This Privacy Notice sets out the basis on which iGameInvest will process personal information provided to us, also referred to as ‘personal data’. This privacy notice applies to all directly and indirectly controlled subsidiary companies, referred to throughout as “we”, “us”, “our” and “ours”.

 

We take our obligations in respect of the privacy of personal data very seriously and will only process personal information as detailed in this notice, unless we inform you otherwise. To ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.

 

iGameInvest is a company with registered in Romania, under the legal name igameinvest management SRL. Our core business activities include investment advisory, consultancy, and M&A Advisory, incorporation setup using 3rd party services, for the iGaming sector. For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Services’, and our actual or potential customers are referred to as ‘Clients’.

 

Our Services are not intended for children, and we do not knowingly collect data relating to children.

 

If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us. Please refer to Section 4 ’Your rights‘, regarding data that we already hold or receive from third parties.

 

 

SECTION 1: This section applies where you are an individual working for a third party with whom we have dealings. For example, a client or a payroll company.

Information you give to us or we may collect about you

 

We may collect your personal data in the course of our dealings and this may include: your contact information, which may include your full name, job role, contact telephone number and email; your statements and opinions about candidates and/or other personnel e.g. a reference; information relating to our relationship with you or the party for whom you work including records of any meetings or discussions; your marketing preferences

 

We may obtain your personal data from a range of sources including: you, including where you have provided us with your contact details or other information for the purposes of using our Services; staff or other representatives of the organization you represent; candidates; marketing databases; social media; the public domain; conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings; notes following a conversation, with you or others, or meetings you attend

 

How we will use your personal data:

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Services. Processing may include: collecting and storing your personal data, whether in manual or electronic files; using the data to communicate with you; sending information to third parties with whom we have or intend to enter into arrangements which are related to our Services; actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for; collating market or sector-specific information and providing the same to our clients; providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers; retaining records of our dealings with you and the organization whom you represent; establishing quality, training, and compliance with our obligations and best practice.

 

Why we process your personal data:

1. Compliance with legal obligations (regulatory and statutory obligations)

We must comply with a number of statutory provisions when providing our Services, which necessitate the processing of personal data. These include but not limited to the UK’s Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to assess suitability of candidates and obtain information from Clients.

We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery, and fraud/crime prevention legislation, and cooperating with regulatory authorities such as HMRC.

 

2. Our legitimate interests (carrying on the commercial activity of Services):

In providing our Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:

• Using your personal data:

o to contact you regarding our Services

o to assess suitability of Candidates and roles, for example, referencing or other feedback

o to collate market information or trends including providing analysis to potential or actual Clients

o as otherwise necessary to provide our Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers

o to personalize your experience and our offering, whether via our website or otherwise

• Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:

o establishing compliance with contractual obligations with Clients or suppliers

o addressing any query or dispute that may arise including establishing, exercising or defending any legal claims

o protecting our reputation

o maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach

o evaluating quality and compliance including compliance with this Privacy Notice

o determining staff training and system requirements

For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

 

3. Consent

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason, for example, references.

 

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have

 

 a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

 

What if we obtain your personal data from a third party?

Part of our business activity involves researching information for the purposes of finding and filling job roles. This may include obtaining personal data from sources including job boards, advertisements, LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from hiring organizations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.

Where information from third party sources is of no use to us we shall discard it, however, we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 3 ‘Your rights’.

 

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Services. This will be for one or more of the following reasons:

• You have explicitly consented to the processing

• Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law

• To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defense of any legal claims

Who we share personal data with:

We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal data include:

• Candidates and other third parties necessary for the provision of our Services

• Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us

• Parties who process data on our behalf, which may include: outsourced payroll providers; IT support; storage service providers including cloud providers; background screening providers

• Legal and professional advisers

• Insurers

 

SECTION 2: This section applies to all personal data

Transfer of data to other jurisdictions

In the course of the provision of our Services we may transfer data to countries or international organizations outside of the EEA. This may, for example, be to Clients or Candidates, or third parties who provide support services to us. Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place.

Details relating to specific countries or organizations are available on request from the person responsible for data protection matters within our organization (name and complete contact details provided previously) at ir@igameinvest.com

 

If you do not wish to provide us with necessary data

There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Services. If you do not wish to provide us with information we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Service, and in some cases may result in a breach of the contract we have with you or a third party you represent.

 

Group companies & transfer

Although this Privacy Notice applies to us your data may be accessible to, and shared with other organizations within our group for any of the purposes set out within this Privacy Notice, or where we have shared administration systems and staff.

In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.

Data Security and Confidentiality

It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorized third parties in line with contemporary practice.

 

 

 

Cookies

A cookie is a small file of letters and numbers that is downloaded onto your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it.

Our websites use cookies in a general way to help us to understand how our website is used and also to improve the user experience. With the exception of storing your login email in a cookie to enable you to log in more easily next time we do not use data from which you can be individually identified.

 

Retaining your data

In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period.

 

If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons. Please see Section 4 ‘Your Rights’ below.

 

Changes to this Privacy Notice

This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of the same.

Section 3: Your rights

We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:

• Request a copy of the personal data that we hold

• Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data

• Request that we restrict processing of your data in certain circumstances

• Request that data is erased where the continued use of that data cannot be justified

• Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process

• Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what

 

 is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal

• Request data portability in certain circumstances

• To lodge a complaint with the Information Commissioner’s Office (ICO) if you think that any of your rights have been infringed by us. You can do this by contacting the ICO directly. Full contact details including a helpline number can be found on the ICO website (www.ico.org.uk). This website has further information on your rights and our obligations.

 

In order to exercise any of your rights detailed above please contact the person responsible for data protection matters within our organization (name and complete contact details provided previously) at ir@igameinvest.com 

 

Please note the following if you are an individual working for a third party with whom we have dealings:

• In the event that we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure

• We may ask you for further information in relation to your request to enable us to action the same, or to ensure that your request is dealt with fully and appropriately

• Where we are under a legal or contractual obligation to retain data, we may not be able to fulfil your request in which case we will let you know our reasons

 

Version 1.0 - Issued on 11th February 2024

Privacy Notice - Version 1.0