Data protection and privacy

1) Why it's needed (iGaming context/fintech)

In iGaming and fintech, PII/findata, biometrics (selfie-liveness), behavioral and payment signals are processed. Privacy violations hit licenses, PSP partnerships, SEO/reputation and financial results. The goal is to ensure legal, safe and transparent processing without killing UX and conversion.

2) Legal principles and roles

Basic principles: legality, fairness and transparency; goal limitation; minimization; accuracy; storage restriction; integrity and confidentiality; accountability.

• Board/Exec: risk appetite, policy approval, resources.
• DPO (Data Protection Officer): independent oversight, DPIA/DSR, consultation.
• Security (CISO): technical controls, incidents, activity log, DLP.
• Engineering/Data: "privacy by design/default" architecture, data catalog.
• Compliance/Legal: legal grounds, contracts, cross-border transfers.
• Operations/Support: processing of requests of subjects and procedures.

3) Data categories and legal grounds

Categories: identification (full name, DOB), contact, payment (tokens), biometrics (selfie/face-template), behavioral (sessions, rates), technical (IP/UA/Device), KYC/AML artifacts, logs, as well as special categories - only if strictly necessary.

• Contract: account, payments, payments, transaction notifications.
• Law (legal obligation): AML/KYC, accounting, tax duties, age checks.
• Legitimate interest (LIA): anti-fraud, security, UX improvement (when testing the balance of interests).
• Consent: marketing mailings, optional cookies, biometrics in a number of jurisdictions.
• Document the selection of the reference in the processing register.

4) Privacy by Design / by Default

Design: before launching features, DPIA (privacy impact assessment), threat modeling (STRIDE/LINDDUN) is carried out.
Default: minimum field sets, disabled optional trackers, closed accesses.
Isolation of environments: dev/stage without real PD (or with masking/synthetics).
Scheme versioning: migrations with migration plans for PD.

5) Data architecture and security

• Zone A (Transactional PII): tokenized payments, KYC artifacts; access - strictly by RBAC/ABAC.
• Zone B (Analytics Pseudonymized): aliases/hashes, aggregated events; prohibition of direct de-identification.
• Zone C (Anonymous BI): anonymous aggregates for reporting/ML training.

• Encryption in transit (TLS 1. 2 +) and at rest (AES-256), keys in HSM/KMS; key rotation.
• Pseudonymization (stable tokens) and anonymization (diffusivity, k-anonymity for publications/studies).
• Secret management: vault, zero-trust access, single-use tokens.
• Logs and audits: unchangeable WORM storage of critical events, traces; control of mass discharges.
• DLP: unloading rules, watermarks, "exfiltration" monitoring.
• Endpoint/Access: SSO/MFA, Just-in-Time access, temporary roles, geo/IP restrictions.
• Reliability: encrypted backups, recovery tests, minimizing blast-radius.

6) DPIA/DTIA: When and How

DPIA is required for high risk (large-scale processing, profiling for RG/fraud, biometrics, new sources).

1. Description of the purpose/processing and categories of PD.

2. Basis and necessity/proportionality (minimization, limitations).

3. Assessment of risks for the rights/freedoms of subjects, veterans by probability/influence.

4. Mitigation measures (tech/org), residual risk, action plan.

DTIA (cross-border transmissions): analysis of the recipient country's law, contractual and those measures (encryption, SCC/analogue), state risk.

7) Data Subject Rights (DSR)

Requests: access, correction, deletion, restriction, portability, objection/refusal of marketing.

• Verify applicant (no leakage).
• Perform on time (usually 30 days) with logging solutions.
• Exceptions: regulatory/contractual responsibilities (e.g. storage of AML artifacts).
• Automated solutions: provide meaningful information about logic (explainability) and the right to review by a person.

8) Retention and disposition

Retention matrix: for each PD category - purpose, term, reason, method of removal/anonymization.
AML/KYC/finance often requires ≥5 years after the end of the relationship - fix local deadlines.
Deletion pipeline: marked deletion → delayed irrecoverable cleaning → deletion report; cascade on backups by term.

9) Cookie/SDK/trackers and marketing

Need a granular consent panel (mandatory/functional/analytical/marketing).
Clear purpose of Cookie/SDK, lifetime, provider, transfer to third parties.
Do-Not-Track/Opt-out for advertising; respect local requirements (banner, registry).
Server analytics/aggregation - prioritized to minimize leaks.

10) Cross-border transfers

Legal instruments: contractual provisions (SCC/analogue), corporate rules, local mechanisms.
Technical measures: encryption before transmission, restricting access to keys in the country of origin, minimizing fields.
Assessment of government access risks: DTIA + additional measures (split-key, client encryption where possible).

11) Vendor and Third Party Management

Vendor audit: licenses/certifications, SOC/ISAE, incidents, processing geography.
DPA/processing acts: purpose, PD categories, deadlines, sub-processors, breach notifications ≤72 h, right to audit.
Technical control: encryption, RBAC, logging, client isolation, fault tolerance tests.
Continuous monitoring: annual review, event review with changes.

12) Incidents and Notifications

1. Detection and classification (PII scope/criticality).

2. Isolation, forensics, elimination, recovery.

3. Risk assessment for subjects, decision to notify the regulator and users.

4. Communications (without disclosing superfluous), coordination with PSP/partners.

5. Post-sea and update controls/policies.

SLO: primary assessment ≤24 h; notification of the regulator/affected within the terms of local law; retest vulnerability.

13) Metrics and quality control

DSR SLA: percentage of requests closed on time, average response time.

Data Minimization Index: average number of fields/events per feature; Percentage of optional trackers that are turned off

Access Violations: number/trend of unauthorized accesses/uploads.
Encryption Coverage:% of tables/buckets/backups with encryption and key rotation.
Incident MTTR/MTTD: detection/response time, repeatability.
Vendor Compliance: passing reviews, closing comments.
Retention Adherence - the proportion of records deleted by date.

14) Policies and documentation (skeleton for wiki)

1. Data protection policy (principles, roles, definitions).
2. Register of processing operations (goals, grounds, categories).
3. DPIA/DTIA procedure (templates, triggers).
4. Entity Rights Policy (DSR) (streams, SLAs, templates).
5. Retention and deletion policy (matrix, processes).
6. Cookie/SDK policy (consent panel, registry).
7. Incident and Notification Policy (RACI, deadlines, forms).
8. Vendor management and DPA (evaluation checklists, templates).
9. Security baseline (encryption, accesses, logs, DLP).
10. Training and awareness (programs, tests).

15) Checklists (operating)

• DPIA performed, risk and measures approved by DPO.
• Objectives/grounds defined, registry updated.
• Minimized fields, PII in a separate zone, masking in dev/stage.
• Cookies/SDKs are considered, banner is configured, Opt-in/Opt-out options are checked.
• Logs/metrics/alerts are configured, retention and deletion are registered.

• Access Review (RBAC/ABAC), revoking "forgotten" rights.
• Backup recovery test.
• DPA and sub-processor validation, SDK inventory.
• Audit retention and actual deletions.
• IR-plan training (table-top).

• Applicant verification.
• Collecting data from the system registry; red lines for AML/legal exemptions.
• Response and logging on time; communication templates.

16) Ethics, Transparency and UX

Clear notifications about goals/tracking, "layer" privacy policy (in short + details).
Granular consent switches, easy rejection of marketing.
Explainability for automated solutions (fraud rates/RG): reasons, right to review.
Avoid hidden "dark patterns"; Do not use sensitive characteristics for targeting.

17) Implementation Roadmap

1. Inventory of data and systems; map of PD flows.
2. DPO assignment, policy approval and RACI.
3. Directory of processing operations and bases; start the DPIA/DTIA loop.
4. Separation of data zones, encryption/keys, DLP/logs, retention pipeline.
5. Consent panel, cookie/SDK registry, server analytics.
6. Vendor Review and DPA; sub-processor monitoring.
7. IR playbook, training, metrics and regular Board reporting.

Result

Reliable data protection is not only encryption: it is a system for managing the PD lifecycle - from goals and foundations to minimization, secure architecture, DPIA/DTIA, subject rights, incidents and metrics. By building privacy "by default" and process discipline, you will comply with the requirements of regulators and payment partners, keep the conversion and strengthen the confidence of players.