1. General
1.1. The organization is committed to maintaining the privacy and security of the Personal Data of all visitors to this Website who have submitted their personal details. As part of this commitment, we have implemented this Confidentiality (Privacy) Policy to reflect the current needs of our visitors, allowing them to know what information about them we collect, why we collect it, where it goes, and to meet regulatory requirements. Your Personal Data comprises any information about you that identifies you or by which your identity can be reasonably determined. SIA “NIKS", a Latvian company with the registration number 40003029864, is the controller of your Personal Data according to the EU General Data Protection Regulation.
1.2. SIA “NIKS” (hereinafter - “SPELET.LV” or “we”). The service provided is registration on the SPELET.LV website and the use of any gaming services provided, or the option to refuse registration.
2. PERSONAL DATA CONTROLLER
SIA “NIKS”
Registration number: 40003029864
Address: Terbatas street 73, Riga, LV-1001, Latvia
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.
3. WHAT PERSONAL DATA WE PROCESS
3.1. Your Personal Data is the information that can be used to identify you directly or indirectly, to contact you or locate you as an individual (hereinafter - Your Personal Data). The processed Personal Data categories are as follows:
3.1.1. Registration data: processes your Personal data, that are related to your registration on SPELET.LV: name, surname, date of birth, personal identification number, e-mail address, phone number and any other contact information you have provided, language, user ID, date and time of registration and access, etc (hereinafter - Registration data).
The source of the processed Personal Data: Your Personal Data, submitted upon registering on SPELET.LV.
3.1.2. Identification data: processes your Personal Data in order to complete your registration and verify your rights and legal capacity to use the Service: name, surname, user ID, type of identity document (ID), copy of the personal identification document, document validity information, citizenship, address, language, currency, phone number, e-mail address, credit institution account or payment institution account or e-wallet account information, the time for using the Service, etc (hereinafter - Identification data).
The source of the processed Personal Data: Your Personal Data, submitted upon registering on SPELET.LV and Your Personal Data received from identification service providers.
3.1.3. AML Data: 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 Republic of Latvia, to identify whether you are a politically exposed person or a person closely related to a politically exposed person, to determine if we can or cannot provide you our Service and to report unusual and suspicious transactions to regulatory authorities: name, surname, date of birth, personal identification number, identification document details, personal transaction details (amount, type of bill, type of transaction), signature, phone number, e-mail address, residence address, a copy of the identification document, information on political status, information on the beneficial owner, source of income and related information, etc (hereinafter - AML data).
The source of the processed Personal Data: Your Personal Data that you provide directly to SPELET.LV and Your Personal Data received from the financial and client identification service providers.
3.1.4. Gambling data: processes Your Personal Data, in order to provide you a Service: self-exclusion data, gaming-exclusion data, user ID, currency, current balance, game / tournament ID, seller ID, 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 that we have received from our gambling service providers, Your Personal Data gathered from the databases available to SPELET.LV in relation to providing the Service, including the self-denied person registry.
3.1.5. Technical data: processes Your Personal data when you visit the website www.spelet.lv: IP address (including the location based on the IP address), access-provider, referring URL, date, time, access codes, session key, browser type and version, operating system, amount and state of transferred data, MAC address, etc (hereinafter - Technical data).
The source of the processed Personal Data: SPELET.LV website generates or collects the Technical Data from your device automatically while your browsing it.
3.1.6. Contact data: processes Your Personal Data when you are contacting us using our website www.spelet.lv chatbot, sending an e-mail or filing a complaint: the content of your message, e-mail address or social media contacts, the contents of the document, etc (hereinafter - Contact Data).
The source of the processed Personal Data: Your Personal Data, provided by you directly.
3.1.7. Money Data: processes Your Personal Data in order to begin the Service-related money transfers: name, surname, user ID, banking, payment institution number, transaction amount, transaction date and time, etc (hereinafter – money data).
The source of the processed Personal Data: Your Personal Data, which you have provided by demanding to perform money transfer, and Your Personal Data received from payment service providers.
3.1.8. Communication Data: processes Your Personal data in means of communication: name, surname, date of birth, contact information, date and time of the communication, Your preferences, etc (hereinafter – communication data).
The source of the processed Personal Data: Your Personal Data, which you provide upon registration regarding the choice of communication directly or indirectly (e.g. – using cookies) whilst using the Service.
3.1.9. Customer Support Data: processes Your Personal Data to improve the providing of Services: user ID, gambling turnover, date of using the service, survey information and other Personal Data that you provide, except sensitive data which you have provided, etc (hereinafter – Customer Support data).
The source of the processed Personal Data: Your Personal Data, which you provide us with directly or indirectly.
3.1.10. Administrative Data: processes Your Personal Data in order to ensure compliance with the applicable laws on archiving and accounting requirements: name, surname, transaction information, personal identification number, contact information, etc (hereinafter Administrative data).
The source of the processed Personal Data: Your Personal Data, which you provide us with while using the Service.
3.1.11. Cookie Data: processes cookies. Please see section “Cookie policy” (paragraph Nr. 9) (hereinafter - Cookie data).
The source of the processed Personal Data: Your Personal Data, which you provide us with indirectly while browsing our Website www.spelet.lv.
4. Basis for processing the personal data
Data processing is based on:
4.1. 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;
4.2. execution of the mutual contract (contracts, general rules, separate rules, etc, between us and you, which you have agreed upon by registering or using the Service;
4.3. our legitimate interests;
4.4. 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 |
|
Communication with the customer, customization of the informational content |
Consent |
Communication data, Cookie data |
|
The registration of a player’s account |
The execution of an Agreement |
Registration data |
|
Identity, PEP, self-exclusion registry, etc checks |
Applicable laws and regulations |
Identification data, AML data |
|
Record keeping of the payments |
Applicable laws and regulations |
Identification data, Gambling data, Money data |
|
Improvement and development of the Website and the Service |
Legitimate interest or your consent |
Technical data, Cookie Data, Contact data, Customer support data |
|
Customer support and communication |
Legitimate interest |
Contact data, Customer support data |
|
User transaction control, AML checks, suspicious transactions |
Applicable laws and regulations |
All data |
|
Statistical data analysis |
Legitimate interest |
Technical data, Cookie data, Gambling data, Customer support data |
|
Data transfers to separate data controllers for receiving verification, payment or other services |
|
Technical data, Money data Gambling data, Identification data |
|
Ensuring the safety of the Service |
Legitime interest |
All data |
|
Data transfer within SPELET.LV |
Legitime interest, Execution of agreement |
All data |
|
Personal data storage in the backup system |
Applicable laws and regulations and Legitime interest |
All data |
|
Erasure of all personal data |
Applicable laws and regulations |
All data |
5. AUTOMATED DECISION-MAKING AND PROFILING
5.1. SPELET.LV may sometimes apply automated processing to Your Personal Data, and in the following situations we may apply automated decision making according to the applicable laws and regulations or the mutual agreement:
5.1.1. Verifying your identity and allowance of providing access to the Service upon registration of the player account on www.spelet.lv website - 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 include analyzing Your Personal Data (birth date (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.
5.1.2. 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. Data subjects, to which the automated decision making is applicable are the banking, payment institution account details (name, bank account number). Money transfers are completed or declined as a result of the automated decision.
5.1.3. Compliance with the rules which you have accepted and to which you must adhere to - we analyze your activities on SPELET.LV to detect any activities that breach applicable laws or Service provider rules.
5.1.4. Risk assessment and compliance with the Service rules: we do not allow access to the Service to third parties that are trying to compromise the code, change the gambling software and other referred activities and, thus, apply active measures to avoid the use of scripts, bots and other devices and techniques interfering the fair play and our work. We may analyse your activities on www.spelet.lv and in the Service. For such analysis we mainly rely on the Technical Data and Gambling Data. We compare the mentioned Personal Data with 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, SPELET.LV and/or the involved gaming service provider (who processes the mentioned data in in aggregated manner based merely on User ID) may restrict the access to the Service’s functions (e.g., limit maximum bet amounts, etc) even if we have the slightest doubt that the activity is non-compliant.
5.1.5. Detection of an unfair game in compliance with applicable laws, we might be obligated to detect and deter activities relating to breaching of the law or unfair gaming. SPELET.LV or a fraud prevention service provider compares your device’s online identifiers (e.g., Technical Data, Cookies and Gambling data) with similar types of Your Personal Data previously collected about you or your device used to access the Website. If your account or device is found to be fraudulent or is connected to breaches of law, as a result of an automated decision, SPELET.LV may restrict your access to the Service.
5.1.6. The automated decisions described above usually take place without an intervention of SPELET.LV employee. You have the right to obtain an intervention of SPELET.LV employee regarding the decision-making process and to express your point of view regarding such decision and contest the decision.
6. RETENTION PERIOD
6.1. 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:
6.1.1. AML data – 5 years from the day we terminate the agreement, except Gaming data that are erased after 5 years after their creation.
6.1.2. Registration data, Identification data and Gambling data – 5 years after you last visit the website www.spelet.lv.
6.1.3. Money data – 6 years after the transactions of 31 of December, that are registered in that particular year until the 31 of December.
6.1.4. Communications data – after terminating the agreement, except the particular content of the communication, that is stored for 3 years.
6.1.5. Technical data – the data storage period is 30 days from the moment of the data collection.
6.1.6. All other data – 5 years from the day when they are received.
6.2. The retention period may be extended after a decision by SPELET.LV if it is necessary to comply with our legal requirements, resolve disputes or enforce the agreement. SPELET.LV may anonymize Your Personal Data and retain this anonymized information indefinitely.
6.3. Data that are stored in backed-up copies are deleted after the end of a backup cycle. SPELET.LV ensures that appropriate safeguards are applied to the data in the backup. The copied data is not used or processed in any other means, and SPELET.LV deletes the data as soon as possible, i.e., after the end of SPELET.LV’s backup cycle.
7. YOUR RIGHTS
7.1. At any given moment You may exercise the following rights with respect to our processing of Your Personal Data by contacting us:
7.1.1. 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.
7.1.2. Right to correct: you have the right to request that we correct any of Your Personal Data if it is inaccurate or incomplete.
7.1.3. Right to object: you have the right to object to certain processing of Your Personal Data, including, for example automated decision making based on Your Personal Data or in the cases of processing Your Personal Data based on our legitimate interests.
7.1.4. Right to restrict the processing of Your Personal Data: You have the right to request that we restrict the processing of Your Personal Data if you wish to: 1) object the lawfulness of the processing: 2) fix unlawful processing of Your Personal Data; 3) receive or avoid deletion of Your Personal Data for establishing or defending against legal claims; or 4) demand restriction of the processing until assessing the plausibility of SPELET.LV's legitimate interest in the specific processing activity.
7.1.5. Right to erasure: you may request Your Personal Data to be erased if they are no longer necessary for the purposes for which they were collected, 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.
7.1.6. 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 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.
7.1.7. 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.
7.1.8. Right 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 that we are not processing Your Personal Data in accordance with the law, you can submit your claim with the Latvian Data Protection Inspectorate at [email protected] (www.dvi.gov.lv).
8. SHARING YOUR PERSONAL DATA AND DATA TRANSFERS
8.1. SPELET.LV discloses Your Personal Data to third parties only in accordance with this Policy, internal data processing policy and to persons authorized to process Personal Data, who have undertaken to observe confidentiality obligations or are the subject to appropriate statutory confidentiality according to applicable laws or if you have given consent to such disclosure.
8.2. SPELET.LV does not transfer Your Personal Data outside of the European Union, however SPELET.LV reserves the right to transfer the Data outside European Union or European Economic Area if the respective operational services are provided outside the European Union or European Economic Area. We may choose to use special Personal Data protective measures 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.
9. COOKIE POLICY
We use cookies to enhance your browsing experience on our websites and applications.
Please read the following to find out more about how cookies work, how we use cookies and other methods for the collection of website usage data, and how you can block or delete them.
What is a cookie?
A ‘cookie’ is a small text file containing information which is stored on your computer or mobile device. Cookies are used for technical reasons and to facilitate your use of our websites and applications and may be stored in your browser or device. Each website can send its own cookie to your web browser if your browser's preferences allows it. Many websites do this every time a user visits their website in order to track online traffic flow.
How we use cookies?
We use cookies and other identifiers to enhance your browsing experience and make your experience with us as enjoyable as possible, for example by:
- recognizing when you log in and your preferred settings;
- evaluating user behavior so that we can make improvements; and
- analyzing your recent searches and behavior while visiting our site to provide you content which we believe improves your experience on our site, and to display appropriate advertising when you visit other selected Websites.
These cookies do not gather information about you that could be used for communication purposes or remembers where you have been on the internet.
We use functionality cookies
We use functionality cookies to remember your preferences on our websites (e.g., crypt ID, language or region you are located) and to provide enhanced, more personal features. It should be noted that if you delete these cookies from your browser, we will no longer be able to remember your preferences or remember your log in details or provide you with the content you have requested. For example, we store your session information within a cookie on your device, in order for you to experience a consistent experience in all of the website; if you opt out from advertising that is based on your interests, we save your opt out preferences in a cookie on your device.
We use performance cookies
These cookies help to improve the performance of SPELET.LV. It can help us reduce the network bandwidth by not saving data that is already saved on your device. All of the information that these cookies gather is aggregated and anonymous. If you do not allow these cookies, we will request the data again every time you visit the website and that will delay your experience. This is used only to improve the functionality of the website and provide a better user experience.
We use web analytics
This Website uses Google Analytics which is the most widely used web analytics service on the internet.
Google will use this information to evaluate the usage of the website, compile website operator reports on website activity, and provide other services related to website functionality and internet usage. We use the information to compile reports and make our website more efficient. The data is usually aggregated to provide trends and usage pattern for business analysis, website/platform improvements and performance indicators. The type of information collected includes how many visitors visited our website, how many are logged in, when they visit it, how long have they visited it, etc. They help us know which pages of the website are the most popular and which are the least popular, as well as to see how visitors move around the website.
Online behavioral communication
Online behavioral communication is a way of serving communication on the Websites you visit and making them more relevant to you and your interests.
These cookies along with other technologies are used to identify your interests bases on your searches and other behaviour while using our website. We may share this information with our trusted media, communication and analytics partners, so that we can show you relevant and personalized advertising.
How to manage your cookie preferences?
You have options about how the cookies are used, and you can change your cookie settings at any time by visiting the cookie setting page. Please be aware that without essential cookies that are necessary to provide you with the best possible service, we cannot maintain the security requirements and guarantee legal requirements.
You can control cookies from your browser
If you do not wish to accept cookies you can change your browser’s settings to automatically deny the storage of cookies or to inform you when a website wants to store cookies on your computer. Previously stored cookies can also be deleted through your browser. At any time you can manage your data preferences in relation to our use of cookies and similar technologies. If you wish to manage your cookies or opt out of using them, you can do so in your browser and setting it to accept or deny certain or all cookies. To find out how to do this, please see your browser’s information or visit www.aboutcookies.org.
Please note that:
- if cookies are deleted or declined:
- some websites and functions in this website require cookies and they might stop functioning.
For more information regarding the cookies used on this Website please contact us via e-mail [email protected].
Which cookies we use
The table below indicates specific cookies that are used on our website and mobile app, respectively. The table also indicates the purpose of each cookie.
|
Cookie name |
Description |
|
"authToken" |
Used in the player’s identification process, mandatory |
|
"refreshToken" |
Used in the player’s identification process, mandatory |
|
"isLeftBettingDrawerOpen" |
Used to save the user interface after the website is updated, optional |
|
"isRightBettingDrawerOpen" |
Used to save the user interface after the website is updated, optional |
|
"affiliate" |
Used for “btag” marketing purposes, optional |
If you choose to not accept certain or all cookies, we cannot guarantee that our website will work properly, and we cannot be held responsible for any errors that may occur.
10. AMENDMENTS TO THIS PRIVACY POLICY
This policy might be changed from time to time, to reflect the changes in the way we process Your Personal Data, in that event the most recent version of the Policy will appear on this page. If you do not agree in any of the made changes, you can immediately withdraw your consent and discontinue using our Service or contact us. Please make sure to periodically check the Policy for any changes, especially before you provide new personally identifiable information.