NOTIFICATION ON PERSONAL DATA PROCESSING
OF THE LIMITED LIABILITY COMPANY “GGBET”

LIMITED LIABILITY COMPANY “GGBET” appreciates your trust and strives to ensure the legality of processing and security of personal data of the Website Users ggbet.ua (“Website”) and/or mobile application IOS and Android (“Mobile Application”).

Adhering to the principles of openness and transparency, we inform you as a subject of personal data about the main aspects of the processing and protection of your data with this Notice on the processing of personal data and GGBET LIMITED LIABILITY COMPANY (hereinafter the "Notice").

We encourage you to read the Notice carefully to ensure that you are aware of the following issues:

  1. who is responsible for processing and protecting your personal data;

  2. what personal data we collect and process;

  3. the purposes and legal basis for processing personal data;

  4. whom and under what circumstances we may disclose your personal data;

  5. how we ensure the protection of your personal data;

  6. how we store your personal data;

  7. the rights of the data subject and how you can exercise them;

  8. how we use cookies.

For convenience, the general term “Website" is used in this Notice to refer to the Website and the Application together, except for the provisions relating exclusively to the Application and personal data processed when using the Application.

In this Notice, the term “User” refers to any person who accesses and uses the Website, regardless of the fact of registration and use of the Services. The term “Client” is used to refer to registered Users.

All terms used in this Notice shall be interpreted in accordance with the Rules of the Gambling Organizer ("Rules") and the Public Offer ("Offer") of GGBET LIMITED LIABILITY COMPANY, unless otherwise defined in this Notice.

Any translation from the Ukrainian version of the Notice is provided for your convenience only. In the event of any discrepancy in meaning or interpretation between the Ukrainian version and any translation, the Ukrainian version of the Notice shall prevail. The original text in Ukrainian is the only legally binding version.

The owner of personal data and his/her contact information

LIMITED LIABILITY COMPANY “GGBET”, legal entity identification code: 44912194, location: 17, Yevhen Sverstyuk St., office 601, Kyiv, 02002 (the “Company”, “we”, "organizer") operates the Website and uses it to provide the Services in accordance with the laws of Ukraine and the Rules.

Within the meaning of the Law of Ukraine “On Personal Data Protection” No. 2297-VI dated June 01, 2010 (the “Law”), the Company is the owner of personal data, as it determines the purpose of processing, the composition of personal data and processing procedures in the context of your use of the Website and Services.

You can send any issues regarding the processing and protection of your personal data while using the Website and Services, to our e-mail address privacy@ggbet.ua or send a letter to the address of location.

Personal data we process

When you use our Website and/or Services, we collect various categories and types of personal data. Below is detailed information about the personal data we collect and otherwise process, broken down by source of its receipt.

Data we receive directly from you

Registration data

To create a Client account on the Website, you provide us with the following information:

  • last name, name and patronymic (if available);
  • your age (date of birth);
  • e-mail address;
  • phone number;
  • password to access your Client account.

 After creating a Client account, we assign you a unique Player’s number in our system.

 

Identification data

For identification purposes, we may request additional information from you:

  • information about the passport or other identity document that can be used in Ukraine to enter into transactions in accordance with the law: number, series (if any), date of issue and the issuing authority and photographs of the document;
  • registration number of the taxpayer's record card (RNTPRC);
  • your phone number and email address;
  • for persons who are residents of countries other than Ukraine (non-residents) - information about your citizenship;
  • information about your place of residence or place of stay (for residents), place of residence or place of temporary stay in Ukraine (for non-residents);
  • your electronic signature, BankID, MobileID if you use these methods to identify yourself on the Website;
  • unique record number in the Unified State Demographic Register (if any) for non-residents.

Verification data

The Company may conduct a verification procedure to confirm that the Identification Data belongs to you. The Company may also initiate other verifications to comply with the requirements of Ukrainian legislation and protect the business. For this purpose, we may request data from you, including, but not limited to, the following:

  • a photo of a passport or other identity document that can be used in Ukraine to enter into transactions in accordance with the law;
  • your own image (photo) with your passport or other identity document, which, in accordance with the law, may be used in Ukraine to conclude transactions, in particular, by taking your photo with such a document;
  • a photo of your payment instrument (payment card) and your own image (photo) with the payment instrument (payment card);
  • documents confirming your place of residence, and for non-residents also information about the place of temporary residence in Ukraine;
  • the Company may conduct verification by means of video communication, which means the use and storage of audiovisual information and photographic data;
  • if you or a member of your family is a politically exposed person, we may request data or documents from you confirming the source of your wealth, the source of funds related to financial transactions, or other information about your income, assets, etc.;
  • other documents that may be necessary to comply with the requirements of Ukrainian legislation.

Communication data

In the course of using the Website and the Services, we may communicate with you via e-mail, the Website interface, paper correspondence, SMS correspondence, social media, as well as audio and video calls. We collect and store the date and time of communication, the means of communication, the content of all messages, call recordings (both audio and video), the status of the issue you have addressed, etc.

Data on self-limitation

If you apply to the Company with an application for self-restriction and entering information about you into the Register of Persons Restricted from Accessing Gambling Facilities and/or Participating in Gambling in the established form, we may process the following data:

  • last name, name and patronymic (if available);
  • your date of birth;
  • your place of residence;
  • your citizenship/nationality;
  • data of the identity document (name of the document, series (if any), number, date of issue, name of the issuing authority, official name of the foreign state authority in which the document was issued);
  • registration number of the taxpayer’s record card (RNTPRC) (if available);
  • means of communication (your phone number and e-mail address);
  • unique record number in the Unified State Demographic Register (if available);
  • self-limitation term;
  • reasons and grounds for self-limitation, as well as information from any documents attached to the application (if available);
  • image of your personal signature.


Data arising from the use of the Website and Services

User’s data

We collect information about how you use our Website: information about the source from which you came to the Website (referrer); date, time and duration of the session; pages you visited; time spent on each page; content you viewed; links you clicked, etc.

Data on gambling activity

When you place bets and perform other gambling activities on the Website, we may process the following data:

  • information about your sports bets: date and time, bet type, bet name, event, bet amount, odds, expected winnings, specific betting conditions (if any), event result, bet outcome, win/loss amount;
  • information about your bets in casino games: date and time, game name, duration of participation in the game, bet amount, specific betting conditions (if any), game outcome, bet result, win/loss amount;
  • information about your use of bonuses: name of the bonus, date and time of activation, and the entire history of your use of bonuses, etc.

The Company generates and stores the entire history of your bets and other gambling activity on the Website from the moment of creating a Client account to achieve the goals set out in this Notice.

Device data

When you use the Website, we collect data about your device: your IP address, device type, operating system type and version, browser type and settings, device identifiers, location data, etc.

Profile data

Based on your activity on the Website and communication with you, we may collect data about your preferences (types of bets, events, games, bonuses, communication channels, language of communication), hobbies, interests, feedback, complaints, satisfaction with the Services, results of your verifications or other checks, information about the application of self-limitation, comments on your profile, etc.

Transactions data

We also collect data about your deposits and winnings, the date and time of transactions, the amount and currency of transactions, the balance of your Client account, the payment methods you use.

Marketing data

We collect data about your interactions with our marketing campaigns (advertising messages, promotions, bonuses, special offers, etc.). This data includes: information about your choice to receive our marketing communications; your preferred means of communication; the type of marketing communications you are most interested in; information about whether you opened our marketing communications, clicked on a link or otherwise interacted with it.


Data we may receive from third parties

Payment service providers

All payment transactions made in connection with the use of the Services are processed by payment service providers (banks, payment institutions, etc.) and not directly by the Company. In order to confirm the success of payment transactions, we may receive the following data from payment service providers (“Payment Data”) date and time of the payment transaction; payment status; payment method used for the payment; transaction amount and currency; transaction code and other information regarding payment transactions. The Company generates and stores the entire history of your payments from the moment of creating a Client account to achieve the goals set out in this Notice.

Social Media

If you log in to the Website using your social media account, we, with your permission, receive your profile information necessary to register a Client account on the Website, in particular: your name, contact information and other data to which you have authorized access (“Social Media Data”).

Analytics providers

We use the services of analytics providers to study your use of the Website and evaluate its performance. Therefore, we may receive some data from them.

Marketing service providers

Marketing service providers may share information about our potential customers with us.


Data we may receive from other sources

Official registers of Ukrainian state authorities and/or other reliable sources

We may receive some Verification Data from official registers of Ukrainian state authorities and/or reliable sources. Such data may include:

  • information about your presence or absence in the Register of persons who are restricted from access to gambling facilities and/or participation in gambling;
  • information about your presence or absence in the list of terrorists, the sanctions list of the National Security and Defense Council of Ukraine (NSDC) for individuals;
  • information about your affiliation with politically exposed persons (politically exposed persons or PEP);
  • information about whether you have a close connection with the Russian Federation, in particular, have a place of residence or are engaged in the main activity in the Russian Federation, regardless of your citizenship;
  • any other data required by the Company to comply with the requirements of the legislation of Ukraine or to protect the interests of the business.

Other publicly available sources

In order to fulfill our obligations under Ukrainian legislation in the field of gambling regulation and financial monitoring, as well as to protect our business from fraud and other illegal activities, we may receive information about you from publicly available sources (social networks, search engines, etc.).


Data collected and processed in our Application

Our Application uses third-party services, in particular, analytics providers, which may collect data about you through the installed Software Development Kit (SDK).

Application data

When you use our Application, the following data may be collected and used:

  • IP-address;
  • unique device identifier for advertisers (if you have your permission or no objections in accordance with the rules of the app store);
  • information about the installation and first opening of the Application on your mobile device;
  • information about your interaction with the Application (pages visited, time spent on each page, etc.)
  • information about which advertisements you have seen and clicked on;
  • information about device specifications, type and version of the operating system.


Purposes and legal grounds for processing personal data

Before carrying out any processing of personal data, we are obliged to determine in advance the purpose of this processing and the legal basis for it.

Processing purpose

Personal data composition

Legal basis for processing

Providing access to the Website functionality, ensuring its correct operation and security

Device data
In certain situations, if necessary, other categories of personal data may be used

Legitimate interest of the Company (in particular, in the convenient and safe use of the Website by Users)

Registering you as a Player on the Website, creating and maintaining a Client account

Device data
Registration data
Identification data
Social media data

Conclusion and execution of a transaction with you

Carrying out verification and other inspections in accordance with the legislation of Ukraine in the field of gambling and financial monitoring and/or inspections that the Company considers necessary to protect its interests

Registration data
Identification data
Verification data
Communication data

Compliance with legal requirements
Legitimate interest of the Company (in particular, in preventing persons recognized by the Company as undesirable from using the Services)

Providing you with the Services on the Website, including accepting and processing your bets, calculating and paying out winnings

Device data
Usage data
Registration data
Gaming activity data
Transaction data
Payment data
Communications data
Profile data

Performing a transaction with you
Legitimate interest of the Company (in particular, the correct processing and recording of bets)

Involving you in loyalty programs

Usage data
Device data
Registration data
Data on gambling activity
Transaction data
Payment data
Communication data
Profile data

Legitimate interest of the Company
(in particular, to improve the relationship with you as a player)

Prevention, detection and termination of any suspicious behavior on the Website that may harm the interests of the Company and/or Users, violate the laws of Ukraine

Usage data
Device data
Registration data
Identification data
Verification data
Gaming activity data
Transaction data
Payment data
Communication data
Profile data

Compliance with legal requirements
Legitimate interest of the Company (in particular, to prevent the use of the Website and Services for fraudulent purposes)

Ensuring compliance with the Rules by all players, preventing, detecting and terminating Violations

Usage data
Device data
Registration data
Identification data
Verification data
Gaming activity data
Transaction data
Payment data
Communications data
Profile data

Legitimate interest of the Company
(in particular, to prevent abuse and violations of the Rules)

Control over compliance with the principles of responsible gaming by monitoring activity on the Website

Usage data
Device data
Registration data
Identification data
Verification data
Gaming activity data
Transaction data
Payment data
Communication data
Profile data

Compliance with legal requirements
Legitimate interest of the Company (in particular, in the timely detection of signs of gambling addiction in Users)

Inclusion of Players in the Register of Persons Restricted from Accessing Gambling Venues and/or Participating in Gambling upon their written application for self-limitation

Self-limitation data
Communication data

Compliance with legal requirements
The Company's legitimate interest (in particular, to prevent the negative impact of the Services on Players)

Non-admission of Players included in the Register of Persons Restricted from Accessing Gambling Venues and/or Participating in Gambling to the Services

Usage data
Device data
Registration data
Identification data
Verification data
Communication data
Profile data
Self-limitation data

Compliance with legal requirements
The Company's legitimate interest (in particular, in compliance with the principles of responsible gambling by the Company and its Players)

Compliance with the requirements of tax legislation on the calculation, withholding and payment of personal income tax and military duty, tax accounting and reporting

Registration data
Identification data
Verification data
Payment data

Compliance with legal requirements
Legitimate interest of the Company (in particular, in the proper maintenance of tax reporting and accounting)

Providing support and communication with you in the context of your use of the Website and Services

Registration data
Communication data
Profile data
Any other data that is necessary to process to resolve your issue

The legitimate interest of the Company (in particular, in the effective resolution of any issues at your request)

Analyzing your interaction with the Website and Services and providing you with a personalized experience on the Website

Usage data
Device data
Registration data
Gaming activity data
Profile data

The legitimate interest of the Company (in particular, to improve our Website and the quality of the Services)

Sending you marketing materials with our offers and bonuses

Registration data
Gaming activity data
Profile data
Marketing data

Your consent

Analysis of the effectiveness of marketing campaigns, personalization of advertising

Usage data
Registration data
Gaming activity data
Transaction data
Profile data
Marketing data

The Company's legitimate interest (e.g., to improve our marketing strategy)


Sharing your personal data

In most cases, the processing of your personal data in connection with the use of the Website and Services is carried out within the Company by its employees. The Company establishes different modes of access to data for its employees, which are necessary for the performance of their duties.

In order to administer the Website and provide the Services in a quality manner, the Company may involve other persons in the processing of personal data as data processors, imposing contractual obligations on them regarding the security and confidentiality of your personal data. In addition, the Company may transfer your data to third parties, in particular, with your consent or in cases determined by the legislation of Ukraine.


Your personal data may be transferred to other parties in the following situations:


Use of third-party services

To support the operation of the Website and the quality of the Services, the Company may use third-party services, such as hosting, cloud storage, analytics, security and protection of information systems, marketing services, postal services, communication services, technical support services, etc.

Fulfillment of official requests from state and local authorities

In cases determined by the legislation of Ukraine, the Company may provide your personal data at the official requests of state and local authorities, provided that they are submitted within their authority, contain a specific purpose of the request and the legal basis for processing the requested data.

At the request of a person authorized by you or your legal representative

We may transfer your personal data at the request of persons whom you have authorized in accordance with the procedure established by law to request access to data on your behalf, or your legal representatives.

To facilitate the investigation of illegal activities

If we detect fraud or other illegal activities, we may transfer your data to authorized bodies for investigation.

Protection of the Company's interests in legal disputes

In the event of legal disputes related to your use of the Website, in particular, regarding violations of the Rules by you, the Company may disclose certain data about you to the dispute resolution body, in particular, a court.

Change of personal data owner

In the event of the sale of all or any part of the Company's business or assets and the change of the Website operator, the Company may transfer your data to the new owner. The new owner will become the owner of personal data and will be primarily responsible for its processing. You will be informed in advance about the transfer of personal data to the new owner.

In other cases, with your consent

With your consent, we may transfer your data to third parties for purposes other than those specified in this Notice.


Personal data protection

To ensure the security of your personal data, we have implemented appropriate technical and organizational measures in accordance with industry best practices.

Organizational measures

  • approved internal policies and procedures for processing and protecting personal data for the Company's employees;
  • providing access to personal data of Users only to those employees or contractors of the Company who need this data to perform their duties and who have contractual obligations regarding confidentiality and security of data.

Technical measures

  • storing personal data in secure storage;
  • use of pseudonymization (for example, when appropriate, a set of numbers is used instead of your name - a unique Player number in our system);
  • data encryption.


Storage of personal data Location of data

The Company stores personal data primarily in Ukraine, but may also use cloud storage services outside of Ukraine.

Personal data storage period

We retain your personal data for no longer than is necessary to achieve the processing purposes set out in this Notice.

However, please note that in some cases, Ukrainian law requires the Company to retain certain data about you even after the purpose of processing set out in the Notice has been achieved.

In particular, the Company, as a subject of primary financial monitoring, is obliged to keep information on financial transactions with Players for at least five years after the termination of business relations with them (clause 18, part 2, article 8 of the Law of Ukraine “On Prevention and Counteraction to Legalization (Laundering) of Proceeds of Crime, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction” of December 06, 2019, No. 361-IX).

This means that within 5 years after the termination of the relationship with you (for example, blocking of the Client account at your initiative), we will not be able to satisfy your request for the destruction (deletion) of your personal data that we need to comply with the requirements of the law. After the expiration of the storage period, the Company has the right to depersonalize (anonymize) the data so that it no longer relates to you for statistical purposes.

Rights of data subject

According to Article 8 of the Law, you as a data subject have the following rights:

know about the sources of collection, location of your personal data, the purpose of its processing, location or place of residence (stay) of the owner or manager of personal data or give an appropriate order to obtain this information to persons authorized by you, except in cases established by law;

receive information about the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred;

access to your personal data;

receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his or her personal data is processed, as well as to receive the content of such personal data;

submit a reasoned request to the personal data controller with an objection to the processing of your personal data;

submit a reasoned request to change or destroy your personal data by any owner and administrator of personal data, if this data is processed illegally or is unreliable;

protect your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honor, dignity and business reputation of an individual;

file complaints about the processing of your personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court;

apply legal remedies in case of violation of the legislation on personal data protection;

make reservations regarding the restriction of the right to process your personal data when providing consent;

withdraw consent to the processing of personal data;

know the mechanism of automatic processing of personal data;

protection against an automated decision that has legal consequences for him/her.

If you wish to exercise any of these rights, please contact us with a request at privacy@ggbet.ua or our registered office address.

Amendments to Notice

If necessary and in order to comply with the requirements of the law, the Company may amend and supplement this Notice at any time. The current version of the Notice is always available on the Website.

How to use cookies

The Website uses cookies - small pieces of text that the visited website sends to your browser (web browser) (Google Chrome, Opera, Safari, etc.) and recognizes them during each subsequent visit. They help to improve the efficiency of the Website, protect it from any harmful behavior, make your use of the Website convenient and personalized, and help us to advertise our Services.

We may use our own cookies on the Website - first-party cookies, as well as cookies of our partners whose services we use - third-party cookies.

Categories of cookies

Strictly necessary

These cookies are essential for you to browse our Website and use its features. Without them, basic functions of the Website will not work properly and we will not be able to provide you with the Services.

Functional

These cookies allow the Website to remember your choices while browsing and using the Website and your preferences.

Analytical

These cookies help us to study the behavior of Users on the Website to improve the user experience and improve the Website and Services.

Advertising

These cookies help us to make our ads more relevant and interesting.


Types of cookies, storage period, purpose

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Managing cookies

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