Privacy policy Introduction Gaming Innovation Group plc, with company registration number C 44319, and having its registered address at @GIG Beach, Triq id-Dragunara, St. Julians STJ 3148, Malta (“GIG” or “We”), respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website at www.gig.com (the “Website”) (regardless of where you visit from) and tell you about your privacy rights and how the law protects you. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. 1. IMPORTANT INFORMATION AND WHO WE ARE 2. THE DATA WE COLLECT ABOUT YOU 3. IF YOU FAIL TO PROVIDE PERSONAL DATA 4. HOW IS YOUR PERSONAL DATA COLLECTED 5. HOW WE USE YOUR PERSONAL DATA 6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 7. CHANGE OF PURPOSE 8. DISCLOSURES OF YOUR PERSONAL DATA 9. INTERNATIONAL TRANSFERS 10. DATA SECURITY 11. DATA RETENTION 12. YOUR LEGAL RIGHTS Important information and who we are Purpose of this privacy policy This privacy policy aims to give you information on how GIG collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you submit an application for an open job role within GIG. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. Controller This privacy policy is issued on behalf of GIG. GIG is the controller and responsible for this website. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Contact details Full name of legal entity: Gaming Innovation Group plc Email address: dataprotection@gig.com Address: Data Protection Officer – Legal Department @ GiGBeach, Triq id-Dragunara, St. Julians, STJ 3148, Malta. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit. 2. The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: “Identity DataPersonal Information” includes first name, last name, or similar identifier (only collected via Careers Page). “Contact Data” includes email address and telephone numbers (collected via the Careers page, newsletter or contact us form) “Recruitment Process InformationApplication documents” includes the CV and any covering letter of a job applicant (in the event that he/she chooses to upload this through the Website when applying for a role within GiG). “Interview date and time” refers to the date and time of an interview of a job applicant with GiG. “Interview feedback” es includes notes taken for the duration of your recruitment process relating to a job application with GiIG which, in the event of an unsuccessful job application, will enable us to consider you such job applicant for future vacancies which may become available.; “Test Data” includes results from tests taken by a job applicant relating to a job application.(in the event that you choose to upload this through the Website when applying for a role within GIG). “Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this Website. “Usage Data” includes information about how you use our Website. We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. However, if you are applying for a job with us, we will collect information about criminal convictions and offences. 3. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. If you provide incorrect details, we may not be able to provide you with the service for which you are enquiring. If you are a job applicant applying for a role through the Website, it is important that you provide us with up-to-date and accurate data in order to enable us to process your application. We may need to reject an application on the basis that insufficient information has been provided to completely assess the application. 4. How is your personal data collected We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity Data, Contact Data and Employment related Data by filling in any one of the following: a) the job application form on the Website when you apply for a job role within GIG, b) provide the email address to receive our newsletter, or c) when you provide your contact details via our contact form. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Third parties or publicly available sources. We may partner with third parties (like content providers and analytics companies eg. Google Analytics) to help us improve the services of the Website and better understand how you interact with the Website, as well as support our initiatives. These companies may collect information from you automatically in connection with your visit. 5. How we use your personal data We will only use your personal data when the law allows us to, such as when you give us consent, or where we have a legitimate interest to process your personal data. Most commonly, we will use your personal data in the following circumstances: Where we need to analyse a job application which you submit to us; Where you permit us to keep your Employment related Data, to consider you for any prospective vacancies; Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; Where we need to comply with a legal obligation; Where you have subscribed to receive our newsletter; Where you have provided your Identity Data and Contact Data via the contact us page (7) Where you have opted into receiving communications about our product and services. 6. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To administer the website and improve it; (a) Technical Data (b) Usage Data Necessary for our legitimate interests.Scientific or Historical Purposes To review applications and register candidates as new job applicants (a) Personal Information (b) Contact Data (c) Application documents (d) Interview date and time (e) Interview feedback (f) Test Data Necessary for our and your legitimate interests (to choose the right candidates for the job roles within GIG and to consider your application for the open job role within GIG) To carry out reference checks when reviewing job applications (a) Personal Information (b) Application documents Necessary for our legitimate interests (to ensure that the right applicants are put through the recruitment process) To enable GIG to respond to potential employment tribunal claims arising out of the recruitment process (a) Identity Data (b) Contact Data (c) Interview date and time (d) Interview feedback Necessary for our legitimate interests (to protect the interests of GIG in case of any claims brought against it) To consider you for future job roles which may come available at a later stage (a) Identity Data (b) Contact Data (c) Application documents (d) Interview feedback (e) Test Data Legitimate interest Consent (in case of Application documents, where it has been over 6 months since the end of the recruitment process) To create Aggregated Data that GIG will use for daily reporting and generation of statistics (a) Usage Data (b) Technical Data Necessary for our legitimate interests (for running our business) To use data analytics to improve our website (a) Technical Data (b) Usage Data Necessary for our legitimate interests (to keep our website updated and relevant and to develop our business) To respond to any enquiry through the contact us form, or to contact you with the information requested on our products and services (a) Identity Data (b) Contact Data Necessary for our legitimate interests. To send you marketing communications relating to our business which we think may be of interest to you by email, sms, or similar technology (you can inform us at any time if you no longer require marketing communications) (a) Identity Data (b) Contact Data (c) Usage Data Consent Google Analytics We may use Google Analytics as well as any other analytics providers that we may use from time to time. We and third parties like Google, use first-party cookies and third-party cookies to inform, optimise and serve ads based on your past visits to our website: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page (https://adssettings.google.com/authenticated). Google also recommends installing the Google Analytics Opt-out Browser Add-on for your browser (https://tools.google.com/dlpage/gaoptout). Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. Facebook Conversion Tracking Pixel We may from time to time use Facebook (Visitor Action Pixel). This tool allows user behaviour to be tracked on Facebook and through the collection of this data, we are able to generate reports and statistics. The data collected remains anonymous and we cannot see the personal data of any individual user. However, this data is collected and processed by Facebook, which may link this information to your Facebook account. For more information click here. Workable`s support in our hiring process We use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. Workable processes your personal data as a data processor on our behalf and is only entitled to process it in accordance with our instructions. Workable provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles. Workable’s technology allows us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way we will obtain your personal data from these sources. We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally. Automated decision making/profiling We may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff. 7. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge in the limited situations where this is required or permitted by law. 8. Disclosures of your personal data We may share your personal data with the parties set out below for the purposes set out in the table above. Your personal data may be shared with third parties on a need to know basis. This may include: (1) Software companies engaged by GIG from time to time to optimize and facilitate the recruiting process by supplying GIG with recruitment management software; (2) Parent or subsidiary companies of GIG forming part of Gaming Innovation Group; Hiring managers involved with respect to a particular job role you have applied for; Individuals within the Human Resources Team at GIG as necessary; (3) Individuals within the marketing and the sales team at GiG in order to send you the newsletter and other marketing communications you may have subscribed for or consented to as applicable. (4) Any potential acquirer, successor, or the assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction in which information is required to be transferred to one or more third parties as part of such transaction. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 9. International transfers We transfer your personal data to our service providers or partners outside the European Economic Area (EEA). We shall only transfer your personal data outside the EEA in the event that the respective countries to which such data is to be transferred provide an adequate level of protection for your personal information. Determining whether an adequate level of protection of your personal data is provided is based on the existence of one of the following: The European Commission has determined that the respective third country, territory or a specified sector within that third country ensures an adequate level of protection for data transfers; The service provider or partner to whom your personal data is to be transferred provides appropriate safeguards and data subject rights and adequate legal remedies for data subjects are available. Appropriate safeguards can be provided in various ways including the use of standard contractual clauses approved by the EU Commission. For more information kindly click here. 10. Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 11. Data retention We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. How long will you use my personal data for? To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (kindly refer to the table above) and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. We might keep your personal data for a longer period of time with your explicit consent. If you unsuccessfully apply to a position within GiG you might request the removal of your personal data after 12 months by sending an email to dataprotection@gig.com and we will make sure to delete all personal data within the regulatory timelines. Date Category Lawful Basis Retention Period Date when retention period starts to apply Personal Information Legitimate interest 2 years The end of recruitment or time of receipt of unsolicited application Contact Data Legitimate interest 2 years The end of recruitment or time of receipt of unsolicited application Application Documents Consent 2 years The end of recruitment or time of receipt of unsolicited application Interview date and time Legitimate interest 2 years The end of recruitment Interview feedback Consent 2 years The end of recruitment Test Data Legitimate interest 3 months Date when data is collected Usage Data Scientific & Historical Purposes 2 years Date when data is collected Technical Data Scientific or Historical Purposes 2 years Date when data is collected We shall retain Aggregated Data for an indefinite period of time as, although this stems from personal data, it does not identify you in any way and does not amount to personal data. In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information. In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 12. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Object to processing of your personal data. Request restriction of processing your personal data. Request transfer of your personal data Right to withdraw consent. If you wish to exercise any of the rights set out above, please contact us at dataprotection@gig.com. Your legal rights You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons where we need to abide by applicable laws or where otherwise there is a legitimate interest for us not to comply with such request. Otherwise, you may ask users to delete all your personal data at any point in time, and at which point we will use our best endeavours to adhere to your request. Please note that in the event that you wish for us to delete your data related to a job application, we will not be able to consider you for future job roles which may become available and which may fit your application unless you re-apply and submit the information again. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, however, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. No fee is usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Contact us Sales enquiries sales@gig.com General enquiries info@gig.com Investment enquiries ir@gig.com ©2019-2021 Gaming Innovation Group. All rights reserved | Company Registration Number: C44319 COMPANY News IR Sustainability Careers Contact Us Privacy Policy Cookie Policy Security Vulnerability Policy SOLUTIONS Platform Omnichannel Data Logic Frontend Sports Managed Services Comply Media The B2B services, including GIG Core (online gaming platform), and GIG Sports (proprietary sportsbook), are licensed and regulated by the Malta Gaming Authority (licence number: MGA/CRP/330/2016 issued on the 1st August 2018) and the UK Gambling Commission (44073). The licences are held by iGamingCloud Limited (Company Reg. No. C48466 of @GIG Beach, Triq id-Dragunara, St. Julians, STJ3148, Malta.) ©2019-2021 Gaming Innovation Group. All rights reserved | Company Registration Number: C44319