1.               General

LUDENZ SRL processes the personal data of Users of the Site, for the purposes and within the limits of Privacy Policy, when visiting or using it.

LUDENZ SRL ensures that, when processing these personal data, it complies with the laws and regulations in force and, in particular, the law of 30 July 2018 on privacy and the European Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter the “Regulation”).

In this respect, and in accordance with that Regulation, LUDENZ SRL:

•         Is legally obliged to process personal data of Users. This processing is described in section 2.1 of the Privacy Policy;
•         Processes personal data for the purpose of enabling Users to use the Site and, in addition, for the necessary and legitimate purposes described in section 2.2 of the Privacy Policy;
•         Process, with the prior, free and explicit consent of Users, the personal data described in- and according to the purposes explained in Article 3.

Users are deemed, by accessing and using the Site, to have read and accepted the Privacy Policy.

They also guarantee that the data and information communicated to LUDENZ SRL are accurate.

2.               Processing of personal data does not require the consent of Users

2.1. The legal obligations of LUDENZ SRL and the processing necessary for the use of the Site

LUDENZ SRL is obliged, under the legal and regulatory obligations to which every online sports betting operator is subject, on the one hand, and for the purpose of authenticating and enabling Users to use the Site, on the other, to process the following personal data for the purposes described below. This processing of personal data by LUDENZ SRL does not require the consent of Users pursuant to Article 6.1(b) and (c) of the Regulation.

The personal data communicated by the User are stored in a register, as described in Article 7.1, which is controlled and remains under the responsibility of LUDENZ SRL at all times.

Within the limits defined by the Regulation, the User also enjoys (certain-) rights defined in Article 4 that he can exercise in the manner defined in Article 4.7.

a.    What data are processed?

The personal data processed are as follows:

•         Name, surname(s), date of birth, language, sex, home/mailing address, National Register Number (or identity card or passport number), email address, landline or mobile phone number;
•         Banking data used for deposit transactions on the Site, and withdrawals of earnings;
•         Copies of personal documents allowing authentication of Users, such as photo of the identity card, credit card, account statement, proof of deposits or any other document likely to prove the User’s domicile and/or residence;
•         Browsing and connection histories (browser data, IP address), in particular through cookies;
•         Any other personal data that may be exchanged between LUDENZ SRL and the User, in particular by e-mail or live chat, as part of his registration or use by the User of the online sports betting offer offered on the Site.

b. What is the processing performed by LUDENZ SRL?

The processing consists in the collection, recording, storage, consultation, organization, use, reconciliation or other operations made necessary or useful under the legal and regulatory provisions described in Article 2.1.c). The processing may also consist in the transfer of personal data:

•         Judicial and administrative authorities, such as, in particular, the Gambling Commission or the Financial Information Processing Unit (CTIF);
•         To the suppliers of LUDENZ SRL, whose services are inseparable from the use of the Site and whose list is available on request from the Contact referred to in Article 7.5.

c. What are the purposes of this treatment?

1) LUDENZ SRL is obliged to process the personal data described in Article 2.1(a) and (b) in order to comply with the legal and regulatory obligations to which it is obliged, in particular, under the following legal provisions:

•         The Act of 18 September 2017 on the prevention of money laundering and the financing of terrorism and the restriction of the use of cash; 
•         The Act of 7 May 1999 on gambling, , and its implementing regulations, including the prevention of responsible betting.

2) LUDENZ SRL also processes the personal data referred to in Article 2.1.a) for the purpose of authenticating Users and enabling them to access and use the Site; this processing is therefore carried out in order to ensure:

•         Management of registrations and User accounts;
•         Managing Users’ deposits and winnings and, more generally, offering online sports betting;
•         Information about the services offered by LUDENZ SRL
•         Customer service management, including support and risk and fraud.

2.2.         Other processing operations that do not require the consent of Users

LUDENZ SRL also processes the following personal data for the legitimate purposes described below. This processing of personal data by LUDENZ SRL does not require the consent of Users pursuant to Article 6.1(f) of the Regulation.

The personal data communicated by the User are stored in a register, as described in Article 7.1, which is controlled and remains under the responsibility of LUDENZ SRL at all times.

a.    What data are processed?

The personal data processed are as follows:

•         Name, surname(s), date of birth, language, sex, home/mailing address, language, email address, landline or mobile phone number; 
•         Browsing and connection histories (browser data, IP address), in particular through cookies;
•         Any other information that may be exchanged between LUDENZ SRL and the User, in particular by e-mail or live chat, in the context of his registration or the use by the User of the online sports betting offer offered on the Site.

b.    What is the processing performed by LUDENZ SRL?

The processing consists in the collection, recording, storage, consultation, organization, use, reconciliation of the personal data described in Article 2.2.a). It also consists in the transfer of this personal data to third parties, the list of which is available on request from the Contact referred to in Article 7.5.

c.     What are the legitimate purposes of the processing?

LUDENZ SRL processes the personal data referred to in Article 2.2(a) for the following legitimate purposes:

•         Promotion, advertising and marketing, including the provision of sports betting online, including text messages, telephone calls, paper or electronic newsletters; 
•         Carrying out satisfaction surveys, statistical studies, trend analyses and market research, with the aim of improving the offer of online sports betting or informing Users or protecting Users and preventing gambling attendance.

3.                         The processing of personal data with the consent of Users

By using the Website of LUDENZ SRL, for any reason whatsoever, the User manifests his free, specific, informed and unequivocal will to expressly authorize LUDENZ SRL to process personal data in accordance with the Regulation, within the limits and for the purposes defined below and without prejudice to the processing referred to in article 2.

The personal data communicated by the User are stored in a register, as described in Article 7.1, which is controlled and remains under the responsibility of LUDENZ SRL at all times.

The User also enjoys the rights, including the right to withdraw his consent at any time, as defined in Article 4.7.

3.1.           Nature of personal data processed

The data processed by LUDENZ SRL are as follows:

•         Name, surname(s), date of birth, language, sex, home/mailing address, National Register Number (or identity card or passport number), email address, landline or mobile phone number;
•         Banking data used for deposit transactions on the Site, and withdrawals of earnings;
•         Copies of personal documents allowing the authentication of Users, such as, in particular, the photo of the identity card, the credit card, an account statement, proof of deposits or any other document likely to prove the User’s domicile and/or residence;
•         Browsing and connection histories (browser data, IP address), in particular through cookies;
•         Any other information that may be exchanged between LUDENZ SRL and the User, in particular by email or live chat, in the context of his registration or the use by the User of the online games offered on the Site.

The personal data communicated by the User are stored in a register, as described in Article 7.1, which is controlled and remains under the responsibility of LUDENZ SRL at all times.

3.2.           Treatment

The processing consists in the collection, recording, storage, consultation, organisation, use, reconciliation of the personal data described in Article 3.1. It also consists in the transfer of these personal data to third parties, the list of which is available on request from the Contact referred to in Article 7.5.

3.3.           Purposes of the processing of personal data

The personal data are collected and processed by LUDENZ SRL for the following purposes:

·        Promotion, advertising and marketing, including the affiliation and management of loyalty programs, relating to the offering of online gaming services, including the sending of text messages, telephone calls, paper or electronic newsletters, not falling within the scope of Article 2.2.c), such as the offline gambling activity of LUDENZ SRL, including advertising, marketing to the extent permitted by law;

•         Participation in contests and promotional offers, including communication about winners; 
•         Development of the offer of online sports betting;
•         Carrying out satisfaction surveys, statistical studies, trend analysis and market research, for management, marketing and reporting purposes, including profiling, outside the scope of the purpose described in Article 2.2.c).

4.      Rights of the User

Without prejudice to Articles 2 and 5, Users have the right to exercise a right of rectification, opposition and limitation, according to the modalities and within the following limits.

4.1.               Right of access

a.         LUDENZ SRL has at its disposal all the following information:

•         The identity and contact details of the controller;
•         Contact details of the Data Protection Officer;
•         Personal data processed;
•         the purposes of the processing for which the personal data are intended and the legal basis for the processing;
•         Recipients or categories of recipients of personal data, where applicable;
•         And, where applicable, the fact that the controller intends to transfer personal data to a country outside the European Union and: either the existence (or absence) of an adequacy decision by the European Commission or, in the absence of such a decision, the guarantees offered by the third country and to the means used to obtain a copy of the personal data.
•         The possibility to object to automated processing of their data, such as profiling, unless justified grounds make such processing necessary, as well as the possibility to object to any processing of their personal data for direct marketing purposes.

b.         Users have the right to request, at any time, access to all the information set out in this Article and in Article 3.1, by contacting the Contact referred to in Article 7.5. LUDENZ SRL will respond to these requests for information within one month.

c.         Users have the right to obtain a copy of the personal data being processed. LUDENZ SRL reserves the right to demand payment of any costs incurred in connection with this request; these costs will be calculated on the basis of the administrative costs incurred in connection with the request; they will not exceed 20 euros.

d.         Users are entitled to obtain, in a structured format, such access or copy, in such a way that the personal data is provided to them in a format conforming to the technical standards in force at the time of the access request; this format will therefore allow its machine readability.

4.2.               Right of correction

LUDENZ SRL guarantees and obliges Users to update and rectify their personal data, insofar as this data is incorrect or incomplete.

This right of rectification may be exercised on request to the Contact referred to in Article 7.5.

4.3.               Right of objection

LUDENZ SRL authorizes Users to object to the processing of all or part of their personal data, for the following reasons:

•         Their data are inaccurate;
•         The processing is no longer necessary for the purposes for which the data were collected;
•         The User withdraws his consent;
•         The data was processed unlawfully. 
• LUDENZ SRL further authorizes Users to object:
•         Automatic processing of their data, such as profiling, unless justified grounds make such processing by LUDENZ SRL necessary;
•         To any processing of their personal data for direct marketing purposes, including profiling, if it is related to such prospecting.

This right to object may be exercised on request to the Contact referred to in Article 7.5.

4.4.           Right to be forgotten

LUDENZ SRL also undertakes to comply with any request to erase personal data as soon as possible (right to be forgotten), when:

•         The processing is no longer necessary for the purposes for which the data were collected;
•         The User withdraws his consent;
•         The data have been unlawfully processed or need to be deleted by law. 
•        The User objects to automated processing of his/her data, such as profiling, and that there are no reasonable grounds for such processing by LUDENZ SRL;
•         The User objects to the processing of his personal data for direct marketing purposes, including profiling, if it is related to this prospecting.

4.5.           Right of limitation

Users also have the right to obtain from LUDENZ SRL the restriction of the processing of their personal data when:

•         The User considers that his personal data is inaccurate, and this for the time necessary for LUDENZ SRL to verify the accuracy thereof;
•         The processing is unlawful but the User does not wish to delete the data but demands a restriction of processing; 
•         The User objects to automated processing, including profiling or processing of his personal data for direct marketing purposes and that it is necessary to verify the legitimacy of the reasons for which LUDENZ SRL intends to maintain this processing;
•         LUDENZ SRL no longer needs the personal data processed but the data subject wishes them to be stored for the establishment, exercise or defence of legal claims;

This right of limitation may be exercised on request from the Contact referred to in Article 7.5.

4.6.           Transfer of data to a processor

Users are entitled to transfer the personal data processed automatically referred to in Articles 2.2 and 3 by LUDENZ SRL to another controller without LUDENZ SRL obstructing this.

Insofar as such a transfer is technically possible, Users are entitled to request LUDENZ SRL to have this transfer carried out directly by its controller.

4.7.           Modalities

The rights granted by LUDENZ SRL to the User must be exercised in accordance with the procedures defined in Article 7.5.

4.8.           Notification

LUDENZ SRL will provide the User with a notification of any deletion or rectification of data made in accordance with Articles 4.2 and 4.4, unless such notification proves impossible or imposes disproportionate efforts.

This notification will be made by email or mail, based on the contact information provided by the User.

5.                Location, retention and retention of personal data

5.1.               LUDENZ SRL keeps Users’ personal data in a form that allows their identification and availability and by appropriate and secure means.

The data is stored and hosted in Belgium by Data Center, which has all the necessary and useful security guarantees according to the technical standards in force.

5.2.               The personal data of Users shall be kept by LUDENZ SRL for the purposes defined in Articles 2 and 3. They are kept for a period of 10 years for all purposes governed by Article 2.1.c); LUDENZ SRL therefore reserves the right to retain Users’ personal data for any purposes imposed on it by law, as a result of its online sports betting activities. Users declare that they are thus informed and agree LUDENZ SRL retains the User’s personal data referred to in Article 2.1.a) for at least ten years from the last activity of the player on the Site in order to comply with its legal obligations.

The personal data shall be kept for a period not exceeding that necessary to achieve the purpose of the processing for all purposes governed by Article 2.2 and 3. The data are then deleted from the files of LUDENZ SRL upon request of the Users addressed to the Contact referred to in Article 7.5.

5.3.               Personal data of Users may be transferred to service providers located outside the European Economic Area for which:

•         the European Commission has issued an adequacy decision recognising that these providers offer an adequate level of protection to Data transferred to them by a European entity;
  
  
•         LUDENZ SRL has provided appropriate safeguards, in particular through the use of standard standard contractual clauses developed by the European Commission.

Personal data are thus transferred on one or other of these grounds.

6.                Liability of LUDENZ SRL – Sub-contractor

6.1.           LUDENZ SRL undertakes that the processing of Users’ personal data will be carried out in a lawful, fair and transparent manner towards the User concerned. Any processing by LUDENZ SRL will comply with the requirements of the Law of 30 July 2018 , Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and this Privacy Policy.

LUDENZ SRL uses all reasonable and appropriate means to ensure the confidentiality, integrity and availability of the personal data we process. These measures, technical and organizational, in particular are described in the Information Security Manual available from the Contact referred to in Article 7.5.

Technical measures include anonymisation and encryption of data

personal, according to the purpose required.

Organisational measures include, in particular, internal audits, in addition to audits to which LUDENZ SRL may be subject by the Gaming Commission, in particular.

If necessary, LUDENZ SRL, with the assistance of the Data Protection Officer, carries out an impact assessment when processing is likely to create a high risk for Users.

6.2.           The Users’ personal data will not be passed on to third parties other than the suppliers and partners of LUDENZ SRL, except for the purposes described in Articles 2.1, 2.2 and 3 and, therefore, if:

•         The transfer is required by law, regulation or order of an administrative or judicial authority;
•         The transfer is necessary for the offer of online sports betting, or for maintenance services;
•         The User has consented to such transfer.

The partner will not be considered a processor unless he processes the Users’ personal data on behalf of LUDENZ SRL. LUDENZ SRL declines any responsibility for the processing of the User’s personal data by the partner who provides its own services on its own behalf and for its own account or if it proves that the fact that caused the damage is not attributable to it in any way.

In the event that LUDENZ SRL acts as the processor of the partner, it is agreed that LUDENZ SRL will only be held liable for damage caused by processing of personal data contrary to the Regulation or this Privacy Policy if it has not complied with the obligations laid down in the Regulation that are specifically incumbent on the processors or has acted outside the lawful instructions of the partner or contrary to these. Likewise, LUDENZ SRL i) cannot be held liable under any circumstances if it proves that the event that caused the damage is not attributable to it in any way and ii) remains subject to the limitation clauses of liability referred to in article 11 of the conditions of use of the Site.

6.3.           LUDENZ SRL ensures that, when processing is carried out by a processor on behalf of LUDENZ SRL, the latter has sufficient guarantees regarding the implementation of appropriate technical and organisational measures and, more generally, compliance with the requirements of the Regulation. In particular, it requires the subcontractor to comply with the Regulation and, therefore, to keep a register.

6.4.           LUDENZ SRL undertakes that in the event of a security problem related to the processed data, which may affect its confidentiality, LUDENZ SRL will notify the data protection authority referred to in Article 7.4 as soon as possible.

LUDENZ SRL will also inform the Users concerned, insofar as the violation of personal data presents a high risk to the rights and freedoms of the User; this information will be carried out by email or mail to the contact details provided by the User.

7.                Other

7.1.           Register personal data

As the controller of personal data, LUDENZ SRL keeps a register of all its processing activities. It shall contain all the information relating to the type of data processed, the persons concerned by the processing of the data, the possible recipients to whom the data are communicated, the purposes for which the data are processed, the retention period of the data and a general description of the technical and organisational security measures put in place.

The personal data communicated by the User are stored, as well as the processing and its purposes, in a register, which is controlled and remains under the responsibility of LUDENZ SRL at all times. This register shall include, in addition to the above information:

•         A description of the purposes of the processing;
•         a description of the categories of data subjects and categories of personal data;
•         The categories of recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organisations;
•         Time limits for erasure of different categories of data;
•         A general description of organisational and technical measures relating to data privacy and security.

7.2.           Integrity - Privacy Policy changes

The Privacy Policy contains all contractual provisions binding on Users, without prejudice to the general provisions contained in the Site Terms of Use of which they form an integral part. The Terms of Use of the Site therefore remain applicable to all matters not related to the protection of personal data.

LUDENZ SRL also reserves the right to modify the Privacy Policy. Any update is binding on Users as soon as it is published on the Site. LUDENZ SRL will mention the date of publication of the Privacy Policy in force on the Site.

7.3.           Evidence

The User acknowledges that the electronic documents exchanged and the electronic data collected during registration or use of the Site have the same probative value as if these documents and data had been communicated or collected on paper. It therefore undertakes not to contest their strength or their probative value because of their electronic medium.

7.4.           Data Protection Authority

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the Law of 8 December 1992, the User has the right to request additional information or lodge a complaint with the Data Protection Authority. The Supervisory Authority is the Data Protection Authority; its contact details are:

Address: Rue de la Presse, 35, 1000 Brussels

Telephone: +32 (0)2 274 48 00

Email: [email protected]

7.5. Contact – Information about the identity of the controller and the data protection officer

LUDENZ SRL may be contacted for any questions relating to the protection of Users' personal data, as follows:

•         By mail: Governor Verwilghensingel 8 Box H2, 3500 Hasselt
•         Email: [email protected]

The controller of the Site is SRL LUDENZ, whose registered office is Governor Verwilghensingel 8 Box H2, 3500 Hasselt (No ECB 0881.806.808).

LUDENZ SRL has also appointed a data protection officer within the meaning of Article 37 of the aforementioned Regulation; he can be contacted by email: [email protected]. This is responsible for monitoring and complying with the processing by LUDENZ SRL of personal data of Users.