SIA LVBet Privacy Policy for LV Club - Loyalty & Rewards Mobile App

11.04.2025

Welcome to LV Club - Loyalty & Rewards Mobile App, a mobile application operated by SIA LVBet, LV50203083121, Rīga, Skanstes iela 50, LV-1013 . Protecting your privacy is a priority for us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). By using the App, you agree to the terms of this Privacy Policy.

1. Contact us

A controller of your data is SIA LVBet, LV50203083121, Rīga, Skanstes iela 50 LV-1013 . If you have any questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer via email: dpo@lvbet.lv

2. Definitions

  • Application refers to LV Club - Loyalty & Rewards Mobile App, the software program provided by the Company.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to SIA LVBet LV50203083121, Rīga, Skanstes iela 50 LV-1013
  • Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  • Device Information means information such as Your device model, operating system, and unique identifiers.
  • LV Club refers to the loyalty program, whose participants have access to the special offers and promotions offered by SIA LV Bet. Membership in the Club is voluntary and free of charge. Registration in the Member Club is possible after acceptance of the TERMS AND CONDITIONS and PRIVACY POLICY only for users over 18 years of age who provide their phone number to which the verification code will be sent.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company to provide the services on behalf of the Company, or to assist the Company in analyzing how the App is used.
  • Usage Data refers to data collected automatically, either generated by the use of the App or from the App infrastructure itself (for example, the duration of an application visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

3. Information We Collect

Unregistered users who download the app but do not register for the Membership Club may access general features and information, such as promotions and advertisements. In such cases, we may collect Usage Data and Device Information.

If you register for the Members Club, we collect the following additional information:

  • Your phone number - to verify your identity and facilitate login
  • User Activity - including interactions with the app, personalized promotion preferences and use of a QR code to enter a company-operated slot machine establishment.

Providing your data is voluntary but necessary for registration to the LV Club. We may use automated processing to deliver personalized offers and promotions to Members Club users. This processing includes analyzing user activity, preferences, and interactions within the App to generate targeted recommendations.

4. How We Use Your Information

We use your information for the following purposes:

Non-registered Users:

  • To provide information about ongoing promotions and events at our Premises based on Your Consent (Article 6(1)(a)).
  • To improve and optimize the App's features and user experience (Legitimate Interest, Article 6(1)(f)).

Registered Users (Members Club):

  • To verify your identity and facilitate login using a PIN code (Performance of a Contract, Article 6(1)(b)).
  • To provide personalized offers and promotions based on your preferences and activity (Consent, Article 6(1)(a), where required).
  • To communicate with you about updates, promotions, and exclusive opportunities (Legitimate Interest, Article 6(1)(f)).
  • To ensure secure access to the services through QR codes (Performance of a Contract, Article 6(1)(b)).
  • To improve and tailor our services to your needs (Your consent, Article 6(1)(a))
  • To manage Your requests: To attend to and manage Your requests to Us (Performance of a Contract, Article 6(1)(b)).
  • To consider possible complaints and complaints, and fulfilling the necessary legal obligations in connection with the use of the App. (Legitimate Interest, Article 6(1)(f)).

5. Sharing Your Information

We may share your information with trusted third parties such as cloud providers, to store your data, to monitor or analyze the use of our App. The App may also link to third-party websites or services (e.g., Google Play or Apple App Store). We are not responsible for their privacy practices. Please review their privacy policies separately

Under certain circumstances, the Company may be required to disclose Your Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

6. International Data Transfers

We may transfer your data to countries outside the European Economic Area (EEA), including the United States, where some of our service providers or partners are located. These transfers are conducted in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

When transferring data to third countries, we ensure that appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs): Contracts approved by the European Commission to ensure your data is protected.
  • Adequacy Decisions: Transfers to countries deemed by the European Commission to provide an adequate level of data protection.
  • Additional Measures: Where necessary, we implement technical and organizational measures to secure your data during transfer and storage.

Some of our third-party service providers are based in the United States. While the United States may not have been deemed to provide an adequate level of data protection, we ensure that any data transfer to the USA complies with GDPR requirements through the safeguards outlined above.

7. Your Rights

You have the following rights regarding your data:

  • Right to information: You have the right at any time to receive information free of charge about the origin, the categories, the recipients to whom your data is disclosed, the storage period, the existence of automated decision-making including profiling, and the processing purposes of your data.
  • Right to rectification: You have the right to have incorrect personal data corrected. This also includes the requirement to complete incomplete personal data.
  • Right to deletion: You have the right to request that we delete personal data relating to you immediately, provided that there are no legal retention obligations to the contrary and the processing does not serve to assert, exercise, or defend legal claims (Art. 17 Para. 3 lit. e GDPR).
  • Right to restrict processing: Under certain circumstances (see requirements Art. 18 GDPR) you have the right to request that the processing of your data be restricted, provided that there are no legal obligations to the contrary and the processing does not serve to assert, exercise or defend legal claims.
  • Right to data portability: This is the right to receive your data in a machine-readable format, which you can have transmitted to another company.
  • Right to revoke the consent given: This allows you to withdraw consent to the processing of your data. The revocation of consent does not affect the lawfulness of the processing carried out up to the revocation. At this point, we would like to point out that such a revocation may result in the Company no longer being able to fulfill the contract or offer any further services via the LV Club - Loyalty & Rewards Mobile App.
  • Right to object: If your data are processed based on legitimate interests, you have the right under Art. 21 DSGVO to object to the processing of your data, provided there are reasons for this that arise from your particular situation. You can exercise your right of withdrawal or objection by sending us an email using the following contact details: dpo@lvbet.lv

8. Data Retention

We retain your data only as long as necessary for the purposes outlined in this policy or as required by law. Members Club registered user data will be deleted after two years after account deactivation unless retention is required for legal or regulatory reasons.

9. Children's Privacy

The App is not intended for users under the age of 18. We do not knowingly collect data from minors.

10. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted in the App and will include the effective date. Continued use of the App constitutes your acceptance of the updated Privacy Policy.

11. Complaints

If you have any concerns about how we use your personal data, you can complain to us at dpo@lvbet.lv. If you believe that we have processed your data inappropriately, you have the right to lodge a complaint with the data protection supervisory authority about our organisation's processing of your data:

Datu valsts inspekcija

Elijas iela 17, Rīga, LV-1050

pasts@dvi.gov.lv

www.dvi.gov.lv

67223131