Premises

The following privacy policy is provided by NET PERFORMANCE LTD with the purposes to describe the management modalities of the website www.weblottopoker.com (below also “Site”) with specific reference to the handling (o processing) of personal data provided by User/Interested.
The policy specifies the modalities, the purpose and the limits of the personal data processing; is compliant with the provisions of Art. 13 of the Regulation (UE) 2016/679 (hereinafter “GDPR” or “Privacy Code”) for the users that enter the website of NET PERFORMANCE LTD.
This Privacy Policy is valid only for www.weblottopoker.com and not other websites or sections/pages/spaces owned by third parties and accessed by the user through links present in this website.
Users are kindly invited to read carefully this Privacy Policy before providing any personal information and/or filling in any form present on the Site.

1. Identity and contact data of the of the Responsable of Treatment

For the purposes referred to under the article 2 letter a) and b), the responsable of treatment is NET PERFORMANCE LTD, address Sofia 1000, blvd.Alexandar Stamboliyski 38, floor 2,apartment 7. For the purposes referred to under the article 2 letter c) independent data controllers are indicated below in section 8 and the third parties belonging to one of the categories listed in section 9.
The list in detail of who is in charge of treatment may be requested to the Holder with a written request at the contacts specified above.

2. Collected data, purposes of and legal basis for the processing

User data collected by the Data Controller for the purpose of possible registration on www.weblottopoker.com and for subscription to services, contests, events (hereinafter Services) accessible from the site include: email address, mobile phone number, account profile, date of birth, gender, province, and municipality of residence as well as all personal information voluntarily provided and published by the User.

Unless the User gives the Data Controller specific and optional consent for processing their data for the additional purposes outlined in the following paragraphs, the User's personal data will be used by the Data Controller solely to verify the User's identity (including validation of the email address and/or mobile phone number), thereby preventing possible fraud or abuse, and to contact the User for service-related reasons only (e.g., sending notifications related to the services offered on the Site).

Without prejudice to what is stated elsewhere in this privacy policy, under no circumstances will the Data Controller make the Users' personal data accessible to other Users and/or third parties.

The personal data provided by Users are collected and processed by NET PERFORMANCE LTD for the following purposes:

• a. Registration on the Site for Events, Contests, and/or Coupons offered by NET PERFORMANCE LTD through the Site www.weblottopoker.com
• b. Provision of the Site's services: the data provided by the User will be processed to provide the services offered by the Site and allow the User to benefit from the Services.
• c. The data collected may be processed by the Autonomous data controllers, on a voluntary basis and with the necessary consent, including enriching the data – unless there is an explicit opt-out or objection – with data and information from other websites they own to which the data subject is subscribed, and/or using data and information available from direct or indirect public sources and/or made public by the data subject. This processing is aimed at sending promotional and commercial communications, advertising material related to the offering of products and/or services, and conducting surveys and market research, using any available means, both traditional (such as phone calls) and automated (such as SMS, push notifications, social media, email, and automated responders) by the Autonomous data controllers on behalf of third parties, without disclosing the personal data of the data subjects to these third parties.
  The data provided may, with the express and voluntary consent of the User, be used for identification purposes, verification of users' identity, and marketing (including but not limited to direct and indirect marketing, market research, prize contests, surveys, commercial communications, even by email).
• d. Profiling of individuals or groups, conducted through the analysis of information provided by the Data Subjects relating to identifying data, preferences, behaviors, and habits of the User to improve the needs of those who have given express consent to NET PERFORMANCE LTD.
• e. Communication to the autonomous data controllers listed in point 8 and to the Third Parties indicated in point 9, who may use them for the activities mentioned in letters c) and d) above.

The provision of personal data referred to in points a) and b) is necessary to participate in and access the Services and to provide the Services requested by the User. Legal basis for processing: fulfillment of contractual and legal obligations, compliance with the User's Service requests.
The processing referred to in letters c), d), and e) requires the express consent of the User and does not affect the provision of the requested Services. Legal basis for processing: fulfillment of requests for receiving newsletters and advertising information based on specific consent expressed by the data subject. We remind you that the User can oppose at any time the processing of their data for such purposes, and they can also exercise the additional rights under EU Regulation no. 679/2016, as provided in article 10 (Rights of the Data Subject).

3. Processing Methods

The processing of the data collected for the purposes referred to in section 2, will be done through IT/telematic tools, paper support and/or tools adequate to guarantee the fulfilment of security and confidentiality measures required by the GDPR.
Such methods will be pertinent and not excessive in relation to the type of services provided.

4. Processed Data

i. Data submitted by the user voluntarily at the site registration or in subsequent phases in order to benifit of the services provided by NET PERFORMANCE LTD.
ii. Navigation Data: IT/telematic systems and the software processes designed for the useful efficiency of the Site acquire, in the course of normal operation, some personal data, which transmission is implicit in the use of communication protocols or it’s useful for better management and optimization of the system used to send data and e-mails. This acquisition, which occurs for statistical purposes only or to track the correct functioning of the Site, is not in any way aimed at identifying Users. The web contact data is not, in any case, retained after being processed, except when required to ascertain responsibility in the case of any electronic crimes which damage the website.

5. Area of publication and circulation of data.

The appointed employees of NET PERFORMANCE LTD will have access to the data and, with prior explicite consent of Users, Sponsors and the third parties belonging to the categories contained in section 9, as well as collaborators and external managers of the Holder assigned to data processing, the trading Partners of the latter as Autonomous Responsable of data. Excluding instances above mentioned, User’s data will not be shared in any way by the Holder.

6. Data Retention Period

The data collected will be processed exclusively for the time required for the purposes set out for which the User has expressed explicit consent and in any case not later than 36 months:

• for the purposes referred to in letters a) and b) in section 2 for the required time necessary for the processing of these and for the time set by laws, regulations or community legislations, especially in administrative and fiscal matters.

• for the purposes referred to in letters c) d) and e) in section 2, the data will be retained for the required time to keep a constant the relationship esteblished wit the User, allowing NET PERFORMANCE LTD to continue, lawfully, their marketing activities and direct sales until the User is interested in our products and services. Of course the retention period will be interrupted as soon as the User will reveal the desire to not receive further information and offers, by communicating it using the methods given in this Privacy Policy. NET PERFORMANCE LTD take appropriate technical and organisational measures to not contact the User anymore.

Subsequently, the data will be anonimised for statistical purposes and then deleted, unless expressly provided otherwise by control authorities, law enforcement and Judiciary. Therefore can be retained for longer periods in cases of dispute, for the purpose to defend or assert a right, in a court of law, both on the part of the Holder and the User.

7. Data transferred to third countries

Currently data will not be transfered to non-EU countries. The database management is entrusted to NET PERFORMANCE LTD and the processing of this data is bound to the purposes for which they were collected and occur in full compliance with the confidentiality and security standards provided by the laws on personal data protection applicable.
Whenever the Users personal data were to be subject of an international transfer outside EU territory, the Holder will take every contratual measure suitable and necessary, in order to ensure appropriate level of the Users personal data protection in accordance with what is stated in this Privacy Policy, including, among others, Standard Contractual Clauses approved by the European Commission. Whenever the adequacy of requirements or the Standard Contractual Clauses fails to be present, we will request againg consent to transfer to non-EU countries.

8. Autonomous data controller list

Write to info@netperformance.group to receive the list of self-employed owners.

9. Categories of autonomous third party controllers

Personal data provided by Users (name, surname, address, email, phone, …) may be disclosed and/or transferred to the following categories of third party companies: associated, parent or subsidiary companies of the same group, or (i) fixed and mobile telephone network companies and ADSL; (ii) companies active in the publishing world (printed media, internet, television and new media); (iii) companies active in the e-commerce sector of products and services; (iv) companies operating in the electric and/or energy sector; (v) travel and leisure operating companies; (vi) companies providing professional and/or scholastic education; (vii) advertising and communication agencies, media and contact centers, active companies in direct marketing and in list brokerage; (viii) companies operating in food industry; (ix) NGOs and No-Profit Organizations (ONLUS); (x) companies operating in the finantial sector, credit brokers, banks, finantial society, agents in the financial and insurance sector; (xi) institutions and/or companies for communication of public utility; (xii) companies operating in marketing and web communication; (xiii) Large Organized Distributor; (xiv) electronic toll, insurance and mobility service companies; (xv) healthcare, dental and hearing aid sectors, as well as to their commercial partners, belonging to the e-commerce, mail order, publishing, utilities, tourism, sports, communication, entertainment, financial insurance, automotive, material suppliers office, providers of digital and/or satellite tv services and television broadcasters, producers and/or distributors of children’s items companies operating in the field of consumer goods, for sending advertising material and other communication purposes promotional and commercial nature through the use of the following means: telephone with an operator and/or automated calling systems or call communication without the intervention of an operator, e-mail, Sms, Whatsapp, Messenger, fax, Mms, push notifications, messages on social networks, autoresponders and/or paper mail.

10. User Rights

Users can exercise the rights guaranteed by the Applicable Legislation, by contacting the Holder via e-mail to: info@netperformance.group, or writing a letter to: NET PERFORMANCE LTD, Sofia 1000, blvd.Alexandar Stamboliyski 38, floor 2,apartment 7. Withing the meaning of the Applicable Legislation, the Holder informs that Users have the right to obtain indication (i) of the source of the personal data; (ii) the purposes and methods of their processing; (iii) the logic applied in case of processing carried out with the aid of electronic instruments; (iv) information about the data holder and responsable parties; (v) of the entities or categories of entity to which the personal data may be disclosed or which may learn them as in their role as data processors or handlers.
Furthermore, the Users have the right to obtain:

a. the access, the updating, the correction, or whenever interested, the integration of data;

b. the cancellation, the transformation into anonymous form or blocking of data which have been processed unlawfully, including the data which doesn't need to be stored if related to the purposes they have been collected or subsequently processed for;

c. the certification that the operations referred to in letters a) and b) have been disclosed, including also their content, of those to whom such data has been communicated or distributed with the exception of the cases the prove to be impossible or requires the use of manifestly disproportionate effort compared to the right to be protected.

Furthermore, Users have:

a. the right to revoke consent at any time, where the processing is based on their consent;

b. the right to data portability(right to receive the personal data concerning them in a structured format, commonly used and machine-readable format), the right to restriction of processing of their personal data and the right to erasure (“right to oblivion”);

c. the right to object: i) in whole or in part, for legitimate reasons to the treatment of personal data concerning them, although pertinent to the purpose for which it was collected; ii) in whole or in part, to the processing of personal data used for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication; iii) whenever the personal data is processed for direct marketing purposes, at any time, to the processing of their personal data for these purposes, including profiling to the extent that it is related to direct marketing;

d. whenever they considered that the processing which concerns them violates the legislation, the right to lodge a complaint with a supervisory authority (in the Member State in which they are ordinarily resident, in the Member State they are employed in or otherwise in the Member State where the alleged violation has occured). The Supervisory Authority BG is the Commission for Protection of Personal Data.
The Data Controller is not responsible for the updating of any link viewable in this Policy, therefor everytime a link is not functioning and/or updated, the Users recognize and accept that they will always refer to the document and/or section of the websites recalled by this link.

11. Update and changes to the Privacy Policy

NET PERFORMANCE LTD reserves the right to modify this Policy and the conditions of use highlighting the changes made on the Site in the section “Privacy Policy”, therefore we reccomend the Users to periodically visit this page in order to view any changes or updates. Any legal dispute will be exclusively under the jurisdiction of Sofia court, Bulgary.

Privacy Policy updated on 03/01/2023