1. Introduction and General information
GG.bet (also referred to as “Website”) is managed by Brivio Limited (hereinafter referred as “Brivio”, “Company”, “us”, “we”, “our”) All gambling services are licensed by Invicta Networks N.V. (License No. 8048/JAZ).
Company is committed to the highest standards of protecting and respecting your privacy when you use the Website and the services we are providing through it.
Data controllers for the Website are Brivio Limited incorporated under the laws of the Republic of Cyprus, registered address is 12A, Lekorpouzier, Flat/Office 102, Limassol, Cyprus and Invicta Networks N.V. registered under the laws of Curacao, registered address Heelsumstraat 51 E-Commerce Park, Willemstad, Curacao.
For any other requests do not hesitate to contact our Customer Support at email@example.com
2. What types of data do we collect?
We collect various types of data when you interact with us and use our services. Most of the time, data is directly provided by you – for example when you register for the first time. Other cases would include third parties or publicly available sources sharing information about you.
Information you provide to us
· Name, email address, telephone or mobile phone number, postal address, date of birth and gender;
· Documents required to fulfill our obligations under AML/CFT legislation such as photos of you and your documents and proof of address, other sufficient evidence (to verify your person);
· Financial information (credit card numbers, bank account data, other payment data where applicable);
· Login details, which include password and username.
While you are using our services:
· Information regarding how you interact and use products available at the Website;
· Communications with our personnel, for example calls, emails and messages via our live chat;
· Data regarding your location, traffic information, IP address;
· Operating system and platform of the devices you used to visit the Website, browser type and version, browser language, time zone setting;
· Marketing information which indicates whether you would like to receive marketing advertisement from us or our partners;
· We may also access public records made by you, for example, social media.
We may use Aggregated data, for example statistical or demographic data for any purpose. Such data may be derived from the data you provided to us, however, such data is held anonymized, thus disallowing anyone to identify you and as a result, such data is not considered to be personal. This data is used for example to see how many users of specific age use a certain feature on the Website.
On some rare occasions if you decide to self-exclude yourself from using the services on the Website we will grant you this right and keep such request. Such data is not considered to be data that relates to health.
3. How do we use collected data?
Collecting the above-mentioned data is crucial in order to provide you with our services. Additionally, such data is used to personalize and improve the usage of our services and reach out to you with important information from time to time.
Legislation requires us to identify the lawful basis on which we process the data we acquired from you. There is no unified way to describe the lawful basis of our processing, thus they are split in the following subsection.
Firstly, we are required to execute the contract with you. By using the Website, you have agreed to our Terms and Conditions and other Policies (collectively referred as “the Terms”), which are a contract setting our mutual rights and obligations while using the Website.
· We rely on the contract to register your account and provide you with betting and gambling services, other activities or online content;
· From time to time you may need to reset a password receive a service message about maintenance or a notification about the update about the Terms or other situations which we categorize as “Website administrating purposes”;
· To process your transactions.
Secondly, gambling and betting is heavily regulated activity and thus, we are obliged to follow the legal obligations set for the providers by the regulators and other authorities. In order to fulfill those obligations, we rely on the data we acquired from you.
This for example includes:
· To make sure we offer our services to eligible persons (for example, over 18 years old, who did not self-exclude themselves from gambling/betting activities, coming from a location where we have the right to provide our services under the license granted to us, etc.);
· Crime detection, prevention, and prosecution (this is why specific verification procedures are in place and you are obliged to follow them);
· To verify your identity and establish the source of funds in any transaction (we are required to prevent usage of our services for the purposes of money laundering and other criminal activities);
· To carry out appropriate anti-fraud checks;
· To assess and manage any potential risks and prevent problem gambling.
Thirdly, we have our legitimate interests in the processing as set below. We shall not process any data if our interests are overridden by your rights, freedoms or interests. This includes the following:
a. To improve our services and products
· To make your usage of the Website user-friendly;
· For testing the new products or upgrading already existing ones;
· In order to analyze the effectiveness of our marketing measures
b. To make your experience personal
· For instance, we could use the history of games you played to provide a personalized recommendations of games that you might like;
· Or we can get the geolocation data to provide you with the services in your native language, if we have such possibility;
c. To be able to detect and prevent violation of our Terms.
d. Simply, to contact you.
· To respond to the issues, you may have from time to time while using the Website via email, live chat, or by phone;
· From time to time you may be invited to fill a survey about your experience on the Website. Such activities are not mandatory and you may decline the request. Such decline will not in any way affect your ability to use the Website.
Fourthly, under your explicit consent.
If you provided your consent to receive relevant offers and news about the products by different ways of communication, for example, email, sms, phone calls, etc. we will send such information.
The consent is given at the moment of registration, and can be withdrawn anytime by phone or in writing. As a result, you will not receive any related marketing material.
4. Who we share your personal data with
During the course of business, we are required to share data including your personal data to third parties. In this cases we make sure that such third party entities have sufficient level of data protection and security and that eligible level of safeguards are used during the transfer.
5. How we store your personal data
We store our data within European Economic Area. However, some of our partners who provide us with services essential to our ability to offer you our gambling/betting products, for example software, banking and payment service, etc. may be located outside EEA.
We ensure there are appropriate contractual controls over any third party that helps us process your data, which ensures that your rights are upheld and your data is secure.
6. How long do we keep your personal data?
We are required to comply with our legal, financial and regulatory requirements, thus we need to keep your data for the minimum amount of time required to fulfil such obligations. When such time has elapsed and in case we do not have any other legitimate reason to maintain your data, such data will be pseudonymised.
Usually your data will be kept for 10 years after you cease being our customer, beginning from the date you instruct us to close your account.
7. Security of the data
We are committed to protect the data entrusted to us. We use all reasonable measures to ensure that all information collected while you are using the Website is treated securely and in line with this Policy and applicable legislation in the field.
8. Your rights
Subject to applicable legislation you are entitled to exercise specific rights in regard to your personal information. You can exercise each of this rights by contacting our DPO or Customer Service by naming the right you wish to exercise and by stating a reason for such request, if applicable.
1) Right to access
You have the right to know whether we are processing a personal data about you, and obtain a copy of such data if we indeed process it. Please keep in mind that we process various types of data and disclosure of such data to the person to whom such data does not belong may cause harm to a data subject. Thus you may be required to provide additional proof in order for us to be able to identify a person making a request.
2) Right to rectify the information we have about you
You have the right to request that information that we hold about you to be changed if the data is incorrect or not up to date. For example, you got married and changed your surname, or your address changed.
3) Right to delete the data we hold about you (“Right to be forgotten”)
You have the right to ask us to delete the data we hold about you if there is no good reason for us to keep processing it.
This right is not absolute, since we have our legal obligations to retain personal information of the users for anti-money laundering, crime prevention, etc. purposes. If we cannot comply with your request, we will let you know about it.
4) Right to restrict processing
You may ask us to stop processing data for particular purpose or as a whole. We will still store your data, but we will not use it for our particular purposes, if you have reasonable grounds to ask for it. Note that this right is not absolute and in certain situations you may be declined in your request.
5) Right to data portability
We will provide you with the copy of data in easily understandable form, so you can use such information for your purposes. We may need additional verification from the person who is making such request due to the reasons described above.
6) Right to object
You may object to our processing of your personal data for marketing purposes, or other situations where you believe we have no legal ground to process information
7) Right to withdraw consent
If we rely on your consent to process your data, you have the right to withdraw such consent anytime.
We heavily rely on your data to provide you with the best experience while you are using the Website. If you decide to restrict the processing of your data in any way, it may result in some functions and features of the Website to be unavailable to you.
Cookies are small text files containing information that are downloaded and stored on your device when you visit the Website. They are used by most of the websites to improve your experience and to ensure that functions of the website are delivered and used in more effective manner.
Cookies may perform various functions. Some are session related, they are downloaded for the period of time when you use a particular site. They allow you to navigate between pages more efficiently, and let the website remember the choices you made. Others are constant cookies that are stored on your device and let the website remember you as a returning visitor.
You agree that we may, from time to time, place cookies on your device to save some information (for example, name, password technical information, IP address) in order to identify you as a user.
You may amend your browser settings in order to block some or all cookies. In order to do so, visit the Settings section of your browser and follow it's instructions. Blocking of some cookies may make some of the Website functions unavailable to you.
The Website uses following cookies:
Remembers the language of your preference
Holds the session name of the current session
Cookie that is used in order to check that user is authorized
Hold the security token
Google analytics cookies, you can opt out from using this Cookies by clicking on the link http://tools.google.com/dlpage/gaoptout and following the instructions
Yandex Metrica cookies, you can opt out from using this Cookies by clicking on the link https://yandex.com/support/metrica/general/opt-out.html and following the instruction
We use third-party cookies (such as Google Analytics and Yandex Metrica) to get information about user interaction with the Website in order to develop and improve the customer’s expirience and provide optimised services
You can find additional information about cookies at www.allaboutcookies.org.
10. The right to lodge a complaint
If you believe we mishandled your data, you can complain to our Data Protection Officer by emailing firstname.lastname@example.org.
If you are not satisfied with a response or believe that we are processing your data not in the accordance with the applicable legislation you can lodge a complaint to Commissioner for the Protection of Personal Data in Cyprus or with your national data protection regulator.
11. Changes to the Policy
If there are substantial changes, you will be notified by email or other means of communication.
DATE 24 May 2018