Introduction
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‍ Soft2Bet takes your privacy seriously. We are committed to protecting your personal data and ensuring the fulfillment of your rights. This privacy policy will provide you with information on the type of personal data we collect, why we collect it, how we use it, who we may share your personal data with, your rights, and how we protect your personal data.
This Privacy Policy applies to the processing of your personal data by us, primarily in connection to your use of this Website.
This Privacy Policy also applies to our processing of your personal data in connection to our communication with you, our processing of your queries and/or job applications, your use of our products and/or services, and any other relationship with you that is not covered by a separate privacy policy.

Who We Are
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‍ This website is operated by Estata Limited, a Cypriot company with its registered address at Griva Digeni, 28, 1st floor, 1066, Nicosia, Cyprus.
Estata Limited determines the means and purposes of the processing of your personal data and therefore acts as the “Data Controller” in terms of the EU General Data Protection Regulations.
Our Data Protection Officer can be contacted by email at dpo@soft2bet.com or by post to Griva Digeni, 28, 1st floor, 1066, Nicosia, Cyprus.

Legal Basis for Processing
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‍ We may process your personal data on several legal grounds. Please see the below section “Which Data We Process” for the legal grounds applicable to each category of your personal data that we process.

Legal Obligation
We may process your personal data as required under the European Union or a Member State law applicable to us.
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Contractual Necessity
We may process your personal data as required to fulfill a legally binding contract between you and us.
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Legitimate Interest
A legitimate interest exists when we have a business or commercial reason upon which personal data will be processed. Before relying on our legitimate interest, we balance it against your interests and ensure that our interest is compelling enough and that pursuing such legitimate interest will not cause any disproportionate risks to your rights and interests.
In particular, our legitimate interests are listed in the “Which Data We Process” section below. You have the right to object against our processing of your personal data on the basis of legitimate interest by contacting us at dpo@soft2bet.com. We will do our best to meet your request, but in certain cases where we will not be in a position to meet your request, you will be informed appropriately. Note that we will always honour your objection with regards to any processing for marketing purposes.
We may process your personal data as required for the establishment or defense of legal claims.
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Consent
We may process your personal data when you give us your consent to do so. We will only process your personal data on the basis of your consent, where we cannot or otherwise choose not to rely on any other legal grounds as previously mentioned. Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. Should you wish to withdraw your consent please contact us at dpo@soft2bet.com. Any such withdrawal of your consent will not invalidate any processing operations carried out prior to you having withdrawn your consent.

Which Data We Process
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The table below outlines the categories of personal data which we process, the purpose for which we process such personal data as well as the corresponding legal basis used for such processing. Note that some categories of personal data may be processed on several legal grounds and/or for several purposes.

We do not perform any automated decision making or profiling using your personal data.
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‍ Your Rights
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As a data subject, you have the following rights under the GDPR, which this Privacy Policy and our use of personal data have been designed to uphold. Please contact us at dpo@soft2bet.com for more information, or to exercise these rights.

• You have the right to be informed about our processing and use of your personal data and the right to access your personal data we process;

• You have the right of rectification if any of your personal data we process is inaccurate or incomplete;

• You have the right to be forgotten – i.e. the right to ask us to delete your personal data we process;

• You have the right to restrict the processing of your personal data, and the right to object to us using your personal data for particular purposes, e.g. for marketing purposes;

• You have the right to data portability (obtaining a copy of your personal data to re-use with another service or organization). We will provide such copy free of charge unless the request is manifestly unfounded or excessive, where in such case a reasonable fee for administration costs may be charged;

• You have the right to lodge a complaint with any relevant Data Protection Supervisory Authority should you feel that any of your rights have been impinged by us. Without limiting this right, we kindly ask you to attempt to resolve any issues you may have with us directly, prior to lodging a complaint;

• You have certain rights with respect to automated decision making and profiling. You have the right to obtain human intervention in the process of automated decision making, to express your point of view and to contest the decision.

Data Security
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‍ Personal data processed by us is protected using the highest industry standard security processes and systems. We store your personal data within the European Union, on encrypted hard drives and/or with certified data centers. Both our storage environment and those of the data centers we employ are compliant with the “ISO/IEC 27001 - Information security management” standard. We use secured https protocol for communication between the Website and your browser. In addition, our secure servers protect all information using advanced firewall technology.
Despite the best practices we employ, neither party can warrant absolute security of your Internet connection. Any data sent via the Internet may be transmitted across international borders even where the sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done with your personal data before such personal data reaches us.

Data Retention
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‍ We do not process your personal data for any longer than is necessary for the purposes of processing for which it was first collected. Your personal data will be retained for as long as we have a relationship with you (for example, evaluating employment opportunities or answering your queries) and up to one (1) year thereafter. With regards to your personal data used to provide you with information on our offers, industry events and other news and products of ours and of our affiliates that may be of interest, such data will be processed until you indicate that you no longer wish to receive such information from us.

Sharing your Personal Data

We may share your personal data with competent authorities having jurisdiction over us. Such disclosures will only be made when permitted or required pursuant to the Data Protection Laws and/or other legislation applicable to us. We may share your personal data with other companies in our corporate group – our parent companies, subsidiaries, and sister companies. These companies, as our processors, will process your personal data on our behalf on the grounds and for the purposes listed in this Privacy Policy.
We may share your personal data with other selected third parties:

• Third parties that may provide more suitable services to you regarding the services you require. With your consent, we may pass on your information to another company that is better suited to provide the specific service you have requested.

• IT and related services’ providers and their sub-processors, engaged in operating our Website, such as service providers contracted to store your personal data (Amazon Web Services);

• analytics, business intelligence partners and search engine providers and their sub-processors;

• our lawyers, advisors, auditors, consultants who we may engage from time to time to advise on any matter which requires them to gain access to personal data.

Your personal data will only be transferred outside of the EEA when such transfer meets the requirements of the Data Protection Laws. Your Personal Data will never be shared with third parties for their own marketing purposes (unless you give your consent thereto).
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Change in Ownership or Control
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In the event of a sale, merger, or any other change in ownership or control of our company, your personal data may be disclosed as part of the transaction or during the preparation for such an event. The new owner or controlling entity will be permitted to use your personal data, but only in accordance with the terms outlined in this Privacy Policy, unless you provide explicit consent for different use.
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Contacting Us
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If you have any questions about the Website or this Privacy Policy, please contact Our Data Protection Officer, by email at dpo@soft2bet.com or by post at 4, Promitheos st., 1st floor, 1065, Nicosia, Cyprus.
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Changes to Our Privacy Policy
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We may change this Privacy Policy from time to time. Changes will be immediately posted on the Website and will be deemed to have been accepted on your first use of the Website following the alterations in the Privacy Policy. We recommend that you check this page regularly to remain up to date with any changes. Where appropriate, we will also notify you by email. In the event that you do not agree with any changes, you must stop using the Website.
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Definitions
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In this Policy, the following terms shall have the following meanings: