1. GENERAL

1.1. This website is operated by „OLYMPIC CASINO GROUP BALTIJA“, UAB, legal entity code 211733760, address Constitutions ave. 12 LT09308 Vilnius, Lithuania (“OLYBET” or “we”). OLYBET recognizes the importance of your privacy and is committed to protecting visitors, who have provided their personal data, the privacy and security of Personal Data. This privacy notice (“Notice”) explains, what information is collected about visitors, the principles on how OLYBET collects and uses information when you visit the website www.olybet.lt („Website“) and use any of the gaming services provided on the Website („Service“).

1.2. OLYBET processes your personal data under this Notice and in accordance with applicable legislation, including the General Data Protection Regulation (2016/679) and the applicable national data protection laws of the Republic of Lithuania, as applicable towards the personal data controller stated in Section 2 of this Notice.

2. PERSONAL DATA CONTROLLER

2.1. The list of personal data managers is specified in 10.1 point of these Privacy rules.

3. BASIC CONCEPT

3.1. Personal data are information that can be used to directly or indirectly uniquely identify, contact, or locate you as a private individual (“Personal Data”). The source of the collected Personal Data depends on how you interact with us.

3.2. Registration data. OLYBET processes the following Personal Data related to your registration to the Website: e-mail address, country of residence, phone number, etc („Registration Data“). Source: Personal Data you directly provide to OLYBET upon registration.

3.3. OLYBET processes the following Personal Data in order to complete your registration and verify your admissibility to use the Service: name, surname, date of birth, personal code, user name, user ID, document type, document number, document validity, document copy, country, which issued document, citizenship, address, language, currency, date, time, mobile sign, etc. („Verification Data“). Source: Personal Data you directly provide to OLYBET upon registration and Personal Data personal data, which provided to us by providers of identification and verification services

3.4. Data is collected for money laundering prevention purposes. Personal data processed by OLYBET in order to ensure possible prevention of money laundering and terrorist financing, fraud prevention, detection of such activities, investigation and notification of possible such activities, as well as to determine applicable sanctions and whether you are a person participating in politics or are related to with a person participating in politics, is the name, surname, personal identification number or date of birth, information about participation in politics, place, time and date of winning, etc. (hereinafter - Money Laundering Prevention Data). Source: Personal data that you provide directly to OLYBET, when necessary, as well as data obtained from state or non-state registers, from companies managing international sanctions registers, law enforcement authorities, from partners or other legal entities that use us or that we use, providing services and other persons.

3.5. Gambling data. OLYBET processes the following data in order to provide you with the Service: self-exclusion data, gaming-exclusion data, user ID, bet ID, currency, bet amount, current balance, game ID, seller ID, bet type, bet status, expected max win amount, bet result date, win amount, payout amount, login data, IP-address, currency, date and time of entering and exiting the Service, etc („Gambling data“). Source: Personal Data you provide us whilst using the Service and the Personal Data gathered from the databases available to OLYBET in relation to providing the Service (e.g. list of persons with restrictions on gambling (https://nelosti.lpt.lt/ext)).

3.6. OLYBET processes the following data to commence the money transfers related to the Service: name, surname, banking number, date, time, transaction amount, etc („Transfer Data“). Source: Personal Data you provide us upon requesting monetary transfer and Personal Data received from the payment service providers.

3.7. OLYBET processes the following Personal Data, if you interact with OLYBET via telephone, Website’s chatbot, e-mails or complaint reports: contents of your message, e- mail address or social media contacts, telephone number and etc („Communication Data“). Source: Personal Data you directly provide to OLYBET.

3.8. OLYBET processes the following data when you visit the Website: IP address (including location based on the IP address), access-provider, referring URL, date, time, access tokens, session key, browser type and version, operating system, amount and state of transferred data, MAC-address (“Technical Data”). Source: While you are browsing through the Website, the Website itself generates or collects the Technical Data from your device automatically.

3.9. OLYBET processes the following personal data for marketing purposes: e-mail address, phone number, your preferences. („Marketing Data“) Source: Personal Data you directly or indirectly (e.g. via cookies) provide to OLYBET whilst using the Service.

3.10. OLYBET implements cookies on the Website for optimizing the Website and its functionalities. The cookies may collect your Personal Data. For further information, please see OLYBET’s cookie notice („Cookie Data“).

3.11. In addition to the specific purposes specified in this section of the Privacy Policy, OLYBET may also process personal data when processing it is necessary to fulfill OLYBET's binding legal obligations, as well as when it is necessary to protect the vital interests of natural persons.

3.12. If you fail to provide necessary information, OLYBET is not able to register your user account, provide you with the Service or fulfill any other purposes provided in Section 5 of this Notice.

4. DATA PROTECTION OFFICER

4.1. You shall have the right to communicate with OLYBET’s data protection officer in order to obtain information on the processing of your personal data. OLYBET’s data protection officer’s contact references are:

E-mail: [email protected]

5. LEGAL BASIS AND PURPOSES FOR PROCESSING THE PERSONAL DATA

5.1. OLYBET’s legal basis to process your Personal Data depends on the objective and context in which we collect the Personal Data. For easier understanding, we have grouped all purposes and data categories for processing the Personal Data with the following legal grounds: performance   of   a   legal   obligation, performance   of   a    contract, OLYBET’s legitimate interest and your consent.

5.2. If the legal basis for processing the Personal Data is:

5.2.1. performance of a legal obligation, then this means first and foremost that OLYBET is required to process certain Personal Data by law. In this case we cannot decide which personal data are collected and processed, as it derives from applicable laws;

5.2.2. performance of the Contract, which means that Personal Data is processed in order to ensure correct compliance with the Regulation and the terms and conditions of the Contract, to which you have agreed by registering for the Service;

5.2.3. OLYBET’s legitimate interest, this means first and foremost the objective of improving the Website and OLYBET’s business activities. However, specifics of the legitimate interests, as used in each separate case, are referred in the table below;

5.2.4. consent, this means first and foremost that Personal data shall only be processed, if your consent is granted, for example, ensuring an effective user experience by adjusting the Service is only possible upon your consent, without your consent it would not be possible to tailor the Service to meet your preferences.

5.3. The following depicts a non-exhaustive list of processing purposes that are linked to the specific data categories and legal basis for processing:

5.4. We may process your Personal Data for other purposes, provided that OLYBET discloses the purposes and use to you at the relevant time, and that you either consent to the proposed use of the Personal Data, other legal grounds exist for the new processing purposes or the new purpose is compatible with the original purpose brought out above.

6. AUTOMATED DECISION MAKING AND PROFILING

6.1. In the course of you browsing the Website and using the Service, OLYBET may sometimes apply automated processing to your Personal Data and make automated decisions based on your Personal Data. These automated decisions can affect the content and access to the Service or its features.

6.2. In the following situations we may apply automated decision making as authorised by applicable laws or is necessary for the performance of the contract between you and OLYBET:

6.2.1. Verifying your identity and allowance of providing access to the Service upon registration of the user account on the Website: upon registering to the Service on the Website, we verify via partially automated decision whether you meet the criteria for registering the user account and accessing the Service. The decision making process entails analyzing your Personal Data, such as date of birth (age), personal identification number, nationality, self-exclusion data and gaming-exclusion data against the statutory allowance requirements. These data are usually directly made available by you or gathered from the databases available to OLYBET in relation to providing the Service (e.g. list of persons with restrictions on gambling). As a result of the partially automated decision your registration and access to the Service is completed or declined;

6.2.2. User payment verification: according to applicable laws, OLYBET is obliged to check whether your payment account details match the user account details you have provided for the use of the Service. Personal Data subject to such automated decision are the banking account details (name, banking account number). These data are collected directly from you and received from the payment service provider. As a result of the automated decision any money transfer to your user account or to you is completed or declined;

6.2.3. Risk assessment and compliance with the sports rules and other Service’s rules: pursuant to the regulations, OLYBET does not allow cooperation between customers and thus applies active measures to avoid the use of scripts, bots and other devices and techniques interfering the fair play. To combat any interferences of fair play and non-compliances of the binding Service’s rules, we analyse your activities on the Website and in the Service. For such analysis we mainly rely on the Technical Data and Gambling Data as defined in Sections 3.5. and 3.8. above. We compare such data against data previously collected by us or received from third party service providers about you or your device. As a result of the automated decision, OLYBET and/or the engaged gaming service provider (who processes such data in aggregated manner based merely on User ID) may restrict the access to the Service’s functions (e.g. cancel repeated bets from the same IP address or shared address, limit maximum bet amounts, etc.) if the activity is non-compliant;

6.2.4. Fraud detection: pursuant to the applicable laws, OLYBET is obligated to detect and deter activities relating to money laundering and fraud. For this purpose, OLYBET or a fraud prevention service provider compares your device’s online identifiers (e.g. Technical Data and Cookie Data as defined in Sections 4.1.7. and 4.1.9. above) and Gambling Data (see 4.1.4 above) against similar type of data previously collected about you or your device used to access the Website. If it is detected that your account or device has fraudulent pattern or is connected to money laundering, as a result of the automated decision, OLYBET may restrict your access to the Service (e.g. block or freeze your user account).

6.3. The automated decisions described in Section 6.2 above usually take place without human intervention. You have the right to obtain human intervention in regard to the decision making defined in Sections 6.2.3 and 6.2.4; express your point of view in regard to such decision and contest the decision.

7. PERSONAL DATA RETENTION PERIOD

7.1. Your Personal Data (all data categories mentioned in Section 3.10, except for Cookie Data) shall be stored insofar as reasonably necessary to attain the objectives stated in Section 5 of this Notice, or until the legal obligation stipulates that we do so. The following is a non-exhaustive summary with examples on storing your Personal Data:

7.1.1. Registration Data, Verification Data, AML Data and Gambling Data will be retained up to 8 years as of the last log-in to your user account.

7.1.2. The documents and data supporting a monetary transaction or transaction or other documents and data having legal effect relating to the execution of monetary transactions or the conclusion of transactions shall be kept for a period of 8 years from the date of execution of the monetary transaction or conclusion of the transaction. Please note that data relating to payment transactions with a value equal to or greater than EUR 1 000 will be kept for 8 years. Reports to the Gambling Supervisory Authority and the Financial Crimes Investigation Service on payment transactions with a value equal to or exceeding EUR 15 000 will be kept for 8 years.

7.1.3. Marketing Data will be retained for 1 year as of the collection of such data;

7.1.4. Communication Data will be retained for 3 months as of the collection of such data;

7.1.5. The documents for the examination of requests, complaints, reports of individuals will be kept for 5 years from the end of the business relationship.

7.1.6. Technical Data will be retained for 30 days as of the collection of such data.

7.2. After the retention period mentioned in Section 7.1 of this Privacy Notice, we might either retain your Personal Data for longer period, if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes and enforce the contract between you and OLYBET or anonymize your Personal Data and retain this anonymized information indefinitely.

7.3. After the expiry of the retention period referred to in Section 7.1. of this Privacy Notice or the termination of the legal basis for processing purpose, OLYBET shall retain the materials containing the Personal Data in the backup systems, from which the corresponding materials will be deleted after the end of the backup cycle. OLYBET ensures that during the backup period, appropriate safeguards are applied to the materials in the backup. The backed-up materials are put beyond the use, i.e. are not processed for any other purpose, and the materials are deleted by OLYBET as soon as possible, i.e. after the end of the OLYBET’s backup cycle, the Personal Data will be destroyed.

8.    YOUR RIGHTS AS A DATA SUBJECT

8.1. We have a legal obligation to ensure that your Personal Data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that have to be made to any of your Personal Data that we are processing.

8.2. You may, at any time, exercise the following rights with respect to our processing of your Personal Data:

8.2.1. Right to access. You have the right to request access to any data that can be considered your Personal Data. This includes the right to be informed on whether we process your Personal data, what Personal Data categories are being processed by us, and the purpose of our data processing;

8.2.2. Right to rectification. You have the right to request that we correct any of your Personal Data if you believe that it is inaccurate or incomplete;

8.2.3. Right to object:. You are entitled to object to certain processing of Personal Data, including for example, making automated decisions based on your Personal Data or when we otherwise base the processing of your Personal Data on our legitimate interest;

8.2.4. Right to restrict Personal Data processing. You have the right to request that we restrict the processing of your Personal Data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of Personal Data; (iii) receive or avoid deletion of Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of OLYBET’s legitimate interest in the specific processing activity;

8.2.5. Right to erasure. You may also request your Personal Data to be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement;

8.2.6. Right to data portability. If your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine- readable format. Moreover, you may request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible;

8.2.7. Right to withdraw your consent. In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time without any adverse effect;

8.2.8. Right to submit your claim with the supervisory authority. If you are not satisfied with our response to your request in relation to Personal Data or you believe we are processing your Personal Data not in accordance with the law, you can submit your claim with the Lithuanian Data Protection Inspectorate at www.ada.lt.

8.3. Please note that you will need to provide sufficient information for us to handle your request regarding your rights brought out in Section 8.2 of the Notice. Prior to answering your request, we may ask you to provide additional information for the purposes of authenticating you and evaluating your request.

9. SHARING YOUR PERSONAL DATA AND DATA TRANSFERS

9.1. OLYBET discloses your Personal Data to third parties only in accordance with this Privacy Policy and to persons authorized to process Personal Data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality. In specific cases, OLYBET will only share your Personal Data with a third party if you have given consent to such disclosure.

9.2. When processing data, OLYBET may disclose your Personal Data to the following recipients (including engaged data processors) only if it is necessary to fulfill legal requirements, contractual obligations, as well as to the extent it is necessary for OLYBET to fulfill the specified purposes. OLYBET ensures that appropriate data processing agreements are signed with data processors and appropriate measures are implemented to ensure the safe processing of customer data and the protection of your rights.

9.3. In some cases, we may transfer your Personal Data outside the European Union or European Economic Area, if the respective operational services are provided outside the European Union or European Economic Area. We shall opt to use special Personal Data protection safeguards, in order to ensure the safety of your Personal Data. You have the right to get acquainted with or obtain information on the comprehensive list of data processors, transferring of your Personal Data outside the European Union or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in this Notice.

10. INFORMATION ABOUT PROCESSING OLYMPIC CASINO AND OLYBET CUSTOMERS’ PERSONAL   DATA   FOR   DIRECT   MARKETING   AND   ANALYTICS   PURPOSES

10.1. The joint controllers of your personal data are Olympic Entertainment Group AS, who is the operator of Olympic Casino in Estonia, OB Holding 1 OÜ, who is the operator of OlyBet in Estonia, and Olympic Casino Group Baltija UAB, who is the operator of Olympic Casino and OlyBet in Lithuania.

The contact details of these data controllers are as follows:

Olympic Entertainment Group AS

Registry code 14437516,

address Pronksi tn 19, 10124 Tallinn, Estonia E-mail [email protected]

OB Holding 1 OÜ

Registry code 14975047

address Pronksi tn 19, 10124 Tallinn, Estonia E-mail [email protected]

Olympic Casino Group Baltija UAB

Registry code 211733760

Address Konstitucijos pr. 12, LT-09308 Vilnius, Lithuania Email [email protected]
10.2. We use the electronic contact details provided by you to send you information and special offers on the subjects chosen by you to promote the businesses of Olympic Casino and OlyBet. The legal basis for processing your personal data is your consent (Art 6(1)(a) of the GDPR).

10.3. If you agree, the information and special offers will be personalised, i.e., sent to you based on our best understanding of your interests and behaviour. In making these offers, we may contact you based on, for example, your use of Olympic Casino and OlyBet services (e.g., if you prefer certain games in Olympic Casino, we may notify you if such games become available in OlyBet; if you have participated in certain events or offers before, offer them to you again; provide special offers to players who have staked a certain amount, etc.). The purpose is to know you better in order to incentivize you to use our services. In doing so, we use both profiling and automated decision-making. The automated decisions usually take place without human intervention. However, they do not bring about any legal effects to you or otherwise similarly significantly affect you. At worst, we may send you offers you are not interested in. The personalised offers may somewhat increase the addiction of compulsive gamblers; however, we have taken the necessary safeguards and never target any such player knowingly and strongly encourage responsible gaming. You have the right to obtain human intervention regarding the decision making, express your point of view regarding such decisions, and contest the decisions. The legal basis for processing your personal data is your consent Art 6 of the GDPR.

We will process your personal data for the above-mentioned purposes until you withdraw your relevant  consent(s), asking you to  update your preferences from time to time.

We will also provide you with information and special offers over the phone or when you visit Olympic Casino or OlyBet. These offers are usually personalised, i.e., based on our best understanding of your interests and behaviour as explained above. The legal basis for processing your personal data is our legitimate interest in making better marketing and business decisions and promoting the business of Olympic Casino and OlyBet (Art 6(1)(f) of the GDPR). In this case, we conclude that, depending on the circumstances, your legitimate interest r the fundamental rights and freedoms to which the protection of personal data applies do not override our legitimate interest. You have the right to object to such processing at any time on grounds relevant to your situation by contacting us at the contact below. In this case, your personal data will not be further processed for direct marketing purposes, nor will your data be further processed for the purposes of personal data analysis, unless we can demonstrate a compelling legitimate ground for such processing that overrides your interests, rights and freedoms. However, we note that withdrawal of consent(s) to the processing of data for marketing and analytical purposes does not prevent us from processing your personal data for the other purposes set out in this Privacy Policy.

10.4. We use the personal data you have provided us or that has been created based on your use of Olympic Casino and OlyBet services on an aggregated level for analytics, i.e., to understand our customers, their needs, and behaviour better in order to make better marketing and business decisions. Your personal data is sent to Estonia and analytics is performed by joint controllers Olympic Entertainment Group AS and OB Holding 1 OÜ. We analyse your data for example to understand which Olympic Casino games are popular and should also be available in OlyBet to increase its use; in which order the games should be listed to increase their popularity; which OlyBet sports events are popular and should be streamed in Olympic Casino; what are the characteristics of customers who are active either only or both online and offline; etc. Although such analytics may initially be based on some of your personal data, the data is aggregated, and no personal data is used in any reports.