Effective date: January 20, 2023
Effective date: January 20, 2023
Respecting the privacy of individuals is essential for Bragg Gaming Group. We are committed to protecting data and ensuring security and confidentiality.
References to “Bragg Gaming Group”, “we” or “our” shall include Bragg Gaming Group Inc. and all its affiliate companies (including Oryx marketing d.o.o., Oryx d.o.o., Oryx podpora d.o.o., Oryx Gaming Limited, Oryx Sales Distribution Limited and others).
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 and services, you confirm that you have reached the age of majority in your country of residence.
3.1. WEBSITE VISITORS
The personal data that are processed due to the use of the 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.
When requesting access and visiting the Client Area of the Website, the controller of personal data is Oryx.
3.2. JOB CANDIDATES
The personal data are processed by the group company offering the job position, including but not limited to:
3.3. NEWSLETTER SUBSCRIBERS
The personal data are processed by Oryx marketing.
3.4. CONTACT FORM USERS
The personal data are processed by Oryx marketing.
3.5. CLIENTS AND SERVICE PROVIDERS
The personal data are processed by the group company entering into the agreement with the client/service provider company.
Personal data of our Slovenian office visitors are processed by Oryx marketing.
For any clarification, question or requirement related to your privacy and the processing of your personal data, please contact: [email protected]
4.1. WEBSITE VISITORS
If you are accessing our Website from the UK, you will 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.
If you are accessing the Client Area of the Website, you will need to provide your name, surname, email address, username and company.
4.2. JOB CANDIDATES
In connection with your job application we process the following categories of personal data about you:
We collect personal data about you from a variety of sources. For example, data are collected from you, recruitment agencies (in case you apply with the recruitment agency and sign a consent for the transfer of data) and publicly accessible sources (e.g. your profile on LinkedIn if you choose to share it).
4.3. NEWSLETTER SUBSCRIBERS
If you choose to subscribe to our Newsletter, we will need to process 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.
4.4. CONTACT FORM USERS
In case you send us a sales or a general inquiry, we will process the information you have provided regarding your inquiry, including first and last name, your email address, phone number, skype handle, position/job role, business information, the preferred method of contact and any other information provided through such inquiry.
4.5. CLIENTS AND SERVICE PROVIDERS
We process the following contact information of our clients’ contact person: name, surname, email, phone number, skype handle, position, username (to access the Client area portal). Similarly, we process the contract information of our service provider’s contact person, legal representative or authorized person: name, surname, email address, phone number, skype handle and position.
Following our internal policies we require information about our business partners in order to fulfil our legitimate interest to combat money laundering and the financing of terrorism, whereby such information has to be provided before establishing the legal agreements. Overall, the following categories of personal data are usually processed in the due diligence procedure:
If you are a visitor, we process the following categories of personal data about you:
First and last name, company name, date, and time of entry into or exit from premises.
Applicable privacy regulation (such as GDPR) requires we process personal data based on a lawful basis. We use the following lawful bases to process personal data of relevant individuals:
5.1. WEBSITE VISITORS
Generally, the technical information that we collect when you visit the Website, is processed by us to deliver and improve our services, including the Website itself. Such non-directly identifiable information (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the Site, the device used and other information) shall also be processed for the purpose of optimising and enhancing the technical security of our Website, for statistical purposes and for providing you with a better experience based on data analytics and market research. Furthermore, such browsing data may be used to verify that our Website is functioning properly. From time to time, browsing data are processed anonymously for statistical purposes.
When applicable, e.g., if you’re accessing the Website from the UK, we process your information for the purpose of verifying that you are of minimum age and thus complying with the local regulatory requirements.
When you request access to the Client Area subpage of the Website, we will process your data to decide on the approval of the access to the Client Area.
5.2. JOB CANDIDATES
We need to process your personal data to decide whether to enter a contract of employment with you and to perform our obligations in accordance with the labor law requirements. Certain information is processed based on your explicit consent.
We will use the personal data we collect about you for the following purposes:
Having received your application form, your CV and covering letter (and your portfolio and recommendation letters, if any) and the results from your expertise test, which you may be asked to complete, we process that information to decide whether you meet the basic requirements to be shortlisted for the role. If we decide to further consider you for the position, we may invite you to an interview and further to complete certain additional assessments. We will use such information to decide whether to offer you the position with us.
If you fail to provide data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application properly or at all.
5.3. NEWSLETTER SUBSCRIBERS
Marketing communications will be delivered to you based on your explicit consent. Our existing customers might also receive marketing communications based on our legitimate interest to notify our clients about products that might be of interest to them.
Users can always easily unsubscribe from receiving e-newsletters and commercial communications in the following ways:
5.4. CONTACT FORM USERS
If you sent us an inquiry, your personal data shall be processed by us to enable us to respond to your request and to deliver you a personalized communication and manage our relationship with you.
5.5. CLIENTS AND SERVICE PROVIDERS
We process personal information of contact persons, legal representatives, authorized persons and ultimate beneficial owners of our clients. The information is processed to enable us to perform the services to our clients – to carry out our contractual obligations with our clients, manage our relationship with the clients and notify the clients about the changes to our service and our terms or policies. Following our legitimate interest, we also execute our internal policies aimed at preventing money laundering and financing of terrorism. For this purpose, we request information in our due diligence questionnaire and in the course of the due diligence process.
We process personal information of contact persons, legal representatives and authorized persons of our service providers. The information is processed to enable us to carry out the contractual relationship with our service providers.
We might occasionally offer certain benefits in the form of promotional gifts and invitations to events organized by the Bragg Gaming Group and personal data might be required to allow us to offer the benefits. We shall ask for a specific consent of the relevant data subjects to enable us to process personal data for such purpose.
We process personal information of individuals visiting our office with the purpose of ensuring the safety of people, activities and property and the control of entry and exit to or from our premises. The basis for the processing is our legitimate interest to ensure security and follow the requirements of ISO27001 certification.
Where the legal basis for processing of your personal information is your consent, you have the right to withdraw that consent at any time. You can exercise this right by contacting us at: [email protected], by clicking the “unsubscribe” button in our marketing emails or by choosing a similar opt-out option that we may provide to exercise your right to object to the processing of your personal data.
When we use legitimate interest to process personal data we are carefully weighing between our interest and the fundamental rights and freedoms of individuals. The data subjects have the right to objects, on grounds relating to each data subject’s particular situation, at any time to processing of personal data concerning the data subject.
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 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.
Should you require further information with regards to transfers of personal data, you can contact us at: [email protected].
We do not keep your personal data for any longer than is necessary to fulfil 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 erased upon receiving your request.
8.1. WEBSITE VISITORS
We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for providing our services.
8.2. JOB CANDIDATES
We will retain your personal data for a minimum period of 3 months after the recruitment process for the position you applied for has been completed or in certain cases for a longer period as defined further below. We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We may retain your personal data for a longer period if required to protect our position in the event of a legal claim or proceeding and/or in case we are required to comply with legal or regulatory requirements. After this period, we will securely destroy or anonymize your personal data in accordance with applicable laws and regulations.
If your application is successful, your personal data gathered during the recruitment process will be transferred to and retained in human resources file.
OPEN APPLICATION AND FUTURE OPEN POSITIONS: Sometimes we do not have an open position for your specific knowledge and qualifications. In such cases, you can submit an open application, and we will keep you in our candidate pool for 24 months and contact you in case a suitable position opens.
When you apply for a specific position in our company, we will ask for your consent to consider you as a candidate for future open job positions in Bragg Gaming Group. You do not have to give us your consent if you do not want to, but we would be happy if you do. Your consent will mean we will keep your data in our records for 24 months after closing the selection process.
8.3. NEWSLETTER SUBSCRIBERS
We will send you our newsletter and keep your personal data for as long as you want us to. You can withdraw your consent at any time.
8.4. CONTACT FORM USERS
If you send us a general inquiry, your data shall be kept for 12 months after we have responded to you, unless we have concluded an agreement. In such cases, your data shall be kept for the duration of the agreement and for 5 years following the termination of the agreement.
8.5. CLIENTS AND SERVICE PROVIDERS
The personal data of contact persons, legal representatives, authorized persons and ultimate beneficial owners of our clients and service providers shall be kept for the duration of the agreement and for 5 years following the termination of the agreement.
We keep personal data of our visitors for 2 years.
We disclose your personal data to our affiliate companies and to our third-party service providers who assist us in providing the services, fulfilling requests for information, receiving and sending communications, providing support services or in performing other tasks. Among others we use Google Analytics from Google Inc., as a third-party service provider for the purposes of delivering our services, conducting analysis and research. We use Bamboo HR LLC to process the employment/candidate records.
Our Website also embeds some social media features from Facebook, LinkedIn, Twitter, Instagram, YouTube, 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:
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 the third-party services, we encourage you to read the privacy notice of every website or application you use.
Under certain circumstances, you have the following rights under data protection legislation in relation to 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 (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.
Please address your requests to: [email protected]
Oryx marketing d.o.o.
Tržaška cesta 118
Email: [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 (see https://edpb.europa.eu/about-edpb/about-edpb/members_en). We would, however, appreciate the opportunity to deal with your concerns before you approach the authorities, so please contact us in the first instance.
COOKIES AND OTHER SIMILAR TECHNOLOGIES
When you use our https://bragg.group/ website (hereinafter »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.
What are cookies?
Cookies are small files that are sent from the web server to the user’s computer via the user’s browser. They are then stored in the user’s computer as text files and passed back to the server. Cookies are generally used to identify users and, on occasion, prepare customized web pages for them.
What cookies do we use?
We use both session and persistent cookies. Session cookies expire when you log out of your account or close your browser. Persistent cookies remain on your computer or other access device until deleted or otherwise expire.
Some of the cookies we use are necessary, which means that without them our website cannot function properly. The remaining cookies are non-necessary.
We use the following cookies:
|__cf_bm||Functional||bragg.group||30 minutes||to read and filter requests from bots.|
|cmplz_banner-status||Functional||bragg.group||1 year||to store cookie banner status (opened / closed)|
|cmplz_statistics||Functional||bragg.group||1 year||to store cookie consent preferences.|
|cmplz_marketing||Functional||bragg.group||1 year||to store cookie consent preferences.|
|cmplz_functional||Functional||bragg.group||1 year||to store cookie consent preferences.|
|cmplz_preferences||Functional||bragg.group||1 year||to store cookie consent preferences.|
|age_gate||Functional (UK only)||bragg.group||Session||to store visitor age preference|
|cmplz_consented_services||Functional||bragg.group||1 year||to store cookie consent preferences.|
|_gat_gtag_UA_130014494_1||Statistics||bragg.group||1 minute||google analytics|
|_gid||Statistics||bragg.group||1 day||google analytics|
|_ga||Statistics||bragg.group||1 year||google analytics|
|VISITOR_INFO1_LIVE||Marketing||.youtube.com||6 months||to provide bandwidth estimations.|
|SOCS||Marketing||.youtube.com||1 year||to store cookie consent preferences.|
|CONSENT||Marketing||.google.com||1 year||to store cookie consent preferences.|
|IDE||Marketing||.doubleclick.net||2 years||to provide ad delivery or retargeting.|
|YSC||Marketing||.youtube.com||Session||to Store and track interaction.|
|DEVICE_INFO||Marketing||.youtube.com||6 months||to track user’s interaction with embedded content.|
|GPS||Marketing||.youtube.com||Session||to store location data.|
|PREF||Marketing||.youtube.com||5 days||to store user preferences.|
|NID||Marketing||.google.com||6 months||to provide ad delivery or retargeting, store user preferences.|
|_fbp||Marketing||.facebook.com||3 months||to store and track visits across websites.|
Where lawfully required, we will ask you to provide your consent for the use of non necessary statistics and marketing cookies.
When using our Website, you may be directed to other websites for example to view content hosted on those sites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our Website.
How to manage cookies?
For more information about cookies and how to block, delete or disable them, please consult your browser’s help pages for instructions on how to do this, or contact us at [email protected].