Privacy Policy

1. Introduction

This policy sets the framework within which your personal data will be processed by us and describes how we process and protect your data. Please read the following carefully to understand our principles and practices regarding personal data and the way we treat them. Please also read our separate cookie policy, from which you will find out how we use cookies and other similar technologies. The words and phrases defined in the Terms and Conditions will have the same meaning in this policy.

According to the requirements of the General Data Protection Regulation no. 679/2016 (hereinafter "GDPR"), of Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector, as well as of the Order no. 52 of 2002 issued by the People's Advocate, we will manage safely and only for the specified purposes, the personal data provided by our clients, collaborators, partners, etc.

This data protection policy applies when you use our services.

2. Data Operator

The data operator is SC MEGABET INTERNATIONAL SRL, based in Bucharest, Bd. Tudor Vladimirescu, No. 29A, AFI Tech Park 1, 5th floor, Office 60, District 5. 

MEGABET INTERNATIONAL holds a Class 1 license issued by the Romanian National Gaming Office (ONJN) to operate in Romania as a distance gambling organizer.

MEGABET INTERNATIONAL will process the personal data of the online gambling platform users of in accordance with the GDPR and its data protection policy, in accordance with the legislation in force. 

The designated Data Protection Officer can be contacted at [email protected].

3. Agreement

Your use of our services is subject to the Data Protection Policy and the Cookies Policy. When you use our services, you agree to the terms of this Data Protection Policy. The purpose of this Policy is to inform players about their personal data that is collected, stored and used.

If you do not agree to this Privacy Policy, you must stop using our services.

4. Collected data

We can collect and process personal data in the following situations:

a. When filling out the forms for creating the user account. To participate in remote gambling, we will collect the following data categories from the players:

• The chosen username;

• The selected password;

• Email Address;

• Name and surname;

• Date of birth;

• Gender;

• Address;

• CNP (personal numeric code);

• Mobile phone number;

• Duplicate copy from the bank card both sides of the if the gambling account it is supplied by card, subject to the terms of the Terms and Conditions;

b. We may request a copy of your identity card in order to fulfil our legal obligations regarding the verification of the players' identity and observance of the age limit;

c. Copy of a utility bill / account statement / other documents to prove the tax residence and residence of the player. This data is required to verify the authenticity of the data provided by the player at registration. Requested documents contain the following categories of personal data: name, surname, address, financial data.

d. We will collect data about your activity as a player on our betting platform, relating to bets, games, stakes, winnings, as well as details of the transactions carried out through the gambling platform, namely the amounts deposited and withdrawn, the payment method;

e. We will collect personal data if you enrol in a contest or promotion that we conduct;

f. If you contact us by (email, online chat, WhatsApp, or by contact form), we will keep the record of correspondence for the entire duration of the Account, but not more than 10 years from the closing of the Account. If you do not have an Account, the registration of the correspondence will be stored for 2 years from the contact date;

g. If you contact us by phone, the call can be recorded, and in this case we will keep a copy of the call. If you have an Account, we will keep the registration for the entire duration of the Account, but not more than maximum 10 years from closing the Account. If you do not have an Account, the registration will be stored for 2 years from the contact date;

h. We can also ask you to fill out surveys that we use for market research purposes;

i. When you visit our websites or when you are using our native applications for mobile devices, we receive information about your device and location, including traffic data, location data, web logs, and other communications data.

j. When you use our native mobile apps, based on your consent, we use Firebase Analytics and Firebase Crashlytics (from Google). We use Firebase Analytics to collect analytical data about the use of the application, to provide a better user experience and a more performing application. This data helps us understand how our application is used, so that we can make informed decisions. We use Firebase Crashlytics to collect data related to errors, bugs and crashes to understand what happened during the problem, what device and what version of the operating system was used. For a complete description of Firebase Crashlytics see - http://firebase.google.com/docs/crashlytics.

5. IP addresses and cookies

As we will explain in the Cookies Policy, we collect data through cookies and related technologies (scripts). We can collect information about your computer including, where available, the IP address (as part of statistical analysis - collecting takes place in anonymous format by removing the last byte of the address, so Ips will have the same format), the operating system and browser type, device, screen resolution, mouse movements, keystrokes, selected language for our services, and date and time of access. These are statistics on the actions and patterns of our users' browsing without directly identifying individuals.

For the same reason, we can get information on the general use of the Internet by using a cookie file that is stored on the hard drive on your computer. Cookies contain information that is transferred to your computer's hard drive. They help us improve our services and improve marketing and advertising campaigns.

Cookies help us to:

• Estimation of audience and usage;

• Storing information about your preferences and thus allowing us to personalize your site according to your individual interests;

• Increase the speed of your searches;

• Improving your experience on the site and identifying the technical difficulties encountered when using the site;

• Your recognition when you return to the site.

We also allow others to use cookies as described in the Cookies Policy.

You can control the cookie modules on your computer/mobile device through your browser settings and through other tools that we can make available to you within the applications for mobile devices. You can also choose to refuse the acceptance of cookies by activating the setting in your browser that allows you to refuse the setting of cookies. However, if you select this option, you may not be able to access certain parts of the site. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you register on the site.

You can learn more about our cookies policy consulting our Cookies Policy.

6. Use of data and their purpose

We can collect and process personal data for the following purposes:

a. Providing gambling services as well as fulfilling the obligations arising from any contracts concluded between you and us: creating, checking and administering the account, processing the data on deposits and withdrawals. On this occasion, we will ask you to share your exact geographic location to determine if we can provide you the services in your location.

b. Compliance with the legal norms in force, including checking the identity of the account holder and the accuracy of the information provided by the account holder;

c. Providing information on updating and changing terms and conditions, as well as on the provision of services;

d. Submitting offers and promotions, if you have explicitly expressed your consent;

e. Investigation of any suspected activity that can be qualified as prohibited behaviour in connection with the provision of services, as well as cooperation with competent authorities;

f. Improve the services we provide by analysing player activity data on our websites or when players are using the native applications for mobile devices. This analysis may take into account the data provided by scripts installed in the websites/gambling platform;

g. Analysis of websites activity data or activity data when players are using the applications for mobile devices to display content relevant to the player;

h. Drawing up statistics on the use of the services provided by clients;

i. Preliminary analysis of a merger or acquisition that may involve a partial or total transfer of activity in the provision of gambling services;

j. Partial or total transfer of gambling activity to another company;

k. Carry out studies and market research.

As far as the basis for the processing of these data is concerned, we hereby notify you that acceptance of the Terms and Conditions is your agreement to be a party to the contract. The categories of data you provide to us are governed by the legal provisions on online bets.

Thus, the collection, use and transmission to the authorities with control and monitoring powers is done by corroborating Articles 8 (5), 127 (1) and 129 (4) of GD no. 111/2016 regarding the Methodological Norms in GEO 77/2009, as well as under art. 10 par. (3) of GO 77/2009, the Fiscal Code - the obligation to declare the revenues achieved and the obligation to inform the players about the achieved gains, as well as based on the provisions of Law no. 129/2019 for preventing and combating money laundering and terrorist financing. As a general rule, the data you provide when concluding this agreement is necessary to verify your age and identity for reasons of both gambling law and reason related to preventing and combating money laundering. Also, regarding the placement of cookies on devices used to participate in remote gambling, the ground is represented by both your consent expressed by ticking the appropriate box, as well as the legal obligation of the operator or even the legitimate interest in the regards of quality assurance and customer experience on our websites and when using the applications for mobile devices.

In relation to processing performed through the statistical analysis tool, we ensure that it does not store your personal data. Therefore, to analyse the rate of use of certain pages and to identify technical problems encountered in their use, our website transmits data, as identified in the cookies chapter, to the analysis tool. If you enter data in existing free fields on pages on the site, they will not be stored and will be transmitted in an anonymous format to the analytics tool.

With regard to the purposes of the preliminary analysis and the partial or total transfer of activity to third parties, the basis is Megabet's legitimate interest in ensuring compliance with the legal principles of processing, in particular as regards the minimization and accuracy of data with processed personal data as well as to ensure the continuity of the transferred assets, given the fact that in the absence of personal data of customers, the platform cannot operate, the two elements being inextricably linked. If necessary, the clients will be informed before the transfer is made, with the possibility for them to exercise their right of opposition, in accordance with the provisions of the GDPR, under the conditions provided in section “Your rights”.

7. Direct marketing 

We promote our services to you and others. We use customer information for invitations and communications that promote the services we provide to you, to the extent that you have agreed to do so.

If you do not want us to use your data in this way or to send your details to our Marketing Authorizing Officers, please do not tick the relevant box on the form used to collect your data.

In all cases, you will be able to unsubscribe from receiving marketing information. Please keep in mind that if you apply for a non-subscription, we may need up to 48/72 hours to run changes to your system, and you may receive marketing information.

Also, unsubscribing from receiving marketing emails will not prevent you from transmitting to you emails that relate to the agreement expressed through the terms and conditions of use of our websites and/or using the applications for mobile devices.

We do not transmit your personal data to third parties for their direct marketing purpose.

8. Personal data disclosure

As a general rule, we will not disclose your personal information to any person excepting our processors. However, with your participation in online gambling, certain data categories are transferred and stored by the persons empowered by us (our processors) to do so. Thus, with respect to data collected for the provision of gambling services, for verifications performed under the provisions of Law 129/2019 for the prevention and combating of money laundering and the financing of terrorism, and to improve our services and identify the technical issues with which you are confronted in using the websites or when using the applications for mobile devices, this data is stored in EEA.

For providing the online gambling services, in accordance with applicable law, we may disclose your personal data to:

- Service providers authorized to process personal data who act as our collaborators, for the purpose of managing our activities:

- Software service providers or who provide technical support to our IT infrastructure, etc.;

- Games providers or gaming mechanism providers;

- Companies acting as independent data controllers and who assist us in the payments secure processing, fraud prevention, misuse of services and money laundering;

- Companies providing services such as SMS delivery, emails mass sending and automated telephone calls for the purpose of marketing communication;

- Companies with whom we collaborate in marketing activities on social media platforms;

- Public and regulatory authorities: National Gambling Office (ONJN): for reporting activities, according to gambling legislation; National Agency for Fiscal Administration (ANAF): for reporting taxes and earnings; National Supervisory Authority for Personal Data Processing: for reporting data privacy or security incidents; law enforcement authorities: for preventing and investigating fraud, money laundering or other crimes;

- Authorities with control responsibilities, in particular the National Office for Gambling (“ONJN”). Your personal data collected and processed in the context of self-exclusion requests will be transmitted to ONJN for inclusion in the self-excluded and undesirable persons national database, managed and permanently updated by ONJN. Data sharing is carried out exclusively for the purpose of prevention and in accordance with legal obligations;

- AML and KYC anti-money laundering solution providers: companies that offer user identity verification and AML monitoring services; providers of screening services for the identification of publicly exposed persons or persons subject to sanctions;

- Social networks and advertising platforms: companies that manage personalized marketing campaigns on platforms such as Facebook, Google, Twitter, etc.; partners for managing interactions on social platforms;

- For example, Google may process your personal data as an independent operator, based on your given consent on the website / mobile applications. For details on how Google manages your personal data, please consult their page: https://business.safety.google/privacy/.

- Commercial partners involved in loyalty programs;

- IT infrastructure and cybersecurity providers: companies that provide solutions for protection against cyber-attacks, vulnerability analysis and system monitoring to detect unauthorized access;

- Audit and compliance companies: internal and external auditors that ensure compliance with applicable legislation and standards;

- Organizations that perform independent checks for the integrity of operations.

- Customer support service providers: companies that provide support via call centre, email, live chat or chatbot;

- Payment processors and financial service providers: banks and other financial institutions involved in the management of transactions; processors that facilitate deposits, withdrawals and other financial operations;

- Data analysis and reporting solution providers: entities that provide solutions for analysing user behaviour and generating reports to optimize services;

- Other international authorities: in the case of cross-border activities, data may be shared with authorities in other jurisdictions to comply with local regulatory requirements.

- Third-party individuals/legal entities whose rights and interests are affected: we may share your personal data, in good faith, to protect, secure or prevent the loss of rights and interests in the context of situations in which the image and interests of Megabet International or the users of the services offered by Megabet International would be exposed or affected;

- Representatives acting on your behalf;

- Other entities at your request or with your consent;

In the case of the transfer of personal data to a processor or to a controller established in a third country, one or more specified guarantees or exceptions apply:

A decision on the adequate protection of personal data

The European Commission can and will assess third countries, a territory and/or certain sectors in third countries to assess whether there is an appropriate level of protection of the rights and freedoms of natural persons. In these cases, no authorization is required.

Countries that are members of the European Economic Area (EEA), but not the EU, are accepted as meeting the conditions of an adequacy decision.

A list of countries that currently meet the Commission's eligibility requirements is published in the Official Journal of the European Union. https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/ade….

Adequacy assessment by the data controller

When assessing the adequacy, the exporting operator must take into account the following factors:

- the nature of the information transferred;

- the country or territory of origin and final destination of the information;

- how the information will be used and for how long;

- the laws and practices of the country of transfer, including relevant codes of practice and international obligations; and

- the security measures to be taken with respect to data from the location abroad.

Agreement on standard contractual clauses - art. 28 (8) of the GDPR

If Megabet International wishes to transfer personal data from the EU to an organization in the United States or outside the EU/EEA, it will ensure that it enters into an agreement with the recipient of the data in the form of standard contractual clauses, as defined by the COMMISSION DECISION of 04.06.2021 on the introduction of a set of standard contractual clauses for the transfer of personal data to third countries. The content of these clauses cannot be changed by the agreement of the parties, they are mandatory and are considered by the Commission to ensure an adequate level of protection. These clauses can be consulted: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/sta….

Mandatory corporate rules

Megabet International may adopt its own rules for the transfer of data outside the EU. They require the prior approval of the competent supervisory authority.

In certain situations, we may be required to disclose your user data to comply with legal requirements. We will do our utmost to inform you of these situations, unless we are forbidden to do so. We may also disclose to enforce or enforce the Terms and Conditions and other agreements to protect our rights, property, security or our clients. This includes sharing information with other companies or organizations to protect against fraud and reduce credit risk.
We may also transfer your personal data to third-party purchasers, to the extent that Megabet's business is transferred (in whole or in part), and personal data is part of the assets that are the subject of such a transaction or to other companies, which will follow Megabet's instructions regarding the processing of your personal data.

9. Data storage

In accordance with European data protection law and national gambling legislation, we use reasonable procedures to prevent unauthorized access and inappropriate use of personal data.

We use appropriate systems and procedures to protect and secure your personal data. We also use security procedures and technical and physical restrictions on accessing and using personal data on our servers. Only authorized personnel can access your personal information while working.

Data collected from you are usually stored in EEA in accordance with the legal provisions on online gambling. They are processed by our staff, or one of our suppliers or processors. Such staff may be involved, among other things, in processing your payment details, verifications performed under the provisions of Law 129/2019, the provision of services specific to our gambling platform or providing support services. By registering your personal data, you agree to such processing. We will take all necessary measures to ensure that your data is treated safely and in accordance with this data protection policy.

All information provided by you is stored on our secure servers. Any payment transactions will be encrypted. Where we have (or have selected) a password that will allow you to access certain parts of the websites or to the applications for mobile devices, you are responsible for keeping this password confidential. Please do not tell anyone this password.

Transmitting information over the Internet is not completely secure. While we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the websites or through the applications for mobile devices; any transmission is at your own risk. Once we receive the information, we will use strict processes and security options to try to prevent unauthorized access.

The websites are protected by Secured Socket Layer (SSL) standard encryption. This technology encrypts all of your personal data transferred between you and us.

Data storage period

We assure you that your personal data will be stored only for a strictly necessary period, in accordance with the purpose for which it is collected and in accordance with applicable laws and regulatory requirements. The information we collect from you will be erased regularly from our servers, subject to your notification in this policy, but to the extent we are legally required by our competent government authorities, we will retain this information in our internal system. If you provided us with your data by completing the account creation form and you are an active user, your data will be retained for a period up to maximum 10 years from the user account closure. If in your account have been not recorded any transactions for twelve (12) months, we will close your account, and your personal data will be destroyed and deleted after a period of up to maximum 10 years from the account closure.

For your information, we will retain your personal data, among others:

• To provide you with the Services and to fulfill our obligations to you;

• To comply with legal obligations under EU / local law (eg anti-money laundering regulations or licensing regulations);

• To comply with reporting and regulatory requirements (for example, the archiving conditions provided for in the accounting law and the requirements of GD 111/2016, Art.137 (3));

• To defend us against claims that may be made against us;

• To comply with our contractual obligations and rights in relation to the information involved.

10. Your rights

You have the right to ask us not to process your personal data for marketing purposes. Prior to data collection, we will let you know if we intend to use your data for such purposes. If you do not want us to use your data, please do not tick the relevant box located on the form used to collect your data because, by ticking this box, you agree to the processing of your personal data for this purpose. You may also withdraw such consent or request that we no longer process your personal data for marketing purposes anytime, by contacting us at e-mail [email protected]. 

Occasionally, the websites and/or our applications for mobile devices may contain links to and from websites of our partner networks, merchants, and affiliates. If you access a link to these websites, please note that they have their own data protection policies and we do not take any liability for these policies. Please check these policies before entering any personal data on these websites.

For gambling platform services users are guaranteed the following rights:

• the right of access, based on which you can ask us, free of charge, to confirm whether or not we process personal data that concerns you. You can also request a copy of the data we process about you. Applications must include relevant information to be able to identify you in our database. We will resolve your request within 30 days;

• the right to rectification, which you can exercise by formulating a request that you can ask us to modify the information we already have about you. You can make such a request when you notice that your data is incomplete or inaccurate;

• the right to restriction of processing, which you can exercise when challenging the accuracy of the data, you consider the processing to be illegal or you will oppose the deletion of the data. Following the exercise of this right, we may still be able to store the data, making other processing operations only with your consent, unless expressly provided for by law;

• the right to data portability, which you can only exercise in cases where processing is based on your consent or contract and only if your data is processed by automated means. If you meet the conditions, you may send us a request for porting the data to the operator you want;

• the right to oppose data processing for marketing purposes or processing based on Megabet's legitimate interest. You may exercise this right at any time and we guarantee that your data will no longer be processed for that purpose. However, there may be a reasonable time (72 hours) to register and resolve your request that you may receive marketing information from us. In terms of collecting data through the script to improve the experience on our websites and using our applications for mobile devices, you can exercise the right of opposition filling the form from the site. 

• the right to erasure, based on which we have the obligation to delete the personal data we process about you. This right is not an absolute one, being applicable only in certain situations expressly provided by law. When making a removal request, please be aware that deleting them may be a complex process.

• if you are not satisfied with the way we have solved your requests, you can address the Supervisory Authority at any time, at its headquarters in B-dul G-ral Gheorghe Magheru no. 28-30, sector 1, Bucharest, postal code 0103336, or by e-mail: [email protected].

11. Access to information

To exercise these rights, the user will send a written, dated and signed application to Megabet International at the email address [email protected] with the subject "Personal Information Request". The request format is on the site. 

12. Changes to our data protection policy

Any changes to the data protection policy in the future will be posted on this page.

13. Contact

Questions, comments and requests regarding this data protection policy are welcome, and therefore please do not hesitate to contact us by e-mail at [email protected],  if you wish to have readings.