This Privacy Policy (hereinafter referred to as the “Policy”) outlines the manner in which Vana Lauri OÜ, a company registered under the laws of Estonia, under the company registration number 16427120 (hereinafter referred to as the “Company” or “We”, or “Us”), having its registered office at Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 7, 10145 handles its players’ personal data and other information (hereinafter referred to as “You” or the “Player”).
This Policy applies to Our websites, applications, products and/or services that link to this Policy or do not have a separate privacy policy (hereinafter referred to as Our services). This Policy is intended to give You a better understanding of the data We collect, the reason why We collect such data, the manner in which We process this data, the entities with whom We share the said personal data, Your rights in relation to the collection, processing and sharing of such data and any other pertinent matter relating to privacy and security.
Any personal data You will provide or which We already hold will be processed in line with and in the manner set out in this Privacy Policy. Any and all information will be provided through the Company website (namely www.lataamo.com, hereafter referred to as the “Website”), the designated telephone numbers or any other means which the Company may make available from time to time.
By reading this Policy You understand and acknowledge that Your personal data may be processed in the manner set out in this Policy. If You do not agree with the terms of this Policy please do not use the Website or otherwise provide Us with Your Personal Data.
All processing of Personal Data performed by the Company as envisaged in this Privacy Policy shall be carried out in line with:
– Regulation (EU) 2016/679 of The European Parliament And of The Council of 27 April 2016 On The Protection of Natural Persons With Regard to The Processing of Personal Data And On The Free Movement of Such Data, And Repealing Directive 95/46/EC (General Data Protection Regulation)” (hereafter referred to as the “Regulation” or “GDPR”).
The DPA and the GDPR shall hereafter be collectively referred to as the “Data Protection Laws”.
The Company determines the means and purposes of the processing of Personal Data and therefore acts as the “Data Controller” in terms of the applicable Data Protection Laws.
DEFINITIONS
The Data Controller
“Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
The Data Processor
“Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Personal Data
“Personal Data” means any information that identifies You individually or relates to an identified or identifiable natural person.
SECURITY
We understand the importance of data security measures and techniques and strive to ensure that Your data is safe with Us. We have put in place several measures to protect Your data from unauthorised access to and alteration as well disclosure and destruction of information.
We have implemented safeguards for the protection of your personal data against unauthorized use, changes, access or disclosure. Our security measures ensure that your data is not accidental or illegally destroyed.
We maintain strict security measures on the website and its associated sites, so that no unauthorized use, loss or alteration of data can be done to player account. Only authorised persons with special access rights have access to the database.
Financial information like credit or debit card data will not be stored in the website, and all credit and debit card transactions are stored for the purpose of processing the payments by a certified payment service provider.
The Player Account can only be accessed with a unique username and password. The password will be stored in the system in encrypted form.
All personnel are subject to confidentiality clauses in addition to the obligation to follow our internal code of conduct, information security policy and data protection policy.
PERSONAL DATA PROTECTION
Personal Data held by Us is protected using the highest industry standard security processes and systems. Our commitment to protect personal data is not merely through quality and high standards but also through the best and most efficient application of the law. We are bound to only process personal data if such processing is based on a genuine and legitimate reason to do so on the basis of one of the legal grounds established in the GDPR.
PROCESSING ON THE BASIS OF OUR LEGITIMATE INTERESTS
A legitimate interest exists when We have a business or commercial reason upon which personal data will be processed. In such a case We undertake to protect any and all of Your personal data and the manner in which such data is processed and to ensure that such processing would not be unfair to You or to Your interest.
If and when We decide to process Your personal data on the basis of legitimate interest, We will inform You of such, what said legitimate interest are and provide a process whereby You will be able to raise any questions and/or objections which You way have in relation to such processing. It is important to note that The Company is not obliged to stop processing if the grounds for processing over-ride Your right to object.
PROCESSING ON THE BASIS OF YOUR CONSENT
Consent is not the only ground we may be permitted or obliged to rely on to process Your personal data. We will only process personal data on the basis of Your consent where we cannot or otherwise choose not to rely on any ulterior legal ground (such as compliance with a legal obligation or legitimate interest). Where we process Your personal data on the basis of Your consent, you shall have the right to withdraw your consent at any time and in the same manner as it had been previously provided by Yourself. In the case that You exercise Your right to withdraw consent, we would then determine whether we are able (or obliged) to process Your personal data on the basis of any other legal ground other than consent. If this is the case We will notify You accordingly. Any such withdrawal of Your consent will not invalidate any processing operations carried out prior to You having withdrawn Your consent.
DATA RETENTION POLICY
Any and all personal data the Company will keep will be protected in the best way possible and will only be used for purposes which are compatible with the applicable Data Protection Laws as well as any other applicable laws. The Company will retain Your Personal Data only for as long as is necessary (taking into consideration the purpose for which it was originally obtained). The criteria We use to determine what is ‘necessary’ depends on the particular Personal Data in question and the specific relationship We have with You (including its duration).
Generally, Our normal practice is to determine whether there is/are any specific EU and/or Estonia law(s) (for example tax or corporate laws) permitting or even obliging Us to keep certain Personal Data for a certain period of time (in which case We will keep the Personal Data for the maximum period indicated by any such law). For example, any data that can be deemed to be ‘accounting records’ must be kept for ten (10 years). We are also subject to a number of rules specific to the gaming sector – for example, responsible gaming/gambling rules. In some cases (for example, in the case of permanent self-exclusions) we are legally obliged to retain your personal data (name, surname, date of birth etc.) on an indefinite basis and this, in Your own best interest.
We would also have to determine whether there are any laws and/or contractual provisions that may be invoked against Us by You and/or third parties and if so, what the prescriptive periods for such actions are (this is usually five (5) years). In the latter case, We will keep any relevant Personal Data that We may need to defend Ourselves against any claim(s), challenge(s) or other such action(s) by You and/or third parties for such time as is necessary.
Where Your Personal Data is no longer required by Us, We will either securely delete or anonymise the Personal Data in question.
Failure to provide Your Personal Data may prevent The Company from meeting its legal and regulatory obligations, fulfilling its contractual obligations and rendering and/or performing the necessary services needed to satisfactorily manage and maintain Your account. Therefore, failure to provide the
necessary personal data may lead to The Company being unable to provide its products and/or services.
PERSONAL DATA WHICH WE COLLECT, PURPOSE OF THE PROCESSING & LEGAL BASIS OF THE PROCESSING
The following table outlines the categories of personal data which We process, the purpose for which We process such data as well as the corresponding legal basis used for such processing. It is pertinent to know that the same categories of personal data may be processed for different purposes and therefore on the basis of a various legal grounds simultaneously depending on the purpose of processing.
| CATEGORIES OF PERSONALDATA | PURPOSE OF THE PROCESSING | LEGAL BASIS USED FORPROCESSING |
| Contact data (Ex: Name, Surname, mailing address, telephone/mobile number, email address) Registration data (Ex:Username, password, date of birth, country of residence, Gender)Financial Data (Ex: Bank details, credit card details, transaction information) | To set up an account on Our system and register you as a new user. To enforce our terms and conditions. | Contractual Necessity Legitimate Interest (ensuring we maintain an accurate record on Our system) |
| Contact data Registration data Financial dataIdentity & Age verification data (Ex: name, surname, address, date of birth, identity card/passport number) | To manage our ongoing relationship with you and provide You with customer care services. AML and Due Diligence purposes. Conduct KYC investigations (e.g. verifying identity, age, address and if You are a politically exposed person) and other investigations during the customer relationship. Age, identity and contact details verification. | Contractual Necessity Compliance with a legal obligation |
| Contact data Registration dataFinancial data | To fulfil Our obligations on reporting to regulators / lawenforcement authorities | Compliance with a legal obligation |
| Contact data Registration data Financial dataIdentity verification data (Ex: name, surname, address, date of birth, identity card/passport number) | To establish and investigate any suspicious behaviour in order to protect our business from any risk and fraud | Legitimate interest (detection and prevention of fraud) |
| Contact data Registration data | To subscribe to a newsletter , campaigns and/or to be addedto a mailing list | Your consent |
| Contact data Registration data | Monitoring and evaluation of Your gambling behaviour/habits and activities for personalized offers,bonuses and user interface. | Your consent |
| Responsible Gaming Data (Ex: Name, Surname, mailing address, telephone/mobile number, email address, data of birth, country of residence, transaction history, transaction attempt history, self-exclusion status) | To adhere to Our Responsible Gaming and/or Self-exclusion obligations | Compliance with a legal obligation |
| Contact data Registration data | To present You Offers , Promotions and newServices/Games | Your consent |
| Contact data Registration data | To participate in any online survey or poll | Your consent |
| Contact data Registration data Financial data | To Perform statistical analysis in order to improve and upgrade Our current services/games, and developupdated or new games. | Legitimate Interest (Service Reports & Business Development) |
| Financial data | To execute and managepayment transactions | Contractual necessity |
| Contact data Registration data Financial data | Monitoring and evaluation of transactions and bets, control and comparison of such information for accuracy andverification with third parties. | Legitimate Interest (Ensuring the accuracy and legal nature of the information provided ) |
| Contact data Registration data Financial data | To allow You to take part in any potential loyalty scheme on Our site | Legitimate interest (loyalty program purposes) |
| Data required for marketing purposes (Ex: Name, Surname, mailing address, telephone/mobile number, email address, proof of opt-in consent (where required), proof of objections to marketing, website data and online identifiers (such as IP address, and other information generated by Your browser)) | To provide You with marketing material that You have requested from Us or that we are otherwise authorised to send You. To personalise Your customer experience. | Your consent (where required) OROur Legitimate interests (for marketing purposes, where We do not require Your consent & to improve Our services) |
| Online Activity Data (Ex: traffic data, geo-location data, weblogs and communication data) | To detect and prevent fraud. To ensure that Our services are only provided to territories We are licenced to operate in. | Legitimate interest (detect and prevent fraud) Compliance with a legal obligation |
The Company may also collect personal data from publicly available sources such as web searches, company registers and broadcast media provided it is reasonable to do so and such conduct is not detrimental to Your rights and freedoms.
MARKETING AND EVENTS
Subject to any preferences You may have chosen (where applicable), personal information will be used to deliver marketing and event communications to You across various platforms. We will do this during the period of Your relationship with Us and, unless specifically instructed otherwise by you, for a reasonable period of time after the relationship has ended in order to inform You about products, services, promotions and special offers which We think may be of interest to you.
Whenever an email or SMS in relation to marketing is sent, it will include instructions on how to opt out of receiving these marketing communications in the future. You can also manage Your information and update Your marketing preferences through the “My Account” tab when You login to Your account. Please allow up to 48 hours for any changes You make to Your marketing preferences to be fully processed. Please remember that even if You opt out of receiving marketing emails, We may still send You important Service information related to Your accounts and subscriptions. We will, from time to time, send You marketing material which may be of particular interest to You based upon Your behaviours i.e. Your betting and gameplay activity, trends and interests. These marketing messages will provide You with information about the products, services, active promotions or offers available to You by any company within the Group and information about products and services provided by Our selected partners and third parties.
Except where We use Your personal data for marketing purposes on the basis of Your prior written consent and subject to any opt out preferences You notify to Us in respect of electronic direct marketing communications, We process personal data for marketing purposes as necessary for the purpose of Our legitimate interests in promoting Our products and services.
We may publish players’ aliases and/or chat names, along with any winnings and prizes received, on Our websites in accordance with Our legitimate interests.
PROFILING
We are taking numerous measures to meet the requirements under the rules around Anti Money Laundering, anti-terrorist financing, fraud and responsible gaming. In order to do this We may rely on programs that monitor player behaviour. We may also use segmentation in order to divide Our Players into groups based on the behaviour, e.g. in the area of marketing.
In accordance with Our legitimate interests detailed below or to comply with Our legal obligations, We carry out profiling and analysis based upon Your location data, age, betting and gameplay activity, interests and behaviours for the following purposes:
Customer segmentation to offer You tailored products and services, and more relevant marketing. For example, if the majority of Your bets are placed on roulette, We will aim to primarily send You marketing material related to roulette.
You may contest a decision made solely by automated means, to express Your point of view and to request that a human review the decision.
COOKIES
When You visit Our Site, We collect certain categories of Personal Data automatically through the use of cookies and similar technologies.
For more detailed information including what cookies are and how and why We process such data in this manner (including the difference between essential and non-essential cookies) please read Our detailed but easy-to-read Cookie Policy at (link to be inserted).
OTHER PURPOSES
We may be required to use and retain personal information for; loss prevention; and to protect Our rights, privacy, safety, or property, or those of other persons in accordance with Our legitimate interests.
AUTHORISED DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES
Without prejudice to anything else contained in this Privacy Policy, personal data relating to You may be shared with authorised third parties located in or outside of the EU/EEA where such disclosures are permitted or required pursuant to Data Protection Laws and/or any other applicable legislation. These authorised third parties may include but are not limited to entities within the Company Group, other third parties and organisations such as law enforcement agencies, collaborating accounting firms, digital marketing providers, regulators, relevant authorities, credit reference agencies, fraud prevention and AML agencies, identity verification agencies and sports governing bodies. We may also share such personal data with organisations who have introduced You to Us, third parties which You have asked Us or permitted Us to share Your data with or any other third party which We must necessarily share Your personal data with so as to be able to provide the products and/or services which You have requested. The personal data shared will depend on the product/s and or service/s You choose to use. We may also share Your personal data within the Company Group for the purposes of developing and improving Our games/services and for developing additional services which will serve You and improve Your customer experience.
When any personal data has to be transferred outside of the EEA – European Economic Area, We ensure that all the necessary and appropriate safeguards are in place. We may also disclose personal
information to other companies within associated or subsidiary companies and to business partners, or successors in title to Our business. The manner in which data transfer outside the EEA is handled is detailed below. Your Personal Data will never be shared with third parties for their marketing purposes (unless You give Your consent thereto).
LINKS TO THIRD PARTY SITES
Links that We provide to third-party websites are clearly marked and We are not in any way whatsoever responsible for (nor can We be deemed to endorse in any way) the content of such websites (including any applicable privacy policies or data processing operations of any kind). We suggest that You should read the privacy policies of any such third-party websites.
TRANSFER OF DATA OUTSIDE OF THE EEA
Your personal data will only be transferred outside of the EEA or any other non-EEA country which has been deemed by the European Commission to offer an adequate level of protection (also referred to as “white-listed countries” – listed here https://ec.europa.eu/info/law/law-topic/data- protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en) in the following circumstances: When You have expressly consented Us to do so; when it is necessary to constitute or execute a contract entered between You and the Company; or to be compliant and in line with any and all legal obligations or duties.
In the event that personal data is transferred outside of the EEA, within the Company Group or to any of the Company’s business partners, We ensure to implement all appropriate safeguards to ensure that the same protection is afforded and the same standards are applied as would be within the EEA. You are entitled to receive a copy of such safeguards by contacting Us at the address below.
Contracts containing the EU Standard Contractual clauses (EU Model Clauses) will be used which require the entity receiving the personal data to use the same standards as they would be subject to within the EEA.
DATA SUBJECT RIGHTS
The Company undertakes to assist You in the best way possible should You choose to exercise any of Your rights with respect to Your personal data. In certain cases We might need to verify Your identity prior to acceding to Your request to exercise any relevant right.
Right of Access
You have a right to ask Us whether We are processing any personal data which concerns You and if this is the case, You shall have the right to access that personal data as well as the following information:
- What Personal Data We have,
- Why We process them,
- Who We disclose them to,
- How long We intend on keeping them for (where possible),
- Whether We transfer them abroad and the safeguards We take to protect them,
- What Your rights are,
- How You can make a complaint,
- Where We got Your Personal Data from and – Whether We have carried out any automated decision-making (including profiling) as well as related information.
Right to Rectification
You have a right to ask us to have any inaccurate or incomplete personal data relating to You rectified and/or completed.
Right of Erasure (the “right to be forgotten”)
You have the right to ask Us to delete Your Personal Data and We shall comply without undue delay but only where:
- The Personal Data are no longer necessary for the purposes for which they were collected; or
- You have withdrawn Your consent (in those instances where We process on the basis of Your consent) and We have no other legal ground to process Your Personal Data; or
- You shall have successfully exercised Your right to object (as explained below); or
- Your Personal Data shall have been processed unlawfully; or
- There exists a legal obligation to which We are subject; or
- Special circumstances exist in connection with certain children’s rights.
In any case, We shall not be legally bound to comply with Your erasure request if the processing of Your Personal Data is necessary to comply with a legal obligation imposed on Us.
Right to Restriction of Processing
You have the right to ask Us to restrict the processing of Your personal data. However, You are only able to exercise this right where:
- The accuracy of Your Personal Data is contested (see the right to data rectification above), for a period enabling Us to verify the accuracy of the Personal Data; or
- The processing is unlawful and You oppose the erasure of Your Personal Data; or
- We no longer need the Personal Data for the purposes for which they were collected but You need the Personal Data for the establishment, exercise or defence of legal claims; or
- You exercised Your right to object and verification of Our legitimate grounds to override Your objection is pending.
Should You successfully exercise this right, We would only be in a position to process Your personal data:
- Where We have Your consent; or
- For the establishment, exercise or defence of legal claims; or
- For the protection of the rights of another natural or legal person; or
- For reasons of important public interest.
Right to Data Portability
You have the right to ask Us to provide You with Your personal data which You would have previously provided to Us. We will provide You such data in a structured, commonly used, machine readable format, or (where technically feasible) We may have the data sent directly to another Data Controller, provided this does not adversely affect the rights and freedoms of others. You may only exercise this right where:
- The processing is based on Your consent or on the performance of a contract with You; and
- The processing is carried out by automated means.
Right to Withdraw Consent
For detailed information on this right, refer to “PROCESSING ON THE BASIS OF CONSENT” section, above.
Right to Object to Processing
In certain instances, You have the right to object to the processing of Your personal data. Where we are only processing Your personal data on the basis of one of the following purposes:
- The processing is necessary for the performance of a task carried out in the public interest; or
- When processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party,
the processing shall only cease where the Data Controller has not provided compelling and legitimate grounds which outweigh the objections raised by You in such a request and which require the processing to continue.
Where Your data is being processed for direct marketing purposes, You have the right to object to the processing of Your personal data at any time.
In all other instances apart from those listed above, this general right to object shall not subsist.
Right to Lodge a Complaint
As a Data subject You may at any time lodge a complaint with any relevant Data Protection Supervisory Authority should You feel that any of Your rights have been impinged by the Company. The Competent Supervisory Authority in relevant country is the Office of the Information and Data Protection Commissioner (‘IDPC’).
Notwithstanding this right, We kindly ask You to please attempt to resolve any issues You may have with Us prior lodging a complaint with the IDPC.
It is important to note that notwithstanding such rights, The Company may still refuse such request if it can reasonably justify such decision. Such refusal does not prohibit You from lodging a complaint with the relevant data protection authority.
COMPANY INFORMATION
If You have any questions/ comments about privacy or should You wish to exercise any of Your individual rights, please contact Us at: [email protected] by contacting Our Data Protection Officer.
