Privacy Policy

GDPR – 09042020 - v.1.0

Gaming1 strives to protect personal data. We therefore take all the necessary action to protect the privacy of those who visit and use (hereinafter referred to as the “Users”) the Gaming1 website (hereinafter referred to as “the Site”).

Users will find below the provisions regarding the processing of personal data which apply during any visit to or use of the Site by the Users (hereinafter referred to as the “Privacy policy”).


1. Background

Gaming1 processes personal data belonging to Users of the Site for the purposes and within the limits of the Privacy policy, during any visit to or use of the Site.

When processing personal data, Gaming1 shall comply with current laws and regulations, namely Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter “the Regulation”).

In this respect, and pursuant to this Regulation, Gaming1 :

  • shall process the personal data set out and for the purposes given in Article 2, further to the prior, free and express consent of Users; and
  • shall also process personal data to enable Users to use the Site and for the necessary and legitimate purposes set out in Article 3 of the Privacy policy.

By accessing and using the Site, Users are deemed to have read and accepted the Privacy policy.


2. Processing of personal data subject to prior consent of Users

By visiting or using the Site, for any reason whatsoever, the User expresses their free, individual, informed and unambiguous consent to expressly authorise Gaming1 to process personal data pursuant to the Regulation, within the limits of and for the purposes set out below and without prejudice to the data processing stipulated in Article 3.

Personal data provided by the User is held in a record which is controlled by and remains the responsibility of Gaming1 at all times, as set out in Article 7.1.

2.1. Nature of the personal data processed

Gaming1 processes the following personal data:

  1. Surname(s), first name(s), company name, domicile/address, email address, landline or mobile telephone number;
  2. Data related to cookies, in accordance with article 7.3;
  3. Any other information that may be exchanged between Gaming1 and the User, namely by email, during the User’s registration or use of on the Site.

2.2. Data processing

The processing consists of collecting, recording, retaining, consulting, organising, using and cross-referencing the personal data set out in Article 2.1.

2.3. Purposes for processing the personal data

The personal data is collected and processed by Gaming1 for the following purposes:

  1. To release new games and betting B2B offers;
  2. To conduct satisfaction surveys, statistical studies, trend analyses, and market research in order to improve gaming and betting services;
  3. Promoting, advertising and marketing activities related to the B2B offering of gaming and betting services, which includes processing of personal data by third parties.

3. Processing of personal data which is not subject to the user's prior consent

Gaming1 shall also process the following personal data for the legitimate purposes set out below. This processing of personal data carried out by Gaming1 does not require the User's consent under Article 6.1.f) of the Regulation.

Personal data provided by the User is held in a record which is controlled by and remains the responsibility of Gaming1 at all times, as set out in Article 7.1.

3.1. Nature of the data processed

Gaming1 processes the following personal data:

  1. Surname(s), first name(s), company name, domicile/address, email address, landline or mobile telephone number;
  2. Any other information that may be exchanged between Gaming1 and the User, namely by email, during the User’s registration or use of on the Site.

3.2. The data processing

The processing consists of collecting, recording, retaining, consulting, organising, using and cross-referencing the personal data set out in Article 2.1.

3.3. Legitimate purposes of the data processing

Gaming1 shall process personal data set out in Article 3.1 for the following legitimate purposes:

  1. To promote, advertise and market B2B gaming and betting offered by landbased and online gambling operators;
  2. To conduct satisfaction surveys, statistical studies, trend analyses, and market research in order to improve gaming and betting services.

4. User rights

Users may exercise their rights to request that their data be rectified, to object to it being processed and to limit the processing, according to the terms and within the limits set out below. 

4.1. Right of access

Gaming1 shall provide Users with the following information:  

  • The name and contact details of the data controller:
  • The contact details for the data protection officer;
  • The personal data processed;
  • The purposes for which the personal data is being processed and the legal basis for this processing;
  • The recipients or categories of recipients of personal data, as appropriate;
  • If relevant, the fact that the data controller intends to transfer personal data to a country outside the European Union and: either the fact that the European Commission has adopted an adequacy decision (or not), and if such a decision has not been adopted, the guarantees offered by the non-EU country and the resources in place for obtaining copies of the personal data.
  • The option to object to the automated processing of their data, including profiling, unless there are justified grounds requiring Gaming1 to process this data, as well as the option to object to any processing of their personal data for marketing purposes.

  1. Users have the right to request to be provided with the information referred to in this Article and in Articles 2.1 and 3.1.
  2. Users may obtain a copy of any personal data that is processed. For any additional requested copy, Gaming1 reserves the right to claim payment for any expenses incurred in this new request. These expenses shall be calculated on the basis of the administrative costs incurred in the request and shall not exceed 20 euros.
  3. Users shall have the right to access the information or a copy thereof in a structured format, such that the personal data is provided to them in a format that meets the technical standards in place when the request for access was made. This format shall therefore allow for automatic readability.  

4.2. Right to request rectification

Gaming1 guarantees and compels Users to update and rectify their personal data if this data becomes incorrect or incomplete.

4.3. Right to object to the processing of data

Gaming1 allows Users to object to their personal data being processed in full or in part on the following grounds:

  • The data is inaccurate;
  • The processing is no longer required for the purposes for which the data was collected;
  • The User has withdrawn consent;
  • The data has been processed illegally.

In addition, Gaming1 allows Users to object to:

  • the automatic processing of their data, unless there are justified grounds requiring Gaming1 to perform this processing;
  • any processing of their personal data for marketing purposes, including profiling if it is linked to this marketing.

4.4. Right to be forgotten

Gaming1 also undertakes to follow up any request to erase personal data at the earliest opportunity (right to be forgotten), when: 

  • the processing is no longer required for the purposes for which the data was collected;
  • the User has withdrawn consent;
  • the data has been processed illegally or must be erased pursuant to a legal obligation;
  • the User objects to the automatic processing of their data, such as profiling, and there are no justified grounds requiring Gaming1 to perform this processing;
  • the User objects to the processing of their personal data for marketing purposes, including profiling if it is linked to this marketing.

4.5. Right torestriction of data processing

Users also have the right to restrict Gaming1’s processing of their personal data when:

  • the User believes the personal data to be inaccurate, whilst Gaming1 checks the accuracy of the information;
  • the processing is illegal and the User does not wish for their data to be erased but requests to limit the processing thereof;
  • the User objects to automatic processing, including profiling or to the processing of their personal data for marketing purposes and it is necessary to verify the legitimacy of Gaming1’s reasons for seeking to continue this processing;
  • Gaming1 no longer requires the personal data processed but the data subject would like it to be held to establish, exercise or defend legal claims;

4.6. Transferring data to a data controller

Users may transfer the personal data processed by Gaming1 to another data controller without objection from Gaming1.

For such a transfer to be technically possible, Users may ask Gaming1 that it be performed directly by its data controller.

4.7. Modalities

The rights recognised to the User must be exercised in accordance with the modalities defined by Article 7.5. Gaming1 shall respond to such requests for information within (1) one month.

4.8. Notification

Gaming1 shall notify the User of any data that is erased or rectified in accordance with Article 4, unless such notification proves impossible or involves disproportionate efforts.

This notification shall be sent by letter or email, using the contact details provided by the User.


5. Location, retention and retention period of personal data

Gaming1 retains Users’ personal data appropriately and securely in a form which enables it to be identified and made available.

The data is retained and hosted in Belgium. Gaming1 provides all of the required or useful security assurances with regard to current technical standards.

Users’ personal data is retained by Gaming1 for the purposes set out in Articles 2 and 3 for a period which does not exceed the timeframe needed for the realisation of the purpose of the processing, for all the purposes governed by Articles 2 and 3.


6. Liability of Gaming1 – Data processor  

6.1.

Gaming1 ensures that the processing of personal data is carried out in a lawful, loyal and transparent manner with regard to the User concerned. Any data processing operation performed by Gaming1 shall comply 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 this Privacy policy.

Gaming1 shall implement all reasonable and appropriate means to ensure the confidentiality, integrity and availability of the personal data it processes. These namely technical and organisational measures are explained in the data protection manual which may be obtained from the contact person detailed in Article 7.5.

Technical measures include the anonymisation and encryption of personal data, depending on the purpose.

Organisational measures include carrying out internal audits, in addition to audits to which Gaming1 may be subject by the Belgian or Maltese Gaming Authorities.

If necessary, Gaming1 and the data protection officer shall carry out an impact assessment when the data processing is likely to pose a high risk for Users.     

6.2.

Users’ personal data is not sent to any third parties other than partners of Gaming1, except if:

  • the data transfer is made mandatory by a law or regulation or when ordered by an administrative or judicial authority;
  • the data transfer proves necessary for the supply of online gaming and betting services, or maintenance services;
  • the User has consented to such a transfer.

Gaming1 shall not be held liable for the processing of Users' personal data by partners who supply their services in their own name and shall be liable for damage caused by processing personal data contrary to the Regulation.

To the extent the processing is carried out by a partner on behalf of Gaming1, the processor shall provide sufficient assurances that appropriate technical and organisational measures have been implemented and, more generally, that the Regulation has been complied with. In particular, the processor is required to comply with the Regulation and, therefore, keep a record of processing activities.


7. Miscellaneous

7.1. Record of personal data

As a personal data controller, Gaming1 keeps a register of all of its data processing activities. This register contains all of the information about the type of data processed, data subjects, potential data recipients, the purposes of the data processing and how long the data shall be retained for, as well as a general description of the technical and organisational security measures in place.  

This record is controlled by and remains the responsibility of Gaming1 at all times. In addition to the information above, this record includes:

  • a description of the purposes of the processing;
  • a description of the categories of data subjects and categories of personal data;
  • the categories of recipients to whom the personal data has been or shall be sent, including recipients in non-EU countries or international organisations;
  • the deadlines for erasing various categories of data.

7.2. Entire agreement - modification of the Privacy policy

The Privacy policy contains all of the contractual provisions binding Users, without prejudice to the legal terms of the Site of which they form an integral part. The legal terms of the Site shall remain applicable for any matters that do not relate to the Users' personal data protection. 

In addition, Gaming1 reserves the right to modify the Privacy policy. Any updates are enforceable against Users once published on the Site. Gaming1 undertakes to state the date on which the Privacy policy that appears on the Site was put online.

7.3. Cookies and trackers policy (analytical data)

  1. A “cookie” is a set of data that the Site records temporarily or permanently on the User's system by means of their web browser.
    The Site uses cookies in order to make browsing more effective, useful and reliable. Some of these cookies are vital for the website to function; others are designed to improve the gaming and betting experience and the browsing of the Website.
    A “tracker” is a set of data collected during the browsing on the website and centralised on a partner server.
  2. By accessing and using the Site, users expressly agree to the cookies and trackers utilisation policy of Gaming1.
  3. The Site uses the following data (cookies and trackers):
    • Cookies necessary to use the Website: these are cookies technically required for operating the Website, as they ensure good communication with the User and facilitate browsing.
    • Functional cookies: they improve the browsing and facilitate Users’ access to their searches. They therefore enable the specific functionalities on the Website to be activated and improve its user-friendliness and the User's experience, including by remembering their preferences (language, for example);
    • Functional cookies: they improve the browsing and facilitate Users’ access to their searches. They therefore enable the specific functionalities on the Website to be activated and improve its user-friendliness and the User's experience, including by remembering their preferences (language, for example);
    • Trackers: the Website uses tracking data via Google Analytics, in order to measure the ways users interact with the Website's content; they enable User recognition and counting, inform about Users’ browsing behaviour on the Website and generate website visit statistics, which may or may not be anonymous. These statistics enable us to continually improve the Site and offer the User appropriate content.
    • The Website uses Google Analytics to get an overview of the traffic on the Website, the origin of this traffic and the pages visited. This means that Google acts as a subcontractor of Gaming1. The information gathered by Google Analytics is generated as anonymously as possible. For example, it is not possible to identify the persons who visit the website. For further information, the User is invited to consult Google's data protection policy, available at the following address: http://www.google.nl/intl/en_uk/policies/privacy/
  4. How can cookies and trackers be deactivated?
    1. Most web browsers are configured to automatically accept cookies. Therefore, if Users wish, within the limits provided in article 7.3, c), to refuse use of cookies or personalise cookie management, they must change their browser settings.

      If the User deactivates certain cookies, certain parts of the Site may not be viewable and/or usable, or may be only partially so.

      The browser can be set to send an alert when a cookie is about to be used so that the User can decide whether to accept it or not. 

      If the User wishes to block cookies, they must use the appropriate link for their browser:

    2. In order to cease to be tracked by Google Analytics on any website, you can go to the following website: http://tools.google.com/dlpage/gaoptout

    7.4. Contact – Information on the identity of the data controller and data protection officer

    Gaming1 may be contacted for any questions regarding the protection of Users’ personal data via the following:

    • Mail: Rue Saint-Exupéry, 17 bte 13, 4460 Grâce-Hollogne, Belgium
    • Email: [email protected]
    • Telephone: +32 4 228.32.00

    The data controller within Gaming1 is Mr. Sylvain BONIVER.

    Gaming1 has also appointed a data protection officer in accordance with Article 37 of the Regulation cited above. This person may be contacted by email: [email protected]. The data controller and data protection officer are responsible for ensuring that processing of Users’ personal data by Gaming1 is monitored and complies with legal requirements.   

    7.5. Data protection authority

    Pursuant to 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, the User has the right to request additional information or lodge a complaint with the relevant data protection authority.  

    The contact details for the Belgian data protection authority are as follows:

    • Autorité pour la protection des données
      Address: Rue de la Presse, 35, 1000 Brussels, Belgium
      Telephone: +32 2 274 48 00
      Fax: +32 2 274 48 35
      Email: [email protected]