1. About the Privacy Policy
1.1. AMUSNET GAMING LIMITED, a company incorporated in the Republic of Malta, with a secondary office at Via Arenula 16, Rome (RM) CAP 00186, Italy, with REA number RM-1677746 and registration number 16819191004, represented by Polina Evgenieva Nedyalkova, Legal Representative – Branch Director, telephone number: +356 2092 5404, e-mail: [email protected] (hereinafter referred to as the “Amusnet Gaming”, “Company”, “we”, “our”, “us”) is a data controller and as a data controller complies with the rules and requirements of the applicable legislation on personal data protection.
1.2. The present Privacy Policy aims to inform you about how Amusnet Gaming processes the personal data related to the persons specified below, for what purposes Amusnet Gaming collects and processes personal data, what are the grounds for processing personal data, the term of processing personal data, what are the rights of data subjects in relation to this processing, as well as other information aimed at ensuring transparent and conscientious processing of personal data by Amusnet Gaming.
1.3. With respect to the processing of personal data relating to individuals who apply for employment with us, this Privacy Policy is applicable in addition to the Privacy Notice for Job Applicants available here.
2. What types of information do we collect and why?
2.1. Amusnet Gaming processes various categories of personal data necessary for the lawful and normal conduct of the Company’s business; the conclusion and execution of various contracts between the Company and third parties; the provision of services to the Company by suppliers; for the fulfilment of obligations established by a legal obligation; communication and provision of information and documents to the national and foreign public and regulatory bodies; as well as for other legal purposes related to the business activities carried out by the Company.
3. Which are the persons whose personal data is processed?
We process personal data related to the following persons (“You”):
3.1. Legal representatives, proxies, subcontractors, associates, and employees of our suppliers and business partners (“Contractors“), as well as personal data of data subjects of legal representatives, proxies, subcontractors, associates, and employees which may become our business partners;
3.2. Visitors of our Website and users of its information resources;
3.3. Persons making inquiries, requests, and other messages to us by mail, e-mail, telephone, and other means of communication;
3.4. The processing of personal data about the abovementioned data subjects is necessary for Amusnet Gaming for the conclusion, execution, and/or termination of contracts; identification of beneficial owners of legal entities – our suppliers and business partners, in view of our internal policies and rules. Without processing of the said personal data, Amusnet Gaming cannot enter into contracts with its Contractors or fulfill its obligations under them.
4. Contractors
4.1. The personal data that may be collected and processed by Amusnet Gaming within our relations with Contractors might be the following:
- Identification data of Contractors, their legal representatives and proxies – full name, citizenship, Personal Identification Number (PIN) or another identification number/code, ID card number, passport details, address, email address as well as identificat ion data about the ultimate beneficial owners and representatives of the companies with which We are to enter into contractual relations;
- Business contact details – address, contact phone, e-mail;
- Other personal data that may be provided by our business contacts when filling out client/partner questionnaires;
- Other information related to the Contractors, their employees and representatives, provided or created in the context of our business relations and activities, including in negotiations and legal disputes.
5. Website visitors
5.1. When you visit our Website, we may process personal data relating to you through the use of cookies or similar technologies. For more information, please see our Cookie Policy here.
5.2. When you make requests, inquiries, and other communications to us, we may process your personal data, such as names and contact details, which you have provided to us voluntarily for the purposes of carrying out communication with you and to respond to your inquiry.
6. For what purpose does Amusnet Gaming process your Personal Data?
Amusnet Gaming processes personal data for the following purposes:
6.1. Processing of personal data necessary for taking actions before concluding a contract, as well as for concluding, performing, and terminating a contract with Contractors:
- Identification of legal representatives, proxies, employees, and beneficial owners through publicly available channels, as well as when these data are provided by the Contractors of Amusnet Gaming before the conclusion of the contract;
- Preparation of offers, contracts, and all other documents accompanying the contract, as well as any other documents created in the context of business relations with the business partners of the Company;
- Notices related to our products and services.
6.2. Processing of personal data needed for compliance with a legal obligation:
- Personal data necessary for compliance with a legal obligation of Amusnet Gaming, including, but not limited to: (i) legal obligations established in the tax and accounting legislation, gambling legislation, customs legislation etc, (ii) obligations provided for by regulations in terms of proper and legal bookkeeping, (iii) obligations for the provision of information to all state commissions and regulatory authorities, (iv) provision of information to courts and law enforcement institutions.
6.3. Processing of personal data based on legitimate interest:
- Provision of data by you in our client/partner questionnaires, such as data about politically exposed persons;
- Verification of the existence of licenses, permits, concessions, and/or other rights related to the exercise of regulated activities by our business partners;
- Exercising and protecting the legal rights and interests of the Company.
7. То whom may Amusnet Gaming disclose your Personal Data?
7.1. Amusnet Gaming may use third parties to support certain contractual activities or with regard to the performance of a legal obligation. Amusnet Gaming does not provide personal data to third parties before the requirements for disclosure of personal data to third parties provided for in the applicable legislation are met.
7.2. Recipients of personal data may be third-party legal and individuals, such as:
- service providers and their subcontractors;
- postal and courier service providers;
- external consultants in various fields providing services to the Company, such as, but not limited to, banks, financial auditors, legal advisers, security companies, and other service providers;
- service providers which on assignment and on behalf of the Company maintain equipment, software, and hardware used to support the activities of Amusnet Gaming, as well as hosting companies and sales agents, etc.;
- state and municipal bodies, including, but not limited to, regulatory bodies, state commissions, institutions and agencies, tax department, law enforcement authorities and others, to which Amusnet Gaming should provide information that may contain personal data under the applicable legislation;
- other entities within the corporate group of Amusnet Gaming.
8. What technical and organizational measures for data protection do we apply?
8.1. In accordance with applicable law, Amusnet Gaming implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.
8.2. In addition, Amusnet Gaming implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.
9. When do we delete your Personal Data?
Amusnet Gaming stores personal data within the statutory time limits, and if there are not explicitly defined statutory time limits, within the time limits set by the Company in order to achieve the purposes of the personal data processing listed above. The Company deletes personal data after the expiration of the statutory deadlines for their storage and/or achieving the purposes of data processing, but in any case, not before the final settlement of all our financial relations.
9.2. Amusnet Gaming stores personal data for the following periods:
- Invoices and other financial information – 10 /ten/ years, starting from the beginning of the year following the year in which the payment of the debt for the respective year is due;
- Information contained in contracts and work orders – for the period of the contract and up to 5 /five/ years from the termination of the contract, except in cases where this information is related to tax and social security control – then the term is 10 /ten/ years, starting from the beginning of the year following the year in which the payment of the debt for the respective year is due;
- Information contained in correspondence with you – up to 5 /five/ years from the end of the correspondence. In cases where the correspondence relates to a valid contract, the term begins from its termination.
9.3. The personal data may also be processed for a longer period than the above-mentioned terms, if such processing is necessary to achieve the purposes set out therein or to protect the rights and/or legitimate interests of Amusnet Gaming, or if the applicable legislation provides for the processing of such data for a longer period.
10. Do we transfer personal data outside EU/EEA?
10.1. The transfer of personal data is secured by modern technical means. In principle, Amusnet Gaming does not transfer personal data to persons outside the EU / EEA. In the event that such transfer is necessary for the fulfilment of some of the above purposes, the transfer will be carried out in compliance with the requirements of applicable law.
11. What are Your rights in relation to the protection of your Personal Data?
11.1. In order to fulfil the obligations of Amusnet Gaming as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.
11.2. You have certain rights related to the processing of your Personal Data provided in the GDPR, including:
- Right to information and free and open access to your Personal Data, as well as the right to request a copy of your personal data stored or otherwise processed by Amusnet Gaming;
- The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete;
- In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your Personal Data or the restriction of their processing, as well as to exercise your right to the portability of your Personal Data (when applicable);
- Right to object, as well as rights related to automated decision-making – you have the right to object at any time, on grounds relating to your specific situation against the processing of your Personal Data, including in the event that your Personal Data is used for profiling;
- If you have any doubts that your Personal Data is not being processed lawfully by Amusnet Gaming, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Policy, or to seek the protection of your rights judicially.
11.3. Please note that Amusnet Gaming does not use your Personal Data for profiling or automated decision making.
11.4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the GDPR and the respective local data protection legislation. You may exercise your rights by making a written request to Amusnet Gaming on the contact details provided in this Policy in accordance with the requirements of applicable law. If necessary, Amusnet Gaming will provide you with full assistance in exercising the rights granted to you.
11.5. All personal data requests mentioned in Article 12.2. shall be made in writing, signed by the data subject and submitted to [email protected] or the address of the Company detailed in Article 1.1. above.
11.6. The Company will respond to such requests by no later than 30 (thirty) calendar days (with the possibility to extend this period for particularly complex requests in accordance with applicable law), implements them if there are grounds for doing so or makes a reasoned refusal if there are reasons for doing so, indicating the right of the data subject to follow.
12. Data Protection Officer
12.1. If you wish to receive additional information on how Amusnet Gaming processes your personal data, you can contact the Data Protection Officer at the following e-mail address: [email protected] or by sending your questions to the registered address of the Company, indicated at the beginning of this Policy.
13. Competent national supervisory authority for Personal Data Protection
Republic of Malta:
Office of the Information and Data Protection Commissioner
Address: Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta
Phone number: +356 2328 7100
E-mail: [email protected]
Website: https://idpc.org.mt/
Italian Republic:
Italian Data Protection Authority (Garante per la protezione dei dati personali)
Address: Piazza Venezia 11 – 00187 Roma (Italy)
Phone number: +39 06.696771
E-mail: [email protected]
Website: https://www.garanteprivacy.it
14. Changes to the present Personal Data Protection Policy
This Data Protection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website.
This Policy is effective as of 01.01.2023.
PRIVACY NOTICE FOR JOB APPLICANTS
at AMUSNET GAMING LIMITED
1. About the Privacy Notice for Job Applicants
1.1. AMUSNET GAMING LIMITED, a company incorporated in the Republic of Malta, with a secondary office at Via Arenula 16, Rome (RM) CAP 00186, Italy, with REA number RM-1677746 and registration number 16819191004, represented by Polina Evgenieva Nedyalkova, Legal Representative – Branch Director, telephone number: +356 2092 5404, e-mail: [email protected] (hereinafter referred to as the “Amusnet Gaming”, “Company”, “we”, “us”, “our”) is a data controller and as a data controller complies with the rules and requirements of the applicable legislation on personal data protection.
1.2. The present Privacy Notice for Job Applicants at Amusnet Gaming (hereinafter also referred to as the “Privacy Notice” or just the “Notice”) aims to provide information on the processing of Personal Data of individuals (hereinafter also referred to as “data subjects”, “job applicants”, “you”, “your”) who have voluntarily and on their initiative submitted an application for employment at Amusnet Gaming by using the following electronic address https://amusnet.it/#positions or in any other way that may be used by Amusnet Gaming for recruitment and selection purposes, e.g. through another electronic address, through a job posting platform maintained by a third-party.
1.3. This Privacy Notice applies also to Personal Data provided by applicants for employment at Amusnet Gaming by sending their application in hard copy to the physical address for correspondence with the Company.
1.4. In the capacity of individuals – applicants for employment, whether you are applying for a specific vacancy advertised by Amusnet Gaming or you are submitting your application without the Company having advertised a current vacancy, you have the right to be informed about how and why Amusnet Gaming, as a data controller, collects, processes, stores and protects your Personal Data which you have provided to the Company in connection with your job application.
1.5. The present Notice is published and is freely available on the website of Amusnet Gaming. The Notice may be amended and/or supplemented at any time by Amusnet Gaming, if necessary.
1.6. Please, read the Notice carefully to understand how we process your Personal Data in the context of recruitment and selection and what your rights are in relation to this processing. By submitting your job application electronically and clicking on the button provided for this purpose, you declare and state that you have read the terms of this Privacy Notice. In case you need any additional information or have any questions regarding the processing of your Personal Data in the recruitment and selection process, you may contact Amusnet Gaming at the contacts listed below in the Notice.
1.7. The present Notice does not restrict your rights related to the processing of your Personal Data by Amusnet Gaming in any way. The purpose of this Notice is to provide you with information that shall ensure the transparent and fair processing of your Personal Data by Amusnet Gaming in the recruitment and selection process.
2. What types of information do we collect when you submit your job application to us and why?
2.1. Аmusnet Gaming processes the personal data provided by you in its capacity as a data controller. The Company collects and processes only those categories of Personal Data that have been provided to the Company voluntarily and directly by the applicants, or such Personal Data that were additionally provided by the applicants during the recruitment procedure and/or requested by Amusnet Gaming within the procedure for evaluating your application and the decision-making process on whether recruit you.
2.2. In certain cases, the Personal Data processed by Amusnet Gaming in connection with your application is not collected or received directly from you, but from third parties such as recruitment agencies – e.g. when you apply through such agencies.
2.3. Amusnet Gaming processes the following categories of Personal Data related to your job application, which you have provided voluntarily as part of your application and recruitment process:
- Identification data about you (full name, contact details – address (current and/or permanent address), telephone number, e-mail address), date of birth, photograph (but only if you have voluntarily provided one as part of your job application);
- Information on education and acquired professional qualifications – completed education, acquired professional qualifications, scientific degree; completed educational courses, trainings, seminars, and/or other information related to acquired education and qualifications; knowledge of foreign languages and previous professional experience, as well as other information related to your skills and qualifications;
- Information on current and/or previous employment – details of employment; work experience; posts/positions held; roles and responsibilities performed; current and/or previous employers; length of service/experience; references and references from employer(s) where these have been volunteered by you;
- Information concerning the possession of a driving license or other certificates of acquired competence (where and to the extent that such competence is necessary and required for the performance of the duties included in the scope of the position for which you are applying or when you have voluntarily provided such information);
- Information on remuneration, including expected remuneration for the position you are applying for;
- Information that you have voluntarily provided on your initiative in the process of your job application and that is not included in the above (e.g. information provided through a CV, cover letter, and/or another document that you have provided or has been additionally requested from Amusnet Gaming within the recruitment procedure);
- Information collected and prepared by recruitment agencies and employment intermediaries to whom Amusnet Gaming has assigned recruitment activities, including collecting, reviewing, and evaluating applications, conducting interviews, and preparing reports and recommendations;
- Other information relating to your application that you have provided voluntarily during the recruitment process.
2.4. The information contained in Article 2.3. may vary from one job applicant to another.
2.5. Amusnet Gaming does not process special categories (“sensitive“) of Personal Data as part of the recruitment process. By way of exception, such categories of Personal Data could be processed only and insofar as they are necessary for the assessment of your application in view of the particularities of the specific job position and the decision to appoint you to a specific job/position, as well as for the fulfillment of certain statutory obligations which shall be observed by Amusnet Gaming in its capacity as an employer, or if there is another reason for processing this category of Personal Data, with your explicit consent for their processing.
3. For what purposes does Amusnet Gaming process your Personal Data?
3.1. As a potential employer, within the recruitment and selection procedure, Amusnet Gaming processes your Personal Data only insofar as it is necessary for the Company to conduct the procedure for selection of potential employees, evaluation of your application, taking a decision on your appointment as an employee of the Company, preparation of a proposal for starting work (offer) and/or preparation of a draft employment contract. In particular, Amusnet Gaming processes the Personal Data you provide for the following purposes:
- Administration and management of your job application in Amusnet Gaming, including identification, written and oral communication with job applicants during the selection procedure;
- Carrying out a selection and evaluation of your application and deciding whether to make you an offer of an employment contract;
- Upon approval of your application, for the preparation of a formal job offer, preparation of a draft employment contract, and other documents necessary to complete the process of appointing you to the position for which you are applying;
- In case you have not been offered an employment contract or it has not been accepted, Amusnet Gaming may process the Personal Data of your application for other current or future vacancies, provided that you have given us your explicit written consent that your application can be considered for this purpose.
3.2. Amusnet Gaming may process your Personal Data in the presence of at least one of the following legal grounds, laid down in the General Data Protection Regulation (“GDPR“):
- In the presence of your consent to the processing of your Personal Data;
- To take the necessary actions to enter into a contract (employment contract) if your application is successful and you have accepted our offer of employment with Amusnet Gaming;
- Existence of a legitimate interest of Amusnet Gaming, as our legitimate interest is to assess the compliance of your application with the needs of the Company, the necessary requirements for the position, and to recruit personnel in order to fill our vacancies;
- In order to comply with a legal obligation that applies to us under the GDPR, such as the obligation to respond to your inquiry relating to the protection of your personal data that we process or in order to protect our legitimate interests.
4. When do we delete your Personal Data, provided within the procedure for selection and evaluation of your application?
4.1. Amusnet Gaming will store and process your Personal Data only for the period necessary to achieve the purposes of Personal Data processing set out above. In case your application is refused, your Personal Data will be stored for a period of 6 (six) months from the final decision in order for us to be able to defend our rights and legitimate interests against any potential legal dispute before any competent court and any other public authority.
4.2. For the purpose of occupying other current or future vacancies, it is possible that Amusnet Gaming will store your Personal Data even after the completion of the procedure for occupying the position for which you are specifically applying. In this case, Amusnet Gaming will process your Personal Data only upon your explicit consent, whereby the storage period will be specified in the consent declaration. You can withdraw your consent at any time by notifying Amusnet Gaming.
4.3. In case your application is approved, when concluding an employment contract between you and Amusnet Gaming, the Personal Data provided by you (or part of them, as the case may be) will continue to be processed by Amusnet Gaming and will become part of your employment dossier, which the employer is obliged to compile and maintain. In case you are selected for a relevant position, to conclude the employment contract it may be necessary to provide additional information and documents, in accordance with the requirements of applicable law and the internal rules and procedures of Amusnet Gaming.
4.4. When concluding an employment contract, Amusnet Gaming will provide you with a detailed privacy notice regarding the processing of your Personal Data in your capacity as an employee of the Company.
4.5. In the event that the data subject applies to work via a third-party online platform, he/she should also consider the Data Protection Policy of this online platform, respectively the stipulated deadlines for storing the data therein for which the Company is not responsible.
5. To whom may we disclose your Personal Data provided in the framework of the recruitment procedure?
5.1. As part of the recruitment procedure, the Personal Data which you provided will not be disclosed by Amusnet Gaming to third parties. Your Personal Data will be brought to knowledge (disclosed) only to employees of the relevant departments of Amusnet Gaming, determined according to the specific position you are applying for, to participate in the process of managing and administering your application, who are directly involved in the process of selection, analysis and evaluation of your application for the position.
6. What technical and organizational measures for data protection do we apply?
6.1. In accordance with applicable law, Amusnet Gaming implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.
6.2. In addition, Amusnet Gaming implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.
7. What are Your rights in relation to the protection of your Personal Data?
In order to fulfill the obligations of Amusnet Gaming as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.
7.2. You have certain rights related to the processing of your Personal Data provided in the GDPR, including:
- Right to information and free and open access to your Personal Data, as well as the right to request a copy of your personal data stored or otherwise processed by Amusnet Gaming;
- The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete;
- In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your Personal Data or the restriction of their processing, as well as to exercise your right to the portability of your Personal Data (when applicable);
- Right to object, as well as rights related to automated decision-making – you have the right to object at any time, on grounds relating to your specific situation against the processing of your Personal Data, including in the event that your Personal Data is used for profiling;
- If you have any doubts that your Personal Data is not being processed lawfully by Amusnet Gaming, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Notice, or to seek the protection of your rights judicially.
7.3. Please note that Amusnet Gaming does not use your Personal Data for profiling or automated decision making.
7.4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the GDPR and the respective local data protection legislation. You may exercise your rights by making a written request to Amusnet Gaming on the contact details provided in this Notice in accordance with the requirements of applicable law. If necessary, Amusnet Gaming will provide you with full assistance in exercising the rights granted to you.
7.5. All personal data requests mentioned in Article 7.2. shall be made in writing, signed by the data subject and submitted to [email protected] or the address of the Company detailed in Article 1.1. above.
7.6. The Company will respond to such requests by no later than 30 (thirty) calendar days (with the possibility to extend this period for particularly complex requests in accordance with applicable law), implements them if there are grounds for doing so or makes a reasoned refusal if there are reasons for doing so, indicating the right of the data subject to follow.
8. Failure to provide the information
8.1. You are under no statutory or contractual obligation to provide your personal data to the Company during the recruitment process. However, if you fail to provide us with the information needed to go through the necessary steps prior to entering into a contract with you, we may not be able to process your application properly, in full or in part.
9. Data Protection Officer
9.1. If you wish to receive additional information on how Amusnet Gaming processes your personal data, you can contact the Data Protection Officer at the following e-mail address: [email protected].
9.2. You can also forward any matters or queries relating to the recruitment process to [email protected] or by sending your questions to the registered address of the Company, indicated at the beginning of this Notice.
10. Competent national supervisory authority for Personal Data Protection
Republic of Malta:
Office of the Information and Data Protection Commissioner
Address: Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta
Phone number: +356 2328 7100
E-mail: [email protected]
Website: https://idpc.org.mt/
Italian Republic:
Italian Data Protection Authority (Garante per la protezione dei dati personali)
Address: Piazza Venezia 11 – 00187 Roma (Italy)
Phone number: +39 06.696771
E-mail: [email protected]
Website: https://www.garanteprivacy.it
11. Changes to the present Privacy Notice
11.1. This Data Protection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website.
This Notice is effective as of 01.01.2023.
