OLYBET WEBSITES PRIVACY NOTICE

1              General

1.1          This website is operated by OB Holding 1 OÜ (“OBH1” or “we”). OBH1 recognizes the importance of your privacy and is committed to protecting your personal data. This privacy notice (“Notice”) explains the principles on how OBH1 collects and uses information when you visit the websites: www.olybet.ee and www.olybet.eu(„Websites“) and use any of the gaming services provided on the Websites („Service“).   

1.2          OBH1 processes your personal data under this Notice and in accordance with applicable legislation, including the General Data Protection Regulation (2016/679) and the applicable national data protection laws of the Republic of Estonia, as applicable towards the personal data controller stated in Section 2 of this Notice.

2              Personal data controller

2.1          For the personal data processing purposes brought out in Section 5 of this Notice, the controller of your your personal data is:

OB Holding 1 OÜ

Registry code: 14975047
Address: Pronksi tn 19,10124 Tallinn, Estonia
E-mail: [email protected]

3              Data protection officer

3.1          You shall have the right to communicate with OBH1’s data protection officer in order to obtain information on the processing of your personal data. OBH1’s data protection officer’s contact references are:

Address: Pronksi tn 19,10124 Tallinn, Estonia
E-mail: [email protected] / [email protected]. 

4              categories and sources of personal data OBH1 collects and processes

4.1          Personal data are information that can be used to directly or indirectly uniquely identify, contact, or locate you as a private individual (“Personal Data”). The source of the collected Personal Data depends on how you interact with us. 

4.1.1      Registration data. OBH1 processes the following Personal Data related to your registration to the Websites: e-mail address, country of residence, phone number, etc. („Registration Data“)

Source: Personal Data you directly provide to OBH1 upon registration.

4.1.2      Verification data. OBH1 processes the following Personal Data in order to complete your registration and verify your admissibility to use the Service: name, surname, date of birth, personal identification number, type, number, validity and copy of personal identificaition document (if you choose verification via document photo), home address and nationality, etc. („Verification Data“)

Source: Personal Data you directly provide to OBH1 upon registration and Personal Data made available to us by the verification service providers.

4.1.3      Anti-money laundering data. OBH1 processes the following Personal Data in order to designate whether you are, or you are related to a politically exposed person: name, surname, personal identification number or date and place of birth, home address, information on political exposure, sum of registered amounts, occupation, copy of the personal identification document, etc. („AML Data“)

Source: Personal Data you directly provide to OBH1 as necessary.

4.1.4      Gambling data. OBH1 processes the following data in order to provide you with the Service: self-exclusion data, gaming-exclusion data, user ID, bet ID, currency, bet amount, current balance, game ID, seller ID, bet type, bet status, expected max win amount, bet result date, win amount, payout amount, login data, IP-address, currency, date and time date and time of entering and exiting the Service, etc. („Gambling Data“)

Source: Personal Data you provide us whilst using the Service and the Personal Data gathered from the databases available to OBH1 in relation to providing the Service (e.g.  list of persons with restrictions on gambling (HAMPI in Estonia)).

4.1.5      Transfer data. OBH1 processes the following data to commence the money transfers related to the Service: name, surname, banking number, transaction amount, etc. („Transfer Data“)

Source: Personal Data you provide us upon requesting monetary transfer and Personal Data received from the payment service providers.

4.1.6      Communications data. OBH1 processes the following Personal Data if you interact with OBH1 via Websites’ chatbot, e-mails or complaint reports: contents of your message, e-mail address or social media contacts, etc.  („Communication Data“)

Source: Personal Data you directly provide to OBH1.

4.1.7      Technical data. OBH1 processes the following data when you visit the Websites: IP address (including location based on the IP address), access-provider, referring URL, date, time, access tokens, session key, browser type and version, operating system, amount and state of transferred data, MAC-address. (“Technical Data”)

Source: While you are browsing through the Website, the Website itself generates or collects the Technical Data from your device automatically.

4.1.8      Marketing data. OBH1 processes the following personal data for marketing purposes: e-mail address, phone number, your preferences. („Marketing Data“)

Source: Personal Data you directly or indirectly (e.g. via cookies) provide to OBH1 whilst using the Service.

4.1.9      Cookie data. OBH1 implements cookies on the Websites, for optimising the Websites and their functionalities. The cookies may collect your Personal Data. For further information, please see OBH1’s cookie notice. („Cookie Data“)

4.2          If you fail to provide necessary information, OBH1 is not able to register your user account, provide you with the Service or fulfil any other purposes provided in Section 5 of this Notice.

5              Legal basis and purposes for processing the personal data

5.1          OBH1’s legal basis to process your Personal Data depends on the objective and context in which we collect the Personal Data. For easier understanding, we have grouped all objectives and data categories for processing the Personal Data with the following legal grounds: performance of a legal obligation, performance of a contract, OBH1’s legitimate interest and your consent.

5.2          If the legal basis for processing the Personal Data is:

5.2.1      performance of a legal obligation, then this means first and foremost that OBH1 is required to process certain Personal Data by law. In this case we cannot decide which personal data are collected and processed, as it derives from applicable laws;

5.2.2      performance of a contract, then this means processing Personal Data for the performance of a contract to which you are a party, i.e. the main rules and rules of games of chance and the game rules, which you have accepted upon registration to the Service;  

5.2.3      OBH1’s legitimate interest, this means first and foremost the objective of improving the Websites and OBH1’s business activities. However, specifics of the legitimate interests, as used in each separate case, are referred in the table below;

5.2.4      consent, this means first and foremost that Personal Data shall only be processed, if your consent is granted, for example, objective of ensuring an effective user experience by adjusting the Service is only possible upon your consent, without your consent it would not be possible to tailor the Service to meet your preferences.

5.3          The following depicts a non-exhaustive list of processing purposes that are linked to the specific data categories and legal basis for processing:

5.4          We may process your Personal Data for other purposes, provided that OBH1 discloses the purposes and use to you at the relevant time, and that you either consent to the proposed use of the Personal Data, other legal grounds exist for the new processing purposes or the new purpose is compatible with the original purpose brought out above.

6              Automated decision making and profiling

6.1          In the course of you browsing the Websites and using the Service, OBH1 may sometimes apply automated processing to your Personal Data and make automated decisions based on your Personal Data. These automated decisions can affect the content and access to the Service or its features.

6.2          In the following situations we may apply automated decision making as authorised by applicable laws or is necessary for the performance of the contract between you and OBH1:

6.2.1      Verifying your identity and allowance of providing access to the Service upon registration of the user account on the Websites: upon registering to the Service on the Websites, we verify via automated decision whether you meet the criteria for registering the user account and accessing the Service. The decision-making process entails analysing your Personal Data, such as date of birth (age), personal identification number, nationality, self-exclusion data and gaming-exclusion data against the statutory allowance requirements. These data are usually directly made available by you or gathered from the databases available to OBH1 in relation to providing the Service (e.g.  list of persons with restrictions on gambling). As a result of the automated decision your registration and access to the Service is completed or declined; 

6.2.2      User payment verification: according to applicable laws, OBH1 is obliged to check whether your payment account details match the user account details you have provided for the use of the Service. Personal Data subject to such automated decision are the banking account details (name, banking account number). These data are collected directly from you and received from the payment service provider. As a result of the automated decision any money transfer to your user account or to you is completed or declined;

6.2.3      Risk assessment and compliance with the sports rules and other Service’s rules: pursuant to the sports rules, OBH1 does not allow cooperation between customers and thus applies active measures to avoid the use of scripts, bots and other devices and techniques interfering the fair play. To combat any interferences of fair play and non-compliances of the binding Service’s rules, we analyse your activities on the Websites and in the Service. For such analysis we mainly rely on the Technical Data and Gambling Data as defined in Sections 4.1.4. and 4.1.7. above.  We compare such data against data previously collected by us or received from third party service providers about you or your device. As a result of the automated decision, OBH1 and/or the engaged gaming service provider (who processes such data in aggregated manner based merely on User ID) may restrict the access to the Service’s functions (e.g. cancel repeated bets from the same IP address or shared address, limit maximum bet amounts, etc.) if the activity is non-compliant;

6.2.4      Fraud detection: pursuant to the applicable laws, OBH1 is obligated to detect and deter activities relating to money laundering and fraud. For this purpose, OBH1 or a fraud prevention service provider compares your device’s online identifiers (e.g. Technical Data and Cookie Data as defined in Sections 4.1.7. and 4.1.9. above) and Gambling Data (see 4.1.4 above) against similar type of data previously collected about you or your device used to access the Websites. If it is detected that your account or device has fraudulent pattern or is connected to money laundering, as a result of the automated decision, OBH1 may restrict your access to the Service (e.g. block or freeze your user account).

6.3          The automated decisions described in Section 6.2 above usually take place without human intervention. You have the right to obtain human intervention in regard to the decision making defined in Sections 6.2.3 and 6.2.4; express your point of view in regard to such decision and contest the decision.

7              PErsonal data retention period

7.1          Your Personal Data (all data categories mentioned in Section 4.1.9, except for Cookie Data) shall be stored insofar as reasonably necessary to attain the objectives stated in Section 5 of this Notice, or until the legal obligation stipulates that we do so. The following is a non-exhaustive summary with examples on storing your Personal Data:

7.1.1      Registration Data, Verification Data, AML Data and Gambling Data will be retained up to 7 years as of the last log-in to your user account;

7.1.2      Transfer Data will be retained for 7 years as of the end of the financial year the transaction was recorded in the accounting documents. Please note that the data about transactions starting from 2000 € will be retained for 7 years as of the last log-in to your user account;

7.1.3      Marketing Data will be retained for 7 year as of the collection of such data;

7.1.4      Communication Data will be retained for 7 years as of the collection of such data;

7.1.5      Technical Data will be retained for 30 days as of the collection of such data.

7.2          After the retention period mentioned in Section 7.1 of this Notice, we might either retain your Personal Data for longer period if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes and enforce the contract between you and OBH1 or anonymize your Personal Data and retain this anonymized information indefinitely.

7.3          After the expiry of the retention period referred to in Section 7.1. of this Notice or the termination of the legal basis for processing purpose, OBH1 shall retain the materials containing the Personal Data in the backup systems, from which the corresponding materials will be deleted after the end of the backup cycle. OBH1 ensures that during the backup period, appropriate safeguards are applied to the materials in the backup. The backed-up materials are put beyond the use, i.e. are not processed for any other purpose, and the materials are deleted by OBH1 as soon as possible, i.e. after the end of the OBH1’s backup cycle, the Personal Data will be destroyed. 

8              Your rights as a data subject

8.1          We have a legal obligation to ensure that your Personal Data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that have to be made to any of your Personal Data that we are processing.

8.2          You may, at any time, exercise the following rights with respect to our processing of your Personal Data by contacting us via contact information referred to in this Notice:

8.2.1      Right to access: you have the right to request access to any data that can be considered your Personal Data. This includes the right to be informed on whether we process your Personal data, what Personal Data categories are being processed by us, and the purpose of our data processing;

8.2.2      Right to rectification: you have the right to request that we correct any of your Personal Data if you believe that it is inaccurate or incomplete;

8.2.3      Right to object: you are entitled to object to certain processing of Personal Data, including for example, making automated decisions based on your Personal Data or when we otherwise base the processing of your Personal Data on our legitimate interest;

8.2.4      Right to restrict Personal Data processing: you have the right to request that we restrict the processing of your Personal Data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of Personal Data; (iii) receive or avoid deletion of Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of OBH1’s legitimate interest in the specific processing activity;

8.2.5      Right to erasure: you may also request your Personal Data to be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement;

8.2.6      Right to data portability: if your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible;

8.2.7      Right to withdraw your consent: in cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time without any adverse effect;

8.2.8      Right to submit your claim with the supervisory authority: if you are not satisfied with our response to your request in relation to Personal Data or you believe we are processing your Personal Data not in accordance with the law, you can submit your claim with the Estonian Data Protection Inspectorate (in Estonian Andmekaitse Inspektsioon) at [email protected] (https://www.aki.ee/).

8.3          Please note that you will need to provide sufficient information for us to handle your request regarding your rights brought out in Section 8.2 of the Notice. Prior to answering your request, we may ask you to provide additional information for the purposes of authenticating you and evaluating your request.

9              Sharing your personal data and data transfers

9.1          OBH1 discloses your Personal Data to third parties only in accordance with this Notice and to persons authorised to process Personal Data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality. In specific cases, OBH1 will only share your Personal Data with a third party if you have given consent to such disclosure.

9.2          Only if necessary for fulfilling its statutory or contractual obligations, OBH1 may disclose your Personal Data to the following recipients (including data processors) in its data processing activities (as necessary):

9.3          In some cases, we may transfer your Personal Data outside the European Union or European Economic Area, if the respective operational services are provided outside the European Union or European Economic Area. We shall opt to use special Personal Data protection safeguards, in order to ensure the safety of your Personal Data. You have the right to get acquainted with or obtain information on the comprehensive list of data processors, transferring of your Personal Data outside the European Union or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in this Notice.

10. Information about Processing Olympic Casino and OlyBet Customers’ Personal Data for Direct Marketing and Analytics Purposes

10.1. The joint controllers of your personal data are OLYMPIC ENTERTAINMENT GROUP AS (registry code 14437516, address Pronksi tn 19, 10124 Tallinn, Estonia), who is the operator of Olympic Casino, and OB Holding 1 OÜ (registry code 14975047, address Pronksi tn 19, 10124 Tallinn, Estonia), who is the operator of OlyBet (together – we). 

10.2. We use the electronic contact details provided by you to send you information and special offers on the subjects chosen by you to promote the businesses of Olympic Casino and OlyBet. The legal basis for processing your personal data is your consent (Art 6(1)(a) of the GDPR). 

10.3. If you agree, the information and special offers will be personalised, i.e., sent to you based on our best understanding of your interests and behaviour. In making these offers, we may contact you based on, for example, your use of Olympic Casino and OlyBet services (e.g., if you prefer certain games in Olympic Casino, we may notify you if such games become available in OlyBet; if you have participated in certain events or offers before, offer them to you again; provide special offers to players who have staked a certain amount, etc.). The purpose is to know you better in order to incentivize you to use our services. In doing so, we use both profiling and automated decision-making. The automated decisions usually take place without human intervention. However, they do not bring about any legal effects to you or otherwise similarly significantly affect you. At worst, we may send you offers you are not interested in. The personalised offers may somewhat increase the addiction of compulsive gamblers; however, we have taken the necessary safeguards and never target any such player knowingly and strongly encourage responsible gaming. You have the right to obtain human intervention regarding the decision making, express your point of view regarding such decisions, and contest the decisions. The legal basis for processing your personal data is your consent (Art 6(1)(a) of the GDPR). 

10.4. We will process your personal data for the above-mentioned purposes until you withdraw your relevant consent(s), asking you to update your preferences from time to time.

10.5. We also provide you information and special offers via phone or when you visit Olympic Casino or OlyBet. These offers are usually personalised, i.e., based on our best understanding of your interests and behaviour as explained above. The legal basis for processing your personal data is our legitimate interest to promote the businesses of Olympic Casino and OlyBet (Art 6(1)(f) of the GDPR). In such case, we have concluded that, considering the circumstances, our legitimate interest is not overridden by your interests or fundamental rights and freedoms which require protection of personal data. You have the right to object at any time to such processing by contacting us on the contact details below. In such case, your personal data will no longer be processed for direct marketing purposes.

10.6. We use the personal data you have provided us or that has been created based on your use of Olympic Casino and OlyBet services on an aggregated level for analytics, i.e., to understand our customers, their needs, and behaviour better in order to make better marketing and business decisions. For example, to understand which Olympic Casino games are popular and should also be available in OlyBet to increase its use; in which order the games should be listed to increase their popularity; which OlyBet sports events are popular and should be streamed in Olympic Casino; what are the characteristics of customers who are active either only or both online and offline; etc. Although such analytics may initially be based on some of your personal data, the data is aggregated, and no personal data is used in any reports. The legal basis for processing your personal data is our legitimate interest to make better marketing and business decisions and to promote the businesses of Olympic Casino and OlyBet (Art 6(1)(f) of the GDPR). In such case, we have concluded that, considering the circumstances, our legitimate interest is not overridden by your interests or fundamental rights and freedoms which require protection of personal data. You have the right to object, on grounds relating to your situation, at any time to such processing by contacting us on the contact details below. In that case, we will no longer process your personal data for analytics purposes unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

10.7. We will process your personal data for the above-mentioned purposes until you object to it and we do not have the right to continue processing or until you have an active agreement with either of us. 

10.8. You have all the rights of a data subject under the GDPR, including the following:
a. The right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
b. The right to obtain confirmation as to whether personal data concerning you are being processed and a copy of those data. 
c. The right to obtain the rectification of inaccurate personal data concerning you, including to have incomplete personal data completed.
d. The right to obtain the erasure of your personal data. 
e. The right to obtain restriction of processing. 
f. The right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and the right to transmit those data to another controller without hindrance from us.
g. The right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or the Estonian Data Protection Inspectorate (www.aki.ee). 
Note that not all rights listed above are absolute and may be restricted for purposes allowed under the GDPR. You can exercise some of your rights by visiting Olympic Casino reception or by logging into your OlyBet account or, in any case, by contacting us on the contact details below. 

10.9. Note that our other personal data processing practices are described in our respective Privacy Policies, available on our respective websites (www.olympic-casino.ee for Olympic Casino and www.olybet.ee for OlyBet). Olympic Casino’s Privacy Policy is also available at the Olympic Casino reception. Also note that the withdrawal of consent(s) for or opting out from the marketing and analytics purposes does not preclude us from processing your personal data for other purposes described in the Privacy Policies. 

10.10. Contact details for inquiries: Data Protection Officer Aare Reinsalu [email protected] / [email protected] or [email protected] / [email protected]. 

11 Amendments to this notice

11.1        This Notice may be amended or modified from time to time to reflect changes in the way we process Personal Data and, in such case, the most recent version of the Notice will appear on this page. Please check back periodically, and especially before you provide any new personally identifiable information.

Last updated: 27.11.2020