Smartsoft Limited
Privacy Policy(Privacy Notice for Website)
INTRODUCTION
This privacy policy (hereinafter “Policy”) applies to Smartsoft Limited (hereinafter “Smartsoft” websites and applications that links to this Policy. The Policy details how we collect, share, and use personal data, and how to exercise your privacy rights. Kindly read this Policy in its entirety to ensure you are fully informed.
Should you have any questions regarding the processing of your personal data, contact our data protection team at privacy@smartsoftgaming.com
Smartsoft respects your privacy and is committed to protecting your personal data and processing it incompliance with applicable laws:
• The Maltese Data Protection Act (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the same – the ‘DPA’;
• The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – the ‘GDPR’;
• Any other data protect ion legislation in the market of operation, as may be applicable.
HOWDO WE COLLECT YOUR PERSONAL DATA?
When using Smartsoft’s websites and social media accounts, Smartsoft collects personal data from you actively and passively.
Personal data is actively collected when you voluntarily provide us with your personal data such as when you are applying for an open job position, building business relationships with us, communicating with us, or subscribing to newsletters(whenever applicable), etc.
Depending on your preferences we may collect information from cookies about you. Please find more information about the use of cookies in our Cookies Policy.
WHAT PERSONAL DATA DO WECOLLECT AND WHY?
The personal data that we process may differ depending on what services, functionalities, or experiences you require and applicable law.
We shall only process your personal data when we have a legal basis for doing so, such as:
a) you have provided your consent.
b) it is necessary to provide services to you under the performance of the contract we have with you.
c) we are required to do so in compliance with legal or regulatory obligations.
d) it is in our legitimate interests to process your personal data, so long as these interests do not prejudice your own rights, freedoms, and interests.
Purpose
Personal Data
Legal Basis
To communicate with you and handle your inquiries, requests, comments, and feedback etc.
First name, Last name, E-mail address, Feedback and comments made by you
Legitimate interests to handle, adequately and in a timely manner, your’ inquiries, complaints, and suggestions regarding the services we provide in our sites.
To provide you with marketing communications and information such as Newsletters etc.
First name, E-mail address, Phone number, Company name, Language settings.
Your freely given consent.
To establish, exercise and defend legal claims.
First name, Last name, E-mail address, Telephone number, Other information as deemed necessary for the purpose.
Legal obligations, legitimate interests to defend ourselves in legal claims.
Participation in social media sharing, including live social media feeds, story sharing, comments, and reviews.
Social networks including your social media profile information, User ID associated with your social media account, and any other information you allow the social network to share with third parties such as ourselves
Legitimate interests to provide you better services and permit you to participate in social sharing.
To detect, prevent, or investigate potential security incidents or fraud.
IP address, Username, transaction and usage data, Other data that is necessary for the purpose
Legal obligations, Legitimate interests to ensure security for our systems and services provided.
To perform analytics, quality control, market research, and determine the effectiveness of our websites, promotional campaigns, and develop new products and services
IP address, Location, Device information, transaction and usage data
Consent and legitimate interests to perform marketing and research activities in order to provide you better service
To comply with our obligations under applicable laws (including gambling legislation, and regulatory and related licensing requirements)
First name, Last name, Company name, IP Address, Username, transaction and usage data, other information as necessary for the purpose.
Necessary to comply with a legal or regulatory obligations
To share your personal data with gambling regulators or other legally required regulators in order to assist and comply with legal requirements and any investigation if applicable
First name, Last name, Username, transaction and usage data, other information as necessary for the purpose.
Necessary for a legal or regulatory obligation
Kindly be aware that the information listed above primarily applies, however, this is not intended to be an exhaustive list. The above may be amended over time due to business operations and in order to comply with specific legal requirements.
YOUR RIGHTS AS A DATA SUBJECT
You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the below.
To exercise your rights, you may contact us as by sending an email to privacy@smartsoftgaming.com
Please be informed that certain rights might not be fulfilled entirely due to legal or regulatory requirements.
• Right to access your personal data
You may request at any time the confirmation whether we process your personal data and you can request to receive a copy of your personal data.
• Right to rectify your personal data
You have the right at any time request to correct your personal data that is inaccurate or incomplete.
• Right to erase your personal data
You have a right to request that we erase your personal data.
• Right to object to certain personal data processing
You have a right to object to the processing of your personal data.
• Right to restrict the processing of personal data
You have a right to ask us to restrict the processing of your personal data.
• Right to withdraw your consent
If you have agreed on data processing based on your consent, you have the right to withdraw your consentat any time.
• Right to transfer your personal data
You have a right to ask us to provide you with the copy of your personal data and if technically possible youcan request to transfer this data to another data controller.
• The right to lodge complaints with the data protection supervisory authority
You have the right to lodge complaints regarding the processing of your personal data to the relevant data protection supervisory authority. The list of national supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en
DISCLOSURE OF YOUR PERSONAL DATA
Your personal data may be shared with other entities within the Smartsoft group and/or contracted third parties for various business purposes to fulfil the services agreed or based on mutually concluded contractual obligations.
Additionally, it may be the case that Smartsoft might transfer personal data to Smartsoft Group entities or external parties located outside the EU/EEA. In such a case Smartsoft will ensure that the Standard Contractual Clauses or other legally required documentations are concluded to ensure an adequate level of protection and security measures are in place before transferring personal data outside EU/EEA.
Please note, that for all personal data transfers an adequate security level is ensured, and all legal requirements are met.
SMARTSOFT GROUP ENTITIES
In order to fulfil the purposes listed above, Smartsoft may need to disclose your personal data to other Smartsoft Group entities.
The data transfer purposes may be:
- To answer various of your requests and questions regarding our provided services;
- To better understand our business practices, services, and products across the Smartsoft Group entities;
- To comply with a legal/regulatory requirement;
- To identify fraud and other criminal activities (based on necessary to comply with a legal/regulatory requirement);
- To provide you services agreed, ensuring the implementation of security measures (based on necessary to comply with a legal/regulatory requirement).
Please note that the above is not an exhaustive list.
DATA PROCESSORS
Smartsoft may disclose personal data to external third parties, such as service providers. Such third parties might also process personal data on behalf of and under the instructions of Smartsoft.
Smartsoft engages with data processors (incl. sub-processors) in order to deliver you the agreed services and to comply with legal and regulatory requirements. The data processors might vary from such as cloud services for data storage purposes, marketing companies in preparing and delivering marketing related materials, to external advisors and auditors.
SECURITY MEASURES
We ensure that all necessary appropriate security measures are in place to process your personal data securely. In support of this obligation, we have implemented appropriate technical, physical, and organizational measures to protect your personal data against unauthorized or accidental destruction, alteration or disclosure, misuse, damage, theft or accidental loss, or unauthorized access.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will retain your personal data for as long as reasonably necessary for the purposes listed in this Policy. In some circumstances, we keep your personal data for a certain period to meet legal requirements.
We maintain a data retention policy for personal data in our care. Where your personal data is no longer required, we will ensure it is either securely deleted or made anonymous.
CONTACTINFORMATION
Smartsoft Limited
Address: Level 3 (Suite 2746), Tower Business Centre, Tower Street, Swatar, Birkirkara, BKR4013, Malta
Email: privacy@smartsoftgaming.com