What we need your OU for

Player account registration:

Using the web/mobile app/sportbox with your loyalty card:

Deposits and withdrawals (web/mobile):

Withdrawal from player account (withdrawals over EUR 2000):

Loyalty program:

Betforum:

Competition:

Customer support:

Sportbox (without registration):

Direct Marketing:

Complaints:

The protection of your personal data is extremely important to us. As one of the fundamental pillars on which the new GDPR legislation is based is the principle of transparency, this Privacy Policy will give you an overview of how we process your personal data. On the following pages we will explain in particular the following:

• why we process your personal data
• what types of data we process
• how long we keep them
• whether we disclose your data to third parties, including the specification
• whether we transfer your data outside the Slovak Republic
• where we obtained the personal data from
• whether automated individual decision-making, including profiling, takes place
• what rights you have in relation to the protection of your personal data

Contact details of the operator

There are a number of ways you can contact us, whether by phone, email or post.

Our postal address is:

DOXXbet, s.r.o.

Kálov 356,

010 01 Žilina

Email: info@doxxbet.sk

Hotline: +421 911 569 909

Contact details of the responsible person

Our responsible person is Ing. Peter Duraj, dpo@doxxbet.sk

How we collect personal data

We obtain your personal data that we process directly from you, for example, for one of the following reasons:

• by registering a player account at www.doxxbet.sk or via the doxxbet mobile app;
• using the Sportbox betting terminal (if linked to a player account);
• in connection with consent to the transmission of data for marketing purposes;
• as long as you post on the betforum;
• in the event of a claim;

We may also receive personal data concerning you indirectly, for example:

• from the affiliate partners through which you have reached us
• from financial institutions (banks, payment gateways, online wallets)
• from card processors

1. Right of access to data

Your fundamental right is the right to obtain confirmation from us as to whether we are processing your personal data. You can also request access to this data from us.

1.1

How do you access your personal data?

You can ask us for access to your data by making a simple request. In this context, we would ask you to state the following:

• your name and contact details
• login to player account
• registration code or registration data - name, surname, address, date of birth, email address
• any other information that is relevant to your request

For example, you can ask us for:

• personal data we process in connection with your player account
• email communication between us and you (e.g. between 25 May 2018 and 1 August 2018)
• a list of your customer support requests (e.g. between 25 May 2018 and 1 August 2018)
• Transaction history (e.g. between 25 May 2018 and 1 August 2018)

What data and information can you access?

Upon your request, we will provide you with information on:

• the purposes of processing personal data concerning you
• categories of personal data concerned
• the recipients or categories of recipients to whom your personal data will be disclosed
• the expected retention period of the relevant personal data
• the existence of the right to request from us the rectification of your personal data, their erasure, restriction of processing, and the right to object to processing
• the right to lodge a complaint with the supervisory authority
• the source of the personal data, unless we have obtained it directly from you
• the existence of automated decision-making, including profiling, as well as their meaning, the process used and the envisaged consequences in relation to your person

Sample application

[Address]

[Contact details]

[Date]

VEC: Request for access to data

Dear Sir/Madam,

In accordance with Article 15 of the GDPR, I hereby request access to the personal data you process about me. Specifically, I am requesting access to: [specify the specific data you are requesting, for example:]

• the personal data you process in connection with my player account (login: XY, registration code: XY)
• email communications between myself (please enter your email) and info@doxxbet.sk between 25 May 2018 and 1 August 2018
• Other

I request the above data in electronic form / by mail to the following address: XY. Should you require any other information from me in this regard, please do not hesitate to contact me.

Regards,

[Name and signature]

2. Right to correction

If you feel that any of the personal data we process about you is incorrect, you can request us to correct it. You can also request us to complete any data that you consider incomplete.

2.1

How can you request correction of your personal data?

You can ask us to correct and/or complete incorrect and/or incomplete personal data concerning you by making a simple request. In this context, we would ask you to state the following:

• state clearly and comprehensibly where, in your opinion, the inaccuracy or incompleteness of the relevant personal data lies
• let us know how you wish the repair to be carried out
• if necessary, demonstrate the inaccuracy of the personal data

3. Right to erasure (oblivion)

You have the right to request that we erase the personal data we process about you, and we are obliged to comply with this request in certain cases specified by law. In the media, this right is often referred to as the "right to be forgotten".

3.1

How can you request the deletion of personal data concerning you?

You can ask us to delete personal data concerning you by making a simple request. In this context, we would ask you to state the following:

• indicate clearly and comprehensibly which personal data you require erasure of

Is the right to erasure absolute?

No, the right to erasure is not an absolute right. Article 17(1) of the GDPR lists the grounds that must be fulfilled in order to trigger an obligation on our part to delete your data. These grounds are as follows:

• Your personal data is no longer necessary for the purposes for which we collected or otherwise processed it
• Your personal data was processed on the basis of your consent, but you later withdrew this consent
• you have objected to the processing of personal data relating to your particular situation and your interests, fundamental rights and freedoms override our legitimate interests
• we have unlawfully processed personal data about you
• there is an obligation to erase your personal data under our law or European Union law

In this regard, we would like to inform you that in certain cases the GDPR allows us to refuse your request for deletion. These cases are as follows:

• the processing of personal data is necessary for the exercise of the right to freedom of expression and information
• we are obliged by our law or European Union law to process your personal data
• the processing is necessary for archiving purposes in the public interest, for scientific research purposes or for statistical purposes
• the processing is necessary for the establishment, exercise or defence of legal claims.

4. Right to restriction of processing

You have the right to limit the extent to which we process personal data relating to you.

4.1

How can you request the restriction of the processing of personal data concerning you?

You can ask us to restrict the processing of personal data concerning you by making a simple request. In this context, we would ask you to state the following:

• state clearly and comprehensibly which personal data you are requesting to restrict the processing of and the reasons for your request

Is the right to restriction of processing absolute?

No, the right to restrict processing is not an absolute right. Article 18(1) of the GDPR lists the cases in which an obligation arises on our part to restrict the processing of your personal data. These cases are as follows:

• we verify the accuracy of your personal data as a result of your objection to its accuracy
• the personal data is being processed unlawfully and instead of erasing the personal data you request us to restrict its use
• you need the personal data to establish, exercise or defend legal claims and we no longer need it for processing purposes
• you have objected that our legitimate grounds outweigh your legitimate grounds

5. Right to data portability

You have the right to obtain your personal data from us in a commonly used format and to transfer this data to another processor. However, this right only applies to data that you have given us your consent to process or is processed on the basis of a contractual relationship with you. Also, this right can only be exercised to the extent that it does not have adverse effects on the rights and freedoms of other persons.

5.1

How can you request restriction of the processing of personal data concerning you?

You can exercise your right to data portability by making a simple request to us.

6.Right to object

In some cases, you have the right to object to the processing of personal data concerning you. This is in particular the processing we carry out on the legal basis of our legitimate interests, including profiling based on that legal basis.

You also have the right to object at any time to the processing of personal data for direct marketing purposes, including profiling to the extent related to such direct marketing.

When processing personal data for scientific or historical research purposes or for statistical purposes, you also have the right to object to the processing on grounds relating to your particular situation.

6.1

How can you request to object to the processing of personal data concerning you?

In practice, objections to processing usually occur if you disagree for some reason with the way we process your personal data. You may get this feeling after reading this Policy, but also, for example, by exercising your right of access. In any case, it will be necessary for you to inform us of your objections.

What must the objection contain?

Your objection should include at least the following:

• a clear and comprehensible description of the circumstances relating to your personal situation on the basis of which you consider that the processing in question unreasonably interferes with your rights and freedoms

7. Rights relating to automated individual decision-making, including profiling

If decision-making occurs without human intervention, solely on the basis of automated processes, this is so-called automated individual decision-making. It is therefore the possibility of making decisions based solely on technological means. Profiling means the analysis of your personal data for the purpose of predicting your later behaviour.

There are situations where, as the person whose personal data is being processed, you have the right to ask us not to apply such a decision to you, as long as the decision has legal effects that concern you or similarly significantly affect you.

An example of an automated individual decision, without human intervention:

• refusal to bet
• refusal of choice
• individual betting limits

7.1

Is the right not to be subject to automated individual decision-making, including profiling, absolute?

No. Similarly for other rights, the legislator lists situations where this right will not apply. These situations are as follows:

• automated individual decision-making is necessary for entering into or performance of a contractual relationship with you (but you have the right to human intervention)
• is permitted by our law or European Union law, while the GDPR itself in recital 71 foresees this possibility in cases of fraud monitoring, tax evasion and prevention
• we have obtained your explicit consent for this purpose (however, you have the right to human intervention)

How can you request not to be subject to automated individual decision-making, including profiling?

You can exercise this right by simply asking. In any case, if you are in any doubt, please do not hesitate to ask us first. We will always be happy to provide you with information on why a certain automated individual decision has been made in relation to your person, as well as what legal effects it may have on you.

8. Right to lodge a complaint

If you have any questions or concerns regarding the processing of your personal data, please do not hesitate to contact us at any time. Our company will always endeavour to resolve any disputed issues to your satisfaction. However, should you be dissatisfied with our procedure, you have the right to lodge a complaint with a supervisory authority.

8.1

The supervisory authority to which you can address your complaint is:

Office for Personal Data Protection of the Slovak Republic

Hraničná 12
820 01 Bratislava 27
https://dataprotection.gov.sk/uoou/

We need to process your personal data in order for you to be able to use our website www.doxxbet.sk (including our mobile apps on iOS and Android), and in some cases when using the Sportbox betting terminal, to make sports betting, betting, virtual games or use other services or products that we offer (hereinafter referred to as the "Services" and/or "Products"). The following sections detail the various processing operations that take place in relation to your personal data.

1. Player account registration

In accordance with the Game Plan, any player who wishes to play (use our products) via our web or mobile application must go through a registration process leading to the creation of a player account. When you first register, we collect the following information from you:

• email address
• phone number
• date of birth
• FB/Google+ login, country, email, age
• details from your identity card and other documents (e.g. driving licence)
• proof of permanent address
• IP address
• data about the device

In this case, the processing of your data is necessary in particular to enable us to safely provide you with our Services and Products. For this purpose, we verify your age, your identity and whether you are on the register of natural persons excluded from participation in gambling.

The legal basis for the processing of your personal data is the performance of our contractual obligations under the Game Plan, as well as the performance of our legal obligations as a controller under the GDPR.

1.1

Pursuant to Article 6(1)(b) of the GDPR, we may process your data as necessary for the performance of the contract to which you are a party. We therefore need this data in order to fulfil our contractual obligations in accordance with the Game Plan, which is the official document - the basic rules for players when betting online or betting via DOXXbet Sportbox.

Furthermore, pursuant to Article 6(1)(c) GDPR, we may also process your personal data if this is necessary for the fulfilment of our legal obligations. In this case, we rely in particular on two laws, namely the Gambling Act and AML.

Participation in gambling is prohibited for persons under the age of 18. For this reason, we must always verify your age. For internet betting, the Gambling Act also requires verification of identity, for which we are obliged to require proof of your identity as well as other official proof of your identity. These obligations are set out in Art. § 35(6) of the Gambling Act. We are also obliged under section 35(7) of the Gambling Act to ascertain whether you have been disqualified from gambling and are on the register of natural persons disqualified from gambling. For these purposes, we are obliged to request information from your identity card as well as from other documents within the meaning of section 12(2)(a)(1.) of the AML.

In accordance with the Game Plan, we also need to process personal data relating to the source of funds in your player account. We need this data both to fulfil our contractual obligations and to pay you your winnings, but also to comply with the AML requirements on the exercise of enhanced due diligence for the purpose of preventing money laundering and the financing of terrorism.

2.Using the web/mobile app

Once you have registered and logged into your player account, we process the personal data you have provided to us which is necessary to provide our Services and Products. We will process the following data about you while you are using your player account through our web or mobile application:

• data processed during player account registration
• betting and gaming activity data
• betting related data (e.g. type of sport, ticket tip, winnings paid, bonuses, etc.)
• IP address
• position data
• data about the device
• number of logins

In this case, the processing of your data is necessary in particular to enable us to safely provide you with our Services and Products. As stated in the section governing the processing of personal data for the purposes of registering a player account, we process your personal data in order to fulfil our contractual and legal obligations. The processing of your personal data is also carried out for the purpose of:

• protection against fraudulent conduct
• ensuring the integrity and functionality of the games
• system error analysis.

2.1

Under Section 3(6) of the Gambling Act, we are obliged to guarantee all players a level playing field, including the possibility of winning. For this reason, we must ensure that your funds, the funds of other players and our systems are protected so that the rules set out in the Game Plan are not circumvented and/or our Services and Products are not abused.

In accordance with Section 14(1) of the AML, as an obliged person, we must ascertain whether there are any unusual business transactions when using our Services and Products. In connection with your activity, we therefore need to monitor e.g. unusual transactions relating to the use of your player account, whether you conduct transactions without an obvious economic purpose (i.e. at a loss), whether you conduct low-value transactions in a disproportionately high volume, etc. If we suspect that your Player Account is being abused you may be restricted in your ability to use our Services and Products.

Similarly, if we suspect that transactions made through your player account give rise to a reasonable suspicion of criminal activity, we may also process your personal data for the purpose of reporting such criminal activity to law enforcement authorities. In these cases, the legal basis for the processing of personal data is, for example, Section 234 of the Criminal Code.

In relation to the above processing of your personal data, we also rely on a legitimate interest on our part, within the meaning of Article 6(1)(f) of the GDPR, which is to protect our systems and ensure the integrity of our Products and Services.

3. Deposits and withdrawals

In order to be able to make full use of your player account and to place bets, you must deposit sufficient funds into your account via a payment source in your name. Similarly, in the case of withdrawals, funds can only be paid into a bank account in your name. For these reasons, your personal data is also processed when you make deposits and withdrawals, the following data:

• data processed during the use of the player account
• data from identity documents
• details of the payment method
• bank account details
• payment card details

In this case, the processing of your personal data is necessary in particular to enable us to provide you with the possibility of online betting and the payment of winnings. As mentioned in the section on processing of personal data for the purpose of player account registration, we process your personal data for the purpose of fulfilling our contractual and legal obligations.

3.1

The legal basis for the processing of personal data for deposits and withdrawals can be found in Article 6 of the Game Plan. In the case of transactions with a value of more than EUR 2,000.00, we are obliged to verify your identity again in accordance with Section 10(2)(e) of the AML. As deposits and withdrawals are made in connection with the use of the web/mobile application, the processing operations set out in the section on the use of the web/mobile application apply accordingly to the processing of your personal data.

4. Betforum

When using your player account, you can post your observations, slips, as well as comment on other players' posts and slips via the discussion forum called Betforum. For this purpose we need to process the following data:

• data processed during the use of the player account
• posts and related user content (e.g. tickets)
• the first and last name of the "personality" of her bet and related user content

The processing of personal data for the purpose of active use of Betforum is carried out on the basis of your consent. This consent can be withdrawn at any time . Revocation. (After logging in under My Account - Settings - Consent to marketing communications and confirmation of ticket)

5. DOXXbet Club loyalty program

According to the General Terms and Conditions of the DOXXbet Club, you automatically become a member of the DOXXbet Club by registering a player account. The DOXXbet Club includes a points account, which records the points earned for placing bets. The points can then be exchanged in the DOXXshop for free bets and products available in its offer. For this purpose, we need to process the following data:

• data processed during the use of the player account
• betting-related data
• record of points earned on the basis of bets placed
• details of benefits used

In this case, the processing of personal data is carried out on a legal basis, which is our legitimate interest as well as the fulfilment of our contractual obligations under the General Terms and Conditions of the DOXXbet Club.

5.1

Pursuant to Article 6(1)(b) of the GDPR, we may process your data as necessary for the performance of the contract to which you are a party. We therefore need this data in order to fulfil our contractual obligations in accordance with the DOXXbet Club General Rules.

Pursuant to Article 6(1)(f) of the GDPR, the processing of personal data is possible insofar as it is necessary for the purposes of the legitimate interests of the controller, except where those legitimate interests are overridden by your interests or fundamental rights and freedoms.

Our legitimate interest in this case is to motivate you by providing bonuses and rewards for the use of your player account. Our company has carried out an interest balancing test in this case and you can exercise your right to object to this processing of your personal data.

6. Competitions

In connection with the use of a player account, you may be given the opportunity to participate in a competition. If you take up the opportunity to participate in a competition, we will process the following data:

• data processed during the use of the player account
• betting data related to the competition

The processing of personal data is necessary to enable your participation in the competition and its subsequent evaluation. In this case, we process personal data on the basis of our legitimate interest as well as the fulfilment of our contractual obligations under the General Terms and Conditions of the DOXXbet Club.

6.1

Pursuant to Article 6(1)(b) of the GDPR, we may process your data as necessary for the performance of the contract to which you are a party. We therefore need this data in order to fulfil our contractual obligations in accordance with the DOXXbet Club General Rules.

Pursuant to Article 6(1)(f) of the GDPR, the processing of personal data is possible insofar as it is necessary for the purposes of the legitimate interests of the controller, except where those legitimate interests are overridden by your interests or fundamental rights and freedoms.

Our legitimate interest in this case is to motivate you by providing bonuses and rewards for the use of your player account. Our company has carried out an interest balancing test in this case and you can exercise your right to object to this processing of your personal data.

7. Customer support

In connection with the provision of our Services, we also provide you with customer support to communicate and resolve any issues that may arise in connection with the use of our Services and Products. This customer support is provided via infoline, email or Live Chat. In order to provide you with customer support services we need to process the following data:

• contact details
• data related to the player's account
• content of the requirements

In this case, the processing of personal data is necessary to enable us to fulfil our contractual obligations as well as our legitimate interest in providing you with quality Services and Products.

7.1

Pursuant to Article 6(1)(b) of the GDPR, we may process your data as necessary for the performance of the contract to which you are a party. We therefore need this data in order to fulfil our contractual obligations in accordance with the Game Plan, which is the official document - the basic rules for players when betting online or betting via DOXXbet Sportbox.

Pursuant to Article 6(1)(f) of the GDPR, the processing of personal data is possible insofar as it is necessary for the purposes of the legitimate interests of the controller, except where those legitimate interests are overridden by your interests or fundamental rights and freedoms.

Our legitimate interest in this case is to ensure the high quality of our Services and Products. Our company has carried out an interest balancing test in this case and you may exercise your right to object to this processing of your personal data.

8. Direct marketing

Your personal data is also processed for the purpose of informing you about news regarding our Services and Products as well as other related advertising communications made on the basis of your preferences in connection with the use of our Services and Products. These updates will be sent to you either by email or by text message to your telephone number. In relation to direct marketing, the following data is processed:

• data processed during the use of the player account (in particular betting data and data about the use of our services)
• email
• telephone number
• mailing address

The processing of personal data is carried out in this context in relation to direct marketing via e-mail on the basis of the EC Act, and in relation to the sending of text messages to your telephone number on the basis of your consent. You can withdraw this consent at any time . Withdraw. (By logging in under My Account - Settings - Consent to Marketing Communications and confirming the ticket)

8.1

Pursuant to Section 62(3) of the EC Act, we may send you commercial communications in the form of direct marketing to your email address if we have obtained it in connection with the provision of our Services or Products. Of course, you have the option to unsubscribe from these emails at any time easily and free of charge. This option is provided to you at the bottom of every email you receive from us.

9. Complaints

When using our services, there may be situations where a claim is made by you. In order to properly process the claim, it is necessary to process some of your personal data, in particular the following data:

• name and surname
• address for receipt of documents
• your player account identifier (login or registration code)
• content of the complaint
• information defining the bet (number, ticket code) or transaction (date, amount, transaction number)

The processing of personal data for the purpose of handling complaints is necessary for the fulfilment of our legal obligations.

9.1

Pursuant to Article 6(1)(c) GDPR, the processing of personal data is possible insofar as it is necessary for the fulfilment of a legal obligation of the controller. Our legal obligation in this case is, for example, the obligation to provide you with the opportunity to make a complaint within the meaning of Section 3(1) of the Consumer Protection Act.

DOXXbet recognises the importance of protecting your personal data and therefore minimises any sharing of your personal data with other parties. Personal data processed in accordance with the provisions of this Policy may only be shared with third parties that provide sufficient guarantees that they will take appropriate technical and organisational measures to ensure that the processing of personal data complies with the requirements of the GDPR and to ensure that your rights are protected. With each such third party, a so-called "processor agreement" is concluded in accordance with Article 28 of the GDPR.

When processing your personal data, the following companies may have access to this data, which are IT system administrators:

• Digmia, s.r.o., with registered office at Lazaretská 12, 811 08 Bratislava, ID No.: 36 654 132, registered in the Commercial Register of the District Court Bratislava I, section Sro, insert. No. 41496/B
• External staff

In connection with making deposits and withdrawals to your player account, we are required to provide certain of your details to payment gateway companies as well as banks.

Last but not least, your personal data may also be accessed by external auditors, tax consultants or legal service providers.

We may also sometimes share your personal data with the relevant tax authorities or public authorities where we are legally obliged to do so.

The GDPR contains provisions to help protect the rights of data subjects so that profiling or automated individual decision-making (AIR) does not unreasonably interfere with your rights.

GDPR Article 4(4) defines profiling as any form of automated processing of personal data which consists of the use of such personal data to evaluate certain personal aspects relating to natural persons, in particular to analyse or predict aspects of the natural person concerned relating to job performance, financial situation, health, personal preferences, interests, reliability, behaviour, location or movements.

In general, profiling can be understood as a series of statistical inferences that aim to predict a person's behaviour based on data from multiple sources and in the context of the characteristics of other, statistically related persons.

The scope of the AIR concept is different from that of profiling, but the concepts may overlap to some extent. The essence of AIR is the ability to make a decision solely on the basis of technical means without human intervention.

Our company carries out profiling of your use of our web/mobile application to the extent set out in the provisions of this Policy, based on AML legal requirements, in particular to monitor your gaming activities in order to protect against fraudulent activity and to ensure the integrity and functionality of our services. Your profiling also occurs when your data is processed for direct marketing purposes. In this context, for example, we track which sport or competition you like to bet on, and on this basis we will offer you promotional offers in that area. You can object to the processing of your personal data for direct marketing purposes at any time and we will comply with your objection.

We also conduct AIR primarily to protect your account from misuse. For example, if, in the course of using your player account, we discover that you routinely use a certain type of payment method and the system detects the use of a new, non-standard payment method, your withdrawal may be rejected and you as the owner of the player account will be notified of this. In either case, you will be provided with the option of human intervention on our part.

Betting with DOXXbet Sportbox is anonymous. Your personal data is only processed if we need to verify your age within the meaning of the Gambling Act or if you log in to your player account when betting with DOXXbet Sportbox. In this case, your personal data is processed to the same extent as if you were using our services via a web or mobile application.

In accordance with the obligations imposed on us by the GDPR, we have taken appropriate technical and organisational measures to ensure the protection of your personal data. These measures are updated at regular intervals to take account of technological developments as well as best practice in our area of business. These include, in particular, measures to ensure physical security, accountability and training of employees with access rights, regular data backups, as well as measures relating to software equipment or penetration testing.

Our company does not transfer your personal data to third countries.

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[Address]

[Contact details]

[Date]

VEC: Request for access to data

Dear Sir/Madam,

In accordance with Article 15 of the GDPR, I hereby request access to the personal data you process about me. Specifically, I am requesting access to: [specify the specific data you are requesting, for example:]

• the personal data you process in connection with my player account (login: XY, registration code: XY)
• email communications between myself (please enter your email) and info@doxxbet.sk between 25 May 2018 and 1 August 2018
• Other

I request the above data in electronic form / by mail to the following address: XY. Should you require any other information from me in this regard, please do not hesitate to contact me.

Regards,

[Name and signature]