BRAGG GAMING GROUP WEBSITE PRIVACY POLICY

v.1.0., Effective date: 14 March 2022

Bragg Gaming Group is committed to protecting your privacy and any personal data or other information that you may provide to us while visiting the https://bragg.group website, together with any other website which may replace it or is added to the list of websites defined by this Privacy Policy (hereinafter referred to as: “Website”). References to “Bragg Gaming Group”, “we” or “our” shall include Bragg Gaming Group Inc. and all its affiliate companies.

This Privacy Policy is intended to provide you with a transparent overview of how the Bragg Gaming Group collects and uses your personal data; please read it carefully before using the Website in order to understand how your personal data will be processed. By using the Website, you acknowledge that you have read and understood this Privacy Policy and you agree to the collection and processing of your data as described herein. If you do not agree with this Privacy Policy, please do not access or use the Website or interact with any other aspect of our business. 

MINIMUM AGE 

We do not accept registrations or orders submitted by and do not knowingly collect or use personal data from anyone under the age of eighteen (18) years, or any other age limit set out by the law of his/her country of residence. By accessing and using our Website, you confirm that you have reached the age of majority in your country of residence. 

PERSONAL DATA WE MAY COLLECT ABOUT YOU

When you access the Website, we will automatically collect some technical information such as your IP address, country of access, information about your device and information collected through cookies, as further specified below in our Cookie Policy. In addition, we may also collect and process some information about how you are using the Website, including log files containing information about your visit to our website (e.g. the duration of your session, time of visit and page interaction information). Although some of this information may uniquely identify your device, however not you personally, pursuant to some legislations such information may still be regarded as personal data.  

In the event that you choose to subscribe to our Newsletter, we will need to collect, store and use your first name, last name and email address. You may also choose to provide us information about your job title, employer company name, type of newsletter you wish to receive etc.  You are under no obligation to provide any such information, however, some of them (such as for example your email address) are necessary for us to communicate with you and provide the Newsletter (if you choose to subscribe to receive it). If you do not provide us with this information, we will not be able to deliver the Newsletter, unfortunately.  

In case you send us a sale or a general inquiry, we will collect, store and use the information you have provided regarding your inquiry, including first and last name, your email address, phone number, Skype, position/job role, business information, the preferred method of contact and any other information provided through such inquiry.  

If you are accessing our Website from the UK, you will also need to provide us information about your birth date for the purpose of proving you have reached the age of majority before we allow you access to the Website.  

USE OF YOUR PERSONAL DATA

Depending on the type of collected information we may use your personal data for different purposes, however, we always do so on a lawful basis for processing.  

Generally, the technical information that we collect when you visit the Website, may be processed by us in order to deliver and improve our services, including the Website itself. Such (non-directly identifiable) information may also be processed for the purpose of optimizing and enhancing the technical security of our Website, for statistical purposes and to provide you with a better experience based on data analytics and market research. 

When applicable, e.g. if you’re accessing the Website from the UK, we may process your information for the purpose of verifying that you are of minimum age and thus complying with the local regulatory requirements.  

If you have subscribed to our Newsletter or sent us an inquiry, your personal data may be processed by us in order to enable us to respond to your request, provide you with the requested services or marketing materials (subject to your consent) and deliver you a personalized communication and manage our relationship with you. 

LEGAL BASES FOR PROCESSING 

If you’re an individual located within the European Economic Area (EEA), we collect and process your personal data only upon the existence of a respective legal base for such processing pursuant to the GDPR. In the majority of cases, the processing of your personal data will be justified on one of the following bases: 

  • you have given us your consent to the processing of your personal data for one or more specific purposes (e.g. for receiving our Newsletter and marketing materials from us); 
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract (e.g. in the event you send us a business inquiry); 
  • processing is necessary for compliance with a legal obligation to which we are subject; 
  • processing is based on legitimate interests pursued by us or by a third party when such interests are not overridden by your data protection rights (e.g. when we use the information for analytics, statistics or market research purposes). 

HOW WE SHARE THE INFORMATION WE COLLECT

We may disclose your personal data to any of our affiliate companies or to our third-party service providers who assist us in providing the services, processing transactions, fulfilling requests for information, receiving and sending communications, providing support services or performing other tasks, from time to time. We use Google Analytics from Google Inc., as a third-party service provider for the purposes of delivering our services, conducting analysis and research. Our Website also embeds some social media features from Facebook, Linkedin, Twitter, Instagram, YouTube, and Vimeo, which require you to set up a cookie in order to function properly and may allow the respective social media provider to collect your IP address and information on which page you are visiting. In the event of a corporate merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, your personal data may also be shared with the relevant third party. 

Access to your personal data will be limited only to authorized personnel of the Bragg Gaming Group and to service providers acting on our behalf on a need-to-know basis. On (rare) occasions, we may also share your personal data with law enforcement, data protection authorities, government officials, and other authorities if: 

  • compelled to do so by a subpoena, court order, or other valid legal procedure; 
  • we believe that the disclosure is necessary to prevent physical harm or financial loss; 
  • disclosure is necessary to report suspected illegal activity; 
  • disclosure is necessary to investigate violations of this Privacy Policy or other legal agreements; 
  • we obtain your consent or at your direction.

INTERNATIONAL TRANSFERS AND SECURITY

While your personal data is primarily stored and processed on servers inside the European Economic Area (EEA), please note that we are a global company and we may need to transfer the information outside the EEA between companies within Bragg Gaming Group and/or to other third-party service providers around the world.  However, if we do transfer personal data collected within the EEA to third parties outside the EEA, such transfer will be done either to a country where the EU Commission has confirmed an adequate level of protection or where careful handling of personal data has been ensured by means of suitable guarantees such as EU Standard Contractual Clauses. 

We place great importance on the security of all personal data associated with our users. Consequently, we have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. To further ensure the best possible protection of your personal data outside the limits of our control, we strongly advise you to protect your device (e.g. by updated antivirus systems) and ensure that your internet service provider has taken appropriate measures for the security of network data transmission (such as for example firewalls and anti-spam filtering). 

Regardless of the steps we take to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur. Respectively, by using the Website you accept the inherent security implications of dealing online over the internet and will not hold Bragg Gaming Group or their processors responsible for any data breach unless it is due to our negligence.

DATA RETENTION  

We do not keep your personal data for any longer than is necessary to fulfill the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims. In some circumstances, certain personal data can be deleted earlier on your request. Any such requests should be sent to the contract information specified below and will be addressed in due time; however, please note that due to technical limitations, the data may not be removed instantly. 

THIRD-PARTY LINKS 

This Website may include links to third-party websites, plugins, channels or other applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you use third-party services, we encourage you to read the privacy notice of every website or application you use.

YOUR DATA PROTECTION RIGHTS 

Under certain circumstances, you have the following rights under data protection legislation in relation to your personal data: 

  • Request access to your personal data. You have the right to request that we provide you access to your personal data held by us. 
  • Request correction of your personal data. You have the right to request correction of any personal data we hold on you that is inaccurate, incorrect, or out of date. 
  • Request erasure of your personal data. You have the right to request deletion of your data when it is no longer necessary, or no longer subject to legal obligations to which we are subject. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  • Object to processing of your personal data. You have the right to request that we cease processing some of your personal data, such as personal data processed for direct marketing purposes. Also, you have the right to object to solely automated processing and to profiling activities based on your own legitimate interests. 
  • Request restriction of processing your personal data. You have the right to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns with this information, or we no longer need your personal data for the purposes of the processing, but they are necessary for the establishment, exercise or defense of legal claims). 
  • Request transfer of your personal data. You have the right to request an export of your personal data.

Whenever personal data is processed based on your consent (i.e., in case you have chosen to subscribe to our Newsletter), you retain the right to withdraw your consent at any time. You can do so by clicking on the ‘unsubscribe’ link in any email that we send you (or a similar opt-out option that we provide) or by contacting us by sending an email to the address stipulated below.  

All requests are generally free of charge and we try to respond to all legitimate requests within one month. However, we may charge a reasonable fee based on administrative costs or/and take more time if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

If you wish to exercise any of the rights set out above, please contact us through email: [email protected].

USE OF COOKIES 

While using our Website, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “cookies”) on your computer or other access devices. To obtain more information on how we use such cookies, please refer to our Cookie Policy. 

CONTROLLER AND CONTACT DETAILS

The personal data that you provide through this Website are controlled by Bragg Gaming Group Inc., a company with its business address at Exchange Tower, 130 King St W, Suite 1968 Toronto, ON M5X 1K6, Canada. 

If you have any questions or concerns regarding our Privacy Policy or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you can file a complaint with us by using the contact details listed below and we will respond to let you know when you can expect a further response. We can request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution. Our contact information: 

Bragg Gaming Group Inc., Exchange Tower, 130 King St W, Suite 1968 Toronto, ON M5X 1K6, Canada (email address: [email protected]) 

You also have the right to lodge a complaint regarding the processing of your personal data by us at any time with your local data protection authority.  

BY ACCESSING THIS WEBSITE, YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN AND BY USING OUR WEBSITE YOU EXPRESSLY CONSENT TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND GRANT US THE RIGHTS SET FORTH HEREIN. 

Occasionally we may, at our discretion, make changes to the Privacy Policy by posting a revised version and stipulating the modification date at the beginning of the document. The revised version will be effective on the date specified therein.