Privacy policy

1. Scope and application

This Privacy Policy (the "Policy") explains how Check In handles personal data in connection with the website [WEBSITE URL] (the "Platform") and the services, tools and communications made available through it. The Policy takes effect on the version date shown above and replaces any earlier version
The Policy is confined to data obtained through the Platform and to electronic correspondence sent through or in connection with it. It does not extend to websites operated by other parties, including those reached by way of a link from the Platform, nor to data you supply to them.
Check In determines the purposes and means of the processing described here and is accordingly the controller of that data within the meaning of Regulation (EU) 2016/679 (the "GDPR"). Check In is established in the Republic of Cyprus, and the processing is therefore also subject to the Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data, Law 125(I)/2018.

2. Who we are and how to reach us

General enquiries concerning the Platform: partners@checkingaming.com
Data protection matters, including the exercise of the rights described in section 13: partners@checkingaming.com
Correspondence in English will be dealt with most promptly.

3. Terms used in this Policy

"you" and "your" refer to any natural person who visits, accesses or otherwise makes use of the Platform, including a person who does so jointly with others.
"Account" means the restricted part of the Platform available to a person who has registered, holding the particulars supplied on registration where registration is required of you.
"Content" means material of any description held on or transmitted through the Platform, including text, images, photographs, audio and video files, location information and comparable data.
The expressions "personal data", "processing", "controller" and "processor" carry the meanings given to them in Article 4 of the GDPR.

4. Categories of personal data we process

We limit our collection of data to what is required in order to operate the Platform, to respond to you and to improve the experience we offer. Depending upon the manner in which you interact with us, the following categories may be processed:
(a) Identification details: your full name and any further particulars you elect to supply through an Account or in a curriculum vitae (a "CV"), which may include a telephone number.
(b) Contact details: your electronic mail address and any alternative channel through which you choose to reach us.
(c) Settings and preferences: display options, selected language and time zone.
(d) Activity within the Platform: search terms entered, results opened, sections consulted, features used and duration of use.
(e) Correspondence: the substance of exchanges between you and our support personnel.
(f) Technical identifiers: your IP address, the identity of your internet service provider, the characteristics of your device and browser, and comparable connection data recorded automatically.
(g) Data associated with a social media account: where you elect to sign in through, or to link, such an account, the identifier attached to it together with any information you have made publicly available there.
(h) Approximate location: where your device or browser has been configured by you to transmit it.
We do not seek personal data falling within the special categories referred to in Article 9 of the GDPR, and we ask that you refrain from sending such data to us save where section 7 expressly contemplates it.

5. How your data reaches us

Directly from you, whenever you complete a field, register an Account, send us a message or submit a CV.
Automatically, through server logs and through cookies and comparable technologies, which record data in a manner that may not be apparent to you as you browse. Section 8 describes these technologies.
From third parties, namely where you connect a social media account and where suppliers engaged by us to provide technical, hosting or analytical support pass us data arising out of that work.

6. Purposes of processing and the legal basis relied upon

We process personal data only where a lawful basis under Article 6 of the GDPR is available to us. For each purpose the basis is identified below.
(a) Making the Platform available and keeping it in working order: performance of our agreement with you, alternatively our legitimate interest in operating the Platform.
(b) Responding to enquiries and providing support: our legitimate interest in dealing with those who approach us.
(c) Administering an Account, verifying your identity and regulating access to it: performance of our agreement with you.
(d) Assessing a candidate who has submitted a CV: steps taken at your request prior to entering into a contract of engagement.
(e) Analysing in aggregate the manner in which the Platform is used, and developing and improving it accordingly: our legitimate interest in the development of the Platform.
(f) Sending you information about our activities where you have asked to receive it, and placing cookies which are not strictly necessary: your consent.
(g) Complying with an obligation imposed upon us by law: compliance with a legal obligation.
(h) Protecting our rights or the safety of any person where this appears to us necessary: our legitimate interests or the vital interests of the person concerned.
Where we rely upon your consent you may withdraw it at any time, and the withdrawal does not affect the lawfulness of processing carried out before we received it.

7. Recruitment and the submission of a CV

Where you send us a CV or apply for a position, we process the ordinary personal data contained in the document, for instance a photograph, your employment history and your qualifications, only so far as this is relevant to the assessment of your application.
Should a CV happen to contain data falling within the special categories referred to in Article 9 of the GDPR, such data will be considered only where it bears upon your suitability for the role in question, and only to the extent that obtaining it is strictly necessary in order to establish an employment or other engagement.
Where an application does not succeed, the material is retained for the period stated in section 11 and is then deleted, unless you have agreed that we may keep it on file against future openings.

8. Cookies and comparable technologies

A cookie is a small file placed upon your device which enables the Platform to recognise a returning browser and to record the manner in which the Platform is used. Certain cookies expire when the browsing session ends; others persist until they lapse or until you remove them.
Cookies which are strictly necessary for the Platform to function are placed as a matter of course. Any other cookie is placed only where you have signified your agreement to it.
You may at any time delete cookies already stored upon your device and configure your browser so as to refuse or restrict them. Parts of the Platform may then operate imperfectly.

9. Disclosure of your data

We do not sell personal data and we do not transfer it to third parties in order that they may direct their own advertising at you. Disclosure may nevertheless occur in the following circumstances:
(a) where you have requested or agreed that it should;
(b) to suppliers and partners engaged by us, among them hosting providers and analytics and support services, who process the data upon our instructions and under a written agreement satisfying Article 28 of the GDPR;
(c) where we form the view in good faith that disclosure is required of us by law or by a court order, summons or comparable instrument;
(d) where we form the view in good faith that disclosure is necessary in order to prevent imminent harm to a person;
(e) and to our professional advisers, and in connection with a reorganisation or transfer of our business, subject in each case to equivalent protection being afforded to the data.
Where disclosure is sought under a legal process we will inform you of the request so that you may object to it, unless we are prohibited from doing so or consider that informing you would place a person at risk. Requests which appear to us to be improper, unfounded or excessive will be contested.
Certain suppliers who provide technical support for the operation of the Platform, our hosting provider among them, will necessarily have access to data held upon the systems they maintain.

10. Transfers outside the European Economic Area

Our processing is carried out principally within the European Economic Area. Where a supplier is situated elsewhere, data is transferred to that supplier only upon the basis of an adequacy decision of the European Commission, or under the standard contractual clauses adopted by the Commission, or under another mechanism permitted by Chapter V of the GDPR. Particulars of the safeguards applied to a given transfer are available upon request addressed to partners@checkingaming.com.

11. Periods of retention

Personal data is retained for no longer than the purpose for which it was obtained requires.
(a) Account data: for so long as the Account remains open to you, and for twenty four months thereafter.
(b) Correspondence with support: twenty four months from the last exchange.
(c) CVs of candidates who are not engaged: six months from the conclusion of the selection process.
(d) Server logs and technical data: six months.
(e) Records which we are required to retain for accounting and taxation purposes: six years from the end of the financial year to which they relate. Data retained pursuant to any other legal obligation: for such period as the relevant law prescribes.
Upon the expiry of the applicable period the data is erased, or is irreversibly stripped of everything by which a person might be identified.

12. Security of your data

We maintain technical, organisational and physical measures intended to preserve the integrity and confidentiality of the data held upon our systems, and we review those measures periodically. No set of measures is capable of removing risk altogether. Should an incident occur which is likely to affect you, we will notify you by electronic means so that you may take protective steps, and we will notify the supervisory authority in the cases in which the GDPR requires us to do so.
We recommend that you for your part use a password of adequate strength which you do not employ elsewhere, keep your software current, treat unexpected attachments and links with suspicion, and review your Account for activity you do not recognise.

13. Your rights

Subject to the conditions laid down in the GDPR, you are entitled:
(a) to obtain confirmation whether we process data concerning you, and a copy of that data (Article 15);
(b) to have inaccurate data corrected and incomplete data completed (Article 16);
(c) to obtain the erasure of data (Article 17), in particular where it is no longer necessary for the purpose for which it was obtained, where it is inaccurate or irrelevant to that purpose, or where the processing does not comply with the applicable requirements;
(d) to obtain the restriction of processing (Article 18);
(e) to receive the data you have provided to us in a structured, commonly used and machine readable form, and to have it transmitted to another controller (Article 20);
(f) to object to processing founded upon our legitimate interests (Article 21);
(g) to withdraw your consent at any time, where consent is the basis upon which we act;
(h) and not to be subject to a decision taken solely by automated means which produces legal effects concerning you (Article 22).
We do not at present take decisions of that description.
A request should be addressed to partners@checkingaming.com. We reply within one month, a period which may be extended by two further months where a request is complex, in which event we will inform you within the first month. We may ask you to establish your identity before we act upon a request.
If you consider that we have not handled your data in accordance with the applicable requirements, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, or with the supervisory authority of the Member State in which you reside or work. Recourse to the courts remains open to you in any event.

14. Data which you make public

Where you include personal information in Content which you post upon the Platform or otherwise make accessible through it, other persons may be able to identify you or to associate the Content with your Account. We ask you to consider what you publish. Sections 12 and 13 describe the means by which you may limit or reverse the consequences of doing so.

15. Age restriction

The Platform is directed at persons who have attained the age of eighteen years, or such greater age as the law of their place of residence requires for participation in gambling activity. We do not knowingly process the data of any person below the applicable age. Where it comes to our notice that we hold such data, it is deleted without delay.
If you have reason to believe that a person below the applicable age has supplied us with personal data, please write to partners@checkingaming.com so that the matter may be attended to.

16. Restriction and discontinuation of access

This Policy applies for so long as you make use of the Platform. If you are no longer prepared to be bound by it, you should cease to use the Platform, and that is the remedy available to you, and the only one, should you be dissatisfied with the Platform, its content or its terms.
We may restrict or withdraw your access to the Platform, in whole or in part and without prior notice, where it appears to us upon reasonable grounds that your use of it contravenes the law, this Policy or the terms of use of the Platform, or is harmful to us or to another person or entity.
Upon your request we will remove your contact details and personal data from our active systems, save to the extent that section 11 or the law requires or entitles us to retain them, in which event we will tell you what has been retained and why.

17. Amendment of this Policy

We may amend this Policy. The version in force is the version published upon the Platform, identified by the version date appearing at the head of the document. Where an amendment is material we will draw attention to it upon the Platform in advance of its taking effect, so far as this can sensibly be done. Your use of the Platform after an amendment has taken effect signifies your acceptance of the Policy as amended. Data obtained before an amendment is dealt with in accordance with the rules applicable at the time it was obtained.

18. General provisions

Accessing the Platform from a jurisdiction other than Cyprus involves the transmission of your personal data to Check In in the Republic of Cyprus, and your use of the Platform signifies your acceptance of that transmission and of the laws applicable to your use of the Platform.
Nothing in this Policy is intended to confer, or does confer, any right of a contractual or other character upon any person other than you and us.
Should we publish this Policy in a language other than English, the translation is provided for convenience only; in the event of divergence between the two, the English text governs your rights and obligations.