Data Processing Information

General information

Welcome to the Vegas.hu online casino!

In order to use the services available in the Vegas.hu online casino, you must register to the IT system of LVC Diamond Játékkaszinó Üzemeltető Korlátolt Felelősségű Társaság as data controller (hereinafter: Controller). Your data provided during registration and the term of the client relationship are processed by the Controller for separately defined purposes or purposes specified by law.

It is the purpose of this this Data Processing Information Document (hereinafter: Information document) to specify - in accordance with the applicable legislative provisions - the data management principles, objectives and relevant other facts which define the purpose, term and manner of managing the personal data your provided, and also your rights to remedies.

The security and appropriate handling of the personal data you provide is of key importance to use, and therefore we kindly request you the carefully and thoroughly read through the provisions of this Information document. Should you have any questions or comments regarding the contents specified herein, please contact our Customer Service or the data protection officer.

Contact of the Controller and the data protection officer:

Controller: LVC Diamond Játékkaszinó Üzemeltető Korlátolt Felelősségű Társaság

Contact: registered office and mailing address: 1088 Budapest, Rákóczi út 1–3. III. em.

E-mail: info@vegas.hu

Web: www.vegas.hu

Data protection officer: Lajer Ügyvédi Társulás (Lajer Attorneys Partnership)

Registered office and mailing address: 1024 Budapest, Lövőház utca 30.

E-mail: DPO.LVC@lajer.net

Definition of the terms used in this Information document

We have summarised the most important terms used in the Information document below.

Personal Data: any piece of information relating to an identified or identifiable Player. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, a number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The Controller collects the personal data of the Player indicated separately herein for each purpose of data processing.

Processing: any operation or the totality of operations performed on the data, irrespective of the procedure applied; in particular, collecting, recording, registering, classifying, storing, modifying, using, querying, transferring, disclosing, synchronising or connecting, blocking, deleting and destructing the data, as well as preventing their further use.

The data provided by the Player are processed by LVC Diamond Játékkaszinó Üzemeltető Korlátolt Felelősségű Társaság [concise name: LVC Diamond Kft.; registered office and mailing address: 1088 Budapest, Rákóczi út 1–3. III. em.; registration number: 01-09-194087 [registered by the Company Registry Court of the Budapest-Capital Regional Court]; mailing address: 1088 Budapest, Rákóczi út 1–3. III. em.; VAT number: 25002889-4-44; e-mail: info@vegas.hu], i.e. only LVC Diamond Kft. makes and executes decisions concerning the personal data of the Player. The Controller also functions as the:

Data Subject: natural person identified or identifiable based on any information (hereinafter: Player).

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Filing System: any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.

Personal data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Cross-border processing of personal data:

Supervisory Authority (in privacy issues): an independent public authority which is established by a Member State pursuant to Article 51 of the GDPR.

Hungarian National Authority for Data Protection and Freedom of Information, Nemzeti Adatvédelmi és Információszabadság Hatóság (address: 1055 Budapest, Falk Miksa utca 9–11.; mailing address: 1363 Budapest, Pf. 9; e-mail: ugyfelszolgalat@naih.hu; website: http://naih.hu; phone: +36 (1) 391-1400) (hereinafter: Authority).

Supervisory authority concerned: a supervisory authority which is concerned by the processing of personal data because:

Data transfer: ensuring access to the data for a third party.

Chat service: service available for use within the customer service of the online casino, primarily for the purposes of general information exchange between the Controller and the Player. However, if the Player’s identity is clearly established, it is suitable for using identical services with those offered by the phone customer service.

Chatbot: The Player can use the Chatbot within the Chat service in order to get information. The Chatbot is primarily suitable to answer general questions, without identifying the Player. Upon the request of the Player, the Chatbot can redirect to a customer service administrator, and in this case, the e-mail address of the Player will be requested from the Player for identification purposes.

E-Commerce Act: Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.

Consumer Protection Act: Act CLV of 1997 on consumer protection.

Gambling Authority: Supervisory Authority of Regulatory Affairs (1123 Budapest, Alkotás utca 50.)

Business Advertising Act: Act XLVIII of 2008 on essential conditions of and certain limitations to business advertising activity.

GDPR: regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Player: any natural person who is at least 18 years old, and

Online Casino: the online casino operated by the Controller, based on the Gambling Act and the applicable legislation, accessible on the online casino website (the Vegas.hu website). According to the terms used in the EULA, each software is considered part of the online casino website.

Game Organisation Decree: Decree 5/2021 (XI. 21.) SZTFH on the detailed rules of responsible game organisation (and any amendments in effect thereof).

SZTFH Decree: Decree 20/2021 (X. 29.) SZTFH on the implementation of tasks concerning the authorisation, organisation and control of certain gambling activities (and any amendments in effect thereof).

Money Laundering Act: Act LIII of 2017 on the prevention and combating of money laundering and terrorist financing.

Registration: data recording and high-level client due diligence procedure (according to the terms used in the Money Laundering Act) commencing with the filling in of the “registration form” (and provision of the username) according to the terms used in the EULA.

End-User Licence Agreement (EULA): the EULA of the Online Casino (and any amendments in effect thereof). The unabridged text of the EULA in effect is constantly and freely available on the online casino website.

Computer: any piece of electronic communications terminal equipment - pursuant to Section 188 item 21 of Act C of 2003 on electronic communications - available to the Player, such as computer equipment, mobile phone, computer, tablet that is suitable to receive so-called cookies (data packages).

Gambling Act: Act XXXIV of 1991 on gambling organisation (and any amendments in effect thereof).

Service: any service available for the Player’s use on the online casino website, including (but not limited to) any “Demo Game”, “Game”, “Service” pursuant to the terms used in the EULA, as well as any service available in the offline casinos of the Controller.

Principles of controlling data

You can find a summary of the principles of data controlling below, completely enforced by the Controller during the entire term of data controlling, and considered obligatory on behalf of the Controller.

Lawfulness, fairness and transparency:

Data processing can be based on:

Upon commencing registration, the Player acknowledges that compulsory data supply and data supply based on legislative provisions enabling optional data controlling are preconditions to finalising the registration, i.e. using the Service.

In the course of providing the Service, the Controller collects the processed personal data from the Player. Processing of the personal data of the Player can only be performed for lawful and fair purposes, in a manner that provides transparency for the Player. The Controller makes available the Information document in effect on the online casino website free of charges and obligations, continuously and publicly. The Controller shall not process the provided personal data for unfair purposes or any additional purposes not specified herein; in the course of its data processing (controlling) activities it constantly acts according to this policy and the applicable legislation.

Purpose Limitation:

Personal data may be processed by the Controller only for purposes specified in the Information document and the relevant legislation, including the Money Laundering Act, the Gambling Act, the SZTFH Decree and the Game Organisation Decree.

Storage limitation:

Personal data of the Player shall be stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. The Controller shall take the processing periods prescribed by law as basis and shall in any case retain the data for the required mandatory period, and for certain processing operations may specify a longer processing period. Personal data processed exclusively according to Article 6 (1) item a) of the GDPR, based on the explicit and voluntary consent of the Player shall be processed by the Controller until the Player requests erasure or revokes consent. Personal data processed according to the Money Laundering Act, unless otherwise regulated by law or this Information document, shall be preserved by the Controller for 8 years after the termination of the business relationship with the Player, in each case (pursuant to Section 56-57 of the Money Laundering Act). The Controller shall process the data controlled in the course of the ban records specified in Section 1 (5c) of the Gambling Act and also herein, for 6 years after the ban is ordered.

Regarding the Controller and the Player, the finalisation of the Player’s registration at the Controller, as the organiser of the Online Casino (LVC Diamond Kft.) shall constitute establishing business relationship (Money Laundering Act Section 3 item 35 point b); Section 6 (1) point a)).

The business relationship of the Controller and the Player is terminated when the Player initiates the termination of his contract established through registration for participating in online casino games, and as the result thereof, the Player’s account is terminated. In case the Player intends to re-register, he can do so pursuant to the provisions of the EULA of the Controller, with the renewed recording of his personal data.

Pursuant to the provisions of Section 56-57 of the Money Laundering Act, upon the request of the Gambling Authority, the authority operating as the financial information unit, the investigating authority, the office of the state attorney and the court, the Controller shall preserve data for the term specified in the request, but no more than 10 years (Money Laundering Act Section 58 (1)).

The 8-year data preservation period specified in the Money Laundering Act may be extended based on the request of an authority, in case the data, document specified therein is necessary for conducting ongoing or future authority proceedings. Following the final decision or the failure of initiating the planned proceedings the Controller shall remove the personal data from its records (Money Laundering Act Section 58 (2)-(3)).

Unless otherwise regulated by law or this Information document, the Controller shall preserve all personal data based on the Gambling Act, the SZTFH Decree or the Game Organisation Decree for 6 years after processing the data (Gambling Act Section 1 (7a)). If the Controller specifies a different period, then it shall be indicated in this Information document and the obligation for a minimum term of 6 years shall also be taken into account.

Data Minimisation:

The personal data processed by the Controller shall be adequate, relevant to the purposes for which they are processed; the Controller shall only process personal data that are absolutely necessary. It is the objective of the Controller to only request consent of the Player for processing personal data that are absolutely necessary for providing the Services at the highest possible level (GDPR Article 6 (1) item a)). At all times, these are personal data that are actually required for the use of the Service. The recording and processing of any additionally processed personal data is required by law or performance of the contract.

Accuracy:

In order to provide Services at the highest possible level, and also to comply with legislative obligations, it is the objective of the Controller to ensure that the recorded personal data are continuously kept updated (Money Laundering Act Section 12 (1)), and the Controller takes all reasonable efforts to ensure that at all times. The Player shall also support the accuracy of the data, and thus during the existence of the business relationship he shall inform the Controller within five business days after receiving information about any changes to the data provided during the customer due diligence according to the Money Laundering Act.

Principle of Data Protection (integrity and confidentiality):

The Controller lays special emphasis on protecting the personal data provided and the private sphere of the Player. The Controller shall ensure the security of personal data at all times, and make arrangements for and carry out data processing operations in a way so as to ensure full respect for the right to privacy of data subjects in due compliance with regulations on data protection and confidentiality. In order to ensure the high level protection of data, the Controller shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures for ensuring the protection of the rights of the Players (GDPR Article 28 (1)). Personal data shall be protected by the Controller through suitable measures against unauthorized access, alteration, transmission, public disclosure, deletion or destruction, as well as damage and accidental loss, and to ensure that stored data cannot be corrupted and rendered inaccessible due to any changes in or modification of the applied technique (including password protection, encryption methods, restoration from backup, in case of data loss).

Purposes of processing

The ranges of cases (purposes of data processing) applied in practice to process the personal data of the Player are summarised below.

Processing type: Preliminary registration

Purpose of processing: the prospective Player can opt for preliminary registration preceding the finalisation of his registration. Upon the preliminary registration, in the course of the registration process required for the use of the service, the Controller creates a technical user account for the person performing the registration. Until the registration is finalised, the registrant has restricted access: he can log in to the user account, browse the contents of the website and access free demo games, but cannot participate in real cash games. During preliminary registration, the Controller does not carry out client due diligence fully, this will happen during registration.

Range of processed personal data: e-mail address, password, selected username, date of birth, statement on politically exposed status, statement of the registrant about being at least 18 years old, playing in his own name and providing the data for registration on his own behalf.

The legal basis for processing is the performance of the contract concluded by accepting the EULA in the preliminary registration process, by the Player and the Controller [GDPR Article 6 (1) point b)].

Processing period: if the registrant finalises the registration, processing of the data is performed according to the rules applicable to registration; if no finalised registration takes place, the Controller will process data for 8 years following the last login.

Processing type: Registration

Purpose of data processing: the Controller registers the Player in order to carry out client due diligence measures specified in the act on the prevention and combating of money laundering and terrorist financing, and to provide player protection.

Name of personal data

[GDPR Article 6 (1) point c)]

1.

surname and forename

Money Laundering Act Section 7 (2) point aa);

Gambling Act Section 29/H (1) point a)

2.

birth surname and forename

Money Laundering Act Section 7 (3) point ab);

Gambling Act Section 29/H (1) point a)

3.

place and date of birth

Money Laundering Act Section 7 (2) point ad); Section 17 (1); Gambling Act Section 29/H (1) point e)

4.

mother’s name

Money Laundering Act Section 7 (2) point ae); Section 17 (1); Gambling Act Section 29/H (1) point a)

5.

address (or place of abode, if the address is not in Hungary)

Money Laundering Act Section 7 (2) point af); Gambling Act Section 29/H (1) point b)

6.

nationality

Money Laundering Act Section 7 (2) point ac); Gambling Act Section 29/H (1) point c)

7.

type and number of the personal identification document

Money Laundering Act Section 7 (2) point ag); Gambling Act Section 29/H (1) point d)

8.

photo of the Player in case of data query from a public register

Money Laundering Act Section 7 (1)

9.

in case of Hungarian nationals:

personal identification document + official certificate of the permanent address, only the side without personal identification (address card) (the latter only if the home address is located in Hungary).

driver’s licence card + address card (the latter only if the home address is located in Hungary) or

passport + official certificate of the permanent address, only the side without personal identification (address card) (the latter only if the home address is located in Hungary);

for Hungarian nationals providing a foreign address, we request a document certifying the foreign address to be uploaded as well.

Money Laundering Act Section 7 (3) point aa)

10.

in case of foreign nationals:

official certificate of having a home address in Hungary (only the side without personal identification if an address card is presented), if the home address is located in Hungary

Money Laundering Act Section 7 (3) point ab); Gambling Act Section 29/H (1) point b)

11.

in case of foreign nationals:

passport or personal identification document, provided that it embodies an authorisation to reside in Hungary, document evidencing the right of residence or a valid residence permit

Money Laundering Act Section 7 (3) point ab)

12.

copy of the document including the data specified in Section 7 (2)-(3) of the Money Laundering Act and the document specified in Section 7 (4) of the Money Laundering Act

Money Laundering Act 17. §

13.

digital copy of the personal identification document

Money Laundering Act Section 7 (8) and (8a)

14.

expiry of the personal identification document

Money Laundering Act Section 7 (5)

15.

in case of business relationship, the type, subject and duration of the agreement (EULA)

Money Laundering Act Section 10 (1) point a)

16.

The Player must provide a written statement to the Controller regarding whether pursuant to the laws of his country of residence he qualifies as a politically exposed person, close relative of a politically exposed person or a close associate of a politically exposed person. If the Player qualifies as a politically exposed person, his statement shall include the specification of which point in Section 4 (2)-(4) of the Money Laundering Act applies to him.

Money Laundering Act Section 9/A (1)

17.

If the Player qualifies as a politically exposed person, close relative of a politically exposed person or a close associate of a politically exposed person, his statement must include the information on the source of funds and the source of assets.

Money Laundering Act Section 9/A (2)

18.

Risk level classification of the Player (low, average, high)

Money Laundering Act Section 6/A and 10 (1) point b)

19.

e-mail address

SZTFH Decree Section 19 point a)

20.

username (unique)

SZTFH Decree Section 19 point b)

21.

existence and period of self-exclusion

SZTFH Decree Section 19 point c)

22.

subject and duration of the self-restriction measure

SZTFH Decree Section 19 point d)

23.

SZTFH Decree Section 20 (2)

24.

IP address of the Player’s computer

Gambling Act Section 29/M

25.

data relevant to the time, duration and location of using the Service

E-Commerce Act Section 13/A (2)

During registration, the Controller is obliged to record the following personal data regarding the type and performance of the Service provided:

Name of personal data

[GDPR Article 6 (1) point c)]

1.

address, surname and given name, birth name, mother’s name, place and date of birth

E-Commerce Act Section 13/A (1)-(2)

2.

player account and the entire data traffic thereof

Gambling Act Section 29/H (5), SZTFH Decree Section 24

3.

circumstances of performance (place, time, method)

Money Laundering Act Section 10 (1) point c)

4.

information on the purpose and planned type of business relationship

Money Laundering Act Section 10 (1) point d)

The data listed in this section (item 42) are hereinafter collectively referred to as: data provided during registration.

Duration of data processing:

The Controller retains the data provided during registration for the period set out in the applicable legislation, as follows:

Processing type: Player protection register

Purpose of data processing: the Controller shall verify whether the Player is under any restriction based on the data of the player protection register, before the registration of the Player and upon each online login instance following registration. The Controller shall inform the Player about denying registration based on the player protection register in e-mail.

Range of processed personal data: surname and forename, birth surname and forename, mother’s name, place and date of birth, type and number of personal identification document, home address. The Controller may access the player protection register for the sole purpose of fulfilling its verification obligation, using an electronic excerpt. The excerpt contains a non-reversible alphanumeric code generated from personal data. The Supervisory Authority of Regulatory Affairs (SZTFH) provides the Controller with the procedure for generating the alphanumeric code in an electronic form. Using the query, the Controller can compare the alphanumeric code generated from the personal data of the Player with the alphanumeric code included in the excerpt. If the two codes match, the Controller denies the registration of the Player, or provides no opportunity to play for the registered Player.

Legal basis for data processing: compliance with a legal obligation [GDPR Article 6 (1) point c)]. Compliance with the legal obligation is required pursuant to Section 1 (6) of the Gambling Act and Sections 7, 8, 20 of the Game Organisation Decree.

Processing period: time of verification and the notice sent to the Player is stored by the Controller for 5 years.

Processing type: Phone communication

Purpose of data processing: ensuring communication with clients, communication with the Player. If the Player wishes to communicate via phone (as well), he can provide his mobile phone number for this purpose during registration.

Range of processed data: mobile phone number of the Player.

Legal basis for data processing: Consent of the data subject pursuant to Article 6 (1) point a) of the GDPR, the Player can disclose his phone number at his own discretion, if he wishes to.

Processing type: Enhanced customer due diligence, Foreign Player, client relationship

In the case of foreign national Players – pursuant to Section 7 (3) item (ab) of the Money Laundering Act – the Controller is obliged to record the following personal data: passport or personal identification document, in case it authorises residence in Hungary, the document certifying residence in Hungary or the document authorising residence, official certificate of the permanent address in Hungary (the side of the address card not carrying the personal identification number), in case the address is located in Hungary. The legal basis for this processing is compliance with a legal obligation to which the Controller is subject, according to GDPR Article 6 (1) point c).

In the course of registration, the Player enters his e-mail address. The Controller informs the data subjects pursuant to Article 13 (3) of the GDPR that it also processes the disclosed e-mail address for the purpose of providing customer services, in order to ensure that the Service can be provided to data subject at the highest level of standard. Processing period: till the termination of the contract. Legal basis for data processing: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. (It is in the legitimate interest of the Controller to provide its service at the highest possible level, to communicate with Players live and to be able to inform the Players about the service. The Controller has carried out the purpose test in a separate document.)

The Controller shall ensure that, with regard to the audited means of electronic communications as defined in the Money Laundering Act, the Controller shall, upon the Player's request, allow the Player to store data relating to his identification, authentication and declaration for a period appropriate to the purpose of data processing and to display the stored data in unchanged form and content. The Player shall send an e-mail with such subject to the ugyfelszolgalat@vegas.hu address to request information on the data recorded by the Controller about the Player in this regard.

Purposes of processing:

Verification of the personal identity of the Player using the entry card issued by the live casino operated by the Controller

In case during the registration, according to the provisions of the EULA, the verification of personal identification is performed using the entry card issued to the Player by the live casino operated by the Controller, then in addition to the data provided during registration, the number of the entry card issued to the Player by the live casino operated by the Controller is also recorded. This processing is optional, subject to the Player’s decision.

Identity verification of the Player through data query from a public register

If the Player wishes to carry out a verification of identity by means of data query from a public register during registration, according to the provisions of the EULA, the Player must take a picture of the document to be used for identification purposes and then take a photo of himself using the software that executes identification electronically. The identification software then uses artificial intelligence to compare and analyse the Player's image and the image in the document used for identification purposes. The software is able to compare the face with the image on the document and verify that the data match based on the unique characteristics. If identification is successful, the Data Controller shall, pursuant to Section 7 (7) of the Money Laundering Act and Section 29/H (2) of the Gambling Act, request data in electronic form from the register of personal data and addresses of citizens in order to verify the identity of the Player, to establish the correspondence of the data with the registration data and the validity of the identity document. Considering the fact that the above data are from data query from the relevant public register, in the verification check the Organiser considers these data approved (until any circumstances of reasonable doubt arise). Data obtained through data query from the public register remain in Hungary or an EEA member state.

Duration of data processing:

UAB "iDenfy" is the processor of the Controller for the verification of personal identification using data query from the public register. Procedure of data processing:

purpose: matching of the characteristics and security features of the document with the requirements applicable to the document and matching of the facial features of the photo image in the document with the facial features of the image captured by the audited electronic communication device for the purpose of verification of identity;

range of data used: photo image, photograph on identity document;

UAB “iDenfy” processes the data disclosed during data query from the public register for the verification of personal identification for up to 5 days.

During data processing, profiling and automated decision-making take place, but final approval is given by human intervention, and the Player may contact the online casino customer service in the event of unsuccessful identification.

Processing type: Initiating the payment of winnings

Purpose of data processing: payment of winnings to the Player. The Player can initiate payment of prizes in his player account, by providing his own bank account number as set out in the EULA.

Range of processed personal data:

Legal basis for data processing: Performance of contract [GDPR Article 6 (1) item b)].

Duration of data processing: 8 years after the termination of the business relationship.

Data transfer: the Controller transfers the Player's full name, the amount of money and currency to be paid and the bank account number to the bank managing the account in order to process the payment.

Processing type: Source of funds and assets

Range of processed personal data: the declaration on the source of funds and assets includes the following data: name, birth name, mother’s name, place and date of birth, address / place of abode, nationality, type and number of identification document, and also the statement on the source of funds used for gambling.

Data subjects: any Player who qualifies as a politically exposed person, close relative of a politically exposed person or close associate of a politically exposed person; who is requested to provide such statement based on a risk sensitivity factor by the Controller; also who qualifies as a client from high-risk third countries with strategic deficiencies.

Legal basis for data processing: compliance with a legal obligation - GDPR Article 6 (1) point c). The legal obligation is set out in Section 9/A, 10, 16/A of the Money Laundering Act.

Duration of data processing: 8 years after the termination of the business relationship (pursuant to Section 56 (2) of the Money Laundering Act).

Processing type: Suspected money laundering and terrorist financing

Purpose of data processing: compliance with reporting obligation.

Range of processed personal data: name, birth name, mother’s name, place and date of birth, nationality, address, identification document type, number and expiry date. (Based on Section 30 (2) item a) of the Money Laundering Act, in its report the Controller shall include the data pursuant to Sections 7 to 14/A of the act and the circumstances used as the basis of the report.)

Legal basis for data processing: compliance with a legal obligation - GDPR Article 6 (1) point c). The legal obligation is set out in Section 30 (1) points a) to b) of the Money Laundering Act.

Duration of data processing: 8 years after the termination of the business relationship (pursuant to Section 56 (2) of the Money Laundering Act).

Processing type: Controlling and reporting restrictive financial and pecuniary measures provided by the EU / UN Security Council

Legal basis for data processing: compliance with a legal obligation [GDPR Article 6 (1) point c)]. The legal obligation is set out in Section 3 (6) of Act LII of 2017.

Duration of data processing: 8 years after the termination of the business relationship.

Data transfer: Pursuant to Section 4 (1) of Act LII of 2017, the Controller shall report to the National Tax and Customs Administration all data, facts, circumstances suggesting that the subject of the financial and pecuniary restrictive measure has funds or financial assets in the territory of Hungary that are subject to the financial and pecuniary measure.

Processing type: record of the Player’s balance/account (hereinafter: player account)

The purpose of data processing is to create and maintain a player balance for the Player at the start of the Player's registration for the purpose of keeping a verifiable record of the events of the player balance.

Range of processed personal data:

Legal basis for data processing: performing the legal obligation pursuant to Article 6 (1) point c) of the GDPR. The legal obligation is set out in Section 29/H (5) of the Gambling Act and Sections 23, 24, 25, 26 of the SZTFH Decree.

Personal data according to this section are processed by the Controller for 8 years after the termination of the business relationship.

Processing type: Records on the validity of the official identification document

The purpose of data processing - in accordance with the provisions of the Money Laundering Act (Sections 7, 10, 17), the Gambling Act (Section 29/H) and the Game Organisation Decree - is to carry out high-level client due diligence measures (Money Laundering Act Section 16-17), to provide player protection (Gambling Act Section 29/H) and to satisfy the principle of data quality (Money Laundering Act Section 11).

The Controller processes these personal data in order to perform legal obligations, based on the legal basis of legal obligations set forth in the legislation specified in point b) (GDPR Article 6 (1) point c)).

Processing type: Keeping of server log/backup server log

The purpose of data processing is to ensure the logging process of the Online Casino server so that the chronological order of events and their recording can be accurately determined at all times.

Legal basis of processing: performing the legal obligation pursuant to Article 6 (1) point c) of the GDPR. The legal obligation of the controller is set out in Annex 2 of the SZTFH Decree item A) point 6, as well as item B) points 7, 8 and 9.

Duration of data processing: The Organiser shall retain the processed personal data for 6 years from the generation of the data.

Data transfer: the Processor, as the operator of the technical IT system for online casino gaming, must provide the Gambling Authority with access to the logs in accordance with Annex 2, item B), point 9 of the SZTFH Decree.

Purpose of processing

Processed personal data

Duration of data processing

Customer service administration, collection of information and problem-solving using chat service (including objections to changes of the EULA).

performance of contract

(GDPR Article 6 (1) item b)).

i. Name;

ii. Username;

iii. IP address;

iv. E-mail address;
v. Chat transcript.

5 years following recording the personal data

Gathering of information using chatbot service

Legitimate interest of the Controller

(GDPR Article 6 (1) point f)).

i. Name;

ii. Username;

iii. IP address;

iv. E-mail address;
v. Chat transcript.

5 years following recording the personal data

Enforcing ban from the chat service, as set out in the EULA.

Legitimate interest of the Controller

(GDPR Article 6 (1) point f)).

i. Name;
ii. Username;

iii. IP address;
iv. E-mail address;

v. Recording conduct of the Player violating provisions of the EULA;
vi. Chat transcript.

5 years following recording the personal data

Provision of chat communication during live games broadcast from the online studio.

performance of contract

(GDPR Article 6 (1) item b)).

i. Name;

ii. Username;

iii. IP address;
iv. E-mail address;
v. Chat transcript.

5 years following recording the personal data

Enforcing ban from chat communication service in live games broadcast from the online studio.

Legitimate interest of the Controller

(GDPR Article 6 (1) point f)).

i. Name;

ii. Username;

iii. IP address
iv. E-mail address;
v. Recording conduct of the Player violating provisions of the EULA;
vi. Chat transcript.

5 years following recording the personal data

Processing type: Records on handling complaints

Purposes of data processing: Management of complaints arising in relation to services provided by the Controller.

Range of processed personal data:

Result of investigation following the complaint, response to the complaint.

Legal basis for data processing: Compliance with legal obligation pursuant to Article 6 (1) point c) of the GDPR. The legal obligation is set out in Section 17/A of the Consumer Protection Act.

The personal data processed with regard to the complaint shall be preserved by the Controller with the records taken on the complaint and a copy of the reply for three years, and these shall be presented to the controlling authorities upon request, in accordance with the provisions of Section 17/A (7) of the Consumer Protection Act. If requested, the Controller shall present the stored complaint to the Consumer Protection Authority.

Processing type: Implementing and recording self-restriction measures

The purpose of data processing is to ensure the following self-restriction measures relevant to player protection:

Range of processed personal data:

The legal basis of processing is performing the legal obligation pursuant to Article 6 (1) point c) of the GDPR. The legal obligation is set out in Section 29/I of the Gambling Act and Sections 11 to 13 of the Game Organisation Decree.

Duration of processing: processing performed to ensure the self-restriction measure is aligned with the duration of the self-restriction measure, otherwise the Controller processes data for 8 years after the termination of the business relationship.

Data transfer: pursuant to Section 13 (2) of the Game Organisation Decree, the Controller keeps monthly records of self-restriction measures, the numbers and durations thereof and the cancellation of self-restriction measures. The Controller provides remote access to its records for the Gambling Authority by no later than the 20th day after the subject month.

Processing type: Prize certificate

Range of processed personal data:

The copy of the prize certificate intended for the Controller shall be processed by the Controller for 8 years pursuant to Section 169 (1) of Act C of 2000 on accounting.

Processing type: Ban records

The purpose of data processing is the effective implementation of denying logging in to the online casino website and participating in gambling (Service) to the Player (hereinafter: ban) who committed a material violation of the EULA.

Range of processed personal data:

Duration of data processing: The Controller can process the data of the ban records for 6 years after ordering the ban, and shall remove them after the 6-year duration expires (Gambling Act Section 1 (5c)).

The Controller can transfer the data of the ban records to the Controller and other gaming casinos operated by the Controller (as an organiser of gambling), and the ban relevant to the Player can also be applied in these casinos (Game Organisation Decree Section 25 (2)).

The legal basis of processing is performing the legal obligation pursuant to Article 6 (1) point c) of the GDPR. The legal obligation is set out in Section 1 (5c) of the Gambling Act and Section 25 (9) of the Game Organisation Decree.

Processing type: Disclosure of the username for promotional purposes

Purpose of data processing: The Controller discloses the usernames of Players using its online service with third parties and publishes them on its own interfaces and the interfaces of third parties, for the purposes of recording and publishing promotion offers, bonus rankings and winners, for the publication of occasional and regular winners/winnings with a marketing purpose, as well as for the interests of display and broadcast of certain online games available under the service (including but not limited to the Youtube.com and Twitch.tv platforms).

Range of processed personal data: under processing for this purpose, the Controller only processes and discloses the username of the Player. According to section 5.1.1 of the EULA the Player shall select a username that does not contain any reference to personal data of the Player.

Legal basis for data processing: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. (It is the legitimate interest of the Controller to promote its service (including through promotions) and to make its service convenient, live and transparent for Players. The Controller has carried out the purpose test in a separate document.)

The duration of this processing ends upon objection of the Player, but no later than until the purpose is achieved or the publication page is operational.

The Player may object to the publication of the username for promotional purposes at any time, free of charge, by contacting the Controller. In the event of an objection, the controller shall no longer process the relevant personal data in order to achieve the purpose of the processing. The objection may be communicated by the data subject via multiple channels, including:

With regard to this purpose of processing, the Controller involves processors (under a separate legal relationship) that act with the purpose of providing the online (web) broadcast, in addition to processing the personal data specified in the scope of this purpose. The persons/entities acting as such processors may be subject to change depending on the web interface and the game type, and therefore their fixed identification is impeded, in accordance with the WP260 guidelines. In order to ensure a high degree of conformity with Article 14 of the GDPR, the Controller identifies the affected processors according to their activity, and provides the opportunity for the data subjects to separately request information on the matter.

Processing type: Sending of newsletter containing general and personalised marketing offers

The purpose of the data processing is to provide general and personalised information, including news about current events, bonuses and promotions of the Controller's online and offline casino and betting services, to those Players who have given their prior and explicit consent. The Player can determine the channels through which communication is made (e-mail, SMS, app push notification, web push notification).

Processed personal data: name, e-mail address and/or phone number.

Legal basis for data processing: the legal basis for sending marketing offers is the voluntary, explicit and informed consent of the Player, pursuant to Article 6 (1) point a) of the GDPR, in accordance with Section 6 (1) of the Business Advertising Act. Processing period: processing is performed until consent is withdrawn (unsubscribe), till a request for self-exclusion is made or, in the lack of the former, until the customer relationship is terminated or self-exclusion expires.

In the framework of sending offers of marketing purposes, the Controller may also advertise services not offered for persons under the age of 18 (pursuant to Section 1 (5b) of the Gambling Act) or which may involve the restriction pursuant to Section 8 (1) of the Business Advertising Act. Only such persons can subscribe to the marketing offers who have provided statement on being at least 18 years old.

Processing type: remarketing enquiries

Purpose of data processing: remarketing enquiries enable Vegas.hu to display advertisements for its services to the Player when visiting a website on the list managed by Ads Interactive FZCO and Adform A/S, provided that the Player consents to the marketing communications upon registration.

Processed personal data: e-mail address, IP address, cookies.

Data transfer: with regard to the data processed during remarketing, the involved service provider (Ads Interactive FZCO and Adform A/S) is considered a data processor.

Profiling for the assessment of personal characteristics

Range of processed personal data: the personal data provided by the Player during registration, online reference number, previous games, transactions, data from previous games and data generated during the use of Vegas.hu.

Legal basis for data processing, i.e. profiling: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. It is the legitimate interest of the Controller to increase its profitability and, in this context, to promote its services and encourage Players to continue to use the services it provides. The Controller has carried out the purpose test in a separate document.)

The Player may object to profiling at any time, free of charge, by way of contacting the Controller. In the event of an objection, the controller shall no longer process the relevant personal data for the purpose of profiling. The objection may be communicated by the data subject via multiple channels, including:

Duration of processing: profiling is performed till the objection of the data subject, or (in the lack thereof) the termination of the client relationship.

During the registration of the Player, the controller assigns the Player an online reference number containing no personal data, accessible in his user account after registration.. When the Controller carries out analyses for the purpose of improving its service, it uses the online reference number to ensure that the analysed data cannot be linked to a specific person, but only the activity of users organised in segments and their usage of the service can be analysed.

Processor: The service providers used in the processing of data during profiling and in sending marketing offers to the target group specified in connection with the processed data (Symplify Technologies AB and Flows Ltd.) are considered data processors.

Processing type: Processing relevant to the use of social media websites

The Controller operates its Facebook page to publish news relevant to its operation, information, current campaigns and games.

Purpose of data processing: providing information to Players on the Controller’s Facebook page, promoting the activities of the Controller.

Range of processed data: name, comment, review.

Legal basis for data processing: consent of the data subject [GDPR Article 6 (1) point a)]. (Withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal.)

Data subjects: fans (people who like the page), followers, commenters who have a Facebook profile.

Duration of data processing: until deletion upon the request of the data subject, but no later than the termination of the social media page.

Facebook page of the Controller: https://www.facebook.com
/vegaskaszino

For the use of the Facebook page the Data Subject must have his own account on the social media website. Operators of social media websites perform processing as independent controllers, according to the terms set out in their own privacy information documents. The controller for Facebook is a Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, D2 Dublin Ireland). By using Facebook, the data subject declares to have read and accepted the proprietary conditions of use and privacy information document of Facebook.

https://www.facebook.com
/policy.php

Facebook receives the information that the data subject wishes to post on the social media page of the online casino, with the data subject's IP address. Rights related to the data (name, photo, comment, rating) that the Data Subject wishes to post, rights can be directly exercised vis-à-vis Facebook, or the Data Subject can contact the Controller.

The Controller can initiate the deletion of data that violate the reputation or rights of the Controller or any third party.

On 10 July 2023, the European Commission adopted its adequacy decision on the EU-US Data Protection Framework ("DPF"). The Decision concludes that the United States provides an adequate level of protection for personal data transferred from the EU to US entities participating in the DPF and therefore personal data can be transferred from the EU to US entities participating in the DPF without the application of additional data protection safeguards. Meta is considered a DPF participating organisation.

Processing type: Security check of documents used for registration

The Controller is entitled to carry out the following processing and take the following measures, as set out in the EULA, in order to detect and prevent registration with falsified data; prevent the misuse of bonuses resulting from registration with false data::

65/A If doubts arise about the authenticity of a document unknown to the Controller, for security reasons the Controller shall compare the photo uploaded during registration, using the TinEye application, with ID photo images in a similar format uploaded to publicly available databases.

Range of processed data: photo of the document used for registration and personal data specified on the document.

Data subjects: person initiating registration.

Legal basis for data processing: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. (It is the legitimate interest [business and economic interest] of the Controller to ensure the security of the service, the fairness of online games and protection of the Players. The Controller has carried out the purpose test in a separate document.)

Duration of data processing: Successful objection of the Player, but no later than the day of conducting the test. Processor: TinEye (223 Queen Street East Toronto, ON M5A 1S2, Canada). The Processor is subject to PIPEDA, so the transfer of data is based on an adequacy decision pursuant to Article 45 of the GDPR, given that the Canadian legal system ensures the level of protection of personal data required by the European Union.

65/B For security reasons, the Controller is entitled to request from the person initiating registration or the Player a photograph showing the Player's face and the identification document held next to his face.

Range of processed personal data: photo.

Data subjects: person initiating registration, Player.

Legal basis for data processing: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. (It is the legitimate interest (business and economic interest) of the Controller to ensure the security of the service, the fairness of online games and protection of the Players. The Controller has carried out the purpose test in a separate document.)

Duration of data processing: Successful objection of the Player, but no later than 8 days after the submission of the photo.

Processing type: Client satisfaction survey

Purpose of data processing: the Controller may contact registered Players for the purpose of a client satisfaction survey in order to gain a better overview of the use of its services and the opinions of its customers, and to improve the quality and use of its services.

These contact efforts are made by e-mail. If the data subject does not wish to take part in the survey, he may disregard the request and can object to the processing at any time, free of charge. In the event of an objection, the Controller shall no longer process the relevant personal data.

Range of processed data: name, e-mail address, answer to the questions. The answers received may be evaluated as statistical data or in a personalised form.

Legal basis: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. (The legitimate interest of the Controller is to maintain its services and to increase the quality and use of its services, which is a business and economic interest. The Controller has carried out the purpose test in a separate document.)

Processing period: until objected by the data subject, in the lack thereof, till the completion of the processing purpose, but for no more than 1 year.

Processing type: Sending system messages

Range of processed personal data: Player’s name and e-mail address.

Legal basis: Legitimate interest [GDPR Article 6 (1) point f)]. The Controller has carried out the purpose test in a separate document.

Duration of data processing: 5 years after sending the message (general civil law limitation period).

Processing type: Recording calls received at the central phone line:

Purpose of processing: Preventing unlawful actions and ensuring lawful operation.

Range of processed personal data: Time of call (day, hour, minute); caller number, extension called; voices of the participants in the conversation, any personal data/information spoken during the conversation.

Legal basis: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. The Controller has carried out the purpose test in a separate document.

Processing period: 7 calendar days after the recording was made. If the data subject objects to the processing of his personal data and there are no overriding legitimate grounds, the Controller will delete the personal data.

If any other authority - including the Police - sends request to the Controller, the requested information will be disclosed by the Controller based on legislative obligation. In certain cases, the Controller may initiate the proceedings of relevant authorities.

Processing type: Ensuring the fairness of the games

Purpose of processing: Preventing, identifying and combating fraud and abuses.

Legal basis: legitimate interest of the Controller [GDPR Article 6 (1) point f)].

(It is in the legitimate interest of the Controller to prevent fraudulent abuse attempts that cause financial damage. Furthermore, it is in the Controller's legitimate interest to ensure the fairness of the game, safe operation and the trust of other Players in the game.)

The Player can object processing at any time, free of charges.

Duration of data processing: Screening and identification of fraud and abuse continues until the termination of the contract with the Player. In the case of sanctions for identified fraud and abuse, 5 years from the date of identification.

If the identified fraud or abuse also constitutes an offence under Act C of 2012 on the Criminal Code, the Controller may file an official report and forward data necessary for the investigation to the competent investigative authority pursuant to section 69 herein.

Processing type: Provision of promotional services

Purpose of processing: Organising and conducting promotions within the framework of promotional service, verifying compliance with the conditions, payment of prizes.

Range of processed personal data: name, vegas.hu player ID, e-mail address, data enabling verification of compliance with the conditions of the promotion, data relating to financial transactions for the payment of the prize.

Legal basis: Performance of contract [GDPR Article 6 (1) item b)]. The Player may set up to participate in the promotions offered by the Controller in the framework of promotional services in his user account, which generates a contract to which the Player is party. The Player can change this setting at any time, and thus the promotional service will be terminated with immediate effect.

Duration of data processing: 5 years after the termination of the promotional service.

Processing type: processing saved bank card data

Purpose of data processing: in order to provide a more comfortable experience of depositing money to the account, the Player can save bank card data in cases of the SimplePay and K&H financial service providers. This ensures that the Player does not have to repeatedly enter its bank card details upon the next deposit to the account.

Range of processed personal data: Player’s name, first 6 and last 4 digits of the bank card number.

Use of Cloudflare

Purpose of processing: In order to enhance security and optimise the display speed of the www.vegas.hu website, the Controller uses the Cloudflare content provider network (“CDN”). A CDN helps website content - especially large media files such as graphics and text - to be made available faster through a geographically distributed network of servers, and includes security features (such as DDoS protection) to protect the website.

Range of processed personal data: The data transmitted through the CDN network are those which the Player provides to the Controller when using the website. Data are transmitted in encrypted form.

Legal basis for data processing: Legal basis for using the CDN: legitimate interest of the Controller [GDPR Article 6 (1) point f)]. It is in the legitimate interest of the Controller to provide its online services in a secure and efficient manner. The Controller has carried out the purpose test in a separate document.

Processing period: till achievement of the purpose of processing, but not longer than 1 year. The Player can object processing at any time, free of charges.

Processor of the Controller during the use of the CDN is Deimos Cloud (pty) Ltd. (registered office: 50 Canterbury street, Cape Town 8001). Data processing takes place mainly in the European Union. In the course of providing the service, data may be transferred to a third country only if it has been established, pursuant to Article 45 of the GDPR, that the level of data protection in that country is equivalent to the level of data protection in the EU or if the recipient of the data ensures an adequate level of data protection by other means provided for by the GDPR.

Use of cookies

Data transfer

The Controller may only transfer the personal data of the Player to third parties in the cases specified below.

Bank card deposit to the player account using the OTP SimplePay application

Purpose of processing: The purpose of Processing is to ensure the payment to the Player's account by means of a payment transaction through the OTP Simple Pay system.

Range of processed personal data: surname, first name, country, phone number, e-mail address, IP address of the Player used to carry out the transaction, transaction data (amount of the transaction, date of execution, address data (country, city, street))

Legal basis: Performance of contract [GDPR Article 6 (1) item b)].

Processing period: 8 years pursuant to Section 169 (1) of Act C of 2000 on accounting.

Processor: During the payment process, the Player is redirected to the secure payment site of OTPSimplePay ("OTP SimplePay") operated by SimplePay Zártkörűen Működő Részvénytársaság (“SimplePay Zrt.”), where the payment will be made. Upon redirection, the Controller transfers the following data to SimplePay Zrt. as the data processor in order to process the payment: (i) surname; (ii) first name; (iii) country; (iv) phone number; (v) e-mail address.

Contact details of SimplePay Zrt.: registered office: 1138 Budapest, Váci út 135-139. B. ép. 5. em.; registration number: 01-09-174466; e-mail address: ugyfelszolgalat@otpmobil.com; website address: www.otpmobil.hu. The OTP SimplePay privacy policy is available at: https://simplepay.hu/adatkezelesi-tajekoztatok/

When the Player enters the OTP SimplePay application, SimplePay Zrt. shall be considered an independent controller with regard to the personal data provided in the app for payments by card. During payment by bank card, LVC Diamond Játékkaszinó Üzemeltető Korlátolt Felelősségű Társaság does not perform any data processing, data collection or other processing activities, and does not have access to these personal data. After successful payment, the OTP SimplePay application redirects the Player to the Controller's website and informs the Controller about the transaction data (amount of the transaction, date of execution, address (country, city, street)).

Data transfer based on official request:

If any other authority - including the National Tax and Customs Administration - sends request to the Controller, the requested information will be disclosed based on legislative obligation.

In certain cases, the Controller may initiate the proceedings of relevant authorities.

Data transfer to the affected authorities:

Pursuant to the money laundering prevention policy of the Controller, in case of circumstances suggesting money laundering, it shall inform the relevant authorities in each case, including the National Tax and Customs Administration Hungarian Financial Intelligence Unit or the Gambling Authority. Pursuant to Section 1/A (1) of the Gambling Act, the Controller is required to provide access for the gambling authority to the records of the processed personal data, in order to perform the tasks specified in Act XXXII of 2021 on the Supervisory Authority of Regulated Activities. Pursuant to Section 17/A (7) of the Consumer Protection Act, the handled complaint shall be presented to the Consumer Protection Authority by the Controller, upon request.

Data transfer for confirming financial transactions:

In order to control the validity of financial transactions, and to identify any possible financial abuses, the Controller is authorised to transfer data to K&H Bank Zrt. (registered office: 1095 Budapest, Lechner Ödön fasor 9.) and K&H Pénzforgalmi Szolgáltató Kft. (registered office: 1095 Budapest, Lechner Ödön fasor 9.) (hereinafter: K&H) based on legitimate interest of the Controller [GDPR Article 6 (1) point f)], pursuant to the provisions of the agreement concluded with K&H.

Upon request submitted in writing, the Controller discloses with K&H the data certifying the identity of the Player, as well as data that certify the completion of the specific transaction subject to the report/complaint (payment transaction receipt). Scope of personal data transferred in this regard: name; address; number of official document suitable to confirm personal identity (personal identification document, driver’s licence or passport) and the official certificate of the permanent address (address card), userID.

Transfers to law office:

In specific cases, including requests and complaints from the data subjects, the Controller cooperates with the Lajer Ügyvédi Társulás (Lajer Attorneys Partnership, 1024 Budapest, Lövőház utca 30.) as the data protection officer of the Controller. The law office processes the disclosed personal data in accordance with the applicable legislation.

Processors involved in providing the service:

Game management: Finnplay Technologies Oy; [Miestentie 9, 02150 Espoo, Finland] – It accesses the data stored in the Controller’s system for providing the IT background of certain games and management as well; privacy policy: https://www.finnplay.com/privacy-policy

Gaming service providers:

the above companies operate certain games available on the online casino website, and therefore as data processors, these companies process certain personal data of the Data Subjects using the specified games;

Chat service: LiveChat Inc. [One International Place Suite 1400 Boston, MA 02110-261, United States of America] – it operates the chat service available on the online casino website as a third party agent, and therefore this company qualifies as a data processor regarding the information transferred as regards the chat service.

The Controller informs data subjects that the processing of personal data in relation to the chat service involves the transfer of personal data to a third country (the United States), which is however not considered risky, taking into account that the processor applies binding corporate rules under Article 47 of the GDPR (https://www.livechat.com/legal/data-processing-addendum/).

Segmentation of personal data in connection with profiling and personalisation and sending of marketing offers:

- Symplify Technologies AB (registration number: 556589-7294, registered office: Drottninggatan 55, 111 21 Sweden, Stockholm; phone: +46 8 505 721 00; email; info@symplify.com; privacy policy: https://symplify.com/privacy-policy/).

- Flows Ltd (registration number: 13303855, registered office: C/O Rw Blears Llp, Suite 32 Brookside Business Park, Cold Meece, Stone, England; privacy policy: https://flows.world/privacy-policy/ ).

Remarketing-purpose enquiries:

Data collection with statistical purpose: Google Analytics - Google Ireland Limited (registration number: 368047; Gordon House, Barrow Street Dublin 4, Ireland; https://policies.google.com/terms?hl=hu).

Hosting service provider: Shock Media B.V. (Twentepoort Oost 18, 7609 RG Almelo, The Netherlands).

Identification using an audited communication device: the identification is carried out electronically by iDenfy (UAB "iDenfy", registered office: Baršausko street 59, 51423 Kaunas, Lithuania; phone: +370 640 84466; email: dpo@idenfy.com; website: www.idenfy.com).

Compiling forms necessary for customer satisfaction feedback (item 66) and promotional services (item 70) data processing purposes, and statistical evalulation of the data provided: Survio s.r.o. (registered office: Hlinky 995/70, 603 00 Brno, Czech Republic, contact address: Hlinky 78a, Brno, 603 00, Czech Republic; privacy policy: https://www.survio.com/hu
/szemelyes-adatok-vedelme

Measurement and assessment of actions on the website in order to improve user experience (e.g. mouse clicks, mouse movements, keystrokes, scrolling activities and pages visited): Microsoft Clarity - Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Privacy policy: https://clarity.microdoft.com/privacy

The Controller also transfers personal data to the United Kingdom, in which case we inform you that the European Commission has issued an adequacy decision in relation to the United Kingdom (COMMISSION IMPLEMENTING DECISION of 28.6.2021 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom). The adequacy decisions have confirmed that personal data are also adequately protected in these countries.

Verification of unknown format foreign documents: TinEye (223 Queen Street East Toronto, ON M5A 1S2, Canada). The Processor is subject to PIPEDA, so the transfer of data is based on an adequacy decision pursuant to Article 45 of the GDPR, given that the Canadian legal system ensures the level of protection of personal data required by the European Union; privacy policy: https://tineye.com/privacy

Use of Cloudflare: Deimos Cloud (pty) Ltd. (registered office: 50 Canterbury street, Cape Town 8001). Privacy policy of this processor: https://www.deimos.io/privacy-policy

Rights of the Player in relation to data processing

The following is a summary of the Player's rights vis-à-vis the Controller in relation to the processing of his personal data.

Right of information and access by the data subject (GDPR Article 15):

Regarding the data subject rights of the Player relevant to data protection, he can contact the Controller via the contacts designated in this Information document and the Vegas.hu website. The Player shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning him are being processed, and, where that is the case, access to the personal data with the following scope.

Right to rectification (GDPR Article 16):

During the existence of the business relationship, the Player shall be based on Section 12 (3) of the Money Laundering Act - inform the Controller (via the customer service of the online casino) about any changes affecting his data provided during registration or subsequently updated, within 5 business days after receiving information thereof. In case the Player fails to report any changes to his personal data without delay, the Player shall be liable for any consequences thereof. In case the submitted personal data is deemed inaccurate, and the correct personal data is at theController’s disposal, the Controller shall rectify the personal data in question automatically.

Right to erasure (GDPR Article 17):

The data subject shall have the right to obtain from the Controller the erasure of personal data concerning him without undue delay, and the Controller shall have the obligation to erase personal data relevant to the data subject without undue delay, when one of the following grounds applies:

The Controller however is not required to erase the processed personal data in the case of the above circumstances, to the extent that processing is necessary:

Right to object (GDPR Article 21):

Right to restriction of processing (GDPR Article 18):

The Player shall have the right to obtain from the Controller restriction of processing where one of the following applies:

Right to data portability (GDPR Article 20):

The Controller shall comply with/respond to the exercise of the right to personal data processing without undue delay, but at the latest within one month of the receipt of the request. Taking into account the complexity of the request and the number of requests, this one-month time limit may be extended by a further two months by means of a reasoned communication to the Player exercising the right, within one month of the submission/receipt of the request to the Controller.

If the Controller does not take action on the above request of the Player, the Controller shall inform the data subject without delay and no later than within 1 month of receipt of the request of the reasons for not taking action, as well as on the possibility of lodging a complaint with the Authority and seeking a judicial remedy.

The Controller only reviews and answers the e-mail sent by the Player regarding data processing, if it is sent from the e-mail address provided by the Player during registration or subsequently updated (unless the Player claims in the message that his e-mail address is changed, or the provision of other data enables the personal identity of the Player to be clearly ascertained).

Right to Remedy

Initiating proceedings of the Authority: The Player shall have the right to notify the Authority and request an investigation alleging an infringement relating to his personal data, or if there is imminent danger of such infringement. The Authority shall carry out the investigation free of charge; the costs thereof shall be advanced and borne by the Authority. Having submitted a notification to the Authority may not entail any discrimination against the notifier. The Authority may reveal the person of the notifier only if the inquiry cannot be carried out otherwise. If so requested by the notifier, the Authority shall not disclose his identity even if the inquiry cannot be carried out otherwise (Freedom of Information Act Section 52). Contact data of the Authority:

Hungarian National Authority for Data Protection and Freedom of Information, Nemzeti Adatvédelmi és Információszabadság Hatóság (address: 1055 Budapest, Falk Miksa utca 9–11.; mailing address: 1363 Budapest, Pf. 9; e-mail: ugyfelszolgalat@naih.hu; website: http://naih.hu; phone: +36 (1) 391-1400)

Judicial enforcement of rights: in the event of any infringement of his rights, the Player may turn to court action against the Controller. The action shall be adjudicated before the regional court. The action shall be heard by the competent tribunal according to the registered office of the Controller. If so requested by the Player, the action may be brought before the regional court in whose jurisdiction the Player’s address or place of abode is located. Jurisdictions of the regional courts can be confirmed using the “Court finder” application on the www.birosag.hu website. The court shall hear such cases in priority proceedings (Freedom of Information Act Section 23).

Damages and restitution: The Controller shall be liable for any damage incurred as a result of unlawful processing or by any breach of data security requirements:

The Controller may be exempted from liability (regarding compensation or restitution) if it proves that the damage or the violation of the Player’s personal rights was caused by unavoidable reasons, beyond the scope of data processing. No compensation or restitution shall be paid where the damage or the violation of personal rights was caused by intentional or seriously negligent conduct on the part of the Player (aggrieved party) (Freedom of Information Act Section 24).

Data security

The Controller ensures the security of data processing according to the provisions of the Information Security Policy and Strategy. It takes the technical and organisational measures necessary to ensure the confidentiality (e.g. unauthorised disclosure, access), integrity (alteration, change, deletion) and availability (accessibility, restorability) of the personal data.

The Controller - among other means - applies the following to satisfy the above criteria:

Miscellany

Pursuant to Section 29/T of the Gambling Act, in the case of gaming casinos and online casinos operated by the Controller, the Controller may apply a single access control and identification system.

The laws of Hungary and the GDPR shall apply to the Information document.

To issues not regulated herein, the EULA of the Online Casino and the provisions of the applicable laws of Hungary shall be applied. This Information document shall be interpreted in accordance with the EULA (in effect), as well as the applicable legislative provisions and authority licences.

The Controller reserves the right to amend the Information document unilaterally at any time. Reasons for amending the Information document may especially include following up on legislative amendments, and introducing measures ensuring the increased protection of the Player’s rights and the security of the Service.

The Controller shall inform the Player about the amendments of the Information document, the entry into effect of the restated Information document (with amendments) and the accessibility thereof through system messages. The unabridged text of the Information document in effect is constantly and freely available on the online casino website.

Information on the right to object pursuant to Article 21 of the GDPR

Right to object: in each individual case, you have the right to object at any time to the processing of your personal data based on Article 6 (1) point f) of the GDPR (processing based on the balance of interests) - the same applies to profiling as defined in Article 4 (4) of the GDPR. If you exercise your right to object, we will no longer process your personal data unless there are legitimate grounds which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Objections should be addressed to: LVC Diamond Játékkaszinó Üzemeltető Korlátolt Felelősségű Társaság, as the Controller, and you can communicate your objection without any format requirements:

Effective from: 01/08/2025