This privacy statement (hereinafter “Privacy Statement”) governs the processing of your personal data by the Azelis group (hereinafter: “Azelis Group”, “Azelis”, “we”, “us”, “our”) as part of your visit to our website www. Washington's Lottery www.belladonnacornwall.com (hereinafter: the “Website”), your communication with us via e-mail, telephone, fax and social media channels (such as Facebook, LinkedIn, Twitter, YouTube, Pinterest and Google+).
This Privacy Statement does not apply to the processing of personal data of people who choose to apply via the “Working at Azelis” website ( www.azelis.com/en/about-azelis/careers/working-at-azelis ) or any other websites of the Azelis Group. The processing of personal data of applicants via the “Working at Azelis” website or any other websites of the Azelis Group is governed by a separate privacy statement.
If you want information on how we process personal data via cookies, social plugins and other types of tracking technology, you are kindly referred to our Cookie Statement .
The data controller of the processing of your personal data is the Azelis Group company with which you usually interact (a list and the contact details of the Azelis Group companies can be found here ) and Azelis Corporate Services NV/SA, Posthofbrug 12 bus 6, 2600 Antwerp, Belgium, with company number 0828.239.349, RPR/RPM Antwerp division Antwerp.
A reference in this Privacy Statement to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.
Azelis reserves the right to from time to time modify, change or amend this Privacy Statement at its own discretion. Such modification, change or amendment will be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to firstname.lastname@example.org. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Statement have been announced on the Website, you will be deemed to have accepted all such changes.
TYPES OF PERSONAL DATA WE PROCESS
Whenever you use our Website and social media channels, we collect:
- Technical information associated with the device you use, such as your IP-address, browser type, geographical location and operating system;
- Information concerning your browsing behaviour, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
When you fill out a contact form on our Website, or contact us via e-mail, telephone, fax or social media channels, we collect:
- The basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, your country, and the company you work for;
- The content of your communication or enquiry and the technical details of the communication itself (with whom you correspond at our end, date, time, etc.);
- Your preferences with regard to the communication medium used;
- Publicly available information of your profile on social media channels;
- Any other personal data you choose to provide to us.
We receive all personal data mentioned above directly from you. It may happen that we receive additional information about your preferences and surfing behaviour from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.
PURPOSES FOR WHICH AZELIS USES YOUR PERSONAL DATA
Azelis processes your personal data to provide you in a personalised and efficient way the information, products and services you request via the Website, by e-mail, telephone, fax or social media channels.
Azelis processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Azelis and selected partners.
Azelis will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels if you consented thereto.
Azelis processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
Your personal data may be transferred upon Azelis’ own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our social media channels or other communications with us.
Azelis processes your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services or to develop new products and services.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
If your personal data is processed for the purpose outlined in Article 3.1 and in order to take steps prior to entering into a contract with us, we base the processing of your personal data on the necessity for the performance of that contract, or in the process of entering into that contract.
The processing of your personal data for the purposes outlined in Article 3.2 above is based on your consent.
For the purpose mentioned in Article 3.3 , the processing of your personal data is necessary for a legal obligation that Azelis must comply with.
For the purposes mentioned in the Articles 3.1 , 3.4 and 3.5 above, the processing of your personal data is necessary for purposes of our legitimate interests, such as:
- Continuous improvements of the Azelis Website, social media channels, products and services to ensure that you have the best experience possible;
- Keeping our Website, social media channels, products and services safe from misuse and illegal activity;
- Marketing and promotion of our products, services, brands and overall successful commercialisation of our products and services.
TO WHOM AZELIS SENDS YOUR DATA
Azelis relies on third-party processors to provide you our Website and process your personal data on our behalf. These third-party processors are only allowed to process your personal data on behalf of Azelis and upon explicit written instruction of Azelis.
Azelis warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.
Azelis may share your personal data with other entities within the Azelis Group. However, we ensure that all Azelis entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Statement.
Azelis does not send your personal data in an identifiable manner to any third party without your explicit permission to do so other than the ones mentioned in Articles 5.1 and 5.2 . However, Azelis may send anonymised data to other organisations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those goods and services.
LOCATION AND TRANSFER
Azelis processes your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to other entities within the Azelis Group or to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:
- The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
- A contractual arrangement between Azelis and that entity. All Azelis entities are parties to a contractual agreement based on the European Commission’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).
Azelis may transfer anonymised and/or aggregated data to organisations outside the EEA. Should such transfer take place, Azelis will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
Azelis does its utmost best to process only those personal data that is necessary to achieve the purposes mentioned in Article 3 above.
Your personal data is only processed for as long as needed to achieve the purposes mentioned in Article 3 above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. Azelis will de-identify your personal data when they are no longer necessary for the purposes outlined in Article 3 above, unless there is:
- An overriding interest of Azelis, or any other third party, in keeping our personal data identifiable;
- A legal or regulatory obligation or a judicial or administrative order that prevents Azelis from de-identifying them.
You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. This means that, when you consent thereto, Azelis builds a profile of you based on relevant characteristics outlined in Article 2 above and then uses this profile to provide you with communications, promotions, offerings, newsletters and other advertisements about products and services that may interest you.
Azelis will take appropriate technical and organizational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss tampering or destruction. Access by personnel of Azelis or its third party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
If you are registered to receive communications, promotions, offerings, newsletter and other advertisements via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletter and other advertisements by following the opt-out link provided in such communications.
You have the right to request access to all personal data processed by Azelis pertaining to you. Azelis reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Azelis. Each request will specify for which processing activity you wish to exercise your right to access and will specify to which data categories you wish to gain access to.
You have the right to ask that any personal data pertaining to you that is inaccurate, is corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.
You have the right to withdraw your earlier given consent for processing of your personal data.
You have the right to request that personal data pertaining to you is deleted if the data is no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Azelis against:
- Overriding interests of Azelis or any other third party;
- Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that Azelis limits the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data is no longer needed for the purposes listed under Article 3 above.
You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with these particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.
If you wish to submit a request to exercise one or more of the rights listed above, please send a letter or e-mail to the Azelis Group company with which you usually interact. In case you are uncertain about the Azelis Group company you interact with, please send a to Azelis Corporate Services NV/SA, Posthofbrug 12 bus 6, 2600 Antwerp, Belgium, or e-mail Washington's Lottery privacy@ Washington's Lottery www.belladonnacornwall.com .
A request to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, Azelis may ask you for your signed confirmation and proof of identity.
Azelis will promptly inform you of having received this request. If the request proves valid, Azelis shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
For questions or complaints regarding the processing of your personal data by Azelis, please feel free to contact Azelis via the Azelis Group’s general privacy e-mail address: Washington's Lottery privacy@ Washington's Lottery www.belladonnacornwall.com . You equally have the right to file a complaint with the competent data protection authority.