This document sets out your personal data processing and your rights under current data protection legislation – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on individuals’ protection with regard to personal data processing and the regulations implementing it, hereinafter “GDPR”. Depending on the relationship we maintain with you, and the services requested and/or provided, the type of data processed and the use of such data may vary.
Data controller and contact details
The entity responsible for the processing of your data is VIVE COLLADOS S.L, with registered office at CRTA. DE LA SAGRA S/N PUEBLA DE D. FADRIQUE, 18820 Granada.
You may contact the Data Protection Delegate via the following e-mail address email@example.com or via the abovementioned postal address.
For what purpose will we process your data (processing purpose) and on what legal basis?
Personal data are processed in accordance with the GDPR provisions, on the following legal basis:
In the context of execution or performance of contractual obligations -Art. 6.1 b) GDPR-
To fulfil our contractual obligations to you, including to register an account to use our services.
- Contracted services management.
- Compliance with accounting, legal, fiscal and administrative obligations.
Justified by a legitimate interest -Art. 6.1. f) GDPR-
When necessary, VIVE COLLADOS S.L. will process your personal data to satisfy its own legitimate interests or those of third parties in the following cases:
- Images recording in VIVE COLLADOS S.L. installations for security reasons, as well as to collect evidence in theft and/or fraud cases.
- Customer complaint management.
- Customer service management for the resolution of requests submitted by customers or potential customers.
- Implementation of controls for fraudulent activities detection.
Consent -Art. 6.1a) RGPD-
Provided that you have given us your consent, we may carry out any additional processing operations of which you have been informed and to which you have consented. You may withdraw your consent at any time. This also applies if your consent was given before the entry into force of the EU General Data Protection Regulation, i.e. before 25 May 2018. It should be noted that objection to a particular processing operation and revocation of consent are not retroactive. You may at any time obtain information about the authorisations you have given us for the various processing operations by exercising your rights in accordance with section 8.
VIVE COLLADOS S.L. will request your authorisation to process your data for the following purposes:
- Contact data collected through forms on the corporate websites management.
- Cash prize payment management.
- Jackpot winners’ registration management.
- Photographs management and publication of participants’ photographs at events.
- Sending commercial, promotional and/or advertising communications, which may be based on the products contracted or services provided.
- The automatic categorisation of my user according to my gambling profile in order to receive communications adapted to my preferences and needs. Personal data may be processed for profiling based on internal sources (e.g. cookie navigation data, historical and statistical data), the results of which allow the creation and analysis of personalised products, through segmentation into different groups in relation to common patterns. These profiles will only be used to send you personalised communications about products and/or services.
- In addition, our Casinos division will also require your consent to:
- Informational communications on the organisation of thematic dinners to interested clients.
- Communications concerning invitations to special events.
- Informational communications regarding poker tournaments to Poker Club members.
- Photographs management and publication of participants’ photographs at poker tournaments.
By law 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 Act, Prevention of Money Laundering and Financing of Terrorism Act, Tax Act), and to various supervisory regulations.
In this regard, we process data on this legal basis in the following cases:
- Portfolio managing of players who make use of services offered by Bingos and Casinos, including prize payments and registration management at the facilities.
- Portfolio managment of registered players on the Online Sports Betting and Online Casino platform, including registration management at the on-site gambling facilities.
- Administrative or judicial file management involving clients and VIVE COLLADOS S.L. This processing may also be based on the legitimate right of VIVE COLLADOS S.L. to effective judicial protection, both in its right of defence and in the filing of legal claims that it deems appropriate, based on the regulations of civil or criminal prosecution.
- Issuing winnings certificates to players upon request.
- Winners registration and prize management for prizes over €2,000.
- Register management of banned players in order to prevent their access to VIVE COLLADOS S.L. facilities.
- Managing liens imposed on clients in order to comply with every legal obligation applicable to VIVE COLLADOS S.L.
- Compliance with legal obligations applicable to VIVE COLLADOS S.L. with regard to the Prevention of Money Laundering.
- External audits or reviews to which VIVE COLLADOS S.L. is subject, either by applicable regulation or carried out voluntarily to verify our internal control framework.
To which recipients will your data be disclosed?
In order to carry out all the purposes described above, VIVE COLLADOS S.L. collaborates with third party service providers who may have access to your personal data as a consequence of executing the contracted services. In any case, VIVE COLLADOS S.L. follows strict criteria for selecting these third parties in order to comply with its data protection obligations and signs the corresponding data protection agreement with them, in which these third parties undertake to comply with their data protection obligations, and specifically, to comply with the legal, technical and organisational measures, to process personal data for the agreed purposes, and to prohibit the processing of such personal data for other purposes or transfer to third parties.
Your data may also be disclosed to Public Bodies, the Tax Agency, Judges and Courts and in general to the Competent Authorities when VIVE COLLADOS S.L. is legally obliged to provide them.
Additionally, VIVE COLLADOS S.L. must inform the Commission for the Prevention of Money Laundering (SEPBLAC) of any evidence or suspicion regarding any operation within anti-money laundering and terrorist financing. It must also report to the said Commission, providing any necessary identification personal details of the users involved, so that information collected is available to judicial bodies for investigations related to money laundering.
Data will only be transferred to countries outside the European Union (so-called third countries) if the European Commission has decided that the third country ensures an adequate protection level, if this is required by law (e.g. tax reporting obligations), if you have given us your consent or in the context of data processing as a service provider.
VIVE COLLADOS S.L. informs that, in order to fulfil its purposes of sending publicity by electronic means, it uses a supplier located in the United States, called MailChimp, producing an international transfer of its clients’ data. This provider subscribes to the Privacy Shield agreement, which regulates international transfers between data controllers located in the European Union and those located in the United States, guaranteeing that the transfer will be carried out in accordance with the terms of the agreement and that the provider will process your data in accordance with the stipulations of said agreement.
For how long will we store your data?
VIVE COLLADOS S.L. will comply with current legislation regarding the obligation to delete personal information that is no longer necessary for the purpose or purposes for which it was collected, remaining at the exclusive disposal of Judges and Courts, the Public Prosecutor’s Office or the competent Public Administrations for attending possible liabilities arising from processing, and only during the description periods of said liabilities. Once these deadlines elapse, such information shall be permanently deleted by secure means.
In case 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 shall be extended in accordance with Article 29.1, which provides that “Obliged entities shall retain documents and keep adequate records of all business relationships and transactions, both domestic and international, for a period of ten years from the termination of the business relationship or the execution of the occasional transaction. Records shall permit reconstruction of individual transactions so that they can, if necessary, have “probative effect”.
On the basis of Instruction 1/2006 of the Spanish Data Protection Agency, the information on video surveillance shall be cancelled within 1 month following the image capture.
Personal data registration
VIVE COLLADOS S.L., as responsible for processing your personal data, keeps a record of all data processing activities. This inventory contains comprehensive information relating to the type of data processed, such as data subjects, possible recipients of the data, processing purposes, how long the data will be retained, and other details.
Personal data provided by the user is kept in a register monitored by VIVE COLLADOS S.L. and therefore remains responsible for its security at all times. This register includes, in addition to the above information, the following:
- Processing department
- Processing lawfulness
- Processing data category
- Processing data origin
- Processing data collection channel
- Support on which processing data is stored
- A description of the treatment carried out
- A list of the systems involved in the treatment
- The data controller
Users accept that, should the processed documents or data be obtained electronically, they shall have the same probative value as if they had been sent or communicated on paper. They therefore undertake not to contest its validity or probative value on the grounds that it is in electronic form.
What rights are you entitled to when you provide your data to us?
According to the General Data Protection Regulation, as well as national data protection regulations, you are entitled to exercise, if you so wish, the access, rectification and deletion rights, as well as to request a restriction on personal data processing, to oppose such processing, to request data portability, and not to be subject to automated individual decisions.
In addition, should personal data processing described above be based on your consent, you may revoke this consent at any time. In this regard, it should be noted that revoking consent will not have any effect on the lawfulness of the processing carried out prior to the withdrawal of such consent.
You may execute the above-described rights through the following channels, providing any necessary documentation which allows us to verify your identity (copy of your ID card, passport, NIE, etc.):
- By written request addressed to VIVE COLLADOS, S.L., CRTA. DE LA SAGRA S/N PUEBLA DE D. FADRIQUE, 18820 Granada.
- Via e-mail to firstname.lastname@example.org. Once your application is received at email@example.com, a confirmation e-mail will be sent to your e-mail address at the same address.
VIVE COLLADOS S.L. undertakes to supply a copy of any personal data processed and reserves the right to charge a reasonable fee based on administrative costs for any other copy requested by the data subject.
Users are entitled to access or receive information, or a copy thereof, in a commonly used structured electronic format, unless the data subject requests it in another format.
Am I obliged to provide information?
As part of our business relationship, you must provide us with personal data which requires your consent for a service to be provided, or which is necessary for the fulfilment of the contractual obligations arising from it, or the collection of which we are obliged by law to collect.
Should you fail to provide us with such data, we will generally be obliged to decline providing the service, or we will no longer be able to provide the existing service and will be obliged to terminate our business relationship.
Particularly pursuant to anti-money laundering regulations, we are obliged to identify you, e.g. by means of your national identity card, and to collect and store your first and last name, place and date of birth, nationality and address prior to initiating our business relationship. You shall also inform us of any changes that may arise in the course of the business relationship. Should you fail to provide us with the necessary information and documentation, we will not be able to establish or continue the business relationship you wish to enter into.
To whom should you address your complaints?
Should you understand that your data protection rights have been violated or if you have any complaints regarding your personal information, you may contact us through the channels provided in section 8.
In any case, data subjects may at any time refer to the Spanish Data Protection Agency, the supervisory authority for data protection, http://www.agpd.es., C/Jorge Juan number 6, 28001, Madrid.