Vie privée

CIRCUS® BELGIUM is concerned about the protection of personal data. This is why we make every effort to protect the privacy of all visitors and users (hereinafter the "Users") of the Circus Poker site (hereinafter the "Site").

Users will find below all the provisions relating to the processing of personal data applicable to all visits to or use of the Site by Users (hereinafter the "Privacy Policy").

With regard to the processing of personal data within our facilities, please refer to:

Plan

1. General

CIRCUS® BELGIUM processes the personal data of Site Users, for the purposes and within the limits of the Privacy Policy, when they visit or use the Site.

CIRCUS® BELGIUM takes care to comply, when processing such personal data, with the laws and regulations in force and, in particular, with European Regulation (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data (hereinafter "the Regulation").

In this respect, and in accordance with the said Regulations, CIRCUS® BELGIUM:

  • Is legally bound to process Users' personal data. This processing is described in article 2.1 of the Privacy Policy;
  • Further processes personal data for the purposes of enabling Users to use the Site and, in addition, for the necessary and legitimate purposes described in article 2.2 of the Privacy Policy;
  • Processes, with the prior, free and explicit consent of Users, the personal data described in- and according to the purposes set out in article 3.

By accessing and using the Site, Users are deemed to have read and accepted the Privacy Policy. They also guarantee that the data and information communicated to CIRCUS®BELGIUM are accurate.

2. Processing of personal data not requiring Users' consent

2.1 CIRCUS® BELGIUM's legal obligations and the processing necessary for use of the Site

CIRCUS® BELGIUM is required, by virtue of the legal and regulatory obligations to which all online gaming and betting operators are subject, on the one hand, and for the purposes of authenticating and enabling Users to use the Site, on the other hand, to process the following personal data for the purposes described below. This processing of personal data by CIRCUS®BELGIUM does not require the consent of Users pursuant to Article 6.1.b) and c) of the Regulation.

The personal data communicated by the User is recorded in a register, as described in article 7.1, which is controlled and remains under the responsibility of CIRCUS® BELGIUM at all times.

a. What data is processed?

The following personal data are processed:

  • Surname, first name(s), date of birth, language, home/postal address, National Register (or ID card or passport) number, email address, landline or mobile telephone number;
  • Bank details used to purchase tickets for tournaments on the Site and other services offered through the Site;
  • The User's browsing and activity history on the Site, including transaction and connection data (browser data, IP address), in particular by means of cookies, the use of which is described here;

b. What treatment does CIRCUS® BELGIUM provide?

The processing consists of the collection, recording, storage, consultation, organization, use, reconciliation or any other operations made necessary or useful by virtue of the legal and regulatory provisions described in article 2.1.c). Processing may also involve the transfer of personal data:

  • To the judicial and administrative authorities, within the framework of their missions;
  • CIRCUS ®BELGIUM's suppliers, whose services are inseparable from the use of the Site and whose list is available on request from the Contact referred to in article 7.5;

c. What are the purposes of this processing?

1°) CIRCUS® BELGIUM is required to process the personal data described in Article 2.1.a) and b) in order to meet the legal and regulatory obligations to which it is bound under, in particular, the Law of September 18, 2017 on the prevention of money laundering and terrorist financing and the restriction of the use of cash.

2°) CIRCUS® BELGIUM also processes the personal data referred to in article 2.1.a) for the purposes of authenticating Users and enabling them to access and use the Site; this processing is therefore carried out in order to ensure:

  • Registration, by the User or the participant on whose behalf the User uses the Site, for tournaments and other services offered by CIRCUS® BELGIUM partners;
  • The User is informed of the services offered by CIRCUS® BELGIUM ;
  • Customer service management by CIRCUS®BELGIUM's tournament partners.

2.2 Other processing operations not requiring Users' consent

CIRCUS® BELGIUM also processes the following personal data for the legitimate purposes described below. This processing of personal data by CIRCUS®BELGIUM does not require the consent of Users pursuant to Article 6.1.f) of the Regulation.

The personal data communicated by the User is recorded in a register, as described in article 7.1, which is controlled and remains under the responsibility of CIRCUS® BELGIUM at all times.

a. What data is processed?

The following personal data are processed:

  • Surname, first name(s), date of birth, language, gender, home/postal address, language, national register number, email address, landline or mobile telephone number;
  • The User's browsing and activity history on the Site, including transaction and connection data (browser data, IP address), in particular by means of cookies;

b. What treatment does CIRCUS® BELGIUM provide?

The processing consists of collecting, recording, storing, consulting, organizing, using and reconciling the personal data described in article 2.2.a). It also involves the transfer of such personal data to third parties, a list of whom is available on request from the Contact referred to in article 7.5.

c. What are the legitimate purposes of the processing?

CIRCUS®BELGIUM processes the personal data referred to in article 2.2.a) for the following legitimate purposes:

  • Promotion, advertising and marketing relating to the offer of participation in the tournaments organized by CIRCUS®BELGIUM and its partners, including the sending of SMS, telephone calls, paper or electronic newsletters;
  • Carrying out satisfaction surveys, statistical studies, trend analyses and market studies, for the purpose of improving online gaming and betting services or informing Users or protecting Users and preventing gambling addiction.

3. Processing of personal data with the consent of Users

By using the CIRCUS® BELGIUM Site, for whatever reason, the User expresses their free, specific, informed and unequivocal will to expressly authorize CIRCUS® BELGIUM to process personal data in accordance with the Regulation, within the limits and for the purposes defined below and without prejudice to the processing referred to in Article 2.

The personal data communicated by the User is recorded in a register, as described in article 7.1, which is controlled and remains under the responsibility of CIRCUS® BELGIUM at all times.

The User also benefits from rights, including the right to withdraw consent at any time, in accordance with the terms set out in article 3.4.

3.1 Nature of personal data processed

CIRCUS® BELGIUM processes the following data:

  • Surname, first name(s), date of birth, language, gender, home/postal address, National Register (or ID card or passport) number, email address, landline or mobile telephone number;
  • The User's browsing and activity history on the Site, including transactions and connection data (browser data, IP address), in particular by means of cookies;

The personal data communicated by the User is recorded in a register, as described in article 7.1, which is controlled and remains under the responsibility of CIRCUS® BELGIUM at all times.

3.2. Processing

The processing involves the collection, recording, storage, consultation, organization, use and reconciliation of the personal data described in article 3.1. It also involves the transfer of such personal data to third parties, a list of whom is available on request from the Contact referred to in article 7.5.

3.3. Purposes of processing personal data

Personal data are collected and processed by CIRCUS® BELGIUM for the following purposes:

  • Promotion, advertising and marketing, including affiliation and management of loyalty programs, relating to the offer of online or offline gaming and betting services, including the sending of SMS, telephone calls, paper or electronic newsletters, not falling within the scope of article 2.2.c), such as the online or offline casino, gaming and betting activities of CIRCUS®BELGIUM and its partners, including advertising, marketing and the management of affiliation and related loyalty programs;
  • The offer of participation in competitions and promotional offers, including communication relating to winners;
  • The development of new products and services, such as games and betting offers;
  • Carrying out satisfaction surveys, statistical studies, trend analyses and market research, for management, marketing and reporting purposes, including profiling, not falling within the scope of the purpose described in article 2.2.c).

4. User rights

Without prejudice to articles 2 and 5, Users are entitled to exercise a right of rectification, opposition and limitation, according to the following terms and within the following limits.

4.1. Right of access

a. CIRCUS® BELGIUM provides Users with all the following information:

  • The identity and contact details of the data controller;
  • Contact details for the Data Protection Officer;
  • Personal data processed;
  • The purposes for which personal data are processed and the legal basis for the processing;
  • The recipients or categories of recipients of personal data, where applicable;
  • And, where applicable, the fact that the data controller intends to transfer personal data to a country outside the European Union and: either the existence (or absence) of an adequacy decision issued by the European Commission, or, in the absence of such a decision, the guarantees offered by the third country and the means implemented to obtain a copy of the personal data;
  • The possibility of objecting to automated processing of their data, such as profiling, unless there are valid grounds for CIRCUS® BELGIUM to do so, as well as the possibility of objecting to any processing of their personal data for canvassing purposes.

b. Users have the right to request, at any time, access to all the information set out in this article and in article 3.1, by contacting the Contact referred to in article 7.5. CIRCUS® BELGIUM will respond to such requests for information within one month.

c. Users are entitled to obtain a copy of the personal data being processed. CIRCUS® BELGIUM reserves the right to demand payment of any costs incurred by this request; these costs will be calculated on the basis of the administrative costs incurred by the request; they will not exceed 20 euros.

d. Users are entitled to obtain such access or copy in a structured format, in such a way that the personal data is provided to them in a format that complies with the technical standards in force at the time of the request for access; this format will therefore allow it to be read by machine.

4.2. Right of rectification

CIRCUS® BELGIUM guarantees and obliges Users to update and rectify any personal data concerning them, should such data be erroneous or incomplete.

This right of rectification may be exercised on request to the Contact referred to in article 7.5.

4.3. Right to object

CIRCUS® BELGIUM authorizes Users to object to the processing of all or part of their personal data on the following grounds:

  • Their data is inaccurate;
  • The processing is no longer necessary for the purposes for which the data were collected;
  • The User withdraws their consent;
  • The data has been processed unlawfully.

CIRCUS® BELGIUM also authorizes Users to object:

  • To automated processing of their data, such as profiling, unless there are legitimate grounds for CIRCUS® BELGIUM to do so;
  • Any processing of their personal data for canvassing purposes, including profiling, if linked to such canvassing.

This right of objection may be exercised on request to the Contact referred to in article 7.5.

4.4. Right to be forgotten

CIRCUS®BELGIUM also undertakes to comply with any request for the deletion of personal data as quickly as possible (right to be forgotten), when:

  • The processing is no longer necessary for the purposes for which the data were collected;
  • The User withdraws their consent;
  • The data has been processed unlawfully or must be deleted to comply with a legal obligation.
  • The User objects to the automated processing of their data, such as profiling, and that there are no legitimate grounds for CIRCUS® BELGIUM to process their data;
  • The User objects to the processing of their personal data for canvassing purposes, including profiling, if it is related to such canvassing.

4.5. Right of limitation

Users also have the right to obtain from CIRCUS®BELGIUM the limitation of the processing of their personal data when:

  • The User considers that their personal data is inaccurate, for the time necessary for CIRCUS®BELGIUM to verify its accuracy;
  • The processing is unlawful, but the User does not want the data to be deleted, but requires the processing to be restricted;
  • The User objects to automated processing, including profiling, or to the processing of their personal data for canvassing purposes and that it is necessary to verify the legitimate nature of the reasons for which CIRCUS@BELGIUM intends to maintain such processing;
  • CIRCUS®BELGIUM no longer requires the processed personal data, but the data subject wishes them to be retained for the establishment, exercise or defense of legal claims;

This right of limitation may be exercised on request to the Contact referred to in article 7.5.

4.6. Transfer of data to a data controller

Users are entitled to transfer their personal data to another data controller without CIRCUS® BELGIUM being able to prevent this.

Insofar as such a transfer is technically possible, Users are authorized to request CIRCUS®BELGIUM to have this transfer carried out directly by its data controller.

4.7. Terms and conditions

The rights granted by CIRCUS® BELGIUM to the User must be exercised according to the methods defined in article 7.5.

4.8. Notification

CIRCUS® BELGIUM will provide the User with notification of any deletion or rectification of data carried out in accordance with articles 4.2 and 4.4, unless such notification proves impossible or imposes disproportionate efforts.

This notification will be sent by email or post, based on the contact details provided by the User.

5. Location, storage and retention period of personal data

5.1. CIRCUS® BELGIUM stores Users' personal data in a form that allows them to be identified and available, using appropriate and secure means.

Data is stored and hosted in Belgium at Data Centers, which offer all the necessary and useful security guarantees in line with current technical standards.

5.2. Users' personal data is kept by CIRCUS®BELGIUM for the purposes defined in articles 2 and 3. They are kept for a period of 10 years for all the purposes governed by article 2.a); CIRCUS®BELGIUM therefore reserves the right to keep Users' personal data for any purposes that may be imposed on it by the Law, as a result of its online gaming and betting activities.

Personal data is kept for a period not exceeding that necessary to achieve the purpose of the processing for all purposes governed by article 2.2 and 3. Data is then deleted from CIRCUS® BELGIUM files at the request of Users addressed to the Contact referred to in article 7.5.

6. Responsibility of CIRCUS® BELGIUM - Subcontractor

6.1. CIRCUS® BELGIUM undertakes that the processing of Users' personal data will be carried out lawfully, fairly, and transparently with respect to the User concerned. Any processing by CIRCUS®BELGIUM will comply with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and with this Privacy Policy.

CIRCUS® BELGIUM implements all reasonable and appropriate means to ensure the confidentiality, integrity and availability of the personal data it processes. These technical and organizational measures are described in the register, access to which is available from the Contact referred to in article 7.5.

Technical measures include the anonymization and encryption of personal data, depending on the required purpose.

Organizational measures include internal audits, in addition to those to which CIRCUS®BELGIUM may be subject by the Gaming Commission.

If necessary, CIRCUS® BELGIUM, with the help of the Data Protection Officer, carries out an impact analysis when processing is likely to result in a high risk for Users.

6.2. Users' personal data is not transmitted to third parties other than CIRCUS® BELGIUM's suppliers and partners, except for the purposes described in articles 2.1, 2.2 and 3 and, consequently, if :

  • The transfer is made compulsory by law, regulation or injunction by an administrative or judicial authority;
  • The transfer is necessary for the provision of online gaming and betting services, or for maintenance services;
  • The User has consented to such transfer.

The partner will not be considered a subcontractor within the meaning of the Regulation, unless it processes the User's personal data on behalf of CIRCUS® BELGIUM. CIRCUS®BELGIUM declines all responsibility for the processing of the User's personal data by the partner who provides its own services in its own name and for its own account or if it proves that the fact which caused the damage is in no way attributable to it.

In the event that CIRCUS®BELGIUM acts as a subcontractor for the partner, it is agreed that CIRCUS®BELGIUM will only be held liable for damage caused by the processing of personal data contrary to the Regulation or to this Privacy Policy if it has not complied with the obligations provided for in the Regulation that are specifically incumbent on subcontractors or if it has acted outside of or contrary to the lawful instructions of the partner. Similarly, CIRCUS®BELGIUM cannot be held liable if it proves that it is not responsible for the event that caused the damage.

6.3. CIRCUS® BELGIUM ensures that, when processing is carried out by a subcontractor on behalf of CIRCUS®BELGIUM, the latter presents sufficient guarantees as to the implementation of appropriate technical and organizational measures and, more generally, compliance with the requirements of the Regulation. In particular, CIRCUS®BELGIUM requires the processor to comply with the Regulation, and to keep a register of its data.

6.4. CIRCUS® BELGIUM undertakes that in the event of a security problem relating to the data processed, likely to affect its confidentiality, CIRCUS®BELGIUM will notify the incident to the data protection authority referred to in article 7.4 as soon as possible.

CIRCUS® BELGIUM will also inform the Users concerned, insofar as the violation of personal data presents a high risk for the rights and freedoms of the User; this information will be sent by email or post to the contact details provided by the User.

7. Miscellaneous

7.1. Personal Data Register and Information Security Manual

As a personal data controller, CIRCUS® BELGIUM keeps a register of all its processing activities. This contains all information relating to the type of data processed, the persons concerned by the data processing, any recipients to whom the data may be communicated, the purposes for which the data is processed, how long the data is kept and a general description of the technical and organizational security measures in place.

The personal data communicated by the User is recorded, together with the processing operations and their purposes, in a register, which is controlled and remains under the responsibility of CIRCUS® BELGIUM at all times. In addition to the above-mentioned information, this register includes:

  • A description of the purposes of the processing;
  • A description of the categories of data subjects and the categories of personal data;
  • The categories of recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations;
  • Deletion deadlines for different categories of data;
  • A general description of technical security measures.

7.2 Completeness - modification of the Privacy Policy

The Privacy Policy contains all the contractual provisions applicable to Users, without prejudice to the general provisions contained in the Site Terms of Use, of which it forms an integral part. The Site's Terms of Use therefore remain applicable to all matters that do not concern the protection of personal data.

CIRCUS® BELGIUM also reserves the right to modify the Privacy Policy. Any update is enforceable against Users as soon as it is published on the Site. CIRCUS®BELGIUM will mention the date of publication of the current Privacy Policy on the Site.

7.3. Evidential value

The Useracknowledges that the electronic documents exchanged and the electronic data collected as part of their registration or use of the Site have the same evidential value as if these documents and data had been communicated or collected on paper. They therefore undertake not to contest their force or evidential value by virtue of their electronic medium.

7.4. Data protection authority

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the Act of 8 December 1992, the User is entitled to request further information or lodge a complaint with the Data Protection Authority. The Supervisory Authority is the Commission for the Protection of Privacy; its contact details are :

  • Address: Rue de la Presse, 35, 1000 Brussels
  • Telephone: +32 (0)2 274 48 00
  • Fax: +32 (0)2 274 48 35
  • Email: contact@apd-gba.be

7.5. Contact - Information on the identity of the data controller and data protection officer

CIRCUS®BELGIUM can be contacted for any questions relating to the protection of Users' personal data, as follows:

The data controller is CIRCUS® BELGIUM.

CIRCUS® BELGIUM has also appointed a Data Protection Officer within the meaning of Article 37 of the aforementioned Regulation, who can be contacted by email: dpo@circus.be. The delegate is responsible for monitoring and ensuring the compliance of CIRCUS® BELGIUM's processing of Users' personal data.