Privacy Policy

1. GENERAL PROVISIONS

   1. Zolotoy Faraon LLC (hereinafter - the Organization, Operator) pays special attention to the protection of personal data during its processing and respects the observance of the rights of personal data subjects.
   2. The approval of the Privacy Policy (hereinafter - the Policy) is one of the measures taken by the Organization to protect personal data, as provided for by Article 17 of the Law of the Republic of Belarus of May 7, 2021 No. 99-Z “On the Protection of Personal Data” (hereinafter - Law No. 99-Z).
   3. The policy explains to personal data subjects how and for what purposes their personal data is collected, used or otherwise processed, and also reflects the rights of personal data subjects and the mechanism for their implementation.
   4. The policy applies to relations related to the processing by LLC Zolotoy Faraon of personal data of users of the website https://brazino777.by/ (hereinafter - the Website), the Brazino777 mobile application, visitors to the virtual gambling establishment (VGE) Brazino777, individuals and representatives of legal entities when considering applications, individuals and representatives of legal entities when concluding civil contracts, candidates (applicants) for employment.
   5. The Operator has adopted separate policies regarding the processing of personal data in the course of labor activity and in the implementation of administrative procedures (in relation to employees and former employees), as well as the processing of cookies on the website and in the mobile application.
   6. This Policy uses terms and their definitions in the meaning defined by Law No. 99-Z, other regulatory legal acts of the Republic of Belarus, and local legal acts of the Organization.
   7. Zolotoy Faraon LLC processes only those personal data that are necessary to achieve the stated goals, and does not allow their excessive processing.
   8. Abbreviations:
      1. Law of the Republic of Belarus of 18.07.2011 No. 300-Z “On appeals of citizens and legal entities” – Law No. 300-Z;
      2. Law of the Republic of Belarus of 30.06.2014 No. 165-Z (as amended on 17.07.2023) "On measures to prevent the legalization of proceeds from crime, the financing of terrorist activities and the financing of the proliferation of weapons of mass destruction" - Law No. 165-Z;
      3. Personal data – PD;
      4. Subject of personal data – subject of PD.

2. PURPOSES, SCOPE, LEGAL BASIS AND TERMS OF PERSONAL DATA PROCESSING

   Zolotoy Faraon LLC processes personal data of personal data subjects for the purposes, scope, on legal grounds and within the terms applicable to each category of personal data subjects in accordance with Appendix 1 to this Policy.

3. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

   1. The processing of personal data by the Operator is carried out in accordance with Law No. 99-Z and other regulatory legal acts of the Republic of Belarus, taking into account the need to ensure the protection of the rights and freedoms of personal data subjects, including the protection of the right to privacy, personal and family secrets.
   2. The processing of personal data by the Operator includes the following actions (their combination) with personal data: collection, systematization, storage, modification, use, depersonalization, blocking, provision, deletion, and other actions in accordance with the legislation of the Republic of Belarus.
   3. Methods of processing personal data by the Operator:
      • non-automated processing of personal data;
      • automated processing of personal data;
      • mixed processing of personal data.
   4. The storage of personal data is carried out in a form that allows identifying the personal data subject, for a period no longer than required by the purposes of processing personal data, except for cases when the storage period of personal data is established by the legislation of the Republic of Belarus.
   5. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the term for processing personal data, the revocation of consent of personal data subject to the processing of his personal data, as well as the identification of unlawful processing of personal data.
   6. When processing personal data, the Organization takes the necessary legal, organizational and technical measures to ensure the protection of personal data from unauthorized or accidental access to them, modification, blocking, copying, distribution, provision, deletion of personal data, as well as from other illegal actions in relation to personal data.

   The processing of personal data is ensured by means of the VGE Brazino777 information system, which has a certificate of compliance of information protection of the information system with the requirements for information protection.

   Access to personal data in the Organization is carried out on the basis of the Regulation on the procedure for access to personal data, including those processed in the information resource (system).

   Zolotoy Pharaoh LLC carries out internal control of compliance of personal data processing and protection processes with the requirements of regulatory legal acts of the Republic of Belarus.

4. TRANSFER OF PERSONAL DATA TO THIRD PARTIES. AUTHORIZED PERSONS. CROSS-BORDER TRANSFER OF PERSONAL DATA

   1. The Organization does not provide personal data to third parties, except in cases stipulated by legislative acts and this Policy.
   2. In accordance with the requirements of regulatory legal acts governing activities in the gambling business (clause 6 of the Regulation on the requirements for virtual gambling establishments and the procedure for conducting an examination of a virtual gambling establishment for compliance with such requirements, approved by Resolution of the Council of Ministers of the Republic of Belarus of March 1, 2019 No. 139), the Operator ensures the transfer of data, including personal data, to a special computer cash system that ensures control over turnover in the gambling business. The operation of this system is provided by the limited liability company "Monitoring Center for Gambling Business".
   3. The organization that ensures the storage of personal data is Belarusian Cloud Technologies LLC, Republic of Belarus, 223050, Minsk Region, Minsk District, Kolodishchi a/g, Centralnaya Street, 22.
   4. The organization entrusts the processing of personal data to authorized persons. The operator approves the list of authorized persons processing personal data as a separate local legal act.
   5. To carry out transactions (deposit to the game account in VGE and withdrawal of funds), the Organization entrusts the processing of personal data to an authorized person iPAY JLLC, 220002, Minsk, Masherov Ave., 25, office 609; personal data processing policy -https://ipay.by/politika-konfidentsialnosti/).
   6. For sending information and advertising messages via SMS, the Organization entrusts the processing of personal data to an authorized person - private enterprise "Leads and Sales", Minsk, Vera Khoruzhey St., 29, office 605I; personal data processing policy -https://rocketsms.by/privacy.
   7. In order to use the services of gambling software providers, the Operator entrusts the processing of personal data to authorized persons who belong to the category of distributors of gaming software and gaming software providers (the list is constantly updated on the main page of the VGE website in the “Providers” section).
   8. Zolotoy Faraon LLC carries out cross-border transfer of personal data to provide support (including technical support) to users and use of services of gambling software providers.
   9. Cross-border transfer of personal data to the territory of a foreign state may be carried out by the Organization if:
      1. an appropriate level of protection of the rights of personal data subjects is ensured on the territory of a foreign state1– without restrictions if there are legal grounds provided for by Law No. 99-Z;
      2. the territory of a foreign state does not ensure an adequate level of protection of the rights of personal data subjects – in cases provided for in Article 9 of Law No. 99-Z, including:
      • when the consent of the personal data subject is given, provided that the personal data subject is informed of the risks arising from the lack of an adequate level of protection
      • when posting information about their activities on the global computer network Internet;
      • when the processing of personal data is necessary to fulfill the obligations (powers) provided for by legislative acts.

5. RIGHTS AND OBLIGATIONS OF THE PERSONAL DATA SUBJECT, MECHANISM OF THEIR IMPLEMENTATION

   INFORMATION FOR VISITORS OF VGE BRAZINO777

   Please note that on the basis of consent to the processing of personal data, only notifications, mailings of an advertising nature related to the activities of Zolotoy Faraon LLC (Brazino777) are sent.

   Registration of a game account and identification are carried out on the basis of fulfilling the obligations (powers) of the gambling organizers, stipulated by legislative acts (subparagraphs 27.3, 27.11 of paragraph 27 of the Regulation on the implementation of activities in the field of gambling business, approved by the Decree of the President of the Republic of Belarus of 10.01.2005 No. 9 (as amended by the Decree dated 07.08.2018 No. 305)).

   The gambling organizer is obliged to store personal data obtained during the process of registering a game account and identifying an individual for at least 5 years from the date of the gambling game.

   Therefore, if you submit a request to delete your personal data provided during registration and identification, we will have the right to do so only after the expiration of the above period.

   1. To exercise their rights, the subject of personal data submits an application to Zolotoy Faraon LLC:
      • in writing to the postal address: 220076, Minsk. Francisk Skorina St., 8, office 41e;
      • in the form of an electronic document containing an electronic digital signature, to the email address: [email protected];
      • in the form of a scanned document containing a personal signature to an e-mail address: [email protected] with subsequent sending of the original application to the address: 220076, Minsk, Francisk Skorina St., 8, office 41e;
      • in the event of the exercise of the right to revoke consent – ​​in the form in which such consent was obtained.
      Such a statement must contain:
      • the surname, first name, patronymic (if any) of the subject of personal data,
      • the address of place of residence (place of stay);
      • date of birth of the personal data subject;
      • a statement of the essence of the requirements of the subject of personal data, taking into account the requirements of paragraphs 5.3.1-5.3.5. of the Policy;
      • the game account number or identification number of the personal data subject, or, in the absence of such a number, the number of the identity document of the personal data subject, in cases where this information was indicated by the personal data subject when giving his/her consent or the processing of personal data is carried out without the consent of the personal data subject;
      • personal signature (for an application in written form) or electronic digital signature (for an application in the form of an electronic document) of the personal data subject.

      Zolotoy Faraon LLC does not consider applications from personal data subjects received by it in ways not specified in paragraph 4.1 of this Policy.

   2. For assistance in realizing rights related to the processing of personal data by the Operator, the subject of personal data may send a message to the e-mail address [email protected].
   3. The subject of personal data has the right to:
      1. to revoke their consent if the Organization has contacted the subject of the personal data to obtain consent for the processing of personal data.

         In order to revoke consent to the sending of notifications and advertising mailings related to the Operator's activities, the player must remove the corresponding marker/check mark in the Personal Account of the gambling participant.

         The right to withdraw consent cannot be exercised in cases where processing is carried out on other legal grounds (for example, in accordance with legal requirements or on the basis of a contract);

      2. to receive information regarding the processing of their personal data by the Operator, containing:
         • location of the Operator;
         • confirmation of the fact that the Operator is processing the personal data of the applicant;
         • personal data and the source of their receipt;
         • legal grounds and purposes of processing personal data;
         • the period for which consent is given (if the processing of personal data is carried out on the basis of consent);
         • name and location of the authorized person(s);
         • other information provided by law;
      3. making changes to your personal data if the personal data is incomplete, outdated or inaccurate.

         For these purposes:

         The Visitor of VGE Brazino777 uploads copies of documents confirming the need to make changes to personal data in the Personal Account of the gambling participant;

         Other subjects of personal data attach to the application the relevant documents and (or) their copies certified in the established manner, confirming the need to make changes to personal data;

      4. to receive information about the provision of your personal data to third parties.

         This right may be exercised once per calendar year free of charge, unless otherwise provided by Law No. 99-Z and other legislative acts;

      5. to terminate processing your personal data, including their deletion, in the absence of grounds for processing personal data provided for by Law No. 99-Z and other legislative acts;
      6. to appeal the actions (inactions) and decisions of the Operator, who violate his rights when processing personal data, to the authorized body for the protection of the rights of personal data subjects (National Center for Personal Data Protection of the Republic of Belarus) in the manner prescribed by law.

   4. After receiving the relevant application from the personal data subject, the Operator: within 5 working days, provides the subject of personal data with information concerning the processing of his personal data, or notifies him of the reasons for refusing to provide it;

      within 15 days:

      • makes changes to personal data and notifies the subject of personal data of this or notifies the subject of personal data of the reasons for refusing to make such changes;
      • provides the subject of personal data with information about what personal data of this subject and to whom were provided during the year preceding the date of filing the application, or notifies the subject of personal data of the reasons for refusing to provide it;
      • stops processing personal data and also deletes them (ensures the termination of processing personal data, as well as their deletion by an authorized person) and notifies the subject of personal data about this. If there is no technical possibility of deleting personal data, takes measures to prevent further processing of personal data, including blocking them, and notifies the subject of personal data about this.

      The response to the application shall be sent to the subject of personal data in a form corresponding to the application submission form, unless otherwise specified in the application itself.

   5. The subject of personal data is obliged to:
      • provide the Operator with reliable information about yourself;
      • inform the Operator about clarification (update, change) of their personal data. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Republic of Belarus.

6. FINAL PROVISIONS

   1. This Privacy Policy is publicly available. Access to the Policy is provided through its publication on the official website of the company: https://brazino777.by/.
   2. The Operator has the right, at its own discretion, to change and (or) supplement the terms of this Policy without prior and (or) subsequent notification of personal data subjects by posting a new version of the Policy on the website https://brazino777.by/.
   3. Issues related to the processing of personal data not specified in this Policy are governed by the legislation of the Republic of Belarus.

Appendix 1

to the Privacy Policy

Purposes, scope, legal grounds and terms of processing personal data by Zolotoy Faraon LLC