6. Use of Data
11. Your Rights
13. Making Changes to this Policy
1. General Information
1.1. “Digitain” Limited Liability Company (hereinafter referred to as “Digitain”) operates the totogaming.am, playin.totogaming.am websites (hereinafter referred to as “Services”). We are committed to protect and respect the privacy of our users (hereinafter referred to as “Your”) and ensure your security when using our Services. The purpose of this policy is to inform you of Digitain’s policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
1.2. We use your data to provide and improve Services. By using the Services, you give your consent to the acquisition and use of your data in accordance with this policy. In case of using Your personal information for secondary purposes, we will directly contact you to obtain your consent by also providing you with an opportunity to say no.
1.3. The terms used in this policy have the same meaning given as in the General Terms and Conditions unless otherwise defined by this document.
2. Contact Information
2.1. Digitain is a personal data controller based in the Republic of Armenia. Our registered address is: 26 Amiryan Street, Yerevan, 0002 Republic of Armenia
2.2. If you have any questions regarding your personal data, please contact our Data Protection Officer at [email protected].
For any other requests please contact our Customer Support team at [email protected].
If you are in EU territory you can address your questions and requests to our representative by email [email protected].
3. Acquired Information
3.1. We acquire different types of information for a number of purposes: When using our Services, we may require certain personal identification data that may be used to contact or identify you. Personal information may include:
• Your name and surname,
• date of birth,
• address, postal code,
• email address,
• phone number,
• photocopy/scan of passport/ID card,
• Your account username and password.
Please note, that the list of personal data mentioned above is not exhaustive and may include other information if necessary.
3.2. Additional information is being processed on a current basis. We can also obtain:
• technical information on how the customer uses our Services, in particular, what device and browser is used to enter our sites,
• details of payment information and transactions initiated through the website, including Your payments, withdrawals, and bets,
• communication with us or our employee, such as calls, letters,
• Your location information, including the IP address, as well as information about the movement,
• any additional information that you will provide us with through our websites,
• we may also request a photocopy of the identity document, a photo of the customer in which the customer's face should be visible, and a page of the passport (or identification card) containing the picture in some cases proof of address, and financial source information
• sometimes, public records related to you (for example, contained in media, social networks, forums, official registers, such as voter lists).
3.3. In order to protect Digitain and its users, we use the services provided by third parties to determine the acceptance of your payments by evaluating the payment method and devices used to visit our websites. Third-party services check whether the device or payment method is identical to previous fraudulent or abusive transactions․
3.4. Digitain can make inquiries about its customers in cooperation with the e-Government Infrastructure Implementation Unit. For this purpose, each of your login to the system is considered as your unconditional consent to Digitain for requesting your personal data from information systems belonging to the state, local self-government bodies, and other persons and for processing your personal data obtained as a result of the request. Personal data are going to be processed for the purposes outlined in paragraph 6 of this policy. It further clarifies that in response to such a request from Digitain, after self-identifying you with an identification card, the personal data processors transfer any of your personal data stored in the databases belonging to state and local self-government bodies to Digitain. The data processed in this way will be stored by Digitain for the period specified in point 9.5 of this policy, without being transferred to third parties. You can request their correction or destruction at any time, the consequences of which will be further informed to you.
4. The Lawful Basis for the Processing of Data
4.1. Processing of personal data is legal, if:
• the data has been processed in compliance with the requirements of the law and the data subject has given consent to this, except for cases directly provided for by law, or
• the data being processed is obtained from publicly available personal data sources
5. Confidentiality of Personal Data
5.1. Information relating to personal data that has become known to us is considered as confidential information and is protected by law.
5.2. Our employees and other persons who have access to the processed personal data have signed a non-disclosure agreement, as well as are warned of possible disciplinary, administrative, civil, and criminal liability in the event of a violation of the norms and requirements of the applicable laws relating to personal data processing.
6. Use of Data
6.1. We use your personal data for the following purposes:
• to provide and maintain our Services;
• to notify you about changes to our Services;
• to ensure you gamble responsibly;
• to comply with our legal and regulatory obligations;
• to process your online financial and wagering transactions;
• to allow you to participate in interactive features of our Services when you choose to do so;
• to provide customer support;
• to gather analysis or valuable information so that we can improve our Services;
• to monitor the usage of our Service;
• to detect, prevent and address technical issues;
• to provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
7. Transfer of Data to Third Parties
7.1. We may use the services of certain trusted third-party companies in connection with the provision of the Company's gambling services. In particular, they ensure the operation of our websites, the provision of banking and payment services, identity verification, fraud prevention, and risk management. In connection with the latter, we may be required to share some of your information with these companies. Moreover, some of which may be based outside of our country of residence to be able to offer our Services to you.
In these instances, we ensure that the third party has appropriate security and privacy arrangements in place so that your data is protected.
7.2. We may also be required to disclose your information to government authorities, such as the police or our regulators, to comply with our legal obligations. Personal information may also be shared with regulators, agencies, or relevant sports bodies where there are suspicions of involvement in match-fixing or breach of sports regulations. The publication of data may be conditioned by the application of the terms of our use as stated in the General Terms and Conditions.
7.3. In case of change of the owner of the Company, its reorganization, or another business event, which results in us having to transfer your personal data to a third party, you will be notified via email, or notice posted on our website, to explain the identity of the new data controller and your options regarding your personal data.
7.4. Our site may contain links to and from the Websites of third party organizations. Please note that these Websites may have their own privacy policies and that we do not accept any responsibility whatsoever for these policies. Please check these policies carefully before submitting any personal data.
8. Disclosure of Data
8.1. Your personal data may be disclosed in the case when it is reasonably necessary:
• to comply with a legal obligation;
• to protect and defend the rights and property of Digitain;
• to prevent or investigate possible wrongdoing in connection with the Service;
• to protect the personal safety of users of the Service or the public;
• to protect against legal liability;
• in case of your agreement, for other purposes as well.
9. Storage of Data
9.1. Digitain is incorporated in the Republic of Armenia and your data is stored within its territory on our servers. You hereby agree that, if necessary, Digitain may transfer personal data to its partners whose servers are not located in countries listed but provide a high level of protection for personal data processing and no less than the level of personal data protection intended by the policy. In all cases, such transfer is carried out in compliance with the requirements of the RA legislation.
9.2. Due to the fact of working with the third parties, the data we collect from you may be transferred to, and stored at, a destination outside of the territory of the RA. It may also be processed by staff operating outside the RA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, customer services, the processing of your payment details and risk/fraud management.
9.3. We ensure there are appropriate contractual controls over any third party that helps us process your data. Hence, this ensures that your rights are upheld and your data is secure.
9.4. Your data will be stored as long as you are our customer. When you cease to be our customer, your personal information is stored in our systems and used to the extent necessary to fulfill our legal obligations (including but not limited to tax, gambling and anti-money laundering laws imposed), resolve disputes and apply our legal agreements and policy. In all cases, the period of preservation of your personal data cannot be less than five years, unless otherwise provided by applicable law.
10. Protection of Data
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. We store all of the personal information we receive directly from you in an encrypted and password-protected database. The database, in turn, resides within our secure network.
11. Your Rights
11.1. Your main rights of the data subject are:
• the revocation of a previously agreed agreement, but this may not result in the invalidity of the previously agreed processing,
• to file a complaint with the relevant data protection bodies,
• enter your personal data which we process,
• require correction of personal data that is incorrect or out of date,
• demand the destruction of any personal data which we have processed, if that personal data is incomplete or inaccurate or outdated, and unless otherwise provided by applicable law,
• apply to provide some of your personal information to you or to a company of your choice
• object the processing of data when that processing is performed by us in our legitimate interest
• to challenge the decision made through automated processing, to express your opinion, and to demand that it be reviewed.
11.2. These rights are not absolute. They are subject to the relevant legal regulations, including gambling regulations and other legal and ethical reporting, or document retention obligations.
If you have any concerns about your rights, you have the right to complain to an authorized state: the Personal Data Protection Agency.
12.1. Cookies are text files containing a small amount of information that are downloaded to your device when you visit a website. They are generally used by most websites to improve your online experience and to ensure that content and functions are delivered and used more effectively.
12.2. Cookies perform various functions. For instance, some cookies are downloaded to your device temporarily for the period that you browse our website. The session cookies, allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Persistent cookies, are used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to your specific needs and interests.
12.4. Using our Services, you agree that Digitain may, from time to time, place cookies on your device to save information (such as user name, other personal details, e-mail address, technical device information such as the model and its IP address) to make full use of the functionality and Services on our website and to allow your browser to identify you as a user. This enables you to not have to re-enter this information each time you visit Digitain’s site. These cookies cannot be used to run programs or deliver viruses to your computer, and are uniquely assigned to you. These cookies can only be read by the web server(s) that placed the cookies on your device.
12.5. At any time, you can amend your browser settings to block some or all our cookies. However, if you block our cookies some or all the website's functions may not perform as intended. For example, you may not actually be able to place any bets.
12.6. Further information about cookies can be found at: www.allaboutcookies.org.
13. Making changes to this policy
Updated on May 25, 2018