Privacy Policy

1. Organization is committed to maintaining the privacy and security of the Personal Data of all visitors to this website BETADRIAN.lv (hereinafter Website) who have submitted their personal details. As part of that commitment, we have implemented this Privacy Policy to reflect the current needs of our visitors to know what information about them we collect, why we collect it, where it goes, as well as to satisfy regulatory requirements. Personal Data comprise any information about you that identifies you or by which your identity can be reasonably determined. For the purposes of the EU General Data Protection Regulation, the Controller is ABC INVITE SYSTEM LTD a Cypress company with registration number ΗΕ393000. ABC INVITE SYSTEM LTD is the subsidiary of INVITE SYSTEM BV registered in Curacao with registration number 148354 and ensures the best gaming experience.
2. Furthermore, INVITE SYSTEM BV and ABC INVITE SYSTEM as we. Service is registration in BETADRIAN and the use of any of the gaming services provided or refusal from registration (therefore Service).

1. For the purpose of processing of personal data, the Personal Data controller is: INVITE SYSTEM BV Registry code: 148354 Address: Johan Van Walbeeckplein 24 Willemstad, Curaçao E-mail: [email protected] If you have any questions regarding the processing of Your Personal Data, please contact us by using the e-mail address mentioned above.

1. Your Personal Data are information that can be used to identify you directly or indirectly, contact or locate you as an individual (hereinafter Your Personal Data). The processed Personal Data categories are as follows:
   • BETADRIAN processes Your Personal Data related to your registration on www.betadrian.lv or totalizator and betting shops: name, date of birth, personal identification number, email, phone number and other contact information, language, user ID, date and time of registration and access, etc (hereinafter Registration data). The source of the processed Personal Data: Your Personal Data, received upon registration to BETADRIAN.
   • BETADRIAN processes Your Personal Data in order to complete your registration and verify your rights and legal capacity to use the Service: name, user ID, type of identity document, copy of ID document, document validity information, citizenship country, nationality, address, language, currency, phone number, email, information on the account or e-wallet of a credit institution or payment institution, date and time for using the Service, etc (hereinafter Identification data). The source of the processed Personal Data: Your Personal Data, received upon registration to BETADRIAN and Your Personal Data, received from identification service providers.
   • BETADRIAN processes Your Personal Data in order to comply with the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and Law on International Sanctions and National Sanctions of the country of Curacao and Cypress; to identify whether you are a politically exposed person or person closely related to a politically exposed person; and whether we can or cannot provide you our Service and to report unusual and suspicious transactions to regulatory authorities: name, date of birth, personal identification number, ID document details, personal transaction details (amount, type of bill, type of transaction), signature, phone number, email address, residence address, a copy of the ID document, information on political status, information on the beneficial owner, sources of income and the related information etc (hereinafter AML data). The source of the processed Personal Data: Your Personal Data, you provide directly to BETADRIAN and Your Personal Data, received from the financial and client identification service providers.
   • BETADRIAN processes Your Personal Data, in order to provide you a Service: self- exclusion data, gaming-exclusion data, automated behavioral monitoring analytical tool to identify high-risk gamblers who have not yet been diagnosed with addiction, user ID, bet or forecast ID, currency, bet or forecast amount, current balance, game / tournament ID, seller ID, bet or forecast type, bet or forecast status, expected win amount, bet result date, win amount, payout amount, tournament revenue, lots, gambling history, authorization data, IP-address, gender, contact information, date and time of using the Service, etc (hereinafter Gambling Data). The source of the processed Personal Data: Your Personal Data, received from you or generated while you use the Service, Your Personal Data, gathered from the databases available to BETADRIAN in relation to providing the Service, including from the Register of individuals refraining from engaging in gambling and interactive lotteries.
   • When you visit www.betadrian.lv, BETADRIAN processes Your Personal Data related to: 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, video data from land-based betting venues, accounting records, references, etc (hereinafter Technical data). The source of the processed Personal Data: while browsing www.betadrian.lv, where the Website itself generates or collects the Technical Data from your device automatically or while being at land-based betting venues, as you are being videotaped, and Your Personal Data is being documented in receipts and accounting records.
   • BETADRIAN processes Your Personal Data when you are contacting us using Website’s www.betadrian.lv chats bots, email, mail or failing a complaint: the content of your message, email address or contacts of social media, details and content of a document (hereinafter Communication Data). The source of the processed Personal Data: Your Personal Data, provided by you directly.
   • BETADRIAN processes Your Personal Data in order to get started the Service related money transfers: name, user ID, banking, payment institution or e-wallet number, transaction amount, prize description, date time of the transaction, etc. (hereinafter Money data). The source of the processed Personal Data: Your Personal Data, which you provide us, by demanding to perform money transfer and Your Personal Data, received from payment service providers.
   • BETADRIAN processes Your Personal Data in means of communication: name, gender, date of birth, contact information, date and time, when the communication has been received, etc (hereinafter Communication data). The source of the processed Personal Data: Your Personal Data, which you are providing upon registration regarding the choice of communication and directly or indirectly whilst using the Service.
   • BETADRIAN processes Your Personal Data in order to improve the providing of Services: user ID, gambling turnover, date of using the Service, survey information and different kind of personal data, except sensitive data,which you provide us with, etc (hereinafter Customer support data). The source of the processed Personal Data: Your Personal Data, which you provide us with directly or indirectly.
   • BETADRIAN processes Your Personal Data in order to ensure compliance with the applicable laws on archiving and accounting requirements: name, transaction information, personal identification number, contact information, etc (hereinafter Administrative data). The source of the processed Personal Data: You Personal Data, which you provide us with while using the Service.
   • BETADRIAN processes cookies. Please see section “Cookie policy” (hereinafter Cookie data). The source of the processed Personal Data: Your Personal Data, which you provide us with indirectly while browsing our Website www.betadrian.lv.

1. The basis and aim of the processing of Your Personal Data is based on:
   1. Compliance with legal requirements - we have to process Your Personal Data in accordance with applicable law and it is not a matter of choice by you or us whether to obey the compliance with laws;
   2. Execution of mutual agreement – agreements, general rules, individual provisions, etc, which are respective to you and us and to which you have agreed upon when registering for or using Service.
   3. Our and society legitimate interests;
   4. Your consent, with an aim to constantly improve or update our offer for you. For transparency and convenience we are indicating the purpose, basis and categories of processing, with a condition, that they are not exhaustive and are provided for convenience only. For any questions, please contact Personal data controller.

      Purpose of processing	Legal basis	Categories
      Customization of the content of communication information via email, SMS or phone	Consent, the execution of an Agreement	Communication data, Cookie data
      The registration of a player or registration of a player’s account	The execution of an Agreement	Registration data
      The identity, self-exclusion verification and identification whether you are a politically exposed person	Laws, including the Law on Prevention of Money Laundering and Terrorism and Proliferation Financing and Law on International Sanctions and National Sanctions of the Republic of Cypress	Identification data, AML data
      Record keeping about the bets or forecasts made by you, funds transferred to us for making the bets or forecasts, refunds made, and monetary transfers made to you, your bank account number	Laws, including Law on Gambling and Lotteries and the Law on Prevention of Money Laundering and Terrorism and Proliferation Financing	Gambling data, Money data
      Improvement and development of the Website and the Service	Legitime interest or Your consent	Technical data, Cookie data, Client support data, Communication data
      Client service and communication	Legitime interest	Communication data, Client service
      Transfer of funds to/from your online Service account	Execution of agreement	Gambling data, Money data
      Tracking and registration of suspicious customer transaction or customer transaction starting from 2000 € pursuant to the AML policy. Reporting to The Financial Intelligence Unit of Cypress regarding suspicious financial transactions	Laws, the Law on Prevention of Money Laundering and Terrorism and Proliferation Financing	All data
      Analysis of statistic	Legitime interest	Technical data, Cookie data, Gambling data, Customer support data
      Data transfers to separate data controllers for receiving verification, payment and fraud prevention services	Legitime interest	Technical data, Money data, Gambling data, Identification data, Money data
      Providing the online gaming environment as a Service for casino, poker or sports betting	Execution of agreement	Cookies data
      Ensuring the safety of the Service by detecting and preventing the use of interfering software, devices, techniques, etc	Legitime interest	Registration data, Technical data, AML data, Gambling data, Identification data, Money data, Client support data, Cookie data
      Storing materials containing Personal Data in BETADRIANS’s backup systems	Laws, Law on Gambling and Lotteries, legitime interest	All data
      Erasure of Your personal data	Laws, Law on Gambling and Lotteries, the Law on Prevention of Money Laundering and Terrorism and Proliferation Financing	All data
      Automated behavioral monitoring analytical tool to identify high-risk gamblers who have not yet been diagnosed with addiction	Legitime Interest	Gambling Data, Money Data

      We may process Your Personal Data for other purposes provided and before the processing of the data we discloses the purposes and use to you, and in a case where your consent is needed, except if the new purpose essentially is identical to a pre-existing purpose.

1. BETADRIAN may sometimes apply automated processing to Your Personal Data.
2. In the following situations we may apply automated decision making according to applicable law for the performance of the mutual agreement:
   • Verifying your identity and allowance of providing access to the Service upon registration of the player account on www.betadrian.lv, upon registering to the Service on the Website, we may verify via automated decision whether you meet the criteria for registering the user account and accessing the Service. The decision-making process may entail 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. Your Personal Data is usually directly made available by you or gathered from the databases available to 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 authorized or declined;
   • User payment verification - according to applicable laws we are obliged to check whether your payment account details match the user account details you have provided for the use of the Service. Your Personal Data subject to such automated decision are the banking, payment institutions or e-wallet account details (name, banking account number). As a result of the automated decision any money transfer to your user account or to you is completed or declined.
   • Compliance with the rules which you have accepted and to which you must adhere to - we analyse your activities on www.betadrian.lv and in the Service in order to detect breaching activities of the applicable laws.
   • Risk assessment and compliance with the Service rules: we do not allow access to the Service to third parties, trying to compromise the code, change the gambling software and other referred activities and, thus, applies active measures to avoid the use of scripts, bots and other devices and techniques interfering the fair play. To combat interferences of fair play, we may analyse your activities
   • On www.betadrian.lv and in the Service. For such analysis we mainly rely on the Technical Data and Gambling Data. We compare such Personal Data against Your Personal Data previously collected by us or received from third party service providers about you or your device. As a result of the automated decision, BETADRIAN 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.) even if we have the slightest doubt that the activity is non-compliant.
     Detection of an unfair game - pursuant to applicable laws, we might be obligated to detect and deter activities relating to breaches of law or unfair gaming. For this purpose, BETADRIAN or a fraud prevention service provider compares your device’s online identifiers (e.g. Technical Data and Cookie) and Gambling Data against similar types of Your Personal Data previously collected about you or your device used to access the Website. If it is detected that your account or device has fraudulent pattern or is connected to breaches of law, as a result of the automated decision, BETADRIAN may restrict your access to the Service.
     Prevention of gambling addiction – Analytical processing of automatic behavioral monitoring of gambling data, which allows identification of risky gamblers and participants of interactive lotteries who have not yet been diagnosed with addiction.
   • The automated decisions described above usually take place without an intervention of BETADRIAN employee. You have the right to obtain an intervention of BETADRIAN employee in regard to the decision making; express your point of view in regard to such decision and contest the decision.

1. Your Personal Data shall be stored insofar as reasonably necessary to attain the purposes stated in this Policy, or until the applicable law stipulates that we do so. For example:
   • AML data – 5 years from the day since we terminate the agreement, except Gaming data (they are erased after 5 years since they were created);
   • Registration data, Identification data and Gambling data – 5 years from the last activity of the player on www.betadrian.lv;
   • Money data – 6 years after the transactions of 31 of December, that are registered in that particular year until the 31 of December;
   • Communications data – after terminating the agreement, except the particular content of the communication, that is stored for 3 years;
   • Technical data – the term is 30 days from the moment of the data collection;
   • Cookies data – as per Article 9;
   • All other data – 5 years from the day when they are received.
2. The retention period may be extended if neccessary after a decision of BETADRIAN in order to comply with our legal requirements, resolve disputes and enforce the agreement or to anonymize Your Personal Data and retain this anonymized information indefinitely
3. The backed-up materials are put beyond the use, i.e. are not processed for any other purpose, and the materials are deleted by BETADRIAN as soon as possible, i.e. after the end of BETADRIAN’s backup cycle, Your Personal Data will be destroyed. During the backup period, appropriate safeguards are applied to the materials in the backup.

1. At any given moment You may exercise the following rights with respect to our processing of Your Personal Data by contacting us.

   Rights	Explanation
   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
   To rectificate	You have the right to request that we correct any of Your Personal Data if it is inaccurate or incomplete
   To object	You are entitled to object to certain processing of Your 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
   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 Your Personal Data; (iii) receive or avoid deletion of Your Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of BETADRIAN's legitimate interest in the specific processing activity
   To erasure	You may also request Your Personal Data to be erased if Your 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 Your Personal Data has to be erased to enable us to comply with a legal requirement
   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 you're your Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that Your Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible
   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
   To submit your claim with the supervisory authority	If you are not satisfied with our response to your request in relation to Your Personal Data or you believe we are processing Your Personal Data not in accordance with the law, you can submit your claim with the Cypressn Data Protection

1. BETADRIAN discloses Your Personal Data to third parties only in accordance with this Policy, internal data processing and to persons authorised to process Personal Data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality according to applicable laws or if you have given consent to such disclosure. BETADRIAN may disclose Your Personal Data to the following recipients (including data processors) in its data processing activities:

   Type of the recipient	Purpose of disclosure	Location of the recipient
   On-line gambling service providers	Providing on-line gambling (Personal Data are being disclosed in a summarized form, that lets You to remain unidentified)	European Union, United Kingdom of Great Britain and Northern Ireland and Gibraltar
   Identification and authentication service providers	Providing identification and authentication services to provide you access to the Service; and deter and detect fraud	European Union, United Kingdom of Great Britain and Northern Ireland and Gibraltar
   Payment service providers (including payment institutions, e.g. banks) and other money transfer service providers	Transfer of funds from a payment service to your online Service account and transfer of the winning amount payment to your account	European Union
   Law enforcement and data protection authorities	Execution of a legitimate legal request if the request has been submitted by a competent national authority	European Union
   Operational service providers (legal advisors, accounting etc. bound to confidentiality)	Legitimate interests in ensuring BETADRIAN’s economic activity; conducting of regular business activities	European Union
   IT-services providers	Providing IT solutions necessary for operating the economic activity of BETADRIAN or Service	European Union
   Third party service providers	Certain services related to Service enhancements or user-friendliness enhancements	European Union
   BETADRIAN group entities, Entain plc group	For the purposes utilising the shared administrative infrastructure and business development purposes	European Union, United Kingdom of Great Britain and Northern Ireland and Gibraltar

2. BETADRIAN does not transfer Your Personal Data outside European Union or European Economic Area, united Kingdom and Gibraltar however BETADRIAN reserves the right to transfer the Data outside European Union or European Economic Area in certain 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 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 Policy.

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