Privacy Policy

“Friendbet”

Friendbet 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”) our betting application Friendbet (hereinafter referred to as “the App”).

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

1. Background

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

When processing personal data, Friendbet takes care to 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, Friendbet:

  • Is legally bound to process the personal data of Users. This processing is explained in Article 2.1 of the Privacy policy;
  • Also processes personal data to enable Users to use the App and for the necessary and legitimate purposes set out in Article 2.2 of the Privacy policy;
  • Processes the personal data set out and for the purposes given in Article 3, further to the prior, free and express consent of Users.

By accessing and using the App, Users are deemed to have read and accepted the Privacy policy. Furthermore, they guarantee that the data and information provided to Friendbet is accurate.

2. Processing of personal data that does not require the consent of Users

2.1 Legal obligations of Frienbet and data processing required for use of the App

Friendbet is bound by the legal and regulatory obligations to which all online gaming and betting operators are subject to, on the one hand, and for the purposes of authenticating Users and enabling them to use the App, on the other hand, to process the following personal data for the reasons set out below. This processing of personal data carried out by Friendbet does not require the consent of Users under Article 6.1.b) and c) of the Regulation.

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

a. What personal data is processed ?

The following personal data is processed:

  • surnames, first name/s, language, email address, landline or mobile telephone number;
  • the User’s browsing history and activities on the App, including betting history transactions (wins and losses, prizes or other forms of rewards), visits (browser data, IP address) ;
  • any other information that may be exchanged between Friendbet and the User, namely by email or live chat, during the User’s registration or use of online betting offered on the App.
b. What data processing does Friendbet carry out?

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 2.2.a). It also consists of transferring this personal data to third parties, a list of whom may be accessed on request from the contact person detailed in Article 7.6.

c. What are the legitimate purposes of the data processing?

Friendbet processes personal data set out in Article 2.2.a) for the following legitimate purposes:

  • New betting offers;
  • to promote, advertise and market, online betting offering (as well as the management of afferent affiliation and loyalty programs relatively),  which includes electronic newsletters;
  • The participation to contests including the communication related to winners;
  • to conduct satisfaction surveys, statistical studies, trend analyses, and market research in order to improve online betting services

3. Processing of personal data that requires the consent of Users

By using the Frienbet App, for any reason whatsoever, the User expresses their free, individual, informed and unambiguous consent to expressly authorise Friendbet 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 2.  

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

The User shall also have certain rights, including the right to withdraw their consent at any time, according to the terms of Article 3.4.

3.1 Nature of the personal data processed

Friendbet processes the following personal data:

  • surnames, first name/s, language, email address ;
  • the User’s browsing history and activities on the App, including betting history their transactions (wins and losses, gifts or any other form of reward), visits (browser data, IP address);
  • any other information that may be exchanged between Friendbet and the User, namely by email or live chat, during the User’s registration or use of online gaming and betting offered on the App.

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

3.2 The data processing

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 3.1. It also consists of transferring this personal data to third parties, a list of whom may be accessed on request from the contact person detailed in Article 7.6.

3.3 Purposes of the personal data processing

The personal data is collected and processed by Friendbet for purposes of:

  • Promoting, advertising and marketing activities, including membership and management of loyalty programs relating to the offering of online betting services, which includes electronic newsletters involving a processing of personal data by third parties

4. Rights of the User

4.1 Right of access      
  1. Friendbet can provide Users with the following information:
    • the name and contact details of the data controller:
    • the contact details of 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;
    • and, 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 Friendbet 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 see the information referred to in this Article and in Article 3.1. at any time via the contact person detailed in Article 7.6. Frienbet shall respond to such requests for information within one month.
  2. Users may obtain a copy of personal data that is processed. For any additional requested copy, Friendbet reserves the right to claim payment for any expenses incurred in this new request. These expenses shall be calculated on the basis of 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 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

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

The right to rectify data may be exercised by contacting the person detailed in Article 7.6.

4.3 Right to object to the processing of data

Friendbet 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, Friendbet allows Users to object to:

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

The right to object to the processing of data may be exercised by contacting the person detailed in Article 7.6.

4.4 Right to be forgotten

Friendbet 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 Friendbet to perform this processing.
  • The User objects to the processing of their personal data for marketing purposes, such as profiling, if it is linked to this marketing.
4.5 Right to limit the processing of data

Users also have the right to limit Friendbet’s processing of their personal data when:

  • the User believes the personal data to be inaccurate, whilst Friendbet 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 Friendbet’s reasons for seeking to continue this processing;
  • Friendbet no longer requires the personal data processed but the data subject would like it to be held to establish, exercise or defend legal claims;

The right to limit the processing of data may be exercised by contacting the person detailed in Article 7.6.

4.6 Transferring data to a data controller

Users may transfer the personal data processed by Friendbet within the scope of articles 2.2 and 3, to another data controller without objection from Friendbet.

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

4.7 Modalities

The rights recognized by Friendbet to the User must be exercised in accordance with the modalities defined by article 7.6.

4.8 Notification

Friendbet shall notify the User of any data that is erased or rectified in accordance with Articles 4.2 and 4.4, 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

 
5.1 

Friendbet 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 at the Data Center. Friendbet provides all of the required or useful security assurances with regard to current technical standards.

5.2 

Users’ personal data is retained by Friendbet for the purposes set out in Articles 2 and 3.   It is retained for a period of 10 years for all of the purposes governed by Article 2.a); Friendbet therefore reserves the right to retain Users’ personal data for any reasons imposed by law due to the fact that its business is that of online betting.

Moreover, personal data is retained for a period which does not exceed the timeframe needed for the realization of the purpose of the processing, for all the purposes governed by articles 2 and 3 given that the retention period has to take into account, considering the specificities of the services offered by Friendbet,  the hypothesis that, on initiative of the Gaming Commission, a judicial authority or another third party, Friendbet would be obliged to state or exercise a judicial right, in line with the treatment of User’s personal data.

6. Liability of Friendbet– Data processor

6.1

Friendbet undertakes to ensure 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 Friendbet 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.

Friendbet 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 7.6.

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 Friendbet may be subject by the Commission des jeux de hasard in particular.

If necessary, Friendbet 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 suppliers and partners of Friendbet, except for the purposes set out in Articles 2.1, 2.2, 3  and 7.2 and, consequently, 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 betting services, or maintenance services;
  • The User has consented to such a transfer;

The partner shall not be deemed a data processor unless they process Users’ personal data on behalf of Friendbet. Friendbet shall not be held liable for the processing of User’s personal data by partners who supply their own services in their own name on their own behalf or if it proves that it is not responsible for the event that gave rise to the damage.

           It is understood that in the event that Friendbet acts in the capacity of the processor’s partner, Friendbet shall be liable for damage caused by processing personal data contrary to the Regulation or this Privacy policy only where it has not complied with obligations of the Regulation or this Privacy policy directed to processors, or where it has acted outside or contrary to lawful instructions of the partner. Similarly, Friendbet shall not be held liable if it proves that it is not responsible for the event that gave rise to the damage.

6.3

Friendbet shall ensure that when the processing is carried out by a processor on behalf of Friendbet, 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.

6.4

Friendbet undertakes to ensure that in the event of a security problem related to data processed which may affect the confidentiality thereof, Friendbet shall report the incident at the earliest opportunity to the data protection authority stipulated in Article 7.5.and, if possible, within 72 hour at the latest, as of the date of acknowledgement of the incident.

Friendbet shall record any security incident and will take technical and organizational necessary  measures in view of resolving the issue in a timely manner.

                      Friendbet shall also inform the Users concerned, insofar as the personal data breach poses a high risk to the rights and freedoms of the User; the User shall be informed by letter or email using the contact details that they have provided. 

7. Miscellaneous

7.1 Record of personal data and data protection manual

As a personal data controller, Friendbet keeps a record of all of its data processing activities. This record 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 technical and organisational security measures in place.  

Personal data provided by the User, any processing of this data and the purposes of such processing are held in a record which is controlled by and remains the responsibility of Friendbet at all times. In addition to the information above, this record includes:

  1. a description of the purposes of the processing;
  2. a description of the categories of data subjects and categories of personal data;
  3. the categories of recipients to whom the personal data has been or shall be sent, including recipients in non-EU countries or international organisations;
  4. the deadlines for erasing various categories of data;
  5. a general description of technical security measures.
7.2 Entire agreement – modification of the Privacy policy

The Privacy policy contains all of the contractual provisions binding Users, without prejudice to the general provisions in the Terms and Conditions of Use of the App of which they form an integral part. The Terms and Conditions of Use of the App shall remain applicable for any matters that do not relate to the protection of personal data. 

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

7.3 Probative value

The User acknowledges that the electronic documents exchanged and electronic data collected during their registration or use of the App have the same probative value as if these documents and data had been sent or communicated on paper. They therefore undertake to not dispute their force or probative value due to the fact that they are in electronic form.  

7.4 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, and the Law of 8 December 1992, the User has the right to request additional information or lodge a complaint with the data protection authority. The data protection authority is the Commission pour la protection de la vie privée (Commission for the protection of privacy).  Contact details are as follows:

Address: Rue de la Presse, 35, 1000 Brussels, Belgium

Telephone: +32 (0)2 274 48 00

Fax: +32 (0)2 274 48 35

Email: commission@privacycommission.be  

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

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

  • Letter: Rue Saint-Exupéry 17/13, 4460 Grâce Hollogne BELGIUM
  • Email: privacy@circus.be
  • Telephone: +32.4.338.82.90

Any request relative to the exercise of the rights contemplated under article 4 must be adressed to the following address: privacy@circus.be

Friendbet has also appointed a data protection officer under Article 37 of the Regulation cited above. This person may be contacted by email: dpo@circus.be They are responsible for ensuring that processing of Users’ personal data by Friendbet is monitored and complies with legal requirements.