“User”, “you” or “your” refers to the person, company or organization that access our Website, whereas “we”, “us” or “ours” refers to Group Oryx Gaming (Oryx Gaming International LLC and other affiliates).
Last modified: February 10, 2021
3. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
Under the GDPR, the controller is the subject that, alone or jointly with others, determines the purposes and means of the processing of personal data.
The controller for the data processing related to the activities on our Website and projects organized by us is Oryx marketing d.o.o., incorporated and registered in Slovenia, with a registered office at Tržaška cesta 118, 1000 Ljubljana, Slovenia which jointly with other affiliates of Group Oryx Gaming determines the purposes and means of the processing of personal information.
For any clarification, question or requirement related to your privacy and the processing of your personal data, please contact: [email protected]
4. PERSONAL DATA WE MAY COLLECT ABOUT YOU
” Direct interactions: You may give us your personal data by filling in forms (e.g. creating an Account with us, providing financial data required to process a withdrawal, as an Oryx visitor) or by corresponding with us directly or by post, phone, email, Website, transactions or otherwise.
” Automated interactions: As you interact with our Website, we may automatically collect some data as described herein.
” Personal data that may be contained in communications you send to us.
You are under no obligation to provide any such information. Providing your personal data to us is necessary for our communication with you and for example for receiving Newsletter (if you choose to subscribe to receive it). Disclosure of personal data is obligatory only if such disclosure is required by law.
You are under no obligation to provide us with data we need for the provision of requested services, however, if you fail to provide these data, we will not be able to execute the services you requested.
4.1. ORYX JOB CANDIDATES
In connection with your application to work with us, we may collect, store and use the following categories of personal data about you:
- The data you have provided on your application, including name, title, address, telephone number, personal email address, Skype name and LinkedIn profile;
- The data you have provided in your curriculum vitae, covering letter and your portfolio or in your reference letters (if any);
- The data about you that is available from a publicly accessible source (such as your profile on LinkedIn);
- The data about your entitlement to work in the country where the local subsidiary is located;
- The data whether you have a disability for which we need to make adjustments during the recruitment process;
- The data you provide during your interview;
- The results of your expertise tests that you may undertake as part of your recruitment process with us;
- The data from your ID or passport document (provided we need such information to organize a live interview or for other such reason during the recruitment process);
- The data from your labor medical examination (provided you are considered as a finalist for the position).
We collect personal data about you from a variety of sources. For example, data are collected from you, recruitment agencies and publicly accessible sources (e.g. your profile on LinkedIn).
4.2. ORYX NEWSLETTER SUBSCRIBERS
If you choose to subscribe to Oryx Newsletters we may collect, store and use the following categories of personal data about you:
- The data you as our client have provided regarding subscription, including first and last name, your email, company name, job position, type of newsletter you wish to receive, etc.
4.3. ORYX CONTACT FORM USERS
In case you send us a sales or a general inquiry we may collect, store and use the following categories of personal data about you:
- The data you have provided regarding your inquiry, including first and last name, your email, phone number, skype number, position/job role, business information, the preferred method of contact.
4.4. ORYX CLIENTS
We require information about each organization and business partner following the laws of prevention of money laundering and the financing of terrorism prior to establishing legal agreements. Overall, the following categories of personal data are usually processed in this Due Diligence procedure:
- Name and email address of the contact person, full name, passport or ID number, full residential address, scanned passport copies, recent utility bill or bank statement of the Company´s Directors and Ultimate Beneficial Owners / Shareholders owning 10 % or more, full name, passport number, scanned passport copies, recent utility bill or bank statement, reason for categorization of a PEP in cases where a politically exposed person is involved.
4.5. ORYX VISITORS
If you are an Oryx visitor we may collect, store and use the following categories of personal data about you:
- First and last name, company name, date and time of entry into or exit from premises.
5. MINIMUM AGE
We do not accept registrations or orders submitted by, and will not knowingly collect or use personal data from anyone under the age of eighteen (18) years, or any other age limit set out by the law of his/her country of residence. By accessing and using our Website you confirm that you have reached the age of majority in your country of residence.
6. USE OF YOUR PERSONAL DATA
Whenever we process your personal data, we do so on the basis of a lawful “justification” (or legal basis) for processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:
- you have given us consent to the processing of your personal data for one or more specific purposes
- processing is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract
- processing is necessary for compliance with a legal obligation to which we are subject
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
6.1. ORYX JOB CANDIDATES
We need to process your personal data to decide whether to enter into a contract of employment with you and to perform our obligations in accordance with the labor law requirements. Article 6(1) (b) and (c) GDPR represents legal ground for processing of your personal data.
We will use the personal data we collect about you for the following purposes:
- Assessing your skills, qualifications, and suitability for the job position you are applying to (or for any job position we have open in the future in case you have sent us your application as a general inquiry);
- Communicating with you about the recruitment process;
- Keeping records related to our recruitment processes;
- Complying with legal or regulatory requirements or for purposes connected to legal claims or proceedings.
Having received your application form, your CV and covering letter (and your portfolio and recommendation letters, if any) and the results from your expertise test, which you may be asked to complete, we process that information to decide whether you meet the basic requirements to be shortlisted for the role. If we decide to further consider you for the position, we may invite you to an interview and further to complete certain additional assessments. We will use such information to decide whether to offer you the position with us.
If you fail to provide data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application properly or at all.
6.2. ORYX NEWSLETTER SUBSCRIBERS
The processing of your personal data will be justified on one of the following bases:
- Marketing communications. To provide news and information services including e-mail briefings and newsletters.
Legal basis: Your explicit consent. We will only send you marketing communications where you have consented and expressed a preference to receive such marketing communications, where it is appropriate and relevant to our business relationship with you, or where we have other lawful right to do so. Users can always easily withdraw their consent from receiving e-newsletters and commercial communications in the following ways:
– By clicking on the ‘unsubscribe’ link in any of such email;
– By contacting us via [email protected]
- Fulfilment of services. To enable us to perform the services to you – to carry out our contractual obligations relating to you, to manage our relationship with you which will also include notifying you about changes to our service and changes to our terms or policies. A lot of information comes from our newsletters. To not overload you with unnecessary details, we segment the relevant information we share to your specific needs.
Legal basis: It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you.
6.3. ORYX CONTACT FORM USERS
We will use the personal data we collect about you for the following purposes:
- Support services. To enable us to respond to your requests in accordance with the content of your request.
Legal basis: It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
- User insight and analysis. To collect insights into how you interact with our services so that we can personalize our communications with you and maintain and improve our websites and services.
Legal basis: Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we deliver our Website and online services to you and our other clients effectively. Where lawfully required, we may also process your personal information in accordance with your consent to the processing.
- Fulfilment of services. To enable us to perform the services to you – to carry out our contractual obligations relating to you, to manage our relationship with you which will also include notifying you about changes to our service and changes to our terms or policies.
Legal basis: It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you.
6.4. ORYX CLIENTS
We inform you that any personal information of your employees/beneficial owners which is provided to Oryx marketing d.o.o. (being the Data Processor) (i) in the Due Diligence Questionnaire and (ii) in the course of Due Diligence Process may be processed by the Data Controller (one of the legal entities of Group Oryx Gaming) or Data Processor for the sole purpose of
- conducting reasonable due diligence inquiries.
Legal basis: the legitimate interest pursued by the Data Controller (such as conducting international sanctions/due diligence screening and compliance evaluations) in the framework of legal and intragroup policy requirements.
6.5. ORYX VISITORS
As an Oryx visitor, you are aware that we may process your personal data with the purpose of:
- Ensuring the safety of people, activities and property and the control of entry and exit to or from our premises.
Legal basis: processing is necessary for compliance with a legal obligation to which we are subject.
7. BROWSING DATA
Our Website might collect non-sensitive browsing data by automatic means in order to enable and improve user navigation (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the Site, the device used and other information). We process Browsing Data for purposes of carrying out data analytics and market research.
The processing of such information allows users to access the Website and fully enjoy its features and services. Furthermore, browsing data may be used to verify that our Website is functioning properly. We will process Browsing data solely upon your prior explicit consent.
From time to time, browsing data are processed anonymously for statistical purposes.
8. RIGHT TO WITHDRAW CONSENT
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time. You can exercise this right by contacting us on: [email protected], by clicking on the “unsubscribe” button on our marketing emails or by choosing a similar opt-out option that we may provide for you to exercise your right to object to the processing of your personal data.
9. HOW WE STORE AND SECURE YOUR PERSONAL DATA?
Where applicable, your personal data is collected and processed in compliance with the GDPR. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your personal data to those employees and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. TRANSFERING YOUR PERSONAL DATA OUTSIDE OF THE EURPOEAN ECONOMIC AREA
Please contact us for further information about these transfers: [email protected].
11. DATA RETENTION
We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims. For example personal data of Oryx visitors may be kept for a maximum period of three years from registration and then deleted or otherwise destroyed unless otherwise provided by law. All personal data obtained in the course of a Due Diligence Process are processed and stored for the duration of the business relationship and according to legal requirements.
In some circumstances, certain personal data can be removed on your request. Also, note that due to technical limitations, the data may not be removed instantly. Please contact us for further information: [email protected].
11.1. ORYX JOB CANDIDATE
11.1.1. How long will you use my personal data?
We will retain your personal data for a minimum period of 30 days after the recruitment process for the position you applied for with us has been completed or in certain cases for a longer period as defined further below. We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We may retain your personal data for a longer period if required to protect our position in the event of a legal claim or proceeding and/or in case we are required to comply with legal or regulatory requirements (max. 5 years after the completed recruitment process). After this period, we will securely destroy or anonymize your personal data in accordance with applicable laws and regulations.
If your application is successful, your personal data gathered during the recruitment process will be transferred to and retained in human resources file.
11.1.2. Consent to keep Your Personal Data in our Candidate File
We will seek your consent in case you sent us your application as a general inquiry. It is completely up to you to decide whether you wish to give us your consent.
Note: If you sent us your application as a general inquiry, we retain your personal data for a period of max. 12 months after the receipt of your consent. After this period (or once you withdraw your consent), your personal data will be securely destroyed or anonymized in accordance with applicable laws and regulations.
12. DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to any of our affiliate companies, or to our service providers who assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing support services or in performing other tasks, from time to time. Your personal data will be accessible by authorized personnel of oryx and affiliated companies, and service providers acting on our behalf on a need-to-know basis.
We may also share your personal data with law enforcement, data protection authorities, government officials, and other authorities when:
” Compelled by subpoena, court order, or other valid legal procedure;
” We believe that the disclosure is necessary to prevent physical harm or financial loss;
” Disclosure is necessary to report suspected illegal activity;
” We obtain your consent or at your direction.
We may also disclose certain personal data to our current or future affiliates, subsidiaries and other related entities, as well as to our operational and business partners and sub-contractors when this is necessary for the performance and execution of any contract we enter into with them or you.
We place great importance on the security of all personal data associated with our users. We have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. For the best possible protection of your personal data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
While we take reasonable steps to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur.
You accept the inherent security implications of dealing online over the Internet and will not hold Oryx or their processors responsible for any data breach unless it is due to our negligence.
14. THIRD PARTY LINKS
This Platform may include links to third-party websites, plug-ins, channels or other applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you use the third-party services, we encourage you to read the privacy notice of every website or application you use.
15. WHAT RIGHTS YOU HAVE REGARDING YOUR PERSONAL DATA?
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
” Request access to your personal data. You have the right to request that we provide you access to your personal data held by us.
” Request correction of your personal data. You have the right to request correction of any personal data we hold on you that is inaccurate, incorrect, or out of date.
” Request erasure of your personal data. You have the right to request deletion of your data when it is no longer necessary, or no longer subject to legal obligations to which we are subject to. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
” Object to processing of your personal data. You have the right to request that we cease processing some of your personal data, such as personal data processed for direct marketing purposes. Also, you have the right to object to solely automated processing and to profiling activities based on our own legitimate interests.
” Request restriction of processing your personal data. You have the right to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns with this information, or we no longer need your personal data for the purposes of the processing, but they are necessary for the establishment, exercise or defense of legal claims).
” Request transfer of your personal data. You have the right to request an export of your personal data.
” Right to withdraw consent. Where you have provided your consent to our processing of personal data, you have the right to withdraw it at any time.
Requests are generally free of charge and we try to respond to all legitimate requests within one month. However, we may charge a reasonable fee based on administrative costs or/and take more time if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may also need to request specific information from you to help us confirm your identity and ensure your right to access your personal data.
If you wish to exercise any of the rights set out above, please contact us through email: [email protected].
16. COOKIES AND OTHER SIMILAR TECHNOLOGIES
When you use our Website, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “cookies”) on your computer or other access devices.
16.1. What are cookies?
Cookies are small files that are sent from the web server to the user’s computer via the user’s browser. They are then stored in the user’s computer as text files and passed back to the server. Cookies are generally used to identify users and, on occasion, prepare customized web pages for them. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.
16.2. What cookies do we use?
We use both session and persistent cookies. Session cookies expire when you log out of your account or close your browser. Persistent cookies remain on your computer or other access device until deleted or otherwise expire.
We use the following cookies:
|viewed_cookie_policy||persistent||Store if a message has been shown||Oryxgaming|
|__cfduid||30 days||Identify trusted web traffic||CloudFlare|
|_ga||2 years||Count and track pageviews|
|_gid||1 day||Count and track pageviews|
|_gat_gtag_UA_*||1 minute||Store a unique user ID|
|YSC||session||Store a unique user ID||youtube|
|PREF||1 year||Store and track visits across websites||youtube|
|VISITOR_INFO1_LIVE||6 months||Estimate bandwidth||Youtube|
|_gcl_au||persistent||Store and track conversions|
|Google Fonts API||none||Request user IP address|
|rc::c||session||Filter requests from bots|
|rc::b||session||Filter requests from bots|
|rc::a||persistent||Filter requests from bots|
|GPS||session||Store location data||Youtube|
By using our Website, you agree that, unless you have set your device’s browser to reject them, we can place the types of cookies set out above on your device and use that data in accordance with this policy. Where lawfully required, we will ask you to provide your consent.
16.4. How to manage cookies?
For more information about cookies and how to block, delete or disable them, please consult your browser’s help pages for instructions on how to do this, or contact us at [email protected].
Oryx marketing d.o.o.
Tržaška cesta 118
Email: [email protected]
You also have the right to lodge a complaint regarding the processing of your personal data by us at any time with your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). We would, however, appreciate the opportunity to deal with your concerns before you approach the authorities, so please contact us in the first instance.
©Oryx (Effective date: February 2021)