Days of Poker 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”) the online poker application Days of Poker (hereinafter referred to as the “App”). Users will find below the provisions regarding the processing of their personal data which apply during any visit to or use of the App by the Users (hereinafter referred to as the “Privacy policy”).

This is the privacy policy for the Days of Poker project.
The document is fully verified by the legal team of Ardent Group to make sure that we can guarantee the best possible protection in terms of privacy for all the Days or Poker players.

This document will be available on the website an in app.
Players must accept our Privacy Policy during the registration process. It will be impossible to play for players if they don’t agree with this policy.

1. Background

Days of Poker 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, Days of Poker 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, Days of Poker:

• 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 Days of Poker is accurate.

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

Legal obligations of Days of Poker and data processing required for use of the App

Days of Poker is bound by the legal and regulatory obligations to which all online gaming and gambling 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 Days of Poker does not require the consent of Users under Article 6.1.2 and 6.1.3 of the Regulation.

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

What personal data is processed?

The following personal data is processed:

• surnames, first name/s, date of birth, language, sex, domicile/address, national identification number (or identity card or passport number), email address, landline or mobile telephone number;
• bank details when transactions are made on the App to deposit sums and withdraw winnings;
• copies of personal documents enabling User authentication, such as the identity card photograph, a statement of account, delivery note or any other document proving the domicile and/or address of the User;
• the User’s history and activities on the App, including playing history (stakes), transactions (wins and losses, deposits, withdrawals, bonuses, gifts and other forms of reward) and visits (browser data, IP address);
• any other information that may be exchanged between Days of Poker and the User, namely by email or live chat, during the User’s registration or use of the gaming activities offered on the App.

What data processing does Days of Poker carry out?

The data processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing or any other transaction that becomes necessary or useful under the legal and regulatory provisions set out in Article 2.1.3). Processing may also consist of transferring personal data:

• to judicial and administrative authorities, including, namely, the Belgian Gaming Commission, or the Financial Information Processing Unit (CTIF);
• to Days of Poker suppliers, whose services are required for use of the App and who are cited on a list that may be requested from the contact person detailed in Article 7.6;

What are the purposes of this data processing?

1° – Days of Poker is required to process personal data as per Articles 2.1.1 and 2.2.2 in order to comply with the legal and regulatory obligations by which it is bound, namely the following legal provisions:

• the law of 18 September 2017 on the prevention of money laundering and terrorist financing and the restriction on the use of cash;
• the law of 7 May 1999 on games of chance, bets, gaming establishments and the protection of players, in particular the obligations it places on operators in terms of management and administration, and its implementing orders, including the Royal Decree of 15 December 2004 on the access register for class I and class II gaming establishments.

2° – Days of Poker also processes personal data set out in Article 2.1.1 to authenticate Users and allow them to access and use the App. This processing is then carried out in order to:

• manage User registrations and accounts;
• manage User deposits and winnings and more generally supply online gaming services;
• keep Users informed about services offered by Days of Poker
• manage customer services, including the support service and risk and fraud.

Other data processing that does not require the consent of Users

Days of Poker also processes the following personal data for the legitimate purposes set out below. This processing of personal data carried out by Days of Poker does not require the consent of Users under Article 6.1.6) of the Regulation.

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

What personal data is processed?

The following personal data is processed:

• surnames, first name/s, date of birth, language, sex, domicile/address, language, email address, landline or mobile telephone number;
• bank details when transactions are made on the App to deposit sums and withdraw winnings;
• copies of personal documents enabling User authentication, such as the identity card photograph, a statement of account, delivery note or any other document proving the domicile and/or address of the User;
• the User’s history and activities on the App, including playing history (stakes), transactions (wins and losses, deposits, withdrawals, bonuses, gifts and other forms of reward) and visits (browser data, IP address);
• any other information that may be exchanged between Days of Poker and the User, namely by email or live chat, during the User’s registration or use of the gaming activities offered on the App.

What data processing does Days of Poker carry out?

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 2.2.1. 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.

What are the legitimate purposes of the data processing?

Days of Poker processes personal data set out in Article 2.2.1 for the following legitimate purposes:

• developing new poker gaming offerings;
• to promote, advertise and market its offering of online poker gaming services (including membership and management of loyalty programs) which includes sending text messages, telephone calls, paper or electronic newsletters;
• the participation in competitions and promotional offers, including the communication to winners;
• to conduct satisfaction surveys, statistical studies, trend analyses, and market research in order to improve online gaming services or to inform or protect Users and prevent gambling addiction, as well as for management, marketing, reporting (including profiling) purposes.

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

By using the Days of Poker App, for any reason whatsoever, the User expresses their free, individual, informed and unambiguous consent to expressly authorise Days of Poker 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 Days of Poker 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.

Nature of the personal data processed

Days of Poker processes the following personal data:

• surnames, first name/s, date of birth, language, sex, domicile/address, national identification number (or identity card or passport number), email address, landline or mobile telephone number;
• the User’s history and activities on the App, including playing history (stakes), transactions (wins and losses, deposits, withdrawals, bonuses, gifts and other forms of reward) and visits (browser data, IP address);
• any other information that may be exchanged between Days of Poker and the User, namely by email or live chat, during the User’s registration or use of online gaming offered on the App.

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

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.

Purposes of the personal data processing

The personal data is collected and processed by Days of Poker for the purpose of promotion, advertising and marketing activities, including membership and management of loyalty programs relating to the offering of online gaming services, which includes sending text messages, telephone calls, paper or electronic newsletters, involving third parties processing of personal data.

4. Rights of Users

Without prejudice to Articles 2 and 5, Users may exercise their rights to request that their data be rectified, to object to it being processed and to limit the processing, according to the terms and within the limits set out below.

Right of access

1° – Days of Poker 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 its legal basis;
• 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 Days of Poker to process this data, as well as the option to object to any processing of their personal data for marketing purposes.

2° – 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.

3° – Users may obtain a copy of their personal data that are processed. For any further copies requested by the Users, Days of Poker reserves the right to claim payment for any expenses incurred in this additional request. These expenses shall be calculated on the basis of administrative costs incurred in the request and shall not exceed 20 euros.

4° – 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.

Right to request rectification

Days of Poker 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.

Right to object to the processing of data

Days of Poker 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, Days of Poker allows Users to object to:

• the automatic processing of their data, including profiling, unless there are justified grounds requiring Days of Poker 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.

Right to be forgotten

Days of Poker 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 Days of Poker 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.

Right to limit the processing of data

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

• the User believes the personal data to be inaccurate, whilst Days of Poker 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 Days of Poker’s reasons for seeking to continue this processing;
• Days of Poker 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.

Transferring data to another data controller

Users may transfer the personal data processed by Days of Poker in the context of Articles 2.2 and 3 to another data controller without objection from Days of Poker. For such a transfer to be technically possible, Users may ask Days of Poker that it be performed directly by its data controller.

Modalities

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

Days of Poker shall respond to such requests of Users within one month and shall maintain a record relatively.

Notification

Days of Poker 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

Location

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

Retention period

Users’ personal data is retained by Days of Poker 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 2.1; Days of Poker 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 gaming. Users declare that they have been informed of this and agree that, by reference to the Royal Decree of 15 December 2004 on the access register for class I and class II gaming establishments, Days of Poker is required to retain a photocopy of the User’s identity card or the document used for identification for at least ten years from the date of the player’s last activity in the App.

For all of the cases governed by Article 2.2. and 3., personal data is, moreover, only retained for the period required for the purpose of the processing, with the understanding that the conservation period must take into account, given the specificity of the services offered by Days of Poker, the case of Days of Poker being obliged – as on the Gaming Commission, a judicial authority or a third party ‘s initiative – to enforce or exercise a right to justice in connection with the personal data of Users

6. Liability of Days of Poker – Data processor

Risks protection

Days of Poker 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 Days of Poker 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.

Days of Poker implements 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 anonymization and encryption of personal data, depending on the purpose. Organisational measures include carrying out internal audits, in addition to audits to which Days of Poker may be subject by the Belgian Gaming Commission in particular.

If necessary, Days of Poker and the data protection officer shall carry out an impact assessment when the data processing is likely to pose a high risk for Users.

Third parties

Users’ personal data is not sent to any third parties other than suppliers and partners of Days of Poker, except for the purposes set out in Articles 2.1, 2.2 and 3 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 gaming 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 Days of Poker. Days of Poker 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 Days of Poker acts in the capacity of the processor’s partner, Days of Poker 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, Days of Poker shall not be held liable if it proves that it is not responsible for the event that gave rise to the damage.

Processing record

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

Security breach

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

Days of Poker shall record any security incident and shall take appropriate organisational and technical measures so it can be resolved promptly.
Days of Poker 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

Record of personal data and data protection manual

As a personal data controller, Days of Poker 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 Days of Poker at all times. In addition to the information above, this record includes:

• a description of the purposes of the processing;
• a description of the categories of data subjects and categories of personal data;
• the categories of recipients to whom the personal data has been or shall be sent, including recipients in non-EU countries or international organisations;
• the deadlines for erasing various categories of data;
• a general description of technical security measures.

Cookies and Trackers policy (analytical data)

1° – A “cookie” is a set of data that the App records temporarily or permanently on the User’s system by means of their web browser.

The App uses cookies in order to make browsing more effective, useful and reliable. Some of these cookies are vital for the App to function; others are designed to improve the gaming experience and the browsing of the App.

A “tracker” is a set of data collected during the browsing on the App and centralised on a partner server.

2° – By accessing and using the App, Users expressly agree to the cookies and trackers utilisation policy of Days of Poker

3° – The App uses the following data (cookies and trackers):

• Cookies necessary to use the App: these are cookies technically required for operating the App, as they ensure good communication with the User and facilitate browsing.
• Functional cookies: they improve the browsing and facilitate Users’ access to their searches. They therefore enable the specific functionalities on the App to be activated and improve its user-friendliness and the User’s experience, including by remembering their preferences (language, for example);
• Trackers: the App uses tracking data via Google Analytics, in order to measure the ways users interact with the website’s content; they enable User recognition and counting, inform about Users’ browsing behaviour on the App and generate website visit statistics, which may or may not be anonymous. These statistics enable us to continually improve the App and offer the User appropriate content.

The App uses Google Analytics to get an overview of the traffic on the website, the origin of this traffic and the pages visited. This means that Google acts as a subcontractor of Days of Poker. The information gathered by Google Analytics is generated as anonymously as possible. For example, it is not possible to identify the persons who visit the App. For further information, the User is invited to consult Google’s data protection policy, available at the following address: http://www.google.nl/intl/en_uk/policies/privacy/.

4° – How can cookies and trackers be deactivated?

Most web browsers are configured to automatically accept cookies. Therefore, if Users wish, within the limits provided in article 3, to refuse use of cookies or personalise cookie management, they must change their browser settings.

If the User deactivates certain cookies, certain parts of the Website may not be viewable and/or usable, or may be only partially so.

The browser can be set to send an alert when a cookie is about to be used so that the User can decide whether to accept it or not.

If the User wishes to block cookies, they must use the appropriate link for their browser:

• Internet Explorer
• Chrome
• Firefox
• Safari

In order to cease to be tracked by Google Analytics on any website, you can go to the following website: http://tools.google.com/dlpage/gaoptout

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

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.

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 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

Identity of the data controller and data protection officer

The data controller within Days of Poker is M. Kristof DE DEKEN. Days of Poker may be contacted for any questions regarding the protection of Users’ personal data via following:

• Letter: Boomsesteenweg, 440, 2610 Wilrijk, Belgium
• Email: info@daysofpoker.com
• Telephone: +32 (0)3 297 43 81

Days of Poker has also appointed a data protection officer under Article 37 of the Regulation cited above. This person may be contacted by email: dpo@daysofpoker.com

They are responsible for ensuring that processing of Users’ personal data by Days of Poker is monitored and complies with legal requirements.

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