Privacy Policy

1. Introduction

SoftGame Soluspil operates the website https://softgamesoluspil.org and provides iGaming platform software and related services. We are the data controller responsible for your personal data under Article 4(7) of the Regulation (EU) 2016/679 (GDPR).

For any questions regarding this Privacy Policy, please contact us at legal@softgamesoluspil.org

Third Party Links

Our website may contain links to third party websites and applications. Clicking these links may allow third parties to collect data about you. We do not control third party websites and are not responsible for their privacy practices. Please review the privacy policy of any third party website you visit.

2. Types of Collected Data

Personal data means any information relating to an identified or identifiable person. We may collect, use, store, and transfer the following categories of personal data:

• Identification Data: First name, last name, company name, and job title when provided through contact forms or inquiries.
• Contact & Communications Data: Email address, phone number, preferred messenger (Telegram, WhatsApp), and message content submitted through our website.
• Technical Data: IP address, browser type and version, time zone and location, operating system, device type, and other technology used to access our website.
• Website Usage Data: Information about how you navigate and interact with our website, including pages visited, time spent, and referral sources.

Aggregated Data

We may collect and use aggregated data such as statistical or demographic information for analysis purposes. Aggregated data is derived from your personal data but does not directly or indirectly reveal your identity under GDPR, as it is anonymized.

Special Categories of Data

We do not collect any special categories of personal data under Article 9(1) of GDPR (such as health data, racial or ethnic origin, religious beliefs) or data related to criminal convictions and offenses.

Processing of Minors' Data

Our website is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If you believe your child has provided us with personal information, please contact us immediately so we can take appropriate action.

3. How We Collect Data

We collect personal data through various methods:

Direct Interactions

You provide identification and contact data when you complete contact forms, request information about our services, or communicate with our team through website chat or email. This information is collected through voluntary submission.

Legal Basis: Your consent (Article 6(1)(a) GDPR)

Automated Technologies

We automatically collect technical and usage data as you navigate our website through cookies and similar tracking technologies. This includes information about your device, browsing patterns, and website interaction.

Legal Basis: Legitimate interests in monitoring and improving our website (Article 6(1)(f) GDPR)

Third Party Sources

We may collect data using services from third parties such as analytics providers (Google Analytics for website traffic analysis) or publicly available sources to verify information accuracy and prevent fraud.

Legal Basis: Legitimate interests in protecting our legal rights and preventing fraud (Article 6(1)(f) GDPR)

Cookies

Cookies are small text files automatically sent to your device when accessing our website. For detailed information about our cookie usage, please review our Cookie Policy.

Legal Basis: Your consent (Article 6(1)(a) GDPR)

4. How We Use Your Data

We only use your personal data when the law allows. Generally, we process your data in the following situations:

• To respond to your inquiries: When you contact us through forms or chat, we use your information to provide appropriate responses (Article 6(1)(a) GDPR - Consent).
• To negotiate and execute contracts: When necessary to discuss business proposals, sign agreements, or provide services you've requested (Article 6(1)(b) GDPR - Contract Performance).
• For legitimate business interests: To improve our website, analyze user behavior, enhance services, and conduct marketing activities, provided your rights do not override these interests (Article 6(1)(f) GDPR - Legitimate Interests).
• To comply with legal obligations: When required by law, regulation, or legal process (Article 6(1)(c) GDPR - Legal Obligation).

Legitimate Interest Purposes

We may process personal data based on legitimate interests for:

• Website administration, development, and service improvement
• Statistical analysis and research for service optimization
• Personalization of user experience and content
• Marketing and communication about our services
• Prevention of fraud and protection of legal rights

5. Data Processing Principles

We adhere to the fundamental data processing principles established by Article 5 of GDPR:

• Lawfulness, Fairness & Transparency: We process your data lawfully, fairly, and in a transparent manner. We provide clear information about how we use your data.
• Purpose Limitation: We collect data only for legitimate, specified, and explicit purposes outlined in this policy. We do not process data in ways incompatible with these purposes.
• Data Minimization: We collect only the personal data necessary for the purposes stated. We do not collect excessive or irrelevant information.
• Accuracy: We take reasonable steps to ensure personal data is accurate and kept up to date. We correct or erase inaccurate data promptly.
• Storage Limitation: We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law.
• Integrity & Confidentiality: We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, loss, or destruction.

6. Data Sharing and Disclosure

We may share your personal data in the following circumstances:

Legal Compliance

We may disclose personal data to courts, governmental authorities, law enforcement, or authorized third parties when required by law or legal obligation, including:

• Compliance with applicable laws and regulations
• Response to legal requests and authority demands
• Prevention of harm, fraud, or illegal activity
• Protection of our legal rights and those of third parties

Service Providers

We engage third party service providers to support our operations, including hosting providers, analytics services, payment processors, and communication platforms. These providers may be located inside or outside the EU/EEA. Service providers have limited access to personal data necessary to perform their functions and are contractually bound to maintain the same level of data protection as outlined in this policy.

Business Partners

We may share personal data with affiliated companies within our corporate group or with authorized business partners and resellers as reasonably necessary for business purposes outlined in this policy.

Aggregated Data

We may share aggregated or anonymized data that does not identify individuals for business analysis, research, marketing, and other legitimate purposes.

7. Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data and information about how we process it.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data when it is no longer necessary or when you withdraw consent.
• Right to Restriction: Request limitation of processing your personal data in certain circumstances.
• Right to Data Portability: Receive your personal data in a structured, machine-readable format for transfer to another controller.
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Withdraw previously given consent at any time without affecting prior processing.

Exercising Your Rights

To exercise any of these rights, please contact us at legal@softgamesoluspil.org. We may request identity verification before processing your request to ensure data security.

We will respond to requests within one month of receipt. This period may be extended by up to three additional months for complex requests or high volumes. If we cannot fulfill your request, we will provide appropriate justification for the refusal.

8. Data Retention and Deletion

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Retention periods depend on:

• The nature and sensitivity of the personal data
• The purposes for which we process the data
• Applicable legal or regulatory requirements
• Potential risks from unauthorized use or disclosure

When personal data is no longer needed, we securely delete or anonymize it. You may request deletion of your data, subject to legal exceptions where processing remains necessary for legal obligations or defense of legal claims.

9. International Data Transfers

We may transfer, store, and process your personal data outside the European Union and European Economic Area (EU/EEA) with affiliated companies or service providers located in other jurisdictions.

When transferring data internationally, we implement appropriate safeguards to ensure your personal data receives adequate protection equivalent to EU/EEA standards. These safeguards may include Standard Contractual Clauses approved by the European Commission or other legally recognized transfer mechanisms.

10. Security Measures

We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, accidental loss, destruction, or damage. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and updates
• Employee training on data protection
• Secure data backup and recovery procedures

While we strive to protect your personal data, no method of transmission or storage is completely secure. We cannot guarantee absolute security but continuously work to maintain and improve our security practices.

11. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or business operations. We will post the updated policy on our website with a revised "Last Updated" date.

For significant changes that materially affect your rights, we will provide additional notice through email or prominent website notification. We encourage you to review this policy regularly to stay informed about how we protect your personal data.