Protection of your personal data is important to us; therefore, we pay special attention to safeguarding the privacy of individuals who provide us with personal data through the website www.favbet.ro (hereinafter referred to as the "website"), for the purpose of entering into and performing a contract, processing a request, as well as those whose personal data has been provided to us by a third party or to which we have had access from another source, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the "GDPR").

Please pay special attention to reading the following Policy (hereinafter referred to as the "PPD") to understand how your information ("personal data") will be treated, including the data we process, the legal basis for processing, and what we do with them when you enter into a legal relationship with our company (including, but not limited to, when you purchase goods from us or visit this website).

The PPD explains the practices of FAVBET ONLINE S.R.L. (hereinafter referred to as "FAVBET"), regarding the implementation of GDPR provisions, as well as the rights you have regarding how your information is processed by FAVBET.

We assure you that the processing of personal data carried out by FAVBET will always be in accordance with the provisions of the GDPR, as well as with the regulations on the protection of personal data in force in our country.

DATA CONTROLLER

The data controller for your personal data is FAVBET ONLINE S.R.L., with its registered office in Bucharest, Sector 1, Calea Griviței, no. 136, Corp C, floor 2, office 6, registered with the Trade Registry under no. J40/14188/18.11.2015, Fiscal Code 35246629.

The data subjects have the possibility to contact us directly at any time regarding any aspects related to this PPD, using the contact details below:

E-mail: [email protected]

Mailing Address: Bucharest, Transilvaniei Street, No. 9, Sector 1, Bucharest, Postal Code 010796.

CATEGORIES OF PERSONAL DATA WE PROCESS

To help you accurately identify the personal data we process, it is necessary to first define two basic concepts in this field.

Thus, "Personal data" means any information or pieces of information that can directly (e.g., your name) or indirectly (e.g., pseudonymous data, such as a unique identification number) identify you.

"Processing" means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Starting from these two definitions, the personal data we process through the website are as follows:

• identification data, such as: name, surname, ID card details.;

• contact information, such as: mailing/delivery address, email address, phone number.

• data regarding consumption history or preferences, such as: game history, information sent by your browser whenever you visit our website, including traffic data, location data, website history, and other communication data; information received from players' devices (e.g., IP address, cookies, hardware model, operating system and version, serial numbers).

• transaction data, personal data related to purchases made, payment methods, etc.

• other data necessary for the conduct of our business activities.. In certain specific cases, we may also process other information necessary for the secure conduct of our business or the legitimate interests of the company.

BASIS AND PURPOSES OF PROCESSING PERSONAL DATA

1. For the purpose of concluding and executing contracts between the parties - According to Article 6(1)(b) of the GDPR. we process your above-mentioned data to take necessary measures for the conclusion and execution of contracts and fulfillment of legal obligations. This includes operations such as operating, managing accounts, and verifying the identity of players, requesting an offer, making payments for purchased goods/services, etc.


2. For the purpose of fulfilling legal obligations - According to Article 6(1)(c) of the GDPR.

We request a series of personal data, including, in certain situations, the personal identification number, for the purpose of fulfilling our obligations imposed by authorities related to archiving accounting documents, invoicing, drafting financial documents, reporting to tax authorities, reporting to competent authorities in the field of gambling, compliance with risk management procedures, and monitoring transactions to prevent fraud, irregular betting, money laundering, and deception, etc.

The processing of your data for this purpose is necessary based on legal obligations. Providing your data for this purpose is necessary. Refusal to provide the data may result in the inability to fulfill our legal obligations and, consequently, the inability to provide you with services through the website.

3. For marketing purposes - According to Article 6(1)(a) of the GDPR.

We process personal data if the data subject has given consent for one or more specific purposes. Thus, in certain situations, your personal data will be used to send you marketing messages, offers, news, future campaigns, invitations to various events, with your explicit consent.

You can give your consent for the processing of data for this purpose by checking the corresponding box.

from the moment of creating the account or later, in the "PROFILE" section

For unsubscribing from receiving such commercial communications, you can use the option at the end of each email/SMS containing commercial communications. Additionally, you can unsubscribe by accessing the "PROFILE" section.

Providing your data for this purpose is voluntary. Refusing to give consent for the processing of your data for

this purpose will not have negative consequences for you.

Therefore:

Cookies for the website www.favbet.ro

Cookies are small-sized files stored on the user's hard drive. Using the "cookie" mechanism is an advantage for the benefit of visitors, as it allows the memorization of navigation options on the site, such as the language in which the site is displayed, types of filters applied to display certain pages, and the memorization of the username and password for quick access to the site's content.

With certain exceptions, not accepting a cookie does not mean that the user will be denied access to navigate the website or read its content. With the help of cookies, we can monitor and segment users' interests in certain areas or applications of the site, which allows us to later improve the browsing experience, introduce relevant content for the user, etc.

Cookies containing your personal information are loaded but are not functional unless you explicitly agree. Following your consent, these cookies are valid for 24 hours. Cookies are used for marketing and analytical purposes.

The presence of FAVBET on social media platforms

Communication with FAVBET can be carried out through the social media platforms on which it is registered.

4. For the purpose of legitimate interests pursued by the operator or a third party - According to Article 6(1)(f) of the GDPR.

Therefore, your data will be processed to monitor traffic and improve your experience on the website. The processing of your data for this purpose is based on the legitimate interest of FAVBET in ensuring the proper functioning of the site and continually enhancing the visitor experience, including addressing various comments, questions, or complaints.

5. For the purpose of administering and maintaining this website, which involves storing cookies.

as described in the Cookie Policy - According to Article 6(1)(a) and (f) of the GDPR.

During the use of our website, we may ask you to provide certain personal data that can be used to contact or identify you. This personal data may include, but is not limited to, your name, email address, information that your browser sends whenever you visit our website.

6. For the purpose of resolving your requests, questions, or complaints - According to Article 6(1)(a), (b), and/or (f) of the GDPR.

For this purpose, we will process personal data such as your name and contact details, which you provide in the respective section of the website, exclusively for the purpose of processing your request.

Please note that to process your requests, in certain circumstances, we may have an obligation to disclose your data to the partners collaborating with FAVBET and/or other third-party service providers of FAVBET.

AlsoFAVBET may have access to other personal data through your connection with FAVBET, through the processing of data communicated during phone conversations, email exchanges, visiting our headquarters for information, etc.

By contactingFAVBET in any of the ways stipulated above or any other method that involves direct or indirect communication between you and FAVBET, you understand and agree that your data will be processed in accordance with the FAVBET PPD.

DATA STORAGE PERIOD

FAVBET will retain processed data for various periods of time, deemed reasonable, in accordance with the purposes mentioned earlier. We retain your data only for the period necessary to achieve the purpose for which we hold the data, to meet your needs, or to fulfill legal obligations.

To determine how long your data can be retained, we use the following criteria:

1. When you access and benefit from the services offered by FAVBET, latform, we retain your personal data for the duration of our contractual relationship, as well as for a subsequent period if there is a legal obligation for FAVBETto retain it. According to the legislation on the organization of remote gambling, we retain your data for a period of 6 years.


2. In case you contact us with a question, we retain your personal data for the time necessary to process your inquiries but not more than 6 months from the last correspondence sent.


3. If you have given consent for marketing, we retain your personal data until you unsubscribe or request their deletion or after a period of inactivity (without active interaction with our brands, defined in accordance with current legal regulations). In this regard, please note that the data stored in our databases for the purpose of marketing communications are deleted from these databases 6 months after the last interaction with you. If you withdraw your consent for data processing for marketing purposes, the processing of your personal data for this purpose will cease, without affecting the processing carried out based on the consent expressed by you before its withdrawal.


4. If your data has been processed as a result of a legitimate interest at FAVBET we retain your data for the period necessary to fulfill our legitimate interest but not more than 6 months from the first interaction with you.

RIGHTS OF DATA SUBJECTS

In accordance with GDPR, you have a series of rights regarding the personal data that FAVBET processes:

1. The right of access to data processing - You have the right to access your personal data that we own. The first provision of information will be made free of charge. If you will still need copies of information already provided we may charge a reasonable fee taking into account the administrative costs of providing the information. Manifestly unfounded requests, excessive or repeated requests may not receive a response.


2. Right to data rectification- You have the right to request that your data to be rectified if they are inaccurate or out of date and/or to complete them if they are incomplete.


3. The right to data deletion (“the right to be forgotten”) - In some cases you have the right to obtain the deletion or destruction of your data. This is not an absolute right because sometimes we may be forced to retain your data for legal or legal reasons.


4. Right to restriction of processing - You have the right to request restriction processing your data. This means that the processing of your data is limited, so that we can keep the data but not use or process it. This right applies in specific circumstances provided for by the General Data Protection Regulation, namely:


• the accuracy of the data is contested by the data subject (i.e. you), for a period which allows the operator (ie FAVBET) to verify the correctness of the data;


• the processing is illegal and the data subject (i.e. you) opposes the deletion of the data and requests the restriction of their use;


• FAVBET no longer needs data for processing, but they are requested by the data subject (i.e. you) for the establishment, exercise or defense of legal claims;


• the data subject (ie you) has objected to the processing based on legitimate grounds on the part FAVBET on the basis of checking whether the legitimate reasons of the operator exceed those of the data subject (i.e. yoŭ ).
5. Right to data portability - You have the right to move, copy or transfer the data you are interested in from our database in another. This only applies to data that you have provided them, when the processing is based on your consent or on the basis of a contract and is implemented by automated means.


6. Right of opposition - You can object at any time to the processing of your data when when such processing is based on a legitimate interest.


7. The right to withdraw consent at any time - You can withdraw your consent in regarding the processing of your data when such processing is based on consent. Withdrawal of consent does not affect the legality of processing based on consent prior to its withdrawal.


8. The right to file a complaint with the competent supervisory authority - You have the right lodge a complaint with the data protection authority in your country of residence or address to challenge the data protection practices offered by FAVBET.


9. The right to object to the processing of your data for direct marketing purposes- You can unsubscribe or opt out of our direct marketing communication at any time. You can do it this by clicking on the "unsubscribe" link in any email or communication we send you.


10. The right to object to us processing your data when we carry out actions in the public interest or in your own or a third party's legitimate interests - You can object to at any time in the processing of your data when such processing is based on a legitimate interest.

DATA PROCESSING PRINCIPLES

FAVBET undertakes to comply with the principles of personal data protection (hereinafter

"Principles") provided for by the GDPR, to ensure that all data is:

1. Processed fairly, legally and transparently;


2. Collected for specified, explicit and legitimate purposes;


3. Adequate, relevant and limited in relation to the purposes for which they are processed;


4. Correct and updated;


5. Kept in a form that does not allow the identification of the data subjects for longer than it is necessary in relation to the purpose of the processing;


6. Processed in accordance with the rights of the data subject, in a way that ensures security adequate processing, so that the data are intact, confidential and available.

PROCESSING ANY OTHER DATA YOU PROVIDE US

FAVBET will use the information you provide, by direct transmission or indirectly or by making it known to the public, in electronic or material format, exclusively in order to process your request or contact you, send you messages of marketing, offers, news, future campaigns, invitations to various events held in related to FAVBET activity, only when we have your express consent.

By providing any personal data in the ways described above you also understand you agree that your data will be processed in accordance with the PPD provisions of FAVBET.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

The personal data processed by FAVBET may be disclosed and/or transferred to third parties only if there is your express consent to do so in this respect, except where there is a legal/contractual obligation for FAVBET to proceed in this way (to detect, prevent and respond to acts of fraud, the use unauthorized use of any material belonging to us, violations of our terms or policies or other harmful or illegal activities, to protect us, including our rights, property or our materials, you and others, including in the course of investigations or inquiries regulatory authorities or to prevent imminent death or personal injury).

To facilitate the carrying out of activities related to the processing purposes detailed above, FAVBET may communicate this data to third parties, such as:

• providers of operational services, such as courier services, telecommunications, IT, payments, processing, training, storage, archiving, investigative services related to customer support;


• any business partner, investor, transferee (current or potential) to facilitate transactions with business assets (which may include a merger, acquisition, debt or asset sale);


• professional advisers, such as auditors or lawyers;


• regulatory authorities, professional bodies and/or public authorities for compliance with applicable regulations.

We do not transfer your personal data outside the European Union, except in compliance with appropriate protection measures.

PROCESSING SECURITY

FAVBET has adopted updated technical and organizational data processing measures in accordance with the requirements of the GDPR, in order to protect your personal data against any actions of unauthorized access, misuse or disclosure, modification unauthorized, accidental destruction or loss. All employees and collaborators of FAVBET, as well as any third parties acting in the name and on behalf of FAVBET are bound to comply with the confidentiality of your information and the requirements of the GDPR, in accordance with the provisions of the PPD.

UPDATE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY

We reserve the right to update or change our Privacy Policy personally at any time and needing to check this policy periodically. Your use subsequent use of the Website after we post any changes to the PPD will constitute consent you expressly agree to comply with and be bound by the terms imposed by the privacy policy so modified.

Any changes to this policy will be brought to your attention by placing a prominent notice on our website.

The terms of the PPD shall be construed in accordance with applicable law.

CONTACT

If you have any questions or concerns about how we treat and use your data personal or wish to exercise any of your rights please us get in touch by accessing the following contact details:

E-mail address: [email protected]

Mailing address: Bucharest, str. Transilvaniei no. 9, sector 1, Bucharest, code 010796