Translation from Lithuanian
PRIVACY POLICY
PERSONAL DATA PROCESSING RULES OF ‘TOP SPORT’, UAB (PRIVACY POLICY)
Valid from 25 May 2018
PERSONAL DATA PROCESSOR
“Top Sport”, UAB
Company code 235787510
S. Dariaus ir S. Girėno str. 31A, Kaunas
Customer Service Division email:
pagalba@topsport.lt
or dap@topsport.lt
CONCEPTS
Customer/Gambler – any natural person who uses, has used, has expressed an intention to use or is in any way related with the services provided by ‘Top Sport’.
Personal data – information directly or indirectly related to the Customer.
Processing – any operation carried out with personal data (including data collection, recording, storage, change, granting of access, submission of inquiries, transfer, etc.).
‘Top Sport’ – a legal entity with its registered office in Lithuania, which acts as a Processor of personal data. A list of all ‘Top Sport’ betting shops can be found at the website: www.topsport.lt.
GENERAL INFORMATION
- These rules (privacy policy) (hereinafter referred to as the Rules or Policy) concerning the processing of personal data shall regulate the main principles and procedures that ‘Top Sport’, UAB (hereinafter referred to as the Company) uses to process the personal data of its customers/gamblers (hereinafter referred to as the Gamblers) participating in remote gambling organized by the Company at the www.topsport.lt website (hereinafter referred to as the Website). Additional information about the processing of personal data may be provided in the service agreement and other documents related to its services.
- The processing of the personal data of Gamblers is governed in accordance with these Rules, the provisions of the Law on Legal Protection of Personal Data of the Republic of Lithuania, the General Data Protection Regulation 2016/679 and other legal acts regulating the collection and processing of such data.
- In processing and protecting the personal data of Gamblers, the Company implements organizational and technical measures which ensure protection from accidental or unlawful destruction, change, copying, disclosure or any other unlawful processing of personal data.
- For the processing of personal data, ‘Top Sport’ may invite data processors to help. In such cases, ‘Top Sport’ takes certain measures necessary in order to ensure that such data processors process personal data in compliance with the instructions of ‘Top Sport’ and the applicable legal acts and requires the implementation of proper personal data protection measures. Concerned parties and persons are informed about the help of such processors.
PURPOSES AND BASIS OF PERSONAL DATA PROCESSING
The ‘Top Sport’ data processor shall process personal data for the following purposes:
- Maintenance of relations with Customers and offering opportunities to use the products and services provided by ‘Top Sport’ and their administration.
- Concluding an agreement with a Customer and its execution, renewal of the data concerning a Customer while aiming to secure its correctness by employing external and internal registers, whenever that is necessary in carrying out an agreement, or in aiming to take actions before concluding an agreement at the request of a Customer or when performing a legal obligation.
- On the basis of the Law on the Prevention of Money Laundering and Terrorist Financing, in order to implement the duties established in the legal acts related to the risk assessment of payouts or contributions, submission of data to the Ministry of Finance and the State Tax Inspectorate, and by executing a strengthened verification to establish the integrity of the personal identity data.
- For accounting purposes and for the purpose of performing financial services – to manage the Customer's indebtedness, carry out claims related to the payment of winnings, including the topping up of accounts or any other financial services.
- A Gambler’s verification for the authorization of gambling via self-exclusion from any gaming programme prepared by the State.
- Identification of a Gambler during live streaming is based on the legal obligation to determine and verify the age and identity of the individual.
- Identification of a Gambler from a photo of the document received from them, while the photo with the document is stored in order to fulfil the legal obligation of identifying the person, and to make sure their age is appropriate for gaming.
- In regards to the purpose of protecting the interests of the Customer and (or) the interests of ‘Top Sport’, to perform verification concerning the quality of services provided by ‘Top Sport’, This includes the provision of evidence (recording of video or conversation) of a transaction or any other business communication whenever it is necessary, and to verify that there are no other proper measures to ensure while implementing the agreement or carrying out any legal duty. All this is to be accomplished in accordance with the legal interests of ‘Top Sport’ in order to implement the prevention and investigation of any improper or unlawful use of ‘Top Stop’ services and products or their violation, and to assure the quality of Customer service.
- To ensure the security of ‘Top Sport’ and (or) the Customer, protect the life and health of the Customer and (or) its representative and other rights (video and (or) sound recording) of ‘Top Sport’ and the Customer, while seeking to ensure the legal interests of ‘Top Sport’ in protecting its customers, employees, visitors and their property, including the property of ‘Top Sport’.
- For the purpose of providing additional services, Customer feedback, direct marketing, market research and statistical data collection. For the purpose of ‘Top Sport’ or the purpose of ‘Top Sport’ responsibly selected services of the partners of the Customer, including personal offers. It is only executed with the consent of the Customer for data processing, or for any legal interests of ‘Top Sport’ related to the offering of additional services.
PERSONAL DATA PROCESSING PRINCIPLES
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The Company is guided by the following principles while processing personal data:
- Personal data shall be collected for specified and legitimate purposes and by refusing the collection of surplus data.
- Personal data shall be handled accurately, transparently and in good faith.
- Customized and standardized protection methods are followed when processing personal data in an automated manner with the help of programmes.
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Personal data are processed legally, i.e. only in cases where:
- The Gambler (the data subject) gives consent to this, i.e. agrees to comply with all the applicable rules to participation in both remote and gambling games.
- A business relationship agreement is concluded or executed where one of the parties is a gambler (data subject).
- When the company is obliged to process personal data in accordance with the law.
- Personal data must be processed on the basis of a legitimate interest pursued by the Company or a third person to whom the personal data are provided, and if the interests of the gambler (data subject) are not more important.
- Personal data are constantly updated.
- Personal data shall not be stored for longer than the purpose for which the data processing was requested, on an average, for 10 years.
- Personal data shall only be processed by employees or institutions of the Republic of Lithuania which have been granted such a privilege.
- All information on processed personal data is confidential.
- The processing of personal data shall be reported to the State Data Protection Inspectorate in accordance with the procedures established by law.
- Personal data are stored on servers located in Lithuania.
- Personal data shall not be transferred to third parties without informing the subject of the data in regard to its transference.
- Personal data shall not go beyond EU or EEA countries.
- There is a strengthened function concerning the determination of the personal identity of persons engaged in political activities or of persons responsible for public duties, or of persons in close contact with such persons.
COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA
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The Company shall recognize and respect the right to privacy of each Gambler who visits the Website. The
Company shall collect and use the Gambler’s data (name, surname, address, date of birth, age group,
telephone, e-mail address, photo, document number, document validity period, signature, visual and/or
audio record material, card number, bank account number, permission to gamble, information about the
fact of political activities carried out, or the fact of an important public occupation or relation with
such persons) for the following purposes:
- To organize remote gambling in a proper manner and grant the opportunity to participate in such gambling to the Gambler.
- To implement any legal requirements in a proper manner regarding the Gambler’s possibilities to participate in remote gambling (for instance, due to age of the Gambler, due to the permission to gamble).
- To solve problems related with the provision of services for remote gambling.
- To issue financial documents and/or to transfer or obtain funds from persons.
- To identify the personality, age or activities carried out by the Gambler in accordance with the procedures established by law.
- For the purposes of direct marketing.
- To implement other contractual obligations of the Company.
- At the moment of registration in the Website and at the moment of the conclusion of the Remote gambling agreement, the Gambler must submit detailed and correct personal data.
- By confirming signing on to the Website and by concluding a Remote gambling agreement, the Gambler shall choose whether he/she agrees that his/her personal data would be submitted for processing to the company in accordance with these Rules.
- The Company may, for statistical purposes, use data not directly related to the Gambler, i.e. data on participation in remote gambling. Such statistical data will be collected and processed in such a way as to prevent disclosure of the identity of the gambler, or other personal data of the Gambler which would allow identification of the person. The Company reserves the right to transfer statistical data to a third party.
- In order to improve the Website and ensure its effective use and the quality of the remote gambling offered, the Company collects information when the Gambler uses the Website and participates in the remote gambling for the purpose of calculating Website traffic (statistical information) in order to provide Website content and other information relevant to the Gambler’s interests and to save the history of the visit (hereinafter referred to as the ‘Cookies’). You can find more information on cookies and how to refuse to install them on your computer on the ‘Cookies Policy’ website column.
- If the Gambler, having received a clear notification on the Website about the use of Cookies, voluntarily marks that he/she has become familiarized with such information and agrees with the use of cookies, and the provided information is clear, and continues to use the Website and participates in remote gambling, the customer is considered to be definitely familiar with this information and agrees with it. In order to restrict or block cookies stored on the Website or to remove those already recorded, the Gambler shall submit the corresponding request by e-mail to pagalba@topsport.lt or follow the instructions on how to do it yourself with the help of his/her computer's browser. The instructions are provided in the description of the cookies policy.
- The Gambler receives a clear informational notification after he/she submits his/her email address and phone number on the Website that he/she may receive the Company’s e-mails and/or SMS messages, or in exclusive cases, the Company may call if the customer chooses such a function. The Company’s e-mails and/or SMS messages shall be sent to the Gambler in order to ensure convenient and effective use of the Website and/or the services of remote gambling organized by the Company and proper and timely provision of such services. Such letters shall be sent in limited quantities and only with informational content which may be interesting to the gambler.
- If the gambler does not want to receive the Company’s emails, the Gambler may use the unsubscribe function, which is indicated in each sent letter or the gambler may apply to the Company by email at pagalba@topsport.lt with their request to stop sending emails.
- If the gambler does not want to receive the Company’s SMS messages, the gambler may apply to the Company by email at pagalba@topsport.lt for a free form in regard to this, and provide the Company with a refusal request.
- ‘Top Sport’, UAB reserves the right to change the scope of data processing and data processing rules, and shall be obliged to inform customers about the changes regarding new projects distributed on the Internet.
TRANSFER OF PERSONAL DATA
Personal data may be transferred to the following data processors:
- State authorities and institutions, other persons performing functions delegated to them by law (for instance, law enforcement authorities, bailiffs, notaries, tax administration companies, and institutions carrying out the supervision of ‘Top Sport’ activities, including financial crime investigation institutions and others).
- Auditors, legal and financial advisers, accountants, and data processors authorized by ‘Top Sport’ who provide these types of services.
- Third parties handling gambling prevention and activity monitoring services, or those who mediate in the provision of personal data from such registers.
- Debt recovery companies to which claims are transferred concerning the Customer’s indebtedness, including courts, out-of-court dispute settlement institutions and bankruptcy administrators.
- Participants and (or) parties related with national, European and international payment systems, for instance, SWIFT.
- Other persons related with ‘Top Sport’ service provision such as archiving, safe data destruction, and mail service providers.
- Providers of services provided to the Customer, for the services of which the Customer transfers, obtains, cashes out or otherwise manages the winnings.
- IT specialists, helpline staff, video material observers, security managers, regional managers, bookmakers, and the betting shop staff.
- BPN Media, a company providing all media services, which collects, searches, manages and prepares promotional projects for the search of potential, current, past and future customers of ‘Top Sport’, UAB.
- ‘Edrana’, UAB, which provides the maintenance services of a financial accounting programme.
- The State Enterprise ‘Centre of Registers’, where the Customer is identified at the moment of registration or while signing on to the account.
DATA STORAGE PERIOD
- Personal data are processed no longer than necessary. The period of Personal data protection is defined by taking into consideration the nature of the agreements concluded with the Customer. The period is established in accordance with the legitimate interests of ‘Top Sport’ or the requirements of legal acts (for instance, regulating accounting, money laundering prevention requirements, time for appealing and other).
- The average data storage term is 10 years.
- The terms concerning separately deleted data may be provided upon the request of the Customer as described in the description of data deletion.
CHANGE OR UPDATE OF PERSONAL DATA
- The Gambler shall have the right to change and update the information provided by the Gambler in the registration form, Remote gambling agreement or elsewhere on the Website.
- The Company must have the latest information in relation to the Gambler that is necessary for timely and qualitative provision of remote gambling services. Therefore, the gambler may be required to periodically confirm that the information available to the Company about his/her identity is correct. On average, such a request is submitted every three years.
- The Gambler shall have the right to request access to the information available to the Company about his/her person. For the provision of such information, the Gambler will be requested in some way to identify himself/herself in order to protect the data from unauthorized disclosure to third parties. This type of information is not provided by telephone or e-mail.
- The Gambler shall have the right to request to transfer the information available to the Company about his/her carried activity. This function is only possible if maximum security is ensured for the data and technical capabilities, and if there is a real legal basis for this request and no threat of violation is imposed on the data of other persons.
- The Gambler may request to delete data about his identity that the Company has collected. This request may be satisfied only if the there is a real legal basis and no legal acts contradict the satisfaction of the person’s request.
- The data relating to individuals who are involved in politics or engaged in such, or involved in important public affair duties or who have close contact with such persons, having confirmed such a fact, are requested to be updated once a year. After the cessation of such activities, the company applies a special, strengthened data identification and control programme to such persons for one more year.
TRANSFER OF INFORMATION OR CLAIM
- All notifications related with the processing of personal data shall be submitted by email to pagalba@topsport.lt or dap@topsport.lt.
- If the Gambler submits a claim to the Company regarding improper collection, processing or storage of the Gambler’s personal data, an answer to the claim must be submitted to the Gambler within 20 (twenty) days from the receipt of the claim.
- Claims are made by filling in an official request filed by the data protection officer upon the receipt of the request.
RIGHTS OF THE PERSON
Having agreed to the processing of personal data, the Gambler shall have the right:
- To require the correction of personal data or suspend the processing of certain personal data, except for storage, when data are processed without complying with this and other laws.
- To request to delete personal data available to the Company. Such a request is satisfied if it is in accordance with the procedures laid out in legal acts, when the proper technical measures and possibilities are available to satisfy such a request, and when its implementation does not violate the security of the personal data of third parties.
- To withdraw consent to the processing of certain personal data.
- To request to be provided with access to whatever personal data are processed by the ‘Top Sport’ Company pertaining to the Gambler.
- If a Gambler submits a claim against the Company regarding improper collection, processing or storage of the Gambler’s personal data, an answer to the claim must be submitted to the Gambler within 20 (twenty) days from receipt of the claim.
AMENDMENT OF PRIVACY POLICY
- The company has the right to unilaterally change the terms of the Rules. The Company shall provide information concerning changes on the Website or in any of the other usual ways it conducts its activities.
- Supplements or amendments to the Rules shall enter into force from the date of their publication, i. e. from the date when they are placed on the Website system or they are otherwise announced, unless another effective term is indicated.
- If a Gambler continues using the remote gambling services provided on the Website after the amendment of such terms, it is considered that the Gambler agreed with the amendment of such terms.
FINAL PROVISIONS
- All disagreements between the parties regarding the implementation of this Privacy Policy are to be settled by negotiation. In cases where there is failure to reach an agreement, the disagreements are resolved in accordance with the procedures established by the laws of the Republic of Lithuania.
