Last updated: March 26th, 2021
1. The policy
1.4. Solvbet is committed to protecting the Client’s personal data. When processing personal data, Solvbet follows the rules stipulated in applicable data protection related legal acts, most importantly Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter the “GDPR”).
2. The controller
2.1. The data controller is Solvbet OÜ (registry code: 14927611). You can contact Solvbet via email at [email protected] or by sending regular post to Raua tn 4-12, 10124 Tallinn, Estonia.
3. The data purposes and legal grounds
3.1. Solvbet processes your personal data for the following purposes:
3.1.1. to provide you with the services offered by Solvbet. The legal basis for the processing of personal data is Article 6(1)(b) in the GDPR;
3.1.2. to make more of such services available to you where possible and appropriate. The legal basis for the processing of personal data is either Article 6(1)(b) or Article 6(1)(f) in the GDPR – the legitimate interest of Solvbet to offer additional services to the Client when appropriate;
3.1.3. for the purposes of security and control related to the service. The legal basis for the processing of personal data is Article 6(1)(f) in the GDPR – the legitimate interest of Solvbet to fulfill the information security requirements;
3.1.4. to satisfy regulatory and legal requirements. The legal basis for the processing of personal data is Article(1)(c);
3.1.5. to communicate offers, newsletters or other types of marketing material to you. The legal basis for this is either your consent (Article 6(1)(a) in the GDPR) or, in cases where you have subscribed to one of our channels on a social media platform, the legal basis is Article 6(1)(b).
3.2. Solvbet collects the following personal data:
3.2.1. your full name;
3.2.2. date of birth;
3.2.3. contact information (address, email address, phone number);
3.2.4. IP address;
3.2.5. If the Client uses an e-wallet, Solvbet will collect information about the full name and the email of the Client;
3.2.6. when the Client makes payments, Solvbet collects information about the billing details regarding the payment (full name, billing address, phone number, email address);
3.2.7. log information regarding your account’s confirmation, account creation date, and account deletion date.
3.3. Solvbet collects some metadata such as browser information in server logs in case of an issue or an attack on the service. For that reason, the IP address is also processed.
3.4. Please note that if the Client refuses to provide certain personal data to Solvbet, it may happen that the Client will not be able to use the service.
4. Time of storage
4.1. Solvbet stores the personal data of you only as long as it is necessary, in accordance with the aim of collecting the data. Please note that Solvbet stores billing information (including address and IP address) as long as required by law.
4.2. Solvbet will store your personal data accordingly:
4.2.1. Personal data which the Client has provided for account creation will be stored until the Client deletes its account.
4.2.2. Personal data for affiliation purposes will be stored until the Client is Solvbet’s affiliate.
4.2.3. Personal data which the Client has provided on social media: Solvbet will have access to this personal data during the time when the Client is a follower of Solvbet on the social media platform.
4.2.4. Personal data related to billing [A15] will be stored for seven years as of the end of the financial year when the transaction was recorded, according to accounting laws.
4.3. Metadata such as IP addresses and browser information will be removed 90 days after the collection.
5. Recipients and data processors
5.1. Solvbet does not disclose personal data to third parties without your consent, except to the supervisory authorities, accountants, and in events arising from law or in case needed for submission or in the processing of a claim against you.
5.2. Solvbet may use the services of other persons when this is necessary to maintain the Platform and/or provide the services of the Platform. In this case, Solvbet is engaging other parties as data processors (including the webmaster, accountant, social media manager). When Solvbet makes use of data processors, Solvbet shall comply with all the requirements stipulated in Article 28 of the GDPR. Solvbet will sign a data processing agreement with the data processors according to Article 28(3) in the GDPR.
6. Security measures
6.1. Solvbet has had a security audit from security experts to ensure that the data is as safe as possible.
6.2. Solvbet keeps your data safe by using organizational, physical, and technological measures.
6.3. The access to personal data is restricted and certain access rights are set.
7. Data location and transfer to third countries or international organizations
7.1. The data processing (including storing) takes place in Solvbet’s servers in Gravelines, France.
7.2. Solvbet does not transfer the data to third countries.
8. Data subject’s rights
8.1. As a data subject, the Client has the following rights, subject to the conditions stipulated in applicable legal acts:
8.1.1. right to correct any inaccurate personal data;
8.1.2. right to access the personal data;
8.1.3. right to submit a claim with a relevant data protection supervisory authority or a court when the Client believes that its rights regarding personal data have been violated;
8.1.4. right to restrict the processing of personal data;
8.1.5. right to ask personal data to be erased;
8.1.6. right to data portability;
8.1.7. right to withdraw consent at any time (where personal data is being processed based on consent) without this affecting the lawfulness of processing based on consent before its withdrawal.
8.2. If the Client wishes to exercise any of its rights as a data subject, then the Client should submit a request to Solvbet, using the contact details given in clause 2.1.
9.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
9.2. Solvbet uses session cookies on the Platform. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
9.4. Solvbet uses the following cookies:
9.4.1. A cookie used to keep you logged in and verify requests on the server (persistent);
9.4.2. Google analytics cookies: Two cookies which register a unique ID that is used to generate statistical data on how you use the website (one is valid for session only, the other is persistent). You can find more information about what Google Analytics collects and their privacy policies on the Google Analytics website https://www.google.com/intl/en/policies/privacy/. You can choose not to submit certain information by opting-out, please see here for details https://tools.google.com/dlpage/gaoptout.
9.4.4. Re-targeting cookies.
9.5. In addition to Google Analytics and Facebook pixel, Solvbet may also use other third-party service providers to help analyze how Clients use the Solvbet’s Platform. Solvbet’s advertisers and payment service providers may also send you cookies.
9.6. It is possible to reject cookies from your browsers (different browsers have different options). Blocking all cookies may affect the usage of Solvbet’s Platform.
10. Social media
10.1. Solvbet is present on the social media platforms of Facebook and Instagram. In addition, Solvbet uses WhatsApp, Twitch.tv, and Telegram channels to communicate with its customers and potential customers. Solvbet communicates with you via WhatsApp, Telegram, and Twitch only when you have subscribed to Solvbet’s channel on those sites. When communicating with you on social media, Solvbet abides by the applicable laws on data protection. The personal data which you provide to Solvbet upon subscribing will be used by Solvbet only. Solvbet will not share the personal data with any third parties.
10.2. When Solvbet is using WhatsApp, Twitch, and Telegram to communicate with its subscribers, it is acting as a data controller. The social media platform is acting as a data processor, providing a platform for Solvbet to carry out its marketing activities towards its subscribers. However, please note that the social media platform may also process your personal data for its own purposes. To find more information about how a social media platform is processing your personal data, please read carefully the privacy terms on the platform’s website.
10.3. Please note that when Solvbet is processing your personal data on its Facebook page, Solvbet is acting as a joint data controller with Facebook Ireland. More information about the personal data processing on Facebook can be found here: https://www.facebook.com/legal/controller_addendum.
12. Governing law, jurisdiction, and submitting complaints
12.2. Any and all disputes arising from or related to the personal data protection will be settled by the parties by way of negotiations. Failing agreement, the parties have the right to lodge a claim to court.
12.3. In case the dispute between the parties is to be resolved in judicial proceedings, the parties agree to refer the dispute to Harju County Court in accordance with the legislation in force in the Republic of Estonia.
12.4. The above clauses shall not affect the rights of consumers regarding jurisdiction.