1. The Introduction

This Privacy Policy was made to:

  • Specify how the Company collects, stores and process your data;
  • Specify the Third-Parties, to which the Company may disclose your data;
  • Describe to you the rights you have in the application of your data processing and how you can control this processing;
  • To point out the contact information of the Company and its employee, responsible for the Personal Data Protection.

1.1 Data Controllers (hereinafter the “Website”) is operated by Brivio Limited (hereinafter the “Company”, ‘we”, “us”, “our”) a company registered in the Republic of Cyprus, with its registered address: Office 102, 12A Lekorpouzier, Limassol, Cyprus; Registration number: HE315596, VAT number 10315596B. All the games, offered on the Website, are licensed by Invicta Networks N.V., registered under the laws of Curacao, with its registered address: Heelsumstraat 51 E-Commerce Park, Willemstad, Curacao, Gaming License 8048/JAZ2012-009. Brivio Limited and Invicta Networks N.V. are joint controllers in regard to the processing of your data.

1.2 How can you contact us?

If you have any questions about this Privacy Policy or about the processing of your data by the Company, please, contact our Data Protection Officer (DPO) by email [email protected] You can also send to our DPO any proposals, requests and complaints (if you believe, that we do not process your data lawfully). If your question does not relate to this Privacy Policy, please, contact our Support Team by email [email protected]

1.3 How can you lodge a complaint?

If you believe that the Company processes your data in the manner, which is unlawful or violates your rights, you can lodge a complaint with the Supervisory Authority. You can send your complaint to the supervisory authority, responsible for the data protection in your place of the residence or to send your complaint to the Commissioner for Personal Data Protection of the Republic of Cyprus.

2. Changes to this Policy

The Company may modify or amend this Policy for a number of the reasons. For example, to be compliant with the new legislation in force or to reflect the changes in our business. The latest version of this Privacy Policy will always be published on the Website, alongside with the date of its Entry into force. If the changes are tangible or make a significant change to the process of personal data processing, registered users of the Website will be notified by e-mail or by Interface of the Website. Your continued use of the Website shall constitute the consent with these changes. If you do not agree with these changes, you should stop using the Website.

3. What data about does the Company collect?

We collect different types of data when you use the Website or when you communicate with the Company by agreed means of communication.

3.1 Registration and verification data.

You submit this data when you register on the Website or when you pass the verification:

  • Email address and password;
  • Your name, the address of your residence, your gender and the date of birth;
  • Verification data. It includes, but not limited to copies of your documents (either scan copies or photos), photos of you and other documents, which may be necessary to pass the verification;
  • Payment information. It includes, but not limited to the card number, your banking information or other information, which may be necessary to conduct your payments.

3.2 The data about your experience with the Website and the records of communications with the Company:

  • The records of communications with the employees of the Company. These records include telephone conversations, SMS, emails and communications via Website interface;
  • Information about the status of your subscription to our marketing newsletter;
  • Information on how do you interact with our Website. It includes the number of games you played, the number of your winning and loses;
  • Information on your social networks presence. For example, existence of Facebook, Twitter or Google account (if you opt a registration via social networks);
  • If you opt to exclude yourself from gambling or impose some limits on your gambling, this information shall also be kept in our database. This data is not considered as the data about the health.

3.3 In addition, when you browse the Website, we collect some technical information:

  • The data about your internet-traffic, IP address and, accordingly, your location;
  • The information about the device you use to access the Website, the type of the browser you use and opted language and time zone;
  • The information about the page you visited before getting into the Website.

4. How the Company uses your data?

The specified data is used in the following way:

4.1 To provide you with the services, offered on the Website:

  • To register your account;
  • To provide you with the Website interface and functionality, including the Customer Support, deposits, bets and other functions and the content, which may be necessary to provide you with the best gambling experience;
  • To provide you with the new features and services of the Website. This point includes giving personalized recommendations, and provision of the services, tailored for your interests or preferences;
  • To process your payments.
  • 4.2 To comply with the laws and regulations

    Please note, that due to the nature of our business, the Company is obliged to comply with a number of laws, regulations and policies. It includes data protection legislation, legislation on Anti Money-Laundering and Counter-Terrorist financing, policies of the payment providers and other financial institutions.
    • To be sure, that you use the Website in a lawful manner. For example, we verify that you are at least 18 years old or older and not a compulsive gamer. In addition, we verify, that you are the resident of the Jurisdiction, in which the Company can provide the services, offered of the Website;
    • To detect and prevent crime, fraud and other attempts to use the Company and its property for illegal and dishonest activity;
    • To establish and verify the source of your funds. This procedure applies to users, who are the Politically Exposed Persons, or reside in High-risk jurisdictions, or present significant risk of Money Laundering or Terrorist Financing;
    • To investigate and prevent other risks (financial, legal or reputational);
    • To prevent violation of our Policies (Including Terms and Conditions, This Policy) and policies of our business partners;

    4.3 To communicate with you

    • To communicate with you via phone calls, emails, SMS, chat, messengers and other agreed and opted means of communications;
    • We may ask you to send us a review of your experience of the usage if the Website. This review(s) are facultative and you may ask us not to send requests for these reviews anymore.

    5. Cookies

    Cookies are text files containing small amounts of information which are downloaded to your device when you visit the Website. The Website sends information to the browser which then creates a text file. The Website uses Cookies for the following purposes:

    • To Recognize your device, time zone and language setting – to provide you with the Website, tailored for your geography and device;
    • To remember you as the returning visitor of the Website;
    • To enhance your experience with the Website.
    You can manage cookies in the setting direction of your device browser – you can either to restrict some cookies or manage to block all cookies. But please note that it this case some functionality of the Website will be unavailable to you.

    6. The recipients of your personal data

    Due to the nature of our business, we can share some of the information you provide to us. All the recipients of your personal data provide an appropriate level of the data protection, security and are legally obliged to process your data in a lawful manner. The recipients of your personal data are the following:

    • Financial Institutions. When we process your transactions, your financial information may be transferred to the banks, financial units, payments service providers. In addition, it may be verification system providers or independent auditors – such transfer of the data is especially necessary when the Company has reasonable grounds to believe, that a user poses a serious risk of money laundering, terrorist financing and other related activity;
    • Providers of Gaming Services, Providers of Software and Host Providers. Please note, that some parts of the informational infrastructure, which you use, do not belong to the Company. Thus, in some cases your personal data may be shared with these providers of IT solutions;
    • Providers of logistic services. This rule applies in case of delivering of physical prizes, winnings and promotional goods;
    • When we apply for accreditation, the accreditation body may perform the checks. This procedure may result in the transfer of your personal data to this third-party;
    • To the third-party in case of selling or transfer of the business or any part of our business. In this case, this third-party shall have the right to process your data in accordance with this Privacy Policy. Your personal data can be shared with any successors of the Company (if applicable).

    7. The place of storage of your data

    The personal data, collected about you, is stored within the territory of the European Economic Area (hereinafter EEA). Nevertheless, some of our partners and Invicta Networks N.V., are located outside the EEA - and that is why some of your data may be transferred outside the EEA. We established all legal mechanisms and technical measures to ensure appropriate safeguards of these transfers and further storage. Please note, that if you agree to this Privacy Policy, you hereby agree to these transfers.

    You can always withdraw your consent to such transfers at any time, but in this case the Company will not be able to provide you with the services, offered on the Website.

    8. Data Security and record keeping

    8.1 Data Security

    The company is under obligation to establish a proper security level of the personal data, which you submit to us. The Company provides the security of your personal data through two approaches:

    • Legal approach, which consists of total compliance with the data security legislation in force;
    • Technical approach, which is realized in the application of all modern technical standards, applicable in data protection, including data encryption standards.

    8.2 Record-keeping period of your personal data

    We keep your data as long you are the user of the Website. When you cease to be a user of our Website, we will remove your personal data or anonymize it for research and analysis. Anonymization means the process of removing all personally identifiable information from data sets. In the case of anonymization of the data, this data can no longer be defined as personal data anymore. Due to the regulatory obligations, we shall keep some types of your data for ten (10) years from the date you cease to use the Services of the Company (for example, you close your account or do not place bets and deposits anymore).

    9. Your rights

    You, as the data subject, have a number of rights in application to the processing of your data. These rights are granted to you by the legislation on data protection – and the Company must follow this legislation fully. If you want to execute any of the rights specified below, you should send a request to our Data Protection Officer.

    9.1 Right to access.

    You have the right to obtain from the Company the confirmation as to whether or not personal data concerning you is being processed, and, if the Company indeed processes it, to obtain a machine-readable copy of the data we process.

    9.2 Right to rectification.

    You have the right to obtain from the Company the rectification of inaccurate personal data concerning you. For example, you changed your residence or address, or got married, or changed your name.

    9.3 Rights to delete the data we collect about you.

    This rights also called “the right to be forgotten”. You can send us a request to delete your account and the data we collect about you. Please note, that this right may not be executed fully due to the reason specified in clause 9.8 of this Privacy Policy.

    9.4 Right to restrict processing.

    You can send us a request do not process your data for a specific purpose anymore. It means that we still will hold your data, but will not process it for the purpose you specified.

    9.5 Right to data portability.

    You can send a request to the Company to provide you with a copy of your data in a structured, commonly used and machine-readable format or to transmit those data to another controller. Please note, that we disclaim all warranties of the correct transmitting of your data to another controller, having regard the fact that we may have a different Application Programming Interface etc.

    9.6 Right to object.

    You can object to the processing of some types of your data, for example, for marketing purposes.

    9.7 Right to withdraw consent.

    You can always withdraw your consent to process your personal data. Please note, that upon your withdrawal some functions or elements of the Website will become unavailable for you.

    9.8 Restrictions

    9.8.1 Before execution of the rights, specified in clause 8 of this Privacy Policy, you may be asked to provide the Company with a proof of your identity. These measures are applied to protect your data from getting into the wrong hands.

    9.8.2 We may restrict execution of some rights, specified in clause 9 of this Privacy Policy. For example, if you ask us to delete your personal data pursuant to clause 9.3 of this Policy, we will not be able to delete all personal data about you. Restrictions, specified in clause 9.3 are made due to Anti-Money Laundering and Counter-Terrorist financing legislation.

    9.8.3 In case of any additional restrictions in the execution of your rights you will be notified in the response to your request (if any).

    DATE: 24 of May 2018