Privacy policy

CIRCUS® BELGIUM is concerned about the protection of personal data. This is why we do everything we can to protect the privacy of the visitors and users (hereinafter the “Users”) of the Circus Poker website (hereinafter the “Website”).

Users will find below all the provisions related to the processing of personal data, which are applicable to all visits and uses of the Website by Users (hereinafter the “Privacy Policy”).

Regarding the processing of personal data within the establishments, please refer to:

• Gambling Management SA's Privacy Policy for Casino Resort Namur.

CONTENTS

• 1. General information
• 2. Personal data processing that does not require User consent
  • 2.1. CIRCUS BELGIUM S.A.’s legal obligations and processing required for use of the Website
  • 2.2. Other processing not requiring Users’ consent
• 3. Processing of personal data subject to Users' consent
  • 3.1. Nature of the personal data processed
  • 3.2. The processing
  • 3.3. Purposes of personal data processing
• 4. Users’ rights
  • 4.1. Right of access
  • 4.2. Right to rectification
  • 4.3. Right to opposition
  • 4.4. Right to be forgotten
  • 4.5. Right to restriction
  • 4.6. Data transfer to a data controller
  • 4.7. Terms and conditions
  • 4.8. Notification
• 5. Location, storage and duration of storage of personal data
• 6. Responsibility of CIRCUS® BELGIUM - Subcontractor
• 7. Other provisions
  • 7.1. Personal Data Register and Information Security Manual
  • 7.2. Entirety - modification of the Privacy Policy
  • 7.3. Probative value
  • 7.4. Data protection authority
  • 7.5. Contact — Information relating to the identity of the data controller and the data protection officer

1. General information

For the purposes and within the limits of the Privacy Policy, CIRCUS® BELGIUM processes the personal data of the Website’s Users during all visits to and uses of the Website.

CIRCUS® BELGIUM ensures to comply, during the processing of this personal data, with the laws and regulations in force and, notably, to the European Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter "the Regulation").

Regarding this, and conforming to the aforementioned Regulation, CIRCUS® BELGIUM:

• is legally obliged to process the personal data of Users. This processing is outlined in Section 2.1 of the Privacy Policy;
• shall process personal data for the purposes of allowing Users to use the Website, as well as for the necessary and legitimate purposes outlined in Section 2.2 of the Privacy Policy;
• shall process the personal data described in Section 3, in accordance with the purposes defined therein, subject to the User’s prior, freely given and explicit consent.

By accessing and using the Website, Users are deemed to have read and accepted the Privacy Policy. Furthermore, they guarantee that the data and information communicated to CIRCUS® BELGIUM is correct.

2. Personal data processing that does not require User consent

2.1 CIRCUS® BELGIUM’s legal obligations and processing required for use of the Website

CIRCUS® BELGIUM is bound, under the legal obligations and regulations that all online gaming and betting operators are subject to, on the one hand, and for the purposes of authenticating and allowing Users to use the Website, on the other hand, to process the following personal data for the purposes outlined below. This processing of personal data carried out by CIRCUS® BELGIUM does not require Users' consent under article 6.1.b) and c) of the Regulation.

The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by CIRCUS® BELGIUM and remains under its responsibility at all times.

1. What data is processed?

The following personal data is processed:

• First name(s) and surname, date of birth, language, home/postal address, National Registration Number (or identity card or passport number), email address, home or mobile phone number;
• Bank details used when purchasing tournament participation tickets on the Website and other services offered through the Website;
• The User's navigation and activity history on the Website, including transaction and connection data (browser data, IP address), notably by using cookies for which the use policy is available here.

1. What processing is carried out by CIRCUS® BELGIUM?

Processing consists of collection, recording, storage, viewing, organization, use, reconciliation or any other necessary or useful action in accordance with the statutory and regulatory provisions referred to in Section 2.1.c) below. Processing may also involve the forwarding of personal data:

• To the judicial and administrative authorities, as part of their missions;
• to suppliers of CIRCUS® BELGIUM, whose services are inseparable from the use of the Website. A list of these suppliers may be obtained upon request by writing to one of the contact addresses provided in Section 7.5 below.

1. What are the purposes of this processing?

1°) CIRCUS® BELGIUM is obliged to carry out the processing of the personal data described in article 2.1.a) and b) to fulfill the legal and regulatory obligations that they are under, notably, the Act of 18 September 2017 on the prevention of money laundering and terrorist financing and on 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 to allow them to access and use the Website; this processing is carried out to ensure:

• Registration of the User or the participant on whose behalf the User uses the Website, for tournaments and other services offered by CIRCUS® BELGIUM’s partners;
• The User’s information related to the services offered by CIRCUS® BELGIUM;
• Management of customer service by CIRCUS® BELGIUM’s partners organizing tournaments.

2.2 Other processing not requiring User consent

CIRCUS® BELGIUM also processes personal data for the legitimate purposes outlined below. This processing of personal data carried out by CIRCUS® BELGIUM does not require Users' consent under article 6.1.f) of the Regulation.

The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by CIRCUS® BELGIUM and remains under its responsibility at all times.

1. What data is processed?

The following personal data is processed:

• First name(s) and surname, date of birth, language, sex, home/postal address, national registration number, email address, home or mobile phone number;
• The User's navigation and activity history on the Website, including transaction and connection data (browser data, IP address), notably by using cookies.

1. What processing is carried out by CIRCUS® BELGIUM?

Processing consists of the collection, recording, storage, viewing, organization, use and reconciliation of the personal data outlined in Section 2.2.a). It also consists of forwarding this personal data to third parties, a list of whom may be obtained upon request by writing to one of the contact addresses provided in Section 7.5 below.

1. What are the legitimate purposes of this 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 tournaments organized by CIRCUS® BELGIUM and its partners, including sending SMS, making telephone calls, and sending paper or electronic newsletters;
• Execution of satisfaction surveys, statistical studies, trend analysis and market studies, for the purpose of improving online gaming and betting services or User information or the protection of Users and prevention of gaming dependency.

3. Processing of personal data subject to Users' consent

By using the CIRCUS® BELGIUM Website, 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 saved on a register, as laid out in Section 7.1 below, which is controlled by CIRCUS® BELGIUM and remains under its responsibility at all times.

The User also benefits from rights, including the right to withdraw their consent at any time, according to the terms and conditions defined in article 3.4.

3.1. Nature of the personal data processed

CIRCUS® BELGIUM processes the following data:

• first name(s) and surname, date of birth, language, sex, home/postal address, National Registration Number (or identity card or passport number), email address, home or mobile phone number;
• The User's navigation and activity history on the Website, including transactions and connection data (browser data, IP address), notably by using cookies.

The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by CIRCUS® BELGIUM and remains under its responsibility at all times.

3.2. Data processing

Processing consists of the collection, recording, storage, viewing, organization, use and reconciliation of the personal data referred to in Section 3.1. It also consists of forwarding this personal data to third parties, a list of whom may be obtained upon request by writing to one of the contact addresses provided in Section 7.5 below.

3.3. Purposes of personal data processing

The personal data is collected and processed by CIRCUS® BELGIUM for the following purposes:

• Promotion, advertising and marketing, including affiliation and loyalty program management, relating to the offer of online or offline gaming services and betting, including text messages, telephone calls, paper or electronic newsletters, not part of article 2.2.c), such as the online or offline casino, game of chance and betting activity of CIRCUS®BELGIUM and its partners, including advertising, marketing and affiliation and loyalty program management related to it;
• The offer of participation in competitions and promotional offers, including communications about winners;
• The development of new products and services, such as games and bets;
• The execution of satisfaction surveys, statistical studies, trend analyses and market studies for the purposes of management, marketing and reporting, including profiling, which do not fall under the purposes set out in Section 2.2.c).

4. Users’ rights

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

4.1. Right of access

1. CIRCUS® BELGIUM makes the following information available to Users:

• The identity and contact details of the data controller;
• The contact details of the Data Protection Officer (DPO);
• The personal data processed;
• The purposes of the personal data processing and the legal basis for such processing;
• The recipients or categories of recipients of personal data, if applicable;
• Where applicable, the data controller’s intention to transfer the personal data to a country located outside the European Union and either (i) the existence (or absence) of an adequacy decision adopted by the European Commission or, (ii) in the absence of such a decision, the guarantees offered by the third country in question and the measures implemented to obtain a copy of the personal data;
• The possibility to oppose the automated processing of their data, such as profiling, unless valid reasons exist rendering said processing by CIRCUS® BELGIUM necessary, as well as the possibility to oppose all processing of their personal data for direct marketing purposes.

3. Users may request access to all the information mentioned in this section and in Section 3.1 at any time by writing to one of the contact addresses provided in Section 7.5 below. CIRCUS® BELGIUM shall respond to these information requests within one month.
4. Users have the right to obtain a copy of their personal data which is processed. CIRCUS® BELGIUM reserves the right to demand payment for the potential costs induced by this request; these costs will be calculated on the basis of administrative costs induced by the request; they will not exceed 20 euros.
5. Users shall have the right to be granted said access or obtain said copy of the personal data, in a structured format and in such a way that the personal data is provided in a format that complies with technical standards in force when the request for access is submitted; this format must allow the data to be machine-readable.

4.2. Right to rectification

CIRCUS® BELGIUM guarantees and obliges the Users to update and rectify the personal data concerning them, as soon as this data is incorrect or incomplete.

This right to rectification may be exercised by sending a request to one of the contact addresses provided in Section 7.5 below.

4.3. Right to opposition

CIRCUS® BELGIUM authorizes Users to oppose the processing of all or part of personal data concerning them, for the following reasons:

• The data is inaccurate;
• The processing is no longer required for the purposes for which the data was collected;
• The User withdraws their consent;
• The data has been subject to illegal processing.

CIRCUS® BELGIUM also authorizes Users to oppose to:

• Automated processing of their data, such as profiling, unless proper reasons make this treatment by CIRCUS® BELGIUM necessary;
• any processing of their personal data for direct marketing purposes, including profiling, if it is linked to such direct marketing.

This right to opposition can be exercised by request to the Contact referred to in article 7.5.

4.4. Right to be forgotten

CIRCUS® BELGIUM also ensures to respond to any request for deletion of personal data in the shortest possible period (right to be forgotten), when:

• The processing is no longer required for the purposes for which the data was collected;
• The User withdraws their consent;
• the data has been subject to illegal processing, or must be deleted due to a legal obligation;
• The User opposes the automated processing of their data, such as profiling, and there are no proper reasons making this processing by CIRCUS® BELGIUM necessary;
• the User opposes the processing of their personal data for direct marketing purposes, including profiling, if it is linked to said direct marketing.

4.5. Right to restriction

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

• The User considers their personal data to be incorrect, for the time necessary for CIRCUS® BELGIUM to verify the accuracy of it;
• The processing is illegal but the User does not wish for their data to be deleted but requests a restriction of the data processing;
• the User opposes automated processing, including profiling or the processing of their personal data for direct marketing purposes, and it is necessary to verify the legitimacy of the reasons for which Gambling Management S.A. intends to carry out this processing;
• CIRCUS® BELGIUM no longer needs the personal data processed but the person concerned wants them to be saved for the observation, exercise or defense of rights in court.

This right to restriction can be exercised by request to the Contact referred to in Section 7.5.

4.6. Data transfer to a data controller

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

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

4.7. Terms and conditions

The rights granted by CIRCUS® BELGIUM to the User must be exercised in accordance with the terms and conditions defined in article 7.5.

4.8. Notification

CIRCUS® BELGIUM will provide the User with a notification of any deletion or rectification of data carried out conforming to articles 4.2 and 4.4, unless such a notification proves to be impossible or imposes disproportionate effort.

This notification will be sent by email or by post, using the details communicated by the User.

5. Location, storage and duration of storage of personal data

5.1. CIRCUS® BELGIUM stores users' personal data in a form that allows their identification and availability and follows appropriate and secure methods.

The data is stored and hosted in Belgium by Data Center, which offers all the necessary and useful security guarantees in accordance with applicable technical standards.

5.2. Users' personal data is stored by CIRCUS® BELGIUM for the purposes defined in articles 2 and 3. The data is stored for a period of ten (10) years for all the purposes mentioned under Section 2.a); CIRCUS® BELGIUM therefore reserves the right to retain Users’ personal data for all purposes required by law in view of its online gaming and betting activity.

The personal data shall be stored for a period not exceeding the period required to fulfill any and all of the purposes of processing defined in Sections 2.2 and 3. The data is then deleted from CIRCUS® BELGIUM's files upon request of the Users addressed to the Contact referred to in article 7.5.

6. Responsibility of CIRCUS® BELGIUM - Subcontractor

6.1. CIRCUS® BELGIUM agrees to process Users' personal data in a legal, loyal and transparent way regarding the User concerned. Any data processing performed by CIRCUS® BELGIUM will comply with the requirements of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to personal data processing and to this Privacy Policy.

CIRCUS® BELGIUM implements all reasonable and appropriate methods to ensure confidentiality, integrity and availability of the personal data it processes. These technical and organizational measures, notably those set out in the register which can be accessed via the Contact referred to in article 7.5.

The technical measures include notably anonymization and encryption of personal data, depending on the required purpose.

The organizational measures notably include the execution of internal audits, in addition to the audits CIRCUS® BELGIUM can be subject to from the Gaming Commission, notably.

If necessary, CIRCUS® BELGIUM carries out, with the help of the data protection officer, an impact analysis when processing is likely to cause a heightened risk for Users.

6.2. Users' personal data is not transferred to third parties other than authorities, CIRCUS® BELGIUM's providers and partners, except for the purposes outlined in articles 2.1, 2.2 and 3 and, therefore, if:

• the transfer is made compulsory by a law, regulation or injunction issued by an administrative or judicial authority;
• The transfer is necessary for the provision of online gaming and betting services or maintenance;
• The User gives their consent for such transfer.

The partner will not be considered as a subcontractor as defined in the Regulation, unless they process Users’ personal data on behalf of CIRCUS® BELGIUM. CIRCUS® BELGIUM declines all responsibility regarding the processing of Users' personal data by the partner that provides their own services in their own name and on their own behalf or if CIRCUS® BELGIUM proves they are not accountable for any damage caused.

Where CIRCUS® BELGIUM is acting as the partner’s data processor, it is agreed that CIRCUS® BELGIUM shall only be held liable for damage caused by the processing of personal data in breach of the Regulation or this Privacy Policy (i) if it has breached the obligations specifically incumbent on data processors pursuant to the Regulation, or (ii) if it has acted outside of or contrary to the partner’s lawful instructions. Similarly, CIRCUS® BELGIUM cannot be held liable under any circumstances if it proves that the fact that caused the damage is in no way attributable to it.

6.3. CIRCUS® BELGIUM ensures that, when processing is carried out by a subcontractor, on behalf of CIRCUS® BELGIUM, they provide sufficient guarantees for the implementation of appropriate technical and organizational measures and, more generally, regarding compliance with the Regulation's demands. In particular, it requires the subcontractor to comply with the Regulation and, therefore, to keep a register

6.4. CIRCUS® BELGIUM undertakes that, in the event of a security problem related to the data processed, likely to affect their 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 heightened risk for Users' rights and freedoms; they will be informed by email or mail using the contact details communicated by the User.

7. Other provisions

7.1. Personal Data Register and Information Security Manual

As the personal data controller, CIRCUS® BELGIUM has a register of all of their processing activities. This register contains all information relating to the type of data processed, data subjects, the potential recipients to whom the data is communicated (where applicable), the purposes for which the data is processed, the data retention period and a general description of the technical and organizational security measures implemented.

The personal data communicated by the User is saved, as well as the processing carried out and its purposes, in a register that is controlled by and remains under the responsibility of CIRCUS® BELGIUM at all times. This register includes, in addition to the aforementioned information:

• a description of the purposes of the processing;
• a description of the categories of data subjects and personal data;
• the categories of recipients to whom the personal data has been or will be communicated, including any recipients in third countries or international organizations;
• the expected deadlines for the deletion of various categories of data;
• A general description of the technical security measures.

7.2. Entirety - modification of the Privacy Policy

This Privacy Policy contains all the contractual provisions enforceable against Users, without prejudice to the general provisions contained in the Website Terms of Use, of which they form an integral part. The Website Terms of Use therefore remain applicable for any matter not related to personal data protection.

CIRCUS® BELGIUM also reserves the right to modify the Privacy policy. All changes shall be enforceable against Users as soon as they are published on the Website. CIRCUS® BELGIUM ensures to mention the date of posting of the Privacy policy in force on the Website.

7.3. Probative value

Users acknowledge that the electronic documents exchanged and electronic data collected in connection with their registration or use of the Website shall have the same probative value as if such documents and data had been communicated or collected via printed media. Users therefore agree not to contest the documents’ validity or probative value on grounds of their digital format.

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 natural persons with regard to the processing of personal data and the Belgian Act of 8 December 1992, Users shall have the right to request extra information or make a complaint to the Belgian Data Protection Authority. The Data Protection Authority shall fulfil the role of supervisory authority. Its contact details are as follows:

• Address: Rue de la Presse, 35, 1000 Brussels, Belgium
• Telephone: +32 (0)2 274 48 00
• Fax: +32 (0)2 274 48 35
• Email: [email protected]

7.5. Contact — Information relating to the identity of the data controller and the data protection officer

CIRCUS®BELGIUM can be contacted for all questions regarding the protection of its Users’ personal data as follows:

• By post: Rue des Guillemins 129, 4000 Liège, Belgium
• By email: [email protected]

The data controller is CIRCUS® BELGIUM.

CIRCUS® BELGIUM has also appointed a Data Protection Officer within the meaning of Section 37 of the Regulation. The Data Protection Officer may be contacted by email at [email protected]. The Data Protection Officer is responsible for monitoring and ensuring the compliance of the personal data processing carried out by CIRCUS® BELGIUM.