This document outlines the processing of your personal data and the rights you are entitled to under the current data protection regulations – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data, and the regulations that develop it, hereinafter “GDPR”. The type of data processed and its use may vary depending on the relationship we have with you and the services requested and/or provided.

  1. Data Controller and Contact Details

The entity responsible for processing your data is VIVE COLLADOS, S.L., with registered office at Avenida Alejandro Valverde, 170, Postal Code 30.007 (Murcia).

If you wish, you may contact the Data Protection Officer via the following email address: dpo@orenesgrupo.com or by postal mail to the address described above.

  1. For what purpose will we process your data (processing purpose) and on what legal basis?

Personal data is processed in accordance with the provisions of the GDPR, based on the legal grounds indicated below:

  1. Within the framework of the execution or fulfillment of contractual obligations – Art. 6.1(b) GDPR-

To fulfill our contractual obligations to you, including registering an account to use our services:

  • Management of contracted services, as well as compliance with accounting, legal, tax, and administrative obligations.
  • Issuance of winnings certificates to players who request them.
  • Management of the registration of jackpot prize winners.
  • Management of reservations in hospitality establishments and verification of ownership.
  • Management of home delivery orders from hospitality establishments. Delivery of orders.
  1. Justified by a legitimate interest – Art. 6.1(f) GDPR-

Where necessary, VIVE COLLADOS, S.L. will process your personal data to satisfy its own or third-party legitimate interests in the following cases

  • Management of customer complaints.
  • Conducting controls to detect fraudulent activities.
  • Registering visits to the central offices of Grupo Orenes.
  • Management of information of particularly relevant clients and communications related to invitations to special events.
  • Study and analysis of the identification process and/or activity of clients who meet patterns or indications of fraud.
  1. Consent – Art. 6.1(a) GDPR-

Whenever you have given us your consent, we may carry out additional processing that is informed to you and to which you consent. You may revoke your consent at any time. This also applies if your consent was given before the entry into force of the GDPR, i.e., before 25 May 2018. It should be noted that opposition to a specific processing and revocation of consent are not retroactive. You may obtain information at any time about the authorizations you have granted us for different processing by exercising your rights as set out in section 8.

VIVE COLLADOS, S.L. will request your authorization for the processing of your data for the following purposes:

  • Management of contact data collected through forms on corporate websites.
  • Management of cash prize payments.
  • Sending commercial, promotional and/or advertising communications, which may be based on contracted products or services provided.
  • Automatic categorization of your user profile according to your gaming profile in order to receive communications tailored to your preferences and needs. Personal data may be processed for profiling based on internal sources (e.g., cookie browsing data, historical and statistical data), the results of which allow the creation and analysis of personalized products through segmentation into different groups based on common patterns. These profiles will be used solely to send you personalized communications about products and/or services.
  • Sharing my contact details with companies of Grupo Orenes (https://orenesgrupo.com/empresas-del-grupo/), so that they may send me commercial communications about their products and services.
  • Management of photographs of participants in poker tournaments, themed dinners, other organizational events and/or testimonials.
  • Verifying the identity of clients through a facial recognition system to facilitate registration and access control to the centers.
  • Capturing images of roulette clients in casinos for online reproduction.
  • Management of customer service to resolve requests generated by clients or potential clients.
  • Management of the Wi-Fi service in our establishments for clients and visitors.
  • Management of the registration of participants in raffles.
  • Management of satisfaction surveys sent to our clients regarding our services.
  1. Due to legal obligation or in the public interest – Art. 6.1(c) and (e) GDPR-

As a company in the gambling and betting sector, VIVE COLLADOS, S.L. is subject to various legal obligations (e.g., Gambling Regulation Law, Anti-Money Laundering and Terrorism Financing Law, Tax Law), and several supervisory regulations.

Thus, we process data under this legal basis in the following cases:

  • Management of the portfolio of players using the services, including prize payments and registration of entry to the facilities.
  • Management of information of players registered on the online sports betting and online casino platform, including prize payments and access registration.
  • Management of the registry of prohibited players to prevent their access to Grupo Orenes facilities or services.
  • Registration of winners and management of prizes exceeding €2,000.
  • Compliance with legal obligations applicable to Grupo Orenes in terms of Anti-Money Laundering.
  • Conducting audits or external reviews to which Grupo Orenes is subject, either by applicable regulation or voluntarily to verify our internal control framework.
  • Recording images in Grupo Orenes facilities for security reasons, as well as to collect evidence in cases of theft and/or fraud.
  • Completion of entry forms in hospitality establishments and communication, if applicable, to State Security Forces and Corps.
  • Management of administrative or judicial files involving clients and Grupo Orenes. This processing may also be based on Grupo Orenes’ legitimate right to effective judicial protection, both in its right of defense and in the filing of legal claims it deems appropriate, based on civil or criminal procedural regulations.
  • Management of complaints regarding acts or conduct, present or past, contrary to our Code of Ethics or applicable legislation received through the different channels enabled by the organization, as well as their processing and investigation.
  • Response to the exercise of rights by data subjects in accordance with data protection regulations.
  1. To whom will your data be disclosed?

To carry out all the purposes described above, VIVE COLLADOS, S.L. collaborates with third-party service providers who may have access to personal data as a result of the execution of contracted services. In any case, VIVE COLLADOS, S.L. follows strict selection criteria for these third parties in order to comply with its data protection obligations and signs the corresponding data protection agreement with them, whereby these third parties undertake to comply with their data protection obligations, and specifically, to comply with the legal, technical and organizational measures, the processing of personal data for the agreed purposes, and the prohibition of processing such personal data for other purposes or transferring them to third parties.

Your data may also be disclosed to Public Bodies, the Tax Agency, Judges and Courts and, in general, to Competent Authorities when VIVE COLLADOS, S.L. is legally obliged to provide them.

Likewise, VIVE COLLADOS, S.L. must report to the Commission for the Prevention of Money Laundering (SEPBLAC) any indication or suspicion of operation in the field of combating and preventing money laundering and terrorism financing and also inform said Commission, providing the necessary identifying data of the users involved, so that the information collected is available to judicial bodies in investigations related to money laundering.

Data transfers to countries outside the European Union (so-called third countries) will only take place when the European Commission has decided that the third country guarantees an adequate level of protection, if required by law (e.g., tax reporting obligations), if you have given us your authorization in this regard or within the framework of data processing as service providers.

Orenes informs that, to fulfill its purposes of sending advertising by electronic means, it uses a provider located in the United States, called Salesforce, resulting in an international transfer of customer data. This provider has binding corporate rules for its services as processor, ensuring that the transfer will be carried out in accordance with the GDPR.

Similarly, for customer service purposes, Orenes uses Zendesk, also located in the United States. This provider guarantees that the transfer will be carried out in accordance with the GDPR through binding corporate rules for its services as processor.

  1. How long will we keep your data?

VIVE COLLADOS, S.L. will comply with the provisions of current regulations regarding the obligation to delete personal information that is no longer necessary for the purpose(s) for which it was collected, remaining exclusively available to Judges and Courts, the Public Prosecutor’s Office or competent Public Administrations for the attention of possible responsibilities arising from the processing, and only during the limitation periods of said responsibilities. Once these periods have elapsed, this information will be permanently deleted using secure methods.

Access data is stored for 6 months from the last visit to the establishment. On the online platform, it is retained for 6 years from the last access. If the data is covered by Royal Decree 304/2014, which approves the regulation of Law 10/2010 on the Prevention of Money Laundering, the retention period will be extended in accordance with Article 29.1, which states: “Obliged entities shall retain documents and maintain adequate records of all business relationships and transactions, national and international, for a period of ten years from the termination of the business relationship or the execution of the occasional transaction. The records must allow the reconstruction of individual transactions so that they may, if necessary, have evidentiary effect.”

Based on Instruction 1/2006 of the Spanish Data Protection Agency, information from video surveillance will be deleted within 1 month from the capture of the images.

In hospitality establishments, the register books must be kept for a period of three years, starting from the date of the last entry sheet that integrates them, in accordance with Order INT/1922/2003, of July 3, on register books and entry forms of travelers in hospitality establishments and similar.

Regarding the management of the Wi-Fi service in our establishments, connection data will be retained for the duration of the user’s connection to the Wi-Fi network and, subsequently, will remain blocked during the limitation periods of legal actions related to this processing.

  1. Personal Data Record

As the data controller of your personal data, VIVE COLLADOS, S.L. maintains a record of all data processing activities. This inventory contains all information about the type of data processed, such as data subjects, possible recipients of the data, purposes of processing, or the time the data will be retained, among other details.

The personal data provided by the user is maintained in a record controlled by VIVE COLLADOS, S.L. and therefore remains responsible for its security at all times. In addition to the above information, this record includes:

  • The department responsible for processing
  • The legal basis for processing
  • The category of data processed
  • The origin of the data processed
  • The channel through which the data was obtained
  • The medium in which the data is stored
  • A description of the processing carried out
  • A list of systems involved in the processing
  • The data processor
  1. Changes to the Privacy Policy

VIVE COLLADOS, S.L. reserves the right to modify the Privacy Policy. Any update is applicable to users once published. VIVE COLLADOS, S.L. undertakes to notify such changes through available means and to expressly indicate the date on which each version of the Privacy Policy comes into effect.

  1. Evidentiary Value

The user agrees that if the channel for obtaining the documents or data processed is an electronic medium, these have the same evidentiary value as if such documents and data had been sent or communicated on paper. Therefore, they undertake not to challenge their validity or evidentiary value on the grounds of being in electronic format.

  1. What are your rights when you provide us with your data?

In accordance with the provisions of the General Data Protection Regulation, as well as national data protection regulations, you have the right to exercise, if you so wish, the rights of access, rectification and deletion of data, as well as to request the limitation of the processing of your personal data, object to it, request the portability of your data, and not be subject to automated individual decisions. In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

  • Request access to your data that we hold.
  • Request that we rectify the data we already hold. Please note that, by actively providing us with your personal data by any means, you guarantee that it is true and accurate and undertake to notify us of any change or modification to it.
  • Request that we delete your data to the extent that it is no longer necessary for the purpose for which we need to process it as previously informed, or that we no longer have legal grounds to do so.
  • Request that we limit the processing of your data, which means that in certain cases you may ask us to temporarily suspend the processing of your data or to retain it beyond the necessary time when you may need it.
  • Receive those personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format, and to transmit them to another data controller.
  • Furthermore, when the processing of your data is based on our legitimate interest, you also have the right to object to the processing of your data.
  • Additionally, if the described personal data processing is based on the consent you have given, you may revoke such consent at any time. In this regard, it should be noted that the revocation of the consent given will not affect the lawfulness of the processing carried out prior to the withdrawal of such consent.

You may exercise the aforementioned rights through the following channels. If we consider it necessary to identify you, we may request a copy of a document proving your identity (copy of ID card, passport, NIE, etc.):

  • In writing, by sending a request to VIVE COLLADOS, S.L., Avenida Alejandro Valverde, 170, Postal Code 30.007 (Murcia).
  • By email to the following address: dpo@orenesgrupo.com

VIVE COLLADOS, S.L. undertakes to provide a copy of the personal data subject to processing and reserves the right to charge a reasonable fee for any additional copy requested by the data subject, based on administrative costs.

Users have the right to access or receive the information, or a copy thereof, in a structured electronic format commonly used, unless the data subject requests it in another format.

  1. Am I obliged to provide information?

Within the framework of our business relationship, you must provide us with those personal data that require your consent for the provision of a service, or that are necessary for the fulfillment of the resulting contractual obligations, or that we are legally obliged to collect.

If you do not provide us with such data, we will generally be forced to refuse to provide the service, or we will not be able to continue providing the existing service and will be forced to terminate our business relationship.

In particular, in accordance with the legal provisions on anti-money laundering, prior to the start of the business relationship we are obliged to identify you, for example, through your national identity document and to collect and store your name and surname, place and date of birth, nationality, as well as address. You must also inform us of any changes that arise during the course of the business relationship. If you do not provide us with the necessary information and documentation, we will not be able to establish or continue the business relationship you wish to initiate.

  1. To whom can you submit complaints?

If you believe that your data protection rights have been violated or have any complaint regarding your personal information, you may contact us through the channels provided in section 8.

In any case, data subjects may always contact the spanish Data Protection Agency, the supervisory authority in data protection matters: http://www.aepd.es, C/Jorge Juan number 6, 28001, Madrid.