitation – data is not used for purposes incompatible with those described here.
Data security – we implement appropriate technical and organisational measures to protect your data.
Consent for non-essential technologies – non-essential analytics and affiliate tracking cookies or similar technologies are used only with your prior consent via the cookie banner.

3.3 Legal bases for EU/EEA users (GDPR)

Where the GDPR applies (e.g. to certain EU/EEA users), we rely on the following legal bases under Art. 6 GDPR:

Art. 6(1)(a) – Consent: for non-essential analytics and affiliate tracking cookies or similar technologies, after you have actively consented via our cookie banner.
Art. 6(1)(f) – Legitimate interests: for basic server logs, security and abuse prevention, and operation of an affiliate information website, provided your interests and fundamental rights do not override these interests.
Art. 6(1)(c) – Legal obligation: where we are required to retain or disclose certain data (e.g. for regulatory or tax reasons).

4. Cookies and Tracking Technologies

We use cookies and similar technologies to operate this Website and, where you consent, to perform analytics and affiliate tracking. Non-essential cookies or tracking technologies are only used after you provide consent via our cookie banner.

Cookie / Technology	Type	Purpose	Provider	Duration	Consent required?
`cookie_consent_status_swissonlinegambling`	Preference / strictly necessary	Stores whether you accepted or rejected non-essential cookies.	First-party (swissonlinegambling.com)	180 days	No (necessary to remember your choice)
`__cf_bm`	Strictly necessary – security	Helps distinguish human traffic from bots and protects the site from abuse.	Cloudflare, Inc. (USA)	30 minutes	No
`cf_clearance`	Strictly necessary – security	Used by Cloudflare to manage challenge/verification when unusual traffic is detected.	Cloudflare, Inc. (USA)	30 days	No
Cloudflare Web Analytics (no cookie)	Analytics (non-essential)	Privacy-focused measurement based on HTTP request data (e.g. IP, user-agent) to produce aggregated statistics such as page views, referrer and device type. No cross-site tracking or individual user profiles are created for us.	Cloudflare, Inc. (USA)	30 days retention for analytics events in our account	Yes
Gambling-Affiliation click / tracking ID	Affiliate tracking (non-essential)	Records that you clicked an outgoing affiliate link (e.g. to Swiss4Win) so that any registration or play can be attributed to our Website for commission purposes.	Gambling-Affiliation.com (EU/EEA)	Maximum 30 days from the click for this campaign	Yes

You can manage your preferences via our cookie banner and settings, and you can delete cookies manually in your browser at any time. Blocking strictly necessary cookies may affect basic functionality of the Website.

5. Third-Party Recipients and Roles

We do not sell your personal data. We share data only as necessary for the purposes described above:

Cloudflare, Inc. (USA)
Role: Processor and independent controller
We use Cloudflare for content delivery network (CDN), DDoS protection, security and Cloudflare Web Analytics. Cloudflare processes technical data (e.g. IP address, device information, requested URLs) on our instructions to protect and optimise our Website. For certain security logs, Cloudflare also acts as an independent controller under its own privacy notice.
Gambling-Affiliation.com
Role: Independent controller
When you click an affiliate link on our Website, Gambling-Affiliation.com processes click and tracking data (such as timestamp, the fact that the click originated from our site, and a unique click identifier) as part of its affiliate network. Gambling-Affiliation.com is responsible for that processing under its own privacy policy and may share necessary information with the casino operator (e.g. Swiss4Win) for attribution and anti-fraud purposes. We receive only aggregated reports (e.g. number of registrations, total commission) and do not receive your betting history or detailed account data.
Casino operators (e.g. Swiss4Win)
Role: Independent controllers
If you register or play on a casino website, that casino becomes the controller for all data processed on its own website and services. Its own privacy policy and Swiss gambling regulations apply. We do not operate any online casino and do not have access to your player account.
Professional advisors / authorities
Role: Independent controllers
In certain cases we may share data with lawyers, tax advisors, courts, regulators or law enforcement if this is legally required or necessary to establish or defend legal claims.

6. International Data Transfers

As MORNING STAR is based in Samoa and we use service providers in different countries, your personal data may be processed outside Switzerland and the EU/EEA.

In particular, data may be transferred to or processed in:

Samoa – where the controller is established
United States – where Cloudflare, Inc. operates infrastructure and analytics services
EU/EEA countries – where Gambling-Affiliation.com and certain infrastructure may be located

For transfers from Switzerland or the EU/EEA to countries without an adequacy decision (e.g. Samoa, United States), we use appropriate safeguards, in particular:

Standard Contractual Clauses (SCCs) approved by the European Commission or recognised by Switzerland, where applicable;
Technical measures such as TLS encryption in transit and minimisation of the data sent;
Limiting the categories of data transferred to what is strictly necessary (primarily technical and pseudonymous data);
Internal access controls and security measures.

Despite these safeguards, such transfers may still carry a higher risk for your data compared to processing in Switzerland or the EU/EEA (e.g. broader government access powers). By using our Website, you are informed of these risks and the safeguards we implement.

7. Retention Periods

Server logs and security data – normally retained for 30 days, and up to 90 days if needed for security analysis or legal defence.
Cookies and tracking technologies – retained as specified in the table in Section 4 (e.g. 180 days for consent status, 30 days for cf_clearance, maximum 30 days for affiliate cookies).
Contact emails – kept for as long as necessary to handle your inquiry and for a reasonable period (normally up to 12 months) to document our correspondence, unless longer retention is required by law.

8. Your Rights

8.1 Rights under Swiss law (revDSG)

If you are located in Switzerland, you have in particular the following rights under revDSG (subject to legal conditions and exceptions):

Right to information and access to your personal data;
Right to rectification of inaccurate data;
Right to deletion of data where no legal grounds require retention;
Right to object to processing in certain situations, especially where it is based on overriding private interests;
Right to data portability where the legal conditions are met.

You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC):

Website: https://www.edoeb.admin.ch
Swiss Federal Data Protection and Information Commissioner (FDPIC)

8.2 Rights under GDPR (for EU/EEA users where applicable)

Where the GDPR applies, you may have the following rights (subject to conditions and exceptions):

Right of access (Art. 15 GDPR);
Right to rectification (Art. 16 GDPR);
Right to erasure (Art. 17 GDPR);
Right to restriction of processing (Art. 18 GDPR);
Right to data portability (Art. 20 GDPR);
Right to object to processing based on legitimate interests (Art. 21 GDPR);
Right to withdraw consent at any time (Art. 7(3) GDPR);
Right to lodge a complaint with a competent supervisory authority (Art. 77 GDPR).

To exercise any of your rights or to submit a privacy-related request, you can contact us at:
info@swissonlinegambling.com
Swiss users may also contact our Swiss representative listed in Section 1.1.

9. Gambling-Affiliate Transparency

swissonlinegambling.com is a gambling affiliate website. We do not operate an online casino and we do not offer gambling services ourselves. Instead, we promote licensed Swiss casino operators (such as Swiss4Win) via affiliate links.

When you click an affiliate link, Gambling-Affiliation.com and/or the casino operator may record that the visit originated from our Website.
If you later register or play, we may receive a commission. This does not change the price, odds or conditions you receive from the casino.
Our rankings and recommendations may take commercial relationships into account (e.g. higher visibility for partners), but we aim to present only regulated and responsible operators.
We do not have access to your player account, deposit amounts, detailed game history or documents submitted for verification. Such data is processed exclusively by the casino operator as an independent controller under its own privacy policy and under Swiss gambling regulations.

10. Minors and Gambling Regulations

This Website and all offers presented on it are intended for adults only (18+). Under Swiss gambling legislation, licensed casino gambling is restricted to persons who are at least 18 years old, and operators may apply additional checks (e.g. identity verification, exclusion registers).

We do not knowingly target or address persons under 18.
We do not knowingly collect personal data from minors.
If we become aware that personal data of a minor has been provided to us, we will delete it as soon as reasonably possible.
Parents and guardians are strongly advised to protect devices and accounts against use by minors and to educate young people about the risks of gambling.

11. Changes to This Policy

We may update this Privacy & Cookies Policy from time to time, for example if our processing activities change or if legal requirements are updated. The latest version is always available on this page, and the “Last updated” date at the top indicates when it was last revised.