PRIVACY POLICY SPELET.LV

1. GENERAL

1.1. Organization is committed to maintaining the privacy and security of the Personal Data of all visitors to this website www.spelet.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 SIA “NIKS" Latvian company with registration number 40003029864.

1.2. Furthermore SIA “NIKS” as “SPELET.LV” or “we”. Service is registration in SPELET.LV and the use of any of the gaming services provided or refusal from registration.

2. PERSONAL DATA CONTROLLER

SIA “NIKS”
Registry code: 40003029864
Address Brivibas street 100C - 28, Riga, LV-1001, Latvia
E-mail: dpo@spelet.lv
If you have any questions regarding the processing of Your Personal Data, please contact us by using the e-mail address mentioned above.

3. THE PERSONAL DATA SPELET.LV COLLECTS AND PROCESSES

3.1. Your Personal Data are information that can be used to identify you directly or indirectly, contact or locate you as a an individual (hereinafter Your Personal Data). The processed Personal Data categories are as follows:

3.1.1. SPELET.LV processes Your Personal Data related to your registration on www.spelet.lv : 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 SPELET.LV.

3.1.2. SPELET.LV 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 SPELET.LV and Your Personal Data, received from identification service providers.

3.1.3. SPELET.LV 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 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 SPELET.LV and Your Personal Data, received from the financial and client identification service providers.

3.1.4. SPELET.LV processes Your Personal Data, in order to provide you a Service: self-exclusion data, gaming-exclusion data, 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 SPELET.LV in relation to providing the Service, including from the Register of individuals refraining from engaging in gambling and interactive lotteries.

3.1.5. When you visit www.spelet.lv , SPELET.LV 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 SPELET.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.

3.1.6. SPELET.LV processes Your Personal Data when you are contacting us using Website’s SPELET.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.

3.1.7. SPELET.LV 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.

3.1.8. SPELET.LV 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.

3.1.9. SPELET.LV processes Your Personal Data 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.

3.1.10. SPELET.LV 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: Your Personal Data, which you provide us with while using the Service.

3.1.11. SPELET.LV processes cookies. Please see section “Cookie policy” (hereinafter Cookie data)(Paragraph Nr.9).

The source of the processed Personal Data: Your Personal Data, which you provide us with indirectly while browsing our Website www.spelet.lv .

4. THE BASIS AND AIM OF THE PROCESSING OF YOUR PERSONAL DATA 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. 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;

4.3. 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
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 Latvia 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 Latvia 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 Registration data, Technical data, AML data, Gambling data, Identification data, Money data, Client support data, Cookie 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
Data transfer within SIA “NIKS” Legitime interest, Execution of agreement Registration data, Technical data, AML data, Gambling data, Identification data, Money data, Client support data, Cookie data
Storing materials containing Personal Data in SPELET.LV’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

We may process Your Personal Data for other purposes provided and before the processing of the data we disclose 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.

5. AUTOMATED DECISION-MAKING AND PROFILING

5.1. SPELET.LV may sometimes apply automated processing to Your Personal Data. In the following situations we may apply automated decision making according to applicable law for the performance of 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, 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 analyzing 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.

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. 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.

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 and in the Service to detect breaching activities of the applicable laws.

5.1.4. 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 analyze 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 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, SPELET.LV 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.

5.1.5. 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, SPELET.LV 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, 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 in regard to the decision making; express your point of view in regard to such decision and contest the decision.

6. PERSONAL DATA 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 since we terminate the agreement, except Gaming data (they are erased after 5 years since they were created).

6.1.2. Registration data, Identification data and Gambling data – 5 years from the last activity of the player on 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 term 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, if necessary, after a decision of SPELET.LV 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.

6.3. The backed-up materials are put beyond the use, i.e. are not processed for any other purpose, and the materials are deleted by SPELET.LV as soon as possible, i.e. after the end of SPELET.LV’s backup cycle, Your Personal Data will be destroyed. During the backup period, appropriate safeguards are applied to the materials in the backup.

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. 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. You have the right to request that we correct any of Your Personal Data if it is inaccurate or incomplete.

7.1.3. 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.

7.1.4. 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. 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.

7.1.6. 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.

7.1.7. 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. 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 Latvian Data Protection Inspectorate (in Latvian Datu valsts inspekcija) at info@dvi.gov.lv (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 and to persons authorized 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. SPELET.LV 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
Online gambling service providers Providing on-line gambling (Personal Data are being disclosed in a summarized form, that lets You to remain unidentified) European Union
Identification and authentication service providers Providing identification and authentication services to provide you access to the Service; and deter and detect fraud European Union
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 SPELET.LV’s economic activity; conducting of regular business activities European Union
IT-services providers Providing IT solutions necessary for operating the economic activity of SPELET.LV or Service European Union
Third party service providers Certain services related to Service enhancements or user-friendliness enhancements European Union

8.2. SPELET.LV does not transfer Your Personal Data outside European Union or European Economic Area, however SPELET.LV 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.

9. COOKIE POLICY

We use cookies to enhance your browsing experience on our Websites and applications.

Please read on to find out more about e.g. 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 for varying lengths of time on your browser or device. Each Website can send its own cookie to your web browser if your browser's preferences allow it. Many Websites do this whenever a user visits their Website in order to track online traffic flows.

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 searches and other behavior while visiting our site to serve you content which we believe improves your experience of our site, and to display appropriate advertising when you visit other selected Websites (for more information on the latter, see “Online behavioral advertising”.

These cookies do not gather information about you that could be used for marketing purposes or remembering where you have been on the internet.

We use functionality cookies

We use functionality cookies to remember your preferences on our websites (such as your crypt ID, language, or the region you are in) and provide enhanced, more personal features. Please note 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. As a few examples: we store your session information within a cookie on your device, so that you can have a consistent experience for the duration on the site; if you opt out of interest-based advertising, we store your opt out preferences in a cookie on your device.

We use performance cookies

These cookies help to improve the performance of SPELET.LV. These will help us to reduce the network bandwidth by not fetching data again if it is already stored on your device. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, then we will have to request the data again every time you visit the site and will delay the experience. It is only used to improve how our website works 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 for the purpose of evaluating your use of the Website, compiling reports on Website activity for Website operators and providing other services relating to Website activity and internet usage. We use the information to compile reports and to make our website run more efficiently. The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site/platform improvement and performance metrics. The type of information we collect includes how many visitors visit our websites, how many customers log in, when they visited, for how long and which areas of our websites and services. They help us to know which pages are the most and least popular and see how visitors move around the site.

Online behavioral advertising

Online behavioral advertising is a way of serving advertisements on the Websites you visit and making them more relevant to you and your interests.

These cookies and other technologies are used to identify your interests based on your searches and other behavior while visiting our site. We may share this information with our trusted media, advertising, and analytics partners so we can display relevant and personalized advertising suited for you.

How to manage your cookie preferences?

You do have choices about how cookies are used, and your cookie settings can be changed at any time by visiting the Cookie Settings page. Please be aware that it is not possible to use our website without the essential cookies, necessary for providing you with the best possible service, for maintaining the security requirements or for guaranteeing any legal requirements, can’t be turned off.

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 the browser. You can at any time manage your data preferences in relation to our use of cookies and similar technologies. If you wish to manage or opt out of using cookies, you can do so by setting you browser to not accept certain or all cookies. For how to do this, please see your browser’s help information or visit www.aboutcookies.org .

Please note that if cookies are deleted or declined:

- certain areas and functions on this Website require cookies and may not function; and - we may no longer recognize your preferences in relation to our use of cookies and other technologies described herein, including in relation to personalized communication, and may ask for your preferences again.

For more information regarding the cookies used on this Website please contact us dpo@spelet.lv

Which cookies we use

The tables below set out the specific cookies that are used on our website and mobile app, respectively. The tables also set out the purpose of each cookie.

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 you may experience. The list below set out the specific cookies that are used on our website and mobile app, respectively.

Cookie name Description
locale Defines user's language to show the relevant content
original_user_id Stores the duplicated user id
trackers Collects the statistics for google analytics
ga_client_id Google analytics id
referral_params Assigns a user to an affiliate if any
btag Identifies the different affiliate systems, campaigns and affiliates
subid Identifies the different affiliate systems, campaigns and affiliates
ctag Identifies the different affiliate systems, campaigns and affiliates
affiliate_link_id Identifies the different affiliate systems, campaigns and affiliates
qtag Identifies the different affiliate systems, campaigns and affiliates
stag Identifies the different affiliate systems, campaigns and affiliates
utm_source UTM parameters of the url
utm_medium UTM parameters of the url
utm_campaign UTM parameters of the url
utm_content UTM parameters of the url
utm_term UTM parameters of the url
_casino_session Allows to stay logged in on each of web-site's page and during the next visits
_cookies_accepted Defines if the cookies have been accepted by a user
_user_visited_app Defines if the user has already visited the website
_access_by_country_policy_accepted Defines the list of countries where the cookies have been accepted by the user
utm_source, utm_medium, utm_campaign, utm_content, utm_term UTM parameters of the url

10. AMENDMENTS TO THIS POLICY

This Policy may be amended from time to time to reflect changes in the way we process Your Personal Data and, in such case, the most recent version of the Policy will appear on this page. If you do not agree to any of the changes you have made, you may immediately withdraw your consent and discontinue using our Services or contact us. Please check back periodically, and especially before you provide any new personally identifiable information.

We use cookies to improve your experience. By using our website you are accepting our Cookie Policy Cookie Policy