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Privacy

This privacy policy is composed of the several sections. Each of the sections is equally important, so we encourage you to carefully read all of them before you consent to the processing of your personal data.  

What information can be found in this Policy?

Introduction

Data Controller and Data Subjects

Data we process
    Identification data
    Private habits and interests

Why we process your data and how
    Identification data
    Private habits and interests

Our use of cookies

How we protect your data

Your rights
    Right to access
    Right to rectification
    Right to erasure (right to be forgotten)
    Right to restrict processing
    Right to object to the processing of your data and rights related to automated decision making
    Right to data portability
    Right to withdraw consent
    Right to lodge a complaint

How long we keep your data for

Who else may access your data

Transfer of your data to third countries

Introduction

 

A MyGDM user ( ‘you’) may share information and opinions regarding different card games we offer on our website ( ‘services’). More about our services is available in our Terms and Conditions. When you use our services many of your information might be shared with us or third parties.

This Privacy Policy is important to you to understand how your personal data is collected, used, consulted or otherwise processed when you use www.mygdm.com ( ‘MyGDM’). Personal data is any information about you that might be used to identify you, or make possible to identify you. This Privacy Policy applies to your personal data processing on MyGDM, and not to data processing that may occur on other services or web pages regardless whether they are provided by the owner of MyGDM of someone else. The owner of MyGDM (‘we’, ‘us’, ‘our’) is:

A/S,

Tolbodgade 12,  

1253 Copenhagen K (Hovedstaden)

Denmark (DK)

CVR. 27652913

This Privacy Policy is effective from 25th May 2018.This Privacy Policy may be modified from time-to-time.

Essential modifications are those that affect your rights, obligations and state with regard to protection and processing of your personal data. The essential modifications might include (but not limited to) launch of new services, deployment of new technologies and processing your data for new purposes. Therefore, if we make essential modifications to the Privacy Policy, we will send you notice through our Services, or by other means, and give you the opportunity to review the changes before they become effective. You will be asked to consent to the processing of your personal data in accordance with updated Privacy Policy. If you do not consent to this, you will not be able to use your account, and services available for registered users.    

In addition, from time to time we make minor modifications of the Privacy Policy. Minor modifications do not impact your rights, obligations and state with regard to protection of personal data. These types of modifications might include (but are not limited to) organizational and grammatical changes to this Privacy Policy in order to makes our policy easy to read. The fact that you continue to use our Services after we publish the updated Privacy Policy with only minor modifications means that the processing of your personal data is subject to the updated Privacy Policy with only minor modifications.

Essential modifications are those that affect your rights, obligations and state with regard to protection and processing of your personal data. The essential modifications might include (but not limited to) launch of new services, deployment of new technologies and processing your data for new purposes. Therefore, if we make essential modifications to the Privacy Policy, we will send you notice through our Services, or by other means, and give you the opportunity to review the changes before they become effective. You will be asked to consent to the processing of your personal data in accordance with updated Privacy Policy. If you do not consent to this, you will not be able to use your account, and services available for registered users.

In addition, from time to time we make minor modifications of the Privacy Policy. Minor modifications do not impact your rights, obligations and state with regard to protection of personal data. These types of modifications might include (but are not limited to) organizational and grammatical changes to this Privacy Policy in order to makes our policy easy to read. The fact that you continue to use our Services after we publish the updated Privacy Policy with only minor modifications means that the processing of your personal data is subject to the updated Privacy Policy with only minor modifications.

Data Controller and Data Subjects

By using MyGDM services you may disclose various pieces of  information, including those that would be considered personal data. When your personal data is processed then you are considered a data subject and you are entitled to exercise your rights guaranteed by EU Data Protection Law, and explained in this Privacy Policy. Taking into account that we determine the purposes and means of processing personal data on MyGDM we are legally considered as data controller over your personal data on this Website. Being data controller provides us the opportunity to process your personal data, but also obliges us to protect them in the way regulated by EU Data Protection Law, particularly by the General Data Protection Regulation (‘GDPR’), and this Privacy Policy.         

Data we process

We are processing (or might process) various categories of your data. Below you may find information on which data we process, as well as their categorizations.   

Identification data

Personal Identifiable Information (PII) - When you create the account on MyGDM, we process your first name and surname, email, user name you choose, as well as the name of the province in Italy you live in.

Electronic identification data - When you log in to the MyGDM we process the IP address of the device you use, the type and version of browser and operating system you use as well as the time of logging in.   

Private habits and interests

Preferences - You can add the information about your card games you play.

Why we process your data and how

We collect and  process data about you when you sign up, and use our service. We process your personal data in order to provide our services to you, to improve your experience about our services, to further develop our service, and to secure and maintain regular functioning of MyGDM. More about purposes for processing your data you may find below.  

Identification data

Personal Identifiable Information (PII) - Your Personal Identifiable Information that we process (first name and surname, user name) serve to distinguish you from other MyGDM users. Your email address is necessary to create an account, but we also use it to communicate with you regarding any changes to your account or our services, as well as for commercial communication if you agree to receive it. You may add the information about the province you live in, if you wish to provide additional information about yourself to other users.  

Electronic identification data - We process the IP address of the device you use in order to enable communication between your device and our server; to determine your approximate geolocation which may be further used for service customization (for instance to provide appropriate content for your language of choice and gambling-related content that is legal in your country) as well as for analytical and safety reasons. More about how we process your data for analytical purposes you may find in our Cookie Policy.

The processing of details about the browser and operating system you use is necessary to ensure the regular provision of our services to you. Also, sometimes we will need this data to solve some technical problems if they emerge.

Private habits and interests

Preferences - You can add the information about your preferred card games, if you wish other users to get to know you better.

Our use of cookies

Any browser visiting our Website will receive cookies from us. We use cookies because we wish to provide the best possible on-site experience to everyone who visits our website.

By the use of cookies we process standard internet log information and details of Website visitors behaviour patterns. The use of cookies enable us to improve site navigation, analyse on-site behaviour of everyone who visits the website, promote our products and provide content from third parties. To find out more about our use of cookies, read our Cookie Policy.

How we protect your data

We do not collect personal data in excessive manner. We only process data that we really need and only for agreed purposes. We are tending to keep your data up to date and to store them securely. We do not process your data for period longer than it is necessary for the purposes for which data is processed. 

We use technical and organisational measures in accordance with good industry practice to safeguard your information. Thus, we take appropriate technical and organizational measures to ensure protection of your personal data against accidental or unlawful loss, alteration, steal, unauthorized disclosure or access, unauthorized use and against all other unlawful forms of processing.

We apply different levels of access control to your data. Restriction of access control is based on business needs and security requirements. We ensure you that only appropriately authorized persons have access to your data, whose knowledge and skills about data is necessary to fulfill their obligations arising out of or in connection with the performance of their job.

Your rights

Right to access

You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. If you would like to get the confirmation as well as the access to your personal data please send contact us via dataprotection@bettercollective.com.

Right to rectification

You have the right to ask us to delete inaccurate personal data concerning you. Taking into account the purposes of the data processing, you have the right to have incomplete personal data completed.

Right to erasure (right to be forgotten)

In limited circumstances, you will have the right to request that we erase the information we hold about you:

  • where the data is no longer needed for the purposes it was collected,
  • where you have withdrawn consent and there is no other lawful basis on which we can continue to process it,
  • where you objected to processing and there are no overriding legitimate grounds to continue,
  • where the data has been unlawfully processed or
  • where the data has to be erased for compliance with a legal obligation.

Right to restrict processing

You have the right to seek the restriction of processing of your personal data in the following circumstances:

  • If the accuracy of the data is contested – processing may be restricted for the period necessary to allow us to verify its accuracy,
  • the processing is unlawful and you request restriction instead of erasure,
  • we no longer need the data for the purposes it was collected, but you need it in connection with a legal claim,
  • if you objected to the processing of personal data that are processed on the grounds of our legitimate interests, while awaiting verification whether our legitimate interests ground for processing your data overrides interest of your fundamental rights and freedoms.

Right to object to the processing of your data and rights related to automated decision making  

You have the right to object our processing of your data on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling. Upon your objection, we will stop processing your data unless we can demonstrate compelling legitimate grounds for continuing the processing which override interests of your fundamental freedoms and rights, or if further processing is necessary for the establishment, exercise or defence of legal claims.

At any time you have the right to object processing your data, including profiling, for direct marketing purposes. We use Eloqua for automated decision making including profiling, for marketing purposes, and you may opt-out from further data processing for this purpose at the following link. Upon your opt-out your personal data will not be longer processed for direct marketing purpose. In regard with automated decision making about you, you may have right to request human intervention.

Right to data portability

Under certain circumstances you have right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format (i.e. in digital form) and you have the right to request the transmission of those data to another entity without hindrance from us, if such transmission is technically feasible.

Right to withdraw consent

If the ground for processing your personal data is your consent, you can withdraw your consent at any time without giving any reason to us, and free of charge. In order withdraw the consent you should delete your account on MyGDM.

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Please be aware that after withdrawal of the consent we will not be able to process your data and consequently we will not be able to offer our services to you.

Right to lodge a complaint

If you feel that your personal data rights have been breached, you can can contact us on dataprotection@bettercollective.com. Also you have the right to lodge a complaint with your local data protection authority. The relevant data protection authority in EU Member States might be determined either by your place of habitual residence, or the place where the alleged infringement emerged.

As we are established in Denmark you may choose to contact Danish Data Protection Agency - Address: Datatilsynet, Borgergade 28, 5, DK-1300 Copenhagen K; email: dt@datatilsynet.dk

How long we keep your data for

We keep your data until you delete your account on MyGDM. When you delete your account we will erase all of your personal data we process.

Who else may access your data

We may share your data with third parties. The third parties are categorized as follows:

  • Members of the Group which includes A/S and its subsidiaries (the BC Group) - More about members of the BC Group is available here. Please be aware that we determine the purpose and means of the processing of your data as well as deciding which of your data is going to be processed by other members of the BC Group. 
  • Entities who help us to regularly provide, and further develop our services (e.g. analytics, maintenance, marketing, development). They are allowed to process your information as reasonably necessary in order to perform delegated tasks. Please be aware that only we determine the purpose and means of the processing of your data as well as we decide which of your data is going to be processed to perform delegated tasks.
  • With public authorities and law enforcement agencies where it is necessary to do so and where we are legally required or permitted to do so.   
  • Third parties who are granted access to our API, which may show your tips, username, avatar, rating, success of your tip and country  

Transfer of your data to third countries

We may transfer your personal data outside the European Economic Area in order to provide our services on regularly base and/or to further develop our services. We take all measures in relation to the recipients of your personal data, to ensure an adequate level of protection and appropriate safeguards as defined by the applicable data protection law and particularly GDPR are implemented.

Your personal data might be transferred to the recipient based in country the European Commission considers to have an adequate level of data protection. You may find out more about countries with adequate level of protection here.  

If your data is transferred to a recipient based in US, then we aim to transfer your data in the way laid down by Privacy Shield mechanism. More about Privacy Shield mechanism is available here.  

We will conclude Data Protection Agreements as necessary  with recipients of your data that will include Standard Contractual Clauses issued by the European Commission and that would oblige the data recipient to provide an adequate level of protection and implement appropriate safeguards as defined by the applicable data protection law, and particularly GDPR, with regard to processing your personal data.