PRIVACY POLICY

www.wellington-casino.be

WELLINGTON CASINO is committed to protecting the personal data of its Players. Therefore, we make every effort to safeguard the privacy of all visitors and Players on our online gambling website www.wellington-casino.be (the 'Site').

Players will find below all the provisions regarding the processing of personal data applicable during any visit or use of the Site by Players.

Article 1 – General Provisions

Article 2 – Processing of Personal Data Not Requiring Player Consent

Article 3 – Processing of Personal Data Requiring Player Consent

Article 4 – Player Rights

Article 5 – Location, Storage, and Retention Period of Personal Data

Article 6 – Responsibility of WELLINGTON CASINO and its Subcontractors

Article 7 – Miscellaneous

Article 1 – General Provisions

WELLINGTON CASINO processes the personal data of Players on the Website, for the purposes and within the limits of the Privacy Policy, during any visit or use of it. WELLINGTON CASINO ensures that, during any collection and processing of this personal data, it complies with the applicable laws and regulations, in particular the European Regulation (EU) 2016/679 of April 27, 2016 on the protection of individuals concerning the processing of personal data (the "GDPR").

Players are presumed to have taken knowledge of and accepted the Privacy Policy when accessing the Website. They guarantee that the data and information provided to WELLINGTON CASINO are accurate.

Article 2 – Processing of Personal Data Not Requiring Player Consent

2.1. Obligations of WELLINGTON CASINO

WELLINGTON CASINO is required, both by virtue of the legal and regulatory obligations to which any online gaming and betting operator is subject, on the one hand, and for the purpose of authenticating and enabling Players to use the Site, on the other hand, to process the following personal data for the purposes described below. This processing of personal data carried out by WELLINGTON CASINO does not require the consent of Players under Article 6.1.b) and c) of the GDPR.

The personal data provided by the Player is recorded in a register, as described in Article 7.1, which is controlled and at all times under the responsibility of WELLINGTON CASINO.

a) Type of Data

The personal data processed includes:

1. Name, first name(s), date of birth, language, gender, home/postal address, National Register Number (or identity card or passport), email address, landline or mobile phone number;

2. Banking data used for deposit and withdrawal operations on the Site;

3. Copies of personal documents for Player authentication, such as a photo of the identity card, an account statement, proof of deposits, or any other document that can prove the Player's residence and/or domicile;

4. Browsing and activity history of the Player on the Site, including game histories (casino and sports betting), transactions (winnings and losses, deposits, withdrawals), logins (browser data, IP address), particularly through the use of cookies;

5. Any other information that may be exchanged between WELLINGTON CASINO and the Player, especially by email or live chat, as part of the Player's registration or use of the online gambling services offered on the Site.

b) Data Processing

The processing involves collecting, recording, storing, consulting, organizing, using, matching, or any other operations required or useful under the legal and regulatory provisions described in Article 2.1.c).

The processing may also involve the transfer of personal data:

1. To judicial and administrative authorities, such as, in particular, the Gaming Commission or the Financial Information Processing Unit (CTIF);

2. To WELLINGTON CASINO's suppliers, whose services are integral to the use of the Site and whose list is available upon request from the Contact mentioned in Article 7.5.

c) Purposes of Data Processing

WELLINGTON CASINO is required to process the personal data described in Article 2.1.a) and b) to comply with the legal and regulatory obligations it is subject to, in particular, the following legal provisions:

1. The Law of September 18, 2017 on the prevention of money laundering and the financing of terrorism and the limitation of the use of cash;

2. The Law of May 7, 1999 on games of chance, betting, gaming establishments, and player protection, in particular, the obligations it imposes on operators in terms of management and administration, and its implementing regulations, such as the Royal Decree of December 15, 2004 on the access register to the gaming rooms of class I and II gaming establishments.

WELLINGTON CASINO also processes the personal data mentioned in Article 2.1.a) for the purpose of authenticating Players and enabling them to access and use the Site. Therefore, this processing is carried out to ensure:

1. The management of Player registrations and Player Accounts;

2. The management of Player deposits and winnings and, more generally, the provision of online gambling services;

3. Player information regarding the services offered by WELLINGTON CASINO;

4. Customer service management, including support and risk and fraud services;

5. Promotion, advertising, and marketing related to new online games and bets, including the sending of SMS, phone calls, paper or electronic newsletters;

6. Conducting satisfaction surveys, statistical studies, trend analyses, and market studies for the purpose of improving online gaming and betting services or informing Players or protecting Players and preventing gambling addiction.

Article 3 – Processing of Personal Data Requiring Player Consent

By using the Site, the Player expresses their free, specific, informed, and unequivocal willingness to expressly authorize WELLINGTON CASINO to process their personal data in accordance with the GDPR, within the limits and for the purposes defined below and without prejudice to data processing as described in Article 2.

The personal data provided by the Player is recorded in a register, as described in Article 7.1, which is controlled and remains under the responsibility of WELLINGTON CASINO. The Player also has rights, including the right to withdraw their consent at any time, as defined in Article 3.4.

3.1. Type of Data

The data processed by WELLINGTON CASINO includes:

1. Name, first name(s), date of birth, language, gender, home/postal address, National Register Number (or identity card or passport), email address, landline or mobile phone number;

2. Banking data used for deposit and withdrawal operations on the Site;

Article 3.2: Data Processing

The processing may also involve the transfer of personal data to third parties, the list of which is available upon request from the Contact mentioned in Article 7.5.

Article 3.3: Purposes of Data Processing

Personal data are collected and processed by WELLINGTON CASINO for the following purposes:

1. Promotion, advertising, and marketing, including affiliation and loyalty program management, related to the online gaming services, including sending SMS, phone calls, paper or electronic newsletters, not covered by Article 2.2.c);

2. Participation in contests and promotional offers, including communication regarding winners;

3. Development of new games and betting offers;

4. Conducting satisfaction surveys, statistical studies, trend analyses, and market studies for management, marketing, and reporting purposes, including profiling, not covered by the purpose described in Article 2.2.c).

Article 4 – Player's Rights

Without prejudice to Articles 2 and 5 of this Privacy Policy, Players have the right to exercise the rights of rectification, opposition, and limitation, under the following terms and limits:

4.1. Right of Access

WELLINGTON CASINO provides Players with the following information:

1. The identity and contact details of the data controller;

2. The contact details of the data protection officer;

3. Personal data processed;

4. The purposes of processing for which personal data are intended and the legal basis for processing;

5. Recipients or categories of recipients of personal data, if applicable;

6. Whether 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 safeguards offered by the third country and the means by which the Player may obtain a copy of personal data;

7. The possibility to object to automated processing of their data, such as profiling, unless legitimate reasons make this processing by WELLINGTON CASINO necessary, as well as the possibility to object to any processing of their personal data for prospecting purposes.

Players have the right to request access to all the information mentioned in this article and in Article 3.1 at any time by contacting the Contact mentioned in Article 7.5. WELLINGTON CASINO will respond to these information requests within one month.

Players have the right to obtain a copy of the personal data being processed. WELLINGTON CASINO reserves the right to request payment of any related fees, which will be calculated based on the administrative costs incurred by the request, not exceeding 20 euros.

Players have the right to obtain, in a structured format, this access or the aforementioned copy, in a manner that provides the personal data in a format compliant with the technical standards in effect at the time of the access request, making it machine-readable.

4.2. Right of Rectification

WELLINGTON CASINO guarantees and obliges Players to update and rectify their personal data as soon as they become inaccurate or incomplete.

This right of rectification can be exercised upon request to the Contact mentioned in Article 7.5.

4.3. Right of Opposition

WELLINGTON CASINO allows Players to object to the processing of all or part of their personal data for the following reasons:

1. Their data is inaccurate;

2. The processing is no longer necessary for the purposes for which the data was collected;

3. The Player withdraws their consent;

4. The data has been unlawfully processed.

WELLINGTON CASINO also allows Players to object:

1. To automated processing of their data, including profiling, unless legitimate reasons make this processing by WELLINGTON CASINO necessary;

2. To any processing of their personal data for prospecting purposes, including profiling if it is related to prospecting.

This right of opposition can be exercised upon request to the Contact mentioned in Article 7.5.

4.4. Right to Erasure

WELLINGTON CASINO also commits to promptly fulfill any request for erasure of personal data (right to be forgotten) when:

1. The processing is no longer necessary for the purposes for which the data was collected;

2. The Player withdraws their consent;

3. The data has been unlawfully processed or needs to be erased to comply with a legal obligation.

4. The Player objects to automated processing of their data, including profiling, and there are no legitimate reasons requiring WELLINGTON CASINO to continue this processing.

5. The Player objects to the processing of their personal data for prospecting purposes, including profiling if it is related to prospecting.

4.5. Right to Restriction of Processing

Players also have the right to obtain from WELLINGTON CASINO the restriction of processing of their personal data in the following cases:

1. The Player considers that their personal data is inaccurate, and this restriction is necessary while WELLINGTON CASINO verifies the accuracy of the data;

2. The processing is unlawful, but the Player does not want the data to be erased and demands the restriction of its processing;

3. The Player objects to automated processing, including profiling, and there is a need to verify the legitimacy of the grounds for WELLINGTON CASINO's continued processing;

4. WELLINGTON CASINO no longer needs the personal data for processing, but the Player requires it for the establishment, exercise, or defense of legal claims.

This right of restriction can be exercised upon request to the Contact mentioned in Article 7.5.

4.6. Transfer of Personal Data to Another Data Controller

Players are allowed to transfer their personal data to another data controller without any hindrance from WELLINGTON CASINO.

To the extent that such transfer is technically possible, Players are authorized to request WELLINGTON CASINO to have this transfer carried out directly by its data controller.

4.7. Procedures

The rights granted by WELLINGTON CASINO to the Player must be exercised according to the procedures defined in Article 7.5.

4.8. Notification

WELLINGTON CASINO will provide the Player with a notification of any erasure or rectification of data in accordance with Articles 4.2 and 4.4, unless such notification is impossible or would require disproportionate effort.

Article 5 – Location, Storage, and Retention Period of Personal Data

WELLINGTON CASINO stores the personal data of Players in a form that allows their identification and availability using appropriate and secure means.

The personal data of Players are stored in Belgium by WELLINGTON CASINO for the purposes defined in Articles 2 and 3, which provide the necessary and useful security guarantees in accordance with current technical standards.

They are retained for a period of 10 years for all purposes governed by Article 2.a). WELLINGTON CASINO reserves the right to retain the personal data of Players for any purposes required by law due to its online gambling activities. Players declare that they are informed and consent to the fact that, with reference to the Royal Decree of December 15, 2004, regarding the register of access to gaming rooms of class I and II gambling establishments, WELLINGTON CASINO is required to retain a photocopy of the identity card or the document used for the identification of the Player for at least ten years from the date of the Player's last activity on the Site.

Personal data is retained for a period not exceeding that necessary for the achievement of the processing purposes for all purposes governed by Article 2.2 and 3. The data is then deleted from WELLINGTON CASINO's records upon the request of the Players addressed to the Contact mentioned in Article 7.5.

Article 6 – Responsibility of WELLINGTON CASINO and Its Subcontractors

WELLINGTON CASINO commits to ensuring that the processing of Players' personal data is carried out lawfully, fairly, and transparently with respect to the concerned Player. Any processing by WELLINGTON CASINO will comply with the requirements of the GDPR and this Privacy Policy.

WELLINGTON CASINO implements all reasonable and appropriate means to ensure the confidentiality, integrity, and availability of the personal data it processes.

Technical measures include the anonymization and encryption of personal data, as required for the purpose.

Organizational measures include conducting internal audits, in addition to audits that WELLINGTON CASINO may be subject to by the Gaming Commission, among others.

When processing is likely to result in a high risk to the Players, WELLINGTON CASINO, with the assistance of the data protection officer, carries out an impact assessment.

The personal data of Players is not transmitted to third parties other than WELLINGTON CASINO's providers and partners, except for the purposes described in Articles 2.1, 2.2, and 3 and, therefore, if:

1. The transfer is mandatory under the law, a regulation, or an order of an administrative or judicial authority;

2. The transfer is necessary for the provision of online gambling services or maintenance services;

3. The Player has given their consent for such a transfer.

The partner will not be considered a subcontractor unless they process the personal data of Players on behalf of WELLINGTON CASINO. WELLINGTON CASINO disclaims all responsibility for the processing of the Player's personal data by the partner providing their own services in their own name and for their own account or if it can prove that the act causing the damage is not attributable to it.

In the event that WELLINGTON CASINO acts as a subcontractor of the partner, it is agreed that WELLINGTON CASINO will only be liable for damage caused by personal data processing contrary to the GDPR or this Privacy Policy if WELLINGTON CASINO has not complied with the specific obligations of subcontractors under the GDPR or has acted outside the lawful instructions of the partner or contrary to them. Likewise, the responsibility of WELLINGTON CASINO cannot in any case be engaged if it proves that the act that caused the damage is not attributable to it.

WELLINGTON CASINO ensures that, when processing is carried out by a subcontractor on behalf of WELLINGTON CASINO, the subcontractor provides sufficient guarantees for the implementation of appropriate technical and organizational measures and, more generally, compliance with the requirements of the Regulation. In particular, it requires the subcontractor to comply with the GDPR and, therefore, to maintain a record.

WELLINGTON CASINO undertakes that, in the event of a security issue related to the data processed, which affects its confidentiality, WELLINGTON CASINO will notify the data protection authority mentioned in Article 7.4 as soon as possible.

WELLINGTON CASINO will also inform the affected Players, provided that the personal data breach presents a high risk to the rights and freedoms of the Player; this information will be sent by email or mail to the contact details provided by the Player.

Article 7 – Miscellaneous

7.1. Register of Personal Data and Information Security Manual

As the data controller, WELLINGTON CASINO maintains a record of all its data processing activities. This record contains all information related to the type of data processed, the individuals concerned by data processing, any potential recipients to whom the data is, if applicable, disclosed, the purposes for which the data is processed, the retention period for the data, and a general description of the technical and organizational security measures in place.

The personal data provided by the Player, as well as the processing and its purposes, are recorded and remain under the responsibility of WELLINGTON CASINO. This record includes, in addition to the aforementioned information:

1. A description of the processing purposes;

2. A description of the categories of individuals concerned and categories of personal data;

3. Categories of recipients to whom personal data has been or will be disclosed, including recipients in third countries or international organizations;

4. Expected timeframes for the deletion of different categories of data;

5. A general description of technical security measures.

7.2. Entirety – Amendment to the Privacy Policy

The Privacy Policy contains the entirety of the contractual provisions applicable to Players, without prejudice to the general provisions contained in the Site's Terms of Use, of which they are an integral part. The Terms of Use of the Site, therefore, remain applicable to any matters not related to the protection of personal data.

WELLINGTON CASINO reserves the right to amend the Privacy Policy. Any updates are binding on Players upon their publication on the Site. WELLINGTON CASINO will ensure that the date of the Privacy Policy in effect on the Site is mentioned.

7.3. Evidentiary Value

The Player acknowledges that electronic documents exchanged and electronic data collected as part of their registration or use of the Site have the same evidentiary value as if these documents and data had been communicated or collected on paper. Consequently, the Player undertakes not to contest their strength or evidentiary value due to their electronic format.

7.4. Data Protection Authority

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and Law of July 30, 2018, the Player has the right to request additional information or file a complaint with the data protection authority. The supervisory authority is the Data Protection Authority. Its contact information is as follows:

- Address: rue de la Presse, 35, 1000 Brussels

- Phone: +32 (0)2 274 48 00

- Email: contact@apd-gdba.be

7.5. Contact – Information about the Data Controller and Data Protection Officer

The Site is operated by SA SONIC, with its registered office at Chaussée de Fleurus 347, boite A001, 6060 Charleroi and registered with the Crossroads Bank for Enterprises under number 0451.511.739 (the "Company").

The Company can be contacted for all questions regarding the processing of personal data, either:

- by mail: to the address of its registered office; or

- on the Contact us | WELLINGTON CASINO

- by email: info@wellington-casino.be

WELLINGTON CASINO has also appointed a data protection officer within the meaning of Article 37 of the GDPR; the data protection officer can be contacted by email: dpo@wellington-casino.be

The data protection officer is responsible for monitoring and ensuring compliance with the processing of Players' personal data by WELLINGTON CASINO.

PRIVACY POLICY

Table of Contents

Article 4 – Player's Rights