GDPR


PRIVACY POLICY


TELEMATIC INTERACTIV BULGARIA EOOD


This Privacy Policy aims to familiarize you with the rules we respect as regards the collection and processing of your personal data when you visit our website and use the services we offer.

Here, you can find information about what personal data of yours are collected, how and for what purpose we use them, to whom we provide them, what your rights are as a data subject, and how to contact us or the data protection supervisor.


Who we are and how you can contact us


TELEMATIC INTERACTIV BULGARIA EOOD is a legal entity entered in the Commercial Register at the Registry Agency with UIC 203127300 and registered office and administrative address at 7, Kukush Str., Sofia.


Palmsbet.com is a registered domain of TELEMATIC INTERACTIV BULGARIA EOOD with UIC 203127300 and registered office and administrative address at 7, Kukush Str., Ilinden District, Sofia, Bulgaria. TELEMATIC INTERACTIV BULGARIA EOOD holds licenses for organizing online gambling games, No. 000030-16257 issued on the grounds of Article 34, paragraph 1 of the Gambling Act by Decision No. 000030-7389/26.09.2014 (Casino Games) and No. 000030-6941 issued on the grounds of Article 34, paragraph 1 of the Gambling Act by Decision No. 000030-3647/ 30.03.2018 (Sports Betting) of the State Gambling Commission.


TELEMATIC INTERACTIV BULGARIA EOOD is the controller of the personal data processed in the course of or in connection with the implementation of the company's business, with the registered office and administrative address of the Company being 7, Kukush Str., Sofia, at which address you can send requests to the Data Protection Officer by mail, personally submit your requests to the registry of the above registered office and administrative address or send by e-mail to dpo@palmsbet.com.

In your message, you should provide the data necessary for your individualization as well as contact details for feedback.


     What data we collect, what purposes we use them for, and what our grounds for processing personal data are


      Please note that detailed personal data about you are collected only after you sign up and log in to your personal account. The grounds for doing so are based on the requirements of the Gambling Act and other special acts and regulations, under which the Company must verify the identity of the gambling participants, and for this purpose various lawful means are used to confirm your identity.


      Data processed when participating in games of palmsbet.com:

      IP address;

      Keeping track of your profile activity: we get this information when you are a registered user and have logged into your account by counting the start and end times of your game session, the total amount of your stake, the total amount that has been deposited or withdrawn from your game account; the date, time, and duration of the game session.


      Prior to accepting your stake, the Company has a legal obligation to carry out a procedure to identify you. When doing so, we may require that you provide us with a copy of an official identity document with a photo, a photo of the face of a credit / debit card, etc.


      Personal data processed when operating your user’s account:

      Prior to authorizing your first payment, you will need to provide a copy of an official ID document by email.

      Personal data for creation, processing, withdrawals, and payments are provided and processed in accordance with the applicable legislation in force and stored in the Company's database.

      When TELEMATIC INTERACTIV BULGARIA EOOD processes data based on the consent of the data subject, the personal data are processed only if the individual has been informed and has freely, specifically, and unambiguously expressed their consent for the processing.

      The processing of the data is done for the specific purposes precisely defined by the act, with the data being processed lawfully and in good faith and not further and in a manner incompatible with such purposes.

      We use your personal data only for the purposes related to the activity pursued by TELEMATIC INTERACTIV BULGARIA EOOD.

      We do not perform any further analysis or other processing of the features of the data provided by you; we do not use the data we hold about you for profiling, extracting information, categorizing you in any way or making automated decisions, which could have legal consequences for you or otherwise affect you.


      Data we process for security purposes, for protection against legal claims and in order to offer better services to our customers:

      Customer profile / Customer record: If you have used any of our services, we will keep your information after having provided you with the relevant service, namely: your name, email address, telephone number, your betting history, and other relevant data related to our services. We do this for two reasons:

      First of all, this information is necessary in case of claims by you or by the user of the service we have provided in order for us to be able to prove the circumstances related to the provision of the service. Information may also be necessary when we are inspected by a competent public authority because of the need to prove to that authority facts and circumstances relating to the provision of the service.

      Next, we keep your customer record based on the legitimate interest to track the development of our potential customers' interest in the services we provide and to improve our offers.


      Online chat: Our website gives you the opportunity to start a chat with our operator where you can enter your name, email address, and the topic you want to chat about. We record such data so that, in a subsequent chat, we can recall our previous chats. We process these categories of data based on the legitimate interest to improve our offers for existing and potential customers based on the analysis of their activity and interests.


      Data we process for the purposes of our newsletter:

      Our website offers you the opportunity to receive information about current or upcoming promotions that we offer upon subscribing to our newsletter. We process the provided category of personal data based on our legitimate interest to keep our existing and potential customers informed about our current and upcoming promotions. We also process such data based on your agreement to receive the newsletter you have expressed by clicking on the subscription button in the Marketing section (I want to receive news).

      You can unsubscribe at any time by removing the check mark showing that you wish to receive the newsletter.


      Categories of data recipients outside of TELEMATIC INTERACTIV BULGARIA EOOD


      The Company does not disclose personal data to third parties and recipients unless there is a legitimate reason to obtain the data or the data are publicly available due to their inclusion in a public register.

      Except in the case of public access to data included in a public register, data recipients, depending on the particular case, may be:

          • State authorities and bodies entrusted with public functions within the framework of their powers (State Commission on Gambling, National Revenue Agency, National Social Security Institute, Ministry of Interior, and other similar institutions);

          • Our trusted partners who meet the highest standards of security and confidentiality of the information provided to them to the extent we need this to provide the services offered by us such as technical support services on our site, chat platforms to contact us, etc.);

          • Banks for the purposes of remuneration payments as well as for the execution of electronic payments;

          • Other third parties who receive your personal data are legal entities offering the following non-cash payment services listed on www.palmsbet.com: CashTerminal, Easy Pay, ePay.bg, Maestro, MasterCard, VISA.

          • Courier companies and postal operators: for the purpose of conducting correspondence with individuals - data subjects.

          • We inform you that, in certain cases, your personal information may be shared with non-EU / EEA third parties in accordance with the applicable law and this Privacy Policy. If we disclose your personal information to non-EU / EEA third parties, we will ensure that our contractual relations with such third parties include adequate safeguards to protect your personal information. We only enter into contractual relations with third parties if they can guarantee a standard of data protection comparable with that of the EU / EEA countries.


      Data Storage Period

      As a data controller, TELEMATIC INTERACTIV BULGARIA EOOD processes data for a minimum duration in accordance with the processing purposes and provided for in the legislation in force in accordance with the principle of restriction of storage.


      As regards the archives containing customer records for a period of 5 years, in accordance with the national legislation regulating gambling, we apply a 5-year-storage period upon expiry of the prescription period for repayment of public obligations related to the geographic location of the IP address; identification of the date, time, and duration of the gaming session of the individual registered as a participant in a game; and the remaining data are kept for a period of between 2 months and 5 years in accordance with the type of data defining the legal obligation for processing, including their storage.


      Rights of individuals - data subjects


      The measures implemented to protect personal data in accordance with the requirements of Regulation 2016/679 aim at ensuring the rights of the individuals whose personal data are processed, namely:

          • Right to access;

          • Right to rectification of inaccurate or incomplete data;

          • Right to erasure (right to be forgotten), should the conditions of Art. 17 of Regulation 2016/679 apply;

          • Right to restriction of processing;

          • Right to data portability should the portability conditions under Art. 20 of Regulation 2016/679 are present;

          • Right to object should the conditions of Art. 21 of Regulation 2016/679 are present;

          • Right not to be subject to a decision based solely on automated processing, including profiling.


      The above rights can be exercised through a written request to TELEMATIC INTERACTIV BULGARIA EOOD (written on paper or by e-mail), in which you should specify your request. The request should be signed and sent to the Company's address and the Data Protection Officer via dpo@palmsbet.com.


      Right to complain to the Commission for Personal Data Protection


      If you believe that your rights under Regulation 2016/679 have been violated, you may file a complaint with the Commission for Personal Data Protection at 2, Prof. Tsvetan Lazarov blvd., 1592 Sofia; www.cpdp.bg, email: kzld@cpdp.bg.


      Transmission of personal data to third countries or international organizations

      The Company does not transmit processed personal data to third countries or international organizations.


      Personal data protection measures implemented by TELEMATIC INTERACTIV BULGARIA EOOD


      TELEMATIC INTERACTIV BULGARIA EOOD has implemented measures for effective protection of the personal data processed and a possibility of exercising the rights of the data subjects provided for in Regulation 2016/679 by adopting Internal Rules for Personal Data Protection. Procedures for communication in case of complaints, data portability, transparency in processing personal data, managing subjects’ requests, obtaining consent, notifying security breaches, storing and destroying documents, as well as a number of other technical measures to ensure the security of the personal data.


      Access to your personal data within our organization is only available to individuals whose work functions require access to the data in order to perform the activities for which the data have been collected and processed. In all contracts we conclude with employees and third parties to whom we assign your personal data processing, we include contractual data privacy clauses.


      Changes


      This Privacy Policy was adopted by decision of the sole owner of the capital of TELEMATIC INTERACTIV BULGARIA EOOD; the Policy complies with the requirements of Regulation 2016/679, the provisions of the Bulgarian legislation in force, and the internal rules and policies adopted by the Company in the field of personal data protection.


      The Company reserves the right to make changes to and to update this Policy, about which we will notify you by posting a message on our website.

      TELEMATIC INTERACTIV BULGARIA EOOD processes personal data in connection with the following main activities: Organizing and conducting online betting.

      When pursuing its business activity, the Company processes personal data of its customers.


      The Company reserves the right to make changes to and to update this Policy, about which we will notify you by posting a message on our website.


      The privacy of all the data we hold about you - our customers - have always been our top priority.

      Thank you for being our customers!