PRIVACY POLICY

In this Privacy Policy ("Policy") you can find the following information:

  • What the data concerning you we collect;
  • Why we collect these data and under what legal grounds;
  • How and how long we will store your data;
  • We whom will/may we share these data, and for what purposes;
  • What rights you have within the terms of processing of the data concerning you;
  • Our contact details and the contact details of the Supervisory authority for your complaints.

If you use and/or register an account on the https://vulkan.bet ("Website"), you hereby agree to be bound by this Policy. If you do not agree to this Policy, please, stop using the Website. The Company may change, amend or modify this Policy from time to time. If the Company does, the Company will let you know by revising the date of this Policy or, if you have an Account, by sending an e-mail to your e-mail address, which you use when registering Your Account on the Website. Your continued use of our Website after Policy changes have come into effect shall be interpreted as your consent to be bound by the revised version of the document.

INFORMATION ABOUT THE DATA CONTROLLER

The data controller within the frame of this Policy is VERBENAZ LIMITED, a company registered in the Republic of Cyprus, with its address: Kasou 13, Strovolos, 2062, Nicosia, Cyprus; Registration number: HE 385376 ("We", "Us", "Our", the "Company"). The gambling facilities and services are provided by Intelligent Innovations N.V., registered address: Heelsumstraat 51 E-commerce Park, P.O. Box 423, Curacao, Registration number: 142065.

E-mail address of our Support Team - [email protected]

WHAT DATA CONCERNING YOU DO WE COLLECT?

Automatically collected data. When you use the Website, the following data concerning you are collected by automatic means:

  • The total time you spend on the Website;
  • The time you spend on each page and in what order those pages were visited;
  • What internal links were clicked (based on the URL of the next pageview);
  • Your IP address;
  • User Agent Strings (which browser is being used, what version, and on which operating system).

Cookies data. To find out more about the usage of Cookies, please, follow Cookies Policy.

Account data. When you create an account ("Your Account") on the Website and further use it, you hereby provide Us with the following data:

  • Your E-mail address;
  • Your password (in hashed form);
  • Your username (if applicable);
  • Your name;
  • Your phone number;
  • Your Skype account;
  • Your gender;
  • Your birth date;
  • The information about coupons (promo-codes) you have activated;
  • Information about the performance of your account: the bets you have made and on what outcomes, games you have played and the total amount of winnings and loses and similar information;
  • If you have excluded your account from gambling for a specific time period or have blocked Your Account permanently - We will also have this information recorded;
  • Information about how much time do you spend on the Website.

Verification data. During the Verification process you shall be required to provide Us with the following data:

  • A copy or a photo of your identification document;
  • A photo of your payment instrument or other evidence that you are a holder of a payment instrument, used or intended to be used for making payments via the Website;
  • A photo of you;
  • A photo of you, bearing your identification document and payment card (-s);
  • Your address confirmation. It may be a utility bill, telephone bill or other documents, which, in accordance with the jurisdiction's legal and regulatory requirements, shall be enough to confirm your address;
  • The Confirmation of the source of your wealth and funds (for so-called "Politically Exposed Persons");
  • The record of your video calls/audio-calls with the Website`s administration (if applicable).

The data, provided by third parties. Third parties, like payment providers, software providers may provide Us with certain information about you, which may be necessary to verify your identity and conduct Verification(s). We can also verify some of your data through open registers, social networks and other public resources.

Payment data. When you make any transactions via the Website, the following data are collected:

  • The information about your payment card or payment instrument (first six and last four digits and a name of the cardholder - first three letters of the name and last three letters of a surname or, in some cases, first three letters of the surname and last three letters of the name);
  • The total amount of the transactions, made via the Website.

Communication data. When you contact the Company via the interface of the Website or via e-mail addresses, you hereby provide the data, that may be defined as "personal data" by the applicable legislation.

Marketing data. We collect the data on whether or not have you agreed to receive our Newsletter or Marketing materials.

THE PURPOSES AND LEGAL BASES FOR THE PROCESSING OF THE DATA CONCERNING YOU

To administer and protect the Website. We use your Automatically collected data for the following purposes:

  • To protect the Website from any cyberattacks (including, but not limited to DDoS attacks);
  • To diagnose any problems with the Website;
  • To prevent any illegal or fraudulent activity on the Website.

Legal basis for this Processing: Article 6(1)(f) of the 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 (hereinafter the "GDPR") - processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

To create Your Account and provide you with Gambling Services of the Website. We use your Account data andCommunication data in order to open your Account and provide you with the Services of the Website. This also includes self - exclusion and other related operations.

Legal basis for this Processing: Article 6(1)(b) of the GDPR - processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

To process your transactions via the Website. We use your Payment data in order to make transactions via the Website.

Legal basis for this Processing: Article 6(1)(b) of the GDPR - processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

To conduct Verification. The Company uses your Verification data to conduct Verification in order to:

  • Comply with Anti-Money Laundering legislation;
  • Prevent usage of the Website by the Children;
  • Prevent other illegal activity and fraud.

Legal bases for this Processing: Article 6(1)(c) of the GDPR - processing is necessary for compliance with a legal obligation to which the Company is subject and article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

To Comply with the Applicable legislation. We may use your data in order to comply with the applicable legislation and requirements of our gambling license.

Legal basis for this Processing: Article 6(1)(c) of the GDPR - processing is necessary for compliance with a legal obligation to which the Company is subject.

To contact you. We may use your Communication data in order to contact you for various purposes.

Legal bases for these types of processing:

Article 6(1)(b) of the GDPR - processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract - this basis shall be applied when you communicate with Company`s Support Team;

Article 6(1)(c) of the GDPR - processing is necessary for compliance with a legal obligation to which the Company is subject - this basis shall be applied when responding to your legal requests (for example, when you implement any of your data subject requests);

Article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Companyor by a third party (for example, when you ask general questions).

To improve the Website and its functionality. We anonymize your personal data (remove all personally identifiable information from your data set) and then use these data for research and analysis.

Legal basis for this Processing: Article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

To test new functions and features of the Website. We use your Automatically collected data and Cookies data to test new functions and features of the Website.

Legal basis for this Processing: Article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

To prevent fraudulent and illegal activity, compulsive and underage gambling. We may use the data concerning you in order to prevent fraudulent and illegal activity, compulsive and underage gambling.

Legal bases for this Processing:

Article 6(1)(c) of the GDPR - processing is necessary for compliance with a legal obligation to which the Company is subject.

Article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Companyor by a third party.

To prevent violation of our Rules, Terms and Conditions and other applicable documents.

Legal bases for this Processing: Article 6(1)(b) of the GDPR - processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

We use your Marketing data in order to send you Our Newsletter and Advertisement Materials, that may be relevant for you.

Legal basis for this Processing: Article 6(1)(a) of the GDPR - your consent.

RECIPIENTS OF THE DATA CONCERNING YOU

Intelligent Innovations N.V.. Our gambling facilities are provided by other company, Intelligent Innovations N. V.. Thus, your personal data shall be disclosed to this recipient.

Contractors and Affiliates of the Company. Some facilities and services, provided via the Website, may be subcontracted to other natural and legal persons. Thus, your data may be share to these recipients.

Employees of the Company. The Customer Support and other employees of the Company may receive the data concerning you. All these employees are legally obliged to handle your data in accordance with this Policy and applicable legislation.

Hosting Providers. This Website may be placed on the Server, maintained and operated by the third-party hosting provider. Thus, the data concerning you (in encrypted form) shall be placed on the Server, operated by the third party.

Financial Institutions. We share the data concerning you with banks, payment services providers, payment gateways and other financial institutions in order to process your transactions via the Website and in order to perform their regulatory and legal obligations.

Accreditation bodies, auditors. When the Company passes an independent audit, the data concerning you may be shared to them. All these bodies or auditors are legally obliged to handle your data in accordance with this Policy and applicable legislation.

Analytics and Service providers. These include Google Analytics, Cloudflare and Yandex Metrika.

Google Analytics. The Website uses Google Analytics, a web analytics service. It is operated by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses previously mentioned "cookies". The information generated by the cookie about your use of the Website is usually transmitted to a Google server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en. Google LLC. has certified under EU-U.S. Privacy Shield Framework - this framework protects the fundamental rights of anyone in the EU whose personal data (any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly) is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield. If you want to find out more about how Google processes your data, please, follow Google`s Privacy Policy https://policies.google.com/privacy. Additionally, you can find the information about certification of Google under EU-US and Swiss-US Privacy Shield frameworks https://policies.google.com/privacy/frameworks?hl=en&gl=de.

Hotjar. Hotjar (registered place of business: Hotjar Ltd, Level 2 St Julians Business Centre, 3, Elia Zammit Street St Julians STJ 1000, Malta) is a technology service that helps Us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, etc.) and this enables us to maintain, and improve our Website. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular a device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor the Company will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please follow Hotjar’s privacy policy (https://www.hotjar.com/legal/policies/privacy). If you want to opt-out from the processing of the data concerning you by Hotjar, please, follow Hotjar`s Opt-out Webpage via the link https://www.hotjar.com/legal/compliance/opt-out/.

Cloudflare, Inc. The Company uses the services, provided by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Сloudflare provides web optimization and security services that the Company uses to improve and protect the Website, including a reverse proxy, pass-through security service. Cloudflare may collect the log data from the visitors of the Website. Additionally, the Company deployed a Cloudflare`s cookie file for security purposes (see Cookies Policy to find out more). To find out more about processing of the data by Cloudflare, please follow https://www.cloudflare.com/privacypolicy/. Additionally, you can find Cloudflare's Privacy Shield Framework Statement via the link https://www.cloudflare.com/privacyshield/.

Yandex.Metrica. Yandex.Metrika is a web analytics service offered by Yandex Oy, Moreenikatu 6, 04600 Mantsala, Finland. Yandex.Mertica that tracks and reports website traffic. Yandex uses the data collected to track and monitor the use of our Service. This data is shared with other Yandex services. If you want to opt-out from the processing of the data concerning you by Yandex, please, install Yandex.Metrica opt-out add-on from this link https://yandex.com/support/metrica/general/opt-out.html.

HOW LONG THE DATA CONCERNING YOU SHALL BE STORED

The data concerning you shall be stored within a period 6 (six) years starting from the date of your last visit to the Website or starting from the date you closed your account on the Website. This period is based on the legal obligation of the Company in the field of Anti-Money Laundering legislation (which requires to store Verification and Communication data for a period of 5 years starting from the date of the last transaction or starting from the date you ceases to be our customer) and based on the purpose of the establishment, exercise or defense of legal claims as allowed by Article 7(1) of Limitation of Legal Proceedings act (Law 66(I)/2012) of the Republic of Cyprus.

YOUR RIGHTS

As the data subject, you have several rights that you may apply in order to control the processing of the data concerning you. Please, send a request us in order to apply any of them: [email protected]

Access to your data (right of access). You have the right to obtain from the Company confirmation as to whether or not the data concerning you are being processed and to obtain a copy of these data (in case if the Company indeed processes your data).

Correct your data (the Right to rectification). You have the right to obtain the rectification of inaccurate data concerning you.

Delete your data (the Right to be forgotten). You can request Us to remove the data concerning you that we have. Please note that this rule may be restricted in accordance with our record-keeping period (please, follow "HOW LONG THE DATA CONCERNING YOU SHALL BE STORED.")

Transmit your data to another controller (the Right to data portability). You have the right to receive in a structured, commonly used and machine-readable format the data concerning you and have the right to transmit those data to another controller (another company, entity or person). This right applies to the following data:

  • Those data that have been collected under your consent or under the contract;
  • Those data that have been collected by automatic means.

The right to withdraw consent. You have the right to withdraw your consent at any time. It means that we shall stop the processing that was based on your consent. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The right to restriction of the processing. You have the right to obtain from the Company restriction of the processing, in case if one of the following applies:

  • The accuracy of the data concerning you was disputed by you - for a period enabling the Company to verify the accuracy of the data concerning you;
  • the processing is unlawful and you oppose the erasure of the data concerning you and requests the restriction of their use instead (if you can prove the unlawfulness of this processing);
  • the Company no longer need the data concerning you for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  • you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of the Company.

The right to object to the processing. You have the right to object, on grounds relating to your particular situation, to processing of the data concerning you, if the legal of this processing is Article 6(1)(f) of the GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Company or by the third party.

Please note, that:

  • we may request additional proofs of your identity prior to realization any of the rights, specified in this Policy;
  • realization of some rights may be restricted under applicable legislation. In this case, you will be notified about the legal basis of this restriction.

The right to lodge a complaint with the supervisory authority. You can always address us any issue/request concerning the processing of the data concerning you, including complaints.

However, if you deem that your rights under current data protection legislation are infringed, you can lodge a complaint with The Commissioner for personal data protection of the Republic of Cyprus.

Website: http://www.dataprotection.gov.cy/;

E-mail: [email protected];

Postal address P.O. Box 23378, 1682 Nicosia, Cyprus;

Tel: +357 22818456;

Fax: +357 22304565.

THIRD-PARTY WEBSITES

This Website may contain the links to the Websites, owned by the third parties. For example, links/hyperlinks to third-party`s websites (hereinafter the "third-party`s websites"). You follow those links/hyperlinks at your own risk. The Company bears no liability for the content of any of those Websites and bears no responsibility for anything, what can happen as a result of your visit to those third-party`s websites. The Company recommends you to visit "Privacy Policy" or "Data Policy" or another privacy document on any of the third-party`s Websites before submitting any data concerning you to the latter.

INTERNATIONAL DATA TRANSFERS

Our Company does business globally. Thus, some pieces of the data concerning you will be transferred from the EU to Curacao, where one of the recipients (namely, Innovations N.V.) is incorporated. These transfers are based on the standard data protection clauses adopted by the European Commission subject to article 46(2)(c) of the GDPR. To find out more about Standard contractual clauses for data transfers between EU and non-EU countries, please, follow this link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

PROCESSING OF CHILDREN`S DATA

The Website is not intended for users under the age of 18 years or under the age required to participate in gambling in the place of the residence (jurisdiction) of the particular user ("legal age"). If you are a parent or a legal guardian and have found that your child used our Website, please contact Us via any available means of communication and we will apply appropriate measures.

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