1. Who we are 

KAIZEN GAMING INTERNATIONAL LTD, an entity based in Flat B8, The Atrium, West Street, Msida, MSD1731, Malta (hereafter the “Company”), is the owner and administrator of the current site. The Company belongs to a group of companies (“Kaizen Gaming Group”) that offer a wide range of services, from software development to optimum online gaming services to customers in multiple jurisdictions around the world, i.e. Greece and Cyprus under Stoiximan brand, and Germany, Portugal, Romania, Czech Republic, Bulgaria, Brazil, Chile, Ecuador, Peru, Mexico, Argentina, Nigeria and Ontario under Betano brand. 

2. Mission Statement 

Recognizing the fast pace of technology and its constant evolution, the protection of an individual’s online privacy is a true concern in today’s digital economy.  Our mission is to provide a safe and secure environment for our users to enjoy our services, while ensuring their privacy is respected and protected at all times.

The following principles set the foundation of Kaizen Gaming Group stance on privacy:

Access: As the owner of the information, you have the control over the privacy of information provided to and processed by our Company; 

Transparency: We will be transparent about the data collected and how that information will be used so as to allow you to make an informed decision.

Data Minimization: We only collect and use personal information that is necessary for providing our services and improving user experience. We limit the collection of personal information to what is necessary and relevant.

Security: Using strong security and encryption techniques, our Company will protect the data entrusted to us by you when using our current site or our services as per market, committed to assure confidentiality, integrity and availability of your data. 

Compliance: As a global organization, Kaizen Gaming respects local privacy laws and will work with you to ensure your legal rights of privacy are respected and adhered to.

By adhering to these privacy principles, we aim to provide our users with the highest level of privacy protection possible. We continuously review and update our privacy practices to ensure they remain in line with best practices and evolving privacy regulations.

Delivering our products and services to our customers around the world, while creating a great environment to work in, in order to provide throughout the world, the best and most trusted online gaming experience and essential intelligence as a global data and analytics company, requires that we maintain and continuously foster the trust of our customers, potential customers, candidates, employees, affiliates and third parties. 

3. Scope of this Privacy Notice 

This Privacy Notice describes how the personal data you may provide to us through our website (kaizengaming.com) and in connection with related services that we offer, is collected, protected and used. It also describes the choices you have as regards this information and guidance on how you can exercise your rights in relation to this data. Our website is provided by the Company as defined below and this Company is the controller of your information. This Privacy Notice applies equally whether you are accessing the website via a personal computer, a mobile device or any other technology or device. For the definitions of commonly used terms in data protection and privacy, you can always refer to our Glossary. 

4. Collection of Personal Data

We use different methods to collect data from and about you including through:

Direct interactions: you may give us your country of residency, your name, surname and email address, and a message by filling in the “Contact Us” form, available on our Website. This includes personal data you provide in your written message when you contact us.

Automated interactions: as you interact with our Website, we will automatically collect Technical Data about your browsing actions and patterns (Cookies). 

5. Types and usage of information we collect 

Purposes of processing your data

Personal Data Involved

Possible consequences of failure to provide the personal data

Legal basis for processing your data

1 Enquiries, complaints & troubleshooting

Country, name, surname, email address, message 

We might not be able to handle/ respond to your query/complaint

Legitimate Interest (Optimal experience for our online visitors and troubleshooting of issues, brand awareness and reputation)*. 

2 Accessing our Website 

Enabling basic functionalities, optimal experience of our online visitors & personalized content/ advertisements.

Cookies (Essential Cookies, Functionality Cookies, Performance/Analytical Cookies).

Basic website functionalities may not operate properly/ We might not be able to offer you a customized online experience when visiting our Website. 

Consent**

*In the event that We have based the processing of your data on “legitimate interest”, we would like to inform you that we have first made an assessment for balancing our interests with your interests, rights and freedoms regarding your privacy and the protection of your data (“balance test”) and we have concluded that such processing is necessary and proportionate to our goal. For more information please contact us. 

**Your consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, through a statement or a clear affirmative action, agree to the processing of your personal data. To the extent required/permitted under applicable privacy laws, and in accordance with the set conditions, Kaizen Gaming will obtain lawful consent for the collection, use or disclosure of your personal data. The form of consent used may differ as per case so as to be appropriate based on sensitivity of the information and your reasonable expectations. Consent can be withdrawn at any time; however, such withdrawal will not affect the validity of the processing conducted so far. 

6. Disclosure of personal data

6.1 We will not sell, disclose, or rent your personal data to any third party/entities in ways different from what is disclosed in this Privacy Notice. We will only share your data with Kaizen Digital Services SINGLE PARTNER S.A., a Greek entity of our Kaizen Gaming Group, based in Neratziotissis Str. no. 111, Marousi, 15124, which is not authorized to process your information except as necessary to perform services on our behalf or comply with legal requirements, and it does only under our instructions as data processor.

6.2 We will not disclose your personal data with any third parties outside of the European Union in countries where there is no adequate data protection regime. However, in the event that such a data transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the EU/EEA and in accordance with this Privacy Notice and the applicable legislation. Additionally, we will update the current Privacy Notice in order to reflect the cross-border data transfer and the relevant safeguards for your privacy. 

6.3 In the case that our website provides links to other sites created and maintained by other public and/or private sector organizations. We provide these links solely for your information and convenience. Kaizen Gaming is not responsible for the privacy practices of websites not administered by or on behalf of Kaizen Gaming.

7. How long we keep your data

It is our policy to only retain individuals’ personal data for as long as is necessary for the purpose for which it was originally obtained, in alignment with the Data Minimisation and Storage Limitation principles. As per our personal data retention scheme, your data will be retained for a period of two (2) years as of the date of collection. This period might be extended in case that there is an open investigation, process, claim or complaint before any competent court, or other body. 

8. Profiling

We do not conduct automated decision-making processes or profiling when we process the personal data you provide to us through the current website (kaizengaming.com). 

9. Your data privacy rights

At any point and while we are maintaining or processing your data, you have the following rights and can submit a relevant request via email at [email protected]: 

Right of access – you have the right to access the personal data that we hold about you.

Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete. Right to erasure – you can ask for the data we hold about you to be erased from our records and we are obliged to satisfy such request in certain circumstances.

Right to restriction on processing – you have the right to request to restrict the processing of your personal data and we are obliged to satisfy such request when certain conditions apply.

Right to data portability – you have the right to have the data we hold about you transferred to another organization.

Right to object – you have the right to object to particular processing activities, under certain conditions.

Right to withdraw consent – you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

We will assess your request and reply to you regarding the progress and outcome of the request (granting of request, partial granting of request, rejection of request), as soon as possible and in any case in no longer than one month from the date of your request’s submission. In the event that the Company refuses your request regarding the aforementioned Data Privacy Rights, we will provide you with a reason as to why. You have the right to lodge a complaint directly before the local Regulatory authority (check here all competent authorities in Europe/EEA) and the Data Protection Officer.

We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical efforts or have disproportionate technical consequences, risk the privacy of others, or would be extremely impractical.

10. Security

Protecting your data is of utmost importance for the Company and in this regard, we constantly strive to provide all possible means of assuring your personal data’s safekeeping, the restriction of unauthorized access and / or potential alterations. Such means include information security measures consistent with current best practices to protect our customers’ privacy. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction.

11. Cookies

11.1 What Cookies are

Cookies are small text files, mainly consisting of letters and numbers, that are stored on users’ devices and saved by their browser when they visit a Website. Our Website uses cookies and similar technologies (e.g., pixel tags, web beacons, clear GIFs, and JavaScript) to recognize our users’ web browser, analyze trends and make Our Website more user-friendly, efficient and secure. 

In this Cookie Policy, we will refer to cookies and similar technologies simply as “Cookies.”

You may find further information about Cookies, including information about how to manage and delete them at www.ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, and www.allaboutcookies.org.

11.2 Cookie Types

Session/Persistent cookies: Session Cookies are one-off and get automatically deleted at the end of the users’ visit, while persistent Cookies remain stored on users’ devices for a predefined period of time after the end of their visiting sessions, enabling us to identify the users’ browser upon next visit as well as measuring the effectiveness of advertising efforts.

Third party cookies: These Cookies are placed by a third party on users’ devices, providing information about users’ browsing actions and patterns (e.g., visits to website, pages visited, links and advertisements clicked). These Cookies may determine whether certain third party services are being used, identify users’ interests, retarget advertisements and serve advertisements that are relevant to the website’s users. It has to be noted that these cookies adhere solely to the 3rd party’s Cookie Policies for the management of personal data and Our Website does not take any responsibility.

Essential or Required cookies: These Cookies are used for providing users with any requested features or services. Disabling Essential Cookies may make certain features and services unavailable.

Functionality cookies: These Cookies are used to identify our users’ selections and settings, maintain our users’ preferences over time and recognize users when they return to Our Website, assist us in personalizing our content and remember certain user preferences (e.g., name, language or region).

Performance/Analytical cookies: These Cookies help us understand how visitors use our Website, collecting information about the number of visitors, pages visited and visits’ duration. These Cookies help us to measure the performance of our promotional campaigns and their optimization for the best experience of our users.

Retargeting/Advertising cookies: These Cookies collect data on our users’ online activity and identify interests so that we can provide relevant advertising.

11.3 Cookie Settings

Any user may decide whether or not to accept Cookies. Users may set their browser so that they only allow cookies in individual cases, excluding the acceptance of cookies for all or certain cases and activate the automatic deletion of cookies when closing the browser. By having these settings, a user can still have full access to Our Website, however preferences have to be manually adjusted at each visit and some functionalities may not work optimally.

12. Changes to our Privacy Notice

We strive to constantly review and update our Privacy Notice in order to address potential legislative and regulatory requirements, while providing optimal protection of your privacy. Any update will be communicated to you via the current web page, therefore we recommend that you check this page from time to time to inform yourself of any changes in this Privacy Notice. 

13. Contact us

If at any time you believe that we have not adhered to the provisions set out within this Privacy Notice or for any other data privacy related matter, please contact us through email at [email protected] or by calling us at 2155609950. 

Kindly be informed that our Data Protection Officer is Eva Rodaki.

14. Related links 

Aiming to be aligned with all applicable local laws and regulations, and being transparent before our customers we provide, through our sites, a separate and customized Privacy Notice, according to the requirements of each market and we keep updated our Group Recruitment Privacy Notice addressed to our job candidates. 

For the respective Privacy Notices per market, please refer to the links below, based on the country of residence:

Greece: https://www.stoiximan.gr/arthro/politiki-aporritou/285127/ 

Cyprus: https://www.stoiximan.com.cy/arthro/politiki-aporritou/295194/ 

Germany: https://de.betano.com/article/privacy-policy/293537/ 

Portugal: https://www.betano.pt/artigo/politica-de-privacidade/300141/ 

Romania: https://ro.betano.com/articol/politica-de-confidentialitate/293856/

Czech Republic: https://www.betano.cz/clanky/zasady-ochrany-osobnich-udaju/344457/

Bulgaria: https://www.betano.bg/statiya/politika-za-poveritelnost/338536/ 

Brazil: https://br.betano.com/artigo/politica-de-privacidade/327859/

Chile: https://cl.betano.com/articulo/politica-de-privacidad/347467/ 

Ecuador: https://ec.betano.com/articulo/politica-de-privacidad/351630/ 

Peru: https://pe.betano.com/articulo/politica-de-privacidad/350768/ 

Mexico: https://www.betano.mx/articulo/aviso-de-privacidad/1016370/

Argentina: https://www.betano.bet.ar/articulo/politica-de-privacidad/1017635/

Nigeria: https://www.betano.ng/article/privacy-policy/1002337/ 

Ontario: https://www.betano.ca/article/privacy-policy/353628/ 

Kindly note that you may not have access to our websites that are offered to countries other than the country of your residence or in the country of residence if your location has changed. This is due to our alignment with local regulatory requirements.

Additionally, you may find the Recruitment Privacy Notice here. 

15. Glossary

Below you may find a list of frequently used data privacy terms and their definitions, aiming to help you understand this Privacy Notice.

Personal Data: any information that can directly or indirectly identify a living individual (‘data subject’). In plain terms, personal data is one data or a set of data that can single out a person from a group of people. We, at Stoiximan, are legally responsible for our customers’ data and its storage, protection and use are governed by the General Data Protection Regulations and associated laws.

Process, Processed, Processing: Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. Operations performed may include collection, storage, access/use, disclosure, erasure.

Data Subject: Anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data Controller: A natural or legal person, Public Authority, Agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of personal data.

Consent: Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of personal data relating to him or her.

Data Protection: The process of safeguarding personal data from unauthorized or unlawful disclosure, access, alteration, processing, transfer or destruction.

Data Processors: A natural or legal person, Public Authority, Agency or other body which Processes personal data on behalf of a Data Controller.

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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

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

Special Categories of Data: Personal data pertaining to or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sex life and sexual orientation, genetic data or biometric data.

Third Party: An external organization with which Stoiximan conducts business and is also authorized to, under the direct authority of Stoiximan, to process the personal data of individuals on its behalf.

Third Country: Any country not recognized as having an adequate level of legal protection for the rights and freedoms of Data Subjects in relation to the Processing of personal data.

[V.3 – 02/2024]