This personal data protection policy reflects the requirements of EU Regulation 2016/679 on the protection of individuals in regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation” or GDPR), with regard to the processing of personal data and the Personal Data Protection Act, as well as other special requirements of the applicable regulations for our activity, incl. but not only: the Gambling Act, the Anti-Money Laundering Act, their by-laws, as well as the mandatory gambling conditions, rules and requirements for organized gambling adopted by the National Revenue Agency for gambling organized by KAZINO WIN BET EOOD, UIC 175086943 (referred to in current policy “WINBET” for brevity).
What information do we collect and why?
We may collect personal information about you when you visit our gaming clubs. In most cases, we require your personal information for the purpose of providing services, to comply with a legal obligation or to protect our legitimate interest.
If you do not provide your credentials, we will not be able to provide you with the relevant service. Depending on the services you use, we may collect and process the following information about you:
When visiting a gaming club:
- Universal Personal Number (UPN) of every visitor for a check in the National Registry of Vulnerable Persons under Art. 10e of the Gambling Act for gaining access to WINBET premises.
- Name and date of birth so that we can establish your identity and if you are at legal age to participate in games, bonus games and to fulfill our legal obligations;
- email address for receiving marketing messages;
- telephone number for receiving marketing messages;
- for peyent of winning of over EUR 2,000 we will collect the following data: your full name, UPN or permanent resident personal number, address, citizenship, place of birth, ID type and number, date of issuing and issuing entity, a photocopy of your ID as well as information for funds origin and if you are a politically active person as stipulated in the Gambling Act and the Anti-Money Laundering Act.
- Video recordings of your visit in order to ensure your and our security and / or fulfill a regulatory obligation.
The purpose of processing your data
In most cases, personal data is required in order to comply with a legal obligation, to execute a contract or on the basis of a legitimate interest. Of course, with some of our services, you agree to provide these data by choice. The personal data we collect and process are most often for the following purposes:
- Gambling Act, Measures against Money Laundering Act, their by-laws, as well as the mandatory gambling conditions, rules and requirements for organized gambling adopted by the National Revenue Agency;
- Personal Income Tax Act;
- Accounting Act and the Tax-Insurance Procedure Code and other related acts, in connection with the keeping of correct and lawful accounting;
- obligations to provide information to all state commissions and regulatory bodies;
- obligations for video surveillance in our gaming clubs;
- obligations to provide information to the courts and to the law enforcement agencies.
Processing of data based on your consent
When we process your data for the purposes of direct marketing, as well as your participation in bonus games and raffles, we will ask for your explicit consent.
Data processing based on our legitimate interest
- video surveillance in our administrative sites;
- sound recordings of telephone conversations with the call center, in order to improve the quality of services provided, as well as for resolving disputes and protecting legitimate interests.
Who can we share your data with?
In some cases, we are obliged to provide your personal data to third parties to comply with our legal obligations. Depending on the games organized by WINBET in which you take part, we may provide your data to the following categories of recipients:
- National Revenue Agency (NRA), State National Security Agency (SNSA), in compliance with statutory requirements and obligations related to gambling. These bodies have the right to receive information about our registered users, the bets made, the winnings paid, as well as other data, in the cases and in the form stipulated by the laws;
- Banks, payment institutions, postal money order companies, specifically identified in the relevant rules for organizing and conducting of the Games, in compliance with the requirements and obligations for making bets and paying out winnings;
- Providers of systems / services for providing games, managing and maintaining the activity and quality of services, incl. those related to the information technology with which we have a contract (e.g. IT providers, software suppliers, computer support providers, prizes providers, etc.), in compliance with the requirements and obligations to maintain the statutory system functionalities, identification of participants, placing bets, determining results and paying out winnings;
- State bodies / institutions, persons in public role, regulators and supervisory bodies (including Ministry of Youth & Sports, NRA, SNSA, the courts, public prosecution and investigation bodies, Consumer Protection Commission, Competition Protection Commission, Personal Data Protection Commission, etc.), if we have sufficient grounds to consider that the access, use, preservation or disclosure of them is necessary for: the implementation of applicable law or other normative act of binding nature; in response to an inquiry made by a supervisory body, regulator or other state institution in connection with or on the occasion of the performance of its statutory functions or initiated inspection, complaint, audit, etc.; detection, prevention or other actions related to fraud, money laundering, terrorist financing, technical or security issues.
WINBET uses third parties to support certain contract activities or in the performance of a legal obligation. We do not provide your personal data to third parties until we are sure that all technical and organizational measures have been taken to protect this data, and we strive to control this strictly. Some of these recipients of personal data may be:
- courier companies, external consultants and specialists, collection companies and law firms, banks, security companies, persons assigned to maintain equipment, software and hardware used for processing personal data by WINBET, hosting companies and sales agents, etc.
Information about us
The personal data of the participants in the organized games can be processed by the following administrators:
When you participate in games in our gaming clubs, the data are processed by KAZINO WIN BET EOOD, UIC: 131496606, with registered office and address in Sofia, Vrana-Lozen-Triagalnika district, 4 Maritsa Str. You can find information about the data being processed by the specific venue you are visiting on the mandatory information sign placed at a visible location near the enetrance of each venue and also at the following website: https://winbet-bg.com/bg/nashite-igralni-zali/.
Technical and organizational security measures
To ensure the maximum level of protection of personal data, WINBET apply the following technical and organizational security measures, such as:
- Protection of the collected personal data from unjustified use and monitors their processing;
- Maintenance of secure computer systems through which personal data is processed. Adequate control mechanisms for data sharing and management are applied to our systems;
- Adopting of strict policies and procedures applicable to its staff to minimize the risks related to personal data processing;
- WINBET employees are familiar with the applicable rules and are trained to process personal data with the utmost care and in full compliance with established good practices;
- In carrying out its activities, WINBET works only with established organizations and avoids working with companies that it believes may endanger the security of personal data of individuals;
- Adopted good practices in the implementation and administration of security systems and monitoring of technological developments in relation to possible risks to the security of information in the company;
- Observance of the security of the computer systems and the personal data contained in them, including the possibilities for access to certain types of personal data by its employees;
- Providing access only to the personal data that is necessary for the performance of the work of the employees.
WINBET have adopted procedures to effectively identify, report and investigate personal data breaches. In the event of a breach of personal data security, the company will take immediate action to limit the effect of the breach, as well as to inform the data subjects concerned and the data protection supervisory authority.
What are your rights and how can you exercise them?
You have the right to information, access and receiving a copy of your personal data that is processed by WINBET. If you believe that information about you that WINBET has is inaccurate or incomplete, you may request that your personal data to be edited.
In addition, you have the right to:
- Object to the processing of your personal data;
- request deletion of your personal data after the legal conditions for this processing expire or cease to exist;
- request restriction on your personal data processing and/or to
- withdraw your consent when WINBET processes your personal data on the basis of consent (without such withdrawal affecting the lawfulness of the processing carried out before the withdrawal);
- to complain with the supervisory body – CPDP (Sofia 1592, Blvd. “Prof. Tsvetan Lazarov” or at cpdp.bg ).
WINBET will process and satisfy requests, consent withdrawals or objections in accordance with the requirements of the applicable data protection rules, but these rules are not absolute: they are not always applicable and there may be exceptions. In response to a request, you will need to verify your identity and / or provide additional information to help us better understand your request.
When you have re-exercised your right to access information or copy machine-readable data, WINBET may charge a reasonable fee based on the administrative costs incurred to provide it.
How to exercise your rights?
Each of the rights provided by law may be exercised by submitting a request, as follows:
- Electronically to the following email address: [email protected].
- In the central office of WINBET at the address: Sofia, Vrana-Lozen-Triagalnika district, 4 Maritsa Str.
The request for exercising of personal data rights should contain the following information:
- Identification of the person – names and UIN;
- Contacts – your address, phone, e-mail;
- Request – description of the request.
WINBET provides information on the actions taken in connection with a request to exercise your rights within one month of receiving the request.
If necessary, this period may be extended by a further two months, depending on the complexity and number of requests from a particular person. WINBET shall inform the person of any such extension within one month of receipt of the request, stating the reasons for the delay. The information provided to the subject and any communication and action to exercise the data subject’s rights shall be provided free of charge (except in the case of abuse of the rights granted).
We may request the provision of additional information necessary to verify your identity when there are concerns about the identity of the requesting individual.
WINBET is not obliged to respond to a request if it is unable to identify the data owner.
Where the request is made by electronic means, the information shall, where possible, be provided by electronic means, unless you have specifically requested otherwise.
Data Protection Officer
The Data Protection Officer of all companies that use the WINBET brand is a lawyer, Mrs. Desislava Dimitrova, e-mail: [email protected]
Update of the personal data protection policy
This policy is subject to change by WINBET, as last updated on January 1, 2019. Any future changes or additions to this policy will be duly noted.