• Marketing Policy

Newaleabet ensures that the processing of personal data for Marketing purposes is made confidentially by the Company, which commits to make exclusive use of them and not to disclose personal data to third parties outside the group.The User is required to carefully read the following privacy policy in order to give his/her informed consent.

Table of contents

  1. Data controller
    2. Purposes of the processing
    3. Legal Basis and consequences of a failure to provide such data
    4. Recipient of Data
    5. Place of data processing
    6. Transfer of personal data abroad
    7. Retention period of Personal data

    8. Rights of the Data subject
    9. Security measures
    10. Changes and updates

    1. Data controller

    The data controller of your personal data is Ulisse GmbH, registered in Austria (FN 427806b) and subject to Austrian law, with registered office at Salurner Straße 12, -6020 Innsbruck (AT).
    mail: [email protected]

    1. Purposes of the processing

    Users’ personal data, upon explicit, specific and informed consent, shall be processed by the Concessionaire for the purposes of commercial promotion, advertising, market research, other marketing research, in a broad sense (including awards, games and competitions) products and/or services referred to the Concessionaire. In particular, these purposes include, receiving information material (e.g. Newsletters) and sending commercial communication, both where the means used for processing for marketing purposes are the telephone with operator or other non-electronic and non-telematic methods, or not supported by automatic, electronic or telematic mechanism and/or procedures, and where the methods used for the processing for marketing purposes are email, fax, SMS, MMS, automatic system without operator intervention and such, including electronic platforms and other telematic methods. Your data will also be processed for profiling purposes, e.g. for the creation of a marketing profile and/or the analysis of your preferences, habits or consumption choices, and, for no reason, they will be processed by third parties outside the group.

    1. Legal Basis and consequences of a failure to provide such data

    Your personal data shall be processed exclusively for the purposes listed above, whose legal basis can be found in its unambiguous, freely given, specific, informed, verifiable and revocable consent. The processing of data for marketing purposes is not mandatory, therefore the non-acceptance will not affect the contract stipulated for the use of gaming services. You can, at any time, choose not to provide your personal data and to exercise your rights as per section 8 of this policy, i.e. access, rectification, cancellation, limitation and portability.

    1. Recipient of Data

    Your personal data are not subject to transfer and disclosure to third parties for marketing purposes, but they will be managed and processed solely by employees and collaborators within the group.

    1. Place of data processing

    Personal data are processed on the premises of the Data controller in Innsbruck and Malta, as well as on IT support by means of the software made available by the various partners and the devices made available to the subjects authorised to process and protect data.

    1. Transfer of personal data abroad

    Your personal data will not be transferred abroad as the servers used by the Data controller are located within the European Union, with the required high levels of data protection.

    7.Retention period of Personal data

    Your data will be stored, pursuant to article 13, paragraph 2, letter (a) of the regulation for the entire duration of the contract and for a maximum of 24 months thereafter.

    1. 8. Rights of the Data subject

    As a data subject, you may at any time make use of the faculties and rights provided by the Regulation.

    In particular, you have:

    • the Right to obtain confirmation of the existence or not of your personal data;
    • the Right to access to and have communication of your data upon a simple request;
    • the Right to rectification, i.e. modification and updating data;
    • the Right to object which provides the possibility to object the processing of personal data for legitimate reasons;
    • the Right to be forgotten, i.e. the right to have your data erased;
    • the Right to restriction of processing, which minimize the use of data processing to the extent necessary for its purpose;
    • the Right to data portability of data provided by the data subject which allows the latter to receive personal data relating to him in a commonly used format;
    • the Right to revoke the consent to the processing of your personal data at any time.In addition to the rights listed above please be informed that you always have the right to lodge a complaint with the Authority for the Protection of personal data. The exercise of rights is not subject to any restrictions and it is free of charge; the rights may be exercised by submitting a request to the Data controller by means of the email address mentioned above.
    1. Security measures

    The processing of personal data is guaranteed by the application of suitable and preventive security measures, that make it possible to reduce the risk of destruction or loss of data, even when accidental, unauthorized access or processing not allowed or not Compliant with the purpose of collection.

    The security system identifies organisational choices and operating procedures regarding security matters in the processing of personal data, in particular with regard to:

    • list of personal data processing;
    • exclusive and specific access to authorised personnel based on the purpose of processing;
    • exclusive access to the indicated places of processing;
    • analysis of the risk to which data is exposed;
    • measures to be taken to ensure data integrity and availability;
    • description of the criteria and methods for restoring data availability in case of destruction or damage;
    • Planning of training/educational interventions for the persons in charge of data processing, to make them aware of the risk to which data could be exposed, of the measures available to prevent harmful events, of the part of the legislation on data protection that most affect the related activities, of the resulting responsibilities and the different methods for being updated on the minimum measures taken by the Data controller;
    • description of the criteria to be taken to ensure the adoption of minimum-security measures in case of processing of personal data entrusted outside the premises of the Data controller or transferred abroad;

    The user, where registered, is committed to keep his/her personal access credentials confidential and not to share them with third parties. The user also commits, once logged into the website of the Data controller with his/her own credentials, not to leave the related terminal unattended. The Data controller shall not be responsible for the unlawful use of said access credentials, except, obviously the case in which the abuse is due to his own responsibility.

    1. Changes and updates

    This privacy policy may be subject to future change and additions. Users will be able to view the updated version of the policy on our website.

    Last update: December 2019