pursuant to articles 13 and 14 of Regulation EU 2016/679

1. Who is the Data Controller? How can I contact the Data Protection Officer (DPO)?

The data controller is:
●  GLEAM Ltd with registered office in Bul. Patriarh Evtimii 60, Fl. 1, Ap.6 - 1000 SOFIA (Bulgaria)
●  VAT number: BG207369817
●  Email: info"@"gleam.bg
●  Phone: +359 888011098

Contact info of the Data Protection Officer (DPO)
The DPO can be contacted by email at: dpo"@"gleam.bg or by sending an email to the DPO’s attention
at the address of the data controller.

2. What personal data are processed and when are they collected?

2.1 Data you provide us directly

When you register or use the "PokerLens" application, please enter the following information:
To register, it is possible to use existing social accounts in Facebook or Google. Using a social account, the "PokerLens" app will inherit the information that the user has given and made available according to a freely agreed privacy level. It is therefore advisable to check and review one’s “Settings and privacy” before logging in via a social account.
As an alternative to registering using a social profile, the user will be asked for the following information:
● Name and surname
● Email address
● Mobile phone number
● Country
● City
● Date of birth (to verify that you are of legal age and therefore eligible for the service)
● Gender
● Nickname

Some of this information must be provided during the creation of the user profile (Name, Surname, Email address), while other information is provided to us as part of the normal use of the PokerLens application. In order to use the Waiting List services you will need to provide all this information.

2.2 Data we collect automatically

When you use the PokerLens application, for technical reasons certain data are automatically collected from your device:
●  User language
●  Phone model and characteristics (Brand, Model, Unique device ID, Operating system and version).

2.3 Geolocation data

Subject to the users' consent, GLEAM will collect location data from the users' mobile phones in real time and only when the application is active.

Geolocation allows the service to locate the poker rooms closest to the user's geographical location.
Consent may be expressed by the user through the “Consent” option displayed at the first use of the app and only when the application is in use.
At any time, users can activate or deactivate geolocation services by accessing the specific section of the localisation permissions managed by their device's operating system.
The system does not store the user's position history, which makes it absolutely impossible to keep track of the user's position or to reconstruct their movements.

3. Why does GLEAM Ltd process my personal data (purposes) and what is the legal basis for the processing?

We process your personal data for the following purposes:

3.1 Create your user profile.

This purpose is based on art. 6, paragraph 1, letter b) of the GDPR. The provision of data for this purpose is necessary to fulfil your request to use our app. Even partial refusal to provide or disclose your data will make it impossible to manage the pre-contractual phase, to conclude the contract, to fulfil the contract or to continue the existing contractual relationship.

3.2 Execute requests made by you via the PokerLens app to use our services.

This purpose is based on art. 6, paragraph 1, letter b) of the GDPR. The provision of data for this purpose is necessary to fulfil your request to use the services provided by the app. Even partial refusal to provide or disclose your data will make it impossible to manage the pre-contractual phase, to conclude the contract, to fulfil the contract or to continue the existing contractual relationship.

3.3 Carry out requests made by you via the PokerLens app to use third-party services.

This purpose is based on art. 6, paragraph 1, letter B) of the GDPR. The provision of data for this purpose is necessary in order to fulfil your requests to use third-party services (restaurant bookings, hotel bookings, tournament bookings and other services requested by you, GDPR art. 13.1.e). Even partial refusal to provide or disclose your data will make it impossible to manage the pre-contractual phase, to conclude the contract, to fulfil the contract or to continue the existing contractual relationship. The list of third parties is available at the following link and may be dynamically updated by the data controller. In this case, each user will receive a notification of such update.

3.4 Display the Poker Rooms closest to the user's geographical location.

GLEAM Ltd collects real-time location data, including geographical location data, from Users' mobile phones.
The system does not store the geolocation data, which makes it impossible to keep track of the user's position or to reconstruct their movements.
The provision of consent to the acquisition of geolocation data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the other services offered by the Data Controller, and that your consent may be withdrawn at any time and that you may also object to the processing of these data at any time.

3.5 Answer a question you asked.

This purpose is based on article 6, paragraph 1, letter B) of the GDPR to execute pre-contractual and contractual measures originating from the expression of interest or contact request made by you. The provision of data for this purpose is necessary to fulfil your request. Even partial refusal to provide data will make it impossible to respond to or fulfil your request.

3.6 Fulfil the obligations established by law, a regulation or European legislation.

This purpose is based on article 6, paragraph 1, letter c) of the GDPR (e.g. requests from the competent authorities for data as part of judicial investigations). Even partial refusal to provide or disclose your data will make it impossible to manage the pre-contractual phase, to conclude the contract, to fulfil the contract or to continue the existing contractual relationship.

3.7 To ascertain, exercise or defend the rights of the Data Controller in court. 

This purpose is based on article 6, paragraph 1, letter f) of the GDPR, and, with respect to the balance of interests, is deemed to prevail over the rights and freedoms of the data subject. Even partial refusal to provide or disclose data will make it impossible to manage the pre-contractual phase, to conclude the contract, to fulfil all the envisaged obligations or to continue the existing contractual relationship. Among others, the data subject may exercise the rights set out in article 21 of the GDPR.

3.8 Analyse traffic in the PokerLens app for market research and statistical analysis.

The provision of data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the services offered by the Data Controller, and that your consent may be withdrawn, and that you have the right to object to such processing at any time.

3.9 Analyse traffic in the PokerLens App to check customer satisfaction.

The provision of data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the services offered by the Data Controller, and that your consent may be withdrawn, and that you have the right to object to such processing at any time.

3.10 Marketing purposes of the Data Controller:

GLEAM Ltd may use your data to send you newsletters, commercial communications and/or advertising material regarding products and/or services offered by GLEAM Ltd Moreover, we may process the data provided by you and the data acquired during the use of the services in order to perform market research and customer satisfaction analysis. These communications may be sent via automated communication channels (e.g. text messages, emails, app alerts) and via traditional channels (operator calls, post). The provision of data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the services offered by the Data Controller, but you will not be able to receive newsletters, commercial communications or advertising material, and that your consent may be withdrawn, and that you have the right to object to such processing at any time.

3.11 Marketing purposes related to third-party products or services:

GLEAM Ltd may use your data to send you commercial communications relating to the services and products of its business partners (event organisers and providers of event-related services). These communications may be sent via automated communication channels (e.g. text messages, emails, app alerts) and via traditional channels (operator calls, post). The provision of data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the services offered by the Data Controller, but you will not be able to receive newsletters, commercial communications or advertising material, and that your consent may be withdrawn, and that you have the right to object to such processing at any time.

3.12 With regard to the Marketing Purposes referred to in points 3.10 - 3.11

Note that your consent may be withdrawn only with respect to the use of automated contact methods, and that you have the right to object to the sending of marketing communications at any time. This right may be exercised by following the instructions contained in the communication, if it is an electronic message, or by contacting the Data Controller at the address specified in this document. You may therefore decide not to provide any data or to subsequently deny the possibility of processing the data already provided. In this case, failure to provide them does not prevent you from benefiting from the services offered by the Data Controller, but you will not be able to receive newsletters, commercial communications or advertising materials.

3.13 For profiling by GLEAM Ltd

In other words, for activities such as the subdivision of users into uniform groups based on their characteristics and/or preferences, for the elaboration of your commercial profile and to allow GLEAM Ltd to identify your use of the PokerLens app in order to improve the services provided and to show you advertisements on the app regarding products and/or services of GLEAM Ltd that correspond with your interests. The provision of data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the services offered by the Data Controller, and that your consent may be withdrawn, and that you have the right to object to such processing at any time.

3.14 For profiling by third-party services

These are activities such as dividing users into groups based on their characteristics and/or preferences, for the development of commercial profiles, to allow GLEAM Ltd to identify user behaviour on the PokerLens app in order to display advertising messages within the app relating to products and/or services of third parties (event organisers and suppliers of event-related services, restaurant bookings, hotel bookings, tournament bookings GDPR art.13.1.e) and other services requested by you in accordance with your interests. The provision of data for this purpose is optional and requires your specific and separate consent, pursuant to article 6, paragraph 1, letter a) of the GDPR. We inform you that failure to provide such information does not prevent you from benefiting from the services offered by the Data Controller, and that your consent may be withdrawn, and that you have the right to object to such processing at any time.

We will never process your personal data for purposes other than those specified without first informing you.

4. Is access to the application allowed for minors?

In order to be able to use the services provided through the app, you must be of legal age, therefore, if you indicate an age of less than 18 when creating your profile you will not be able to use the app.

5. How long will my personal data be stored?

We will only keep your personal data for the time necessary for the purposes specified and not exceeding the periods indicated below:

Once these periods have expired, we will delete or anonymise your personal data.

6. Are my personal data secure?

We take the security of your personal data very seriously. That is why we have taken internal measures to ensure the integrity of your data as far as possible.
If you would like more information about the security measures implemented by GLEAM Ltd to protect your personal data, please send your request to the following address: info"@"gleam.bg

7. Where are my personal data processed?

Your personal data are mainly processed within the European Economic Area or in countries outside the European Economic Area (EEA) which offer an adequate level of data protection in accordance with the "adequacy decisions" of the European Commission.
In specific cases, pursuant to art. 49/1/B GDPR, in its capacity as mere technology provider and in order to fulfil your requests for inclusion in the tournament booking waiting list and/or to respond to your requests to use third-party services, GLEAM Ltd transfers your personal data to the entities you have selected, which act as independent third-party data controllers, in countries that are not part of the European Economic Area (EEA) and whose laws do not ensure a level of protection of personal data equal to what is guaranteed by the laws of the EEA.

8. Who are my personal data shared with?

In order to give you access to the PokerLens app and to enable you to use its functions, the following recipients will have access to your personal data:

• GLEAM Ltd personnel assigned to manage user accounts;
• Service providers that GLEAM Ltd uses, appointed as data processors;
• Competent authorities, to respond to your requests and to handle complaints against GLEAM Ltd;
• Authorities that can access your data by law;
• Parties to whom the data must be disclosed (Casino - Poker Room - event organisers, event-related service providers) in order to fulfil a request made by you, in their capacity as Autonomous Third-Party Data Controllers. We therefore invite you to acquaint yourself with their privacy policies.
• Social networks connected by the User. If the User connects their GLEAM Ltd account to social networks or third-party platforms, GLEAM Ltd may use the information provided by such social networks or third parties provided that such information is made available to GLEAM Ltd in accordance with the privacy policy of such social networks or third-party platforms.

9. What are my rights regarding my personal data?

In the course of our business we are required to process your personal data in various ways. However, you are in control of your data and their use. For this reason, pursuant to and for the purposes of articles 15 to 22 of EU Regulation no. 2016/679, you may exercise the following rights at any time:

• Ask for confirmation of the existence or otherwise of your personal data.
• Obtain information about the purposes of the processing, the categories of personal data, the recipients or

The categories of recipients to whom the personal data have been or will be disclosed and, where possible,
The storage period.

• Obtain the correction and erasure of the data.
• Obtain the restriction of processing.
• Obtain the portability of the data, i.e. receive them from a data controller in a structured, commonly used and machine-readable format, and send them to another data controller without hindrance.
• Object to the processing at any time, even in the case of processing for direct marketing purposes.
• Oppose automated decision-making concerning natural persons, including profiling.
• Ask the data controller for access to and correction or erasure of the personal data or restriction of processing concerning them, or to object to the processing of personal data, as well as the right to data portability.
• Withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.
• Lodge a complaint with the supervisory authority.  In Bulgaria, this authority is the Privacy Authority.

If you wish to exercise your rights, please contact our data protection
team:

• By email, at the following address: info"@"gleam.bg
• By post, at the following address: Str. 60 Patriarch Euthymius Blvd., fl. 1, appartament 6 - 1000 SOFIA (Bulgaria), specifying in the subject: Exercise of rights

If you wish, you can also contact the Data Protection Officer (DPO) by email at the following address: dpo"@"gleam.bg

As part of the processing of this request, we may check your identity or to ask you for proof of identity in order to verify that you are indeed the sender of the submitted request.

10. Changes to this Privacy Policy

GLEAM Ltd reserves the right to make changes to this Privacy Policy at any time. In the event of changes to this Privacy Policy, we will endeavour to publish the new version on our websites and/or applications.