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  1. PRIVACY POLICY
    If the user does not agree to the provision of their personal data or does not agree with the policy, then they must stop using the website, services and tools of the Operator immediately.

  2. General Provisions

    1. This privacy policy (hereinafter referred to as the Policy) applies to any and all information, including personal data that Zolotoy Faraon Limeted Liability Operator, legal address: 220113, Minsk, st. Leonid Beda, 45, office 775 (room 308) (hereinafter – the Operator and/or Operator) may collect, receive and process about the Operator’s users and clients in the course of using the Operator’s website, services and tools, including in the process of the Operator’s performance of contracts concluded with the user and/or the client.
    2. This Policy is compiled in accordance with the Law "On the protection of personal data", the legislation of the Republic of Belarus, locally regulations of the Operator.
    3. The Operator applies measures aimed at protection of the information in accordance with the legislation of the Republic of Belarus on information protection with due regard for the best international practices in this field.

  3. Basic concepts used in the policy

    1. Website means any website addresses used by the Operator as an organizer of gambling ( and );
    2. Personal data processing shall mean any action (operation) or a set of actions (operations) performed with personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
    3. Personal data means any information relating to an identified natural person or a natural person who can be identified;
    4. User shall mean any visitor of the website, a person using the Trading System irrespective of whether they are the client of the Operator;
    5. Specific personal data means personal data concerning race or nationality, political views, membership in trade unions, religious or other beliefs, health or sex life, administrative or criminal prosecution, as well as biometric and genetic personal data;
    6. Cross-border transfer of personal data shall mean transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity;
    7. Deletion of personal data shall mean actions as a result of which it becomes impossible to restore personal data in information resources (systems) containing personal data, and(or) as a result of which tangible carriers of personal data are destroyed;
    8. An authorized person is a state body, a legal entity of the Republic of Belarus, another organization, an individual who, in accordance with an act of legislation or on the basis of an agreement with the Operator, process personal data on behalf of the Operator or in its interests.
    9. Other terms in this Policy may be used in the meanings defined in the Law of the Republic of Belarus dated May 7, 2021 No. 99-З "On the protection of personal data".

  4. Principles

    1. Personal data of users are handled in accordance with the following principles:
      • - the principle of legality;
      • - the principle of transparency of data processing;
      • - the principle of limiting the goals of processing;
      • - the principle of minimization of personal data;
      • - the principle of accuracy of personal data;
      • - the principle of limiting the personal data storage period;
      • - the confidentiality principle.

  5. Types of personal data processed by the Operator

    1. For the purposes of this policy, the below listed items are combined in a common concept “personal data”.
    2. The Operator may collect the following user information:
      • - personal and contact information (last name, first name, patronymic (if any), data on citizenship (nationality), gender, date, month, year (hereinafter - date) of birth, place of birth, data of registration at the place of residence and(or) place of stay, date of issue of the passport or other identity document, identification number and other details of the identity document and(or) other document on the basis of which identification is carried out, previous surnames (when registering birth, marriage(s), etc.), other data obtained from verification of personal and contact data);
      • - digital photo;
      • - mobile phone number;
      • - e-mail;
      • - registration data (login/name/e-mail address and password);
      • - information about payment tools applied by the user to deposit/withdraw funds (current (settlement) bank account, e-wallet, virtual wallet address (identifier));
      • - information about all transactions performed by the user;
      • - information about the sources of origin of user funds;
      • - ip-addresses applied by the user;
      • - taxpayer account number;
      • - place of work/activity, position, work phone number;
      • - the address of website;
      • - information about representatives, persons who are able to directly and(or) indirectly (through other persons) determine (influence) the decision of an individual, about persons on who’s decision-making the individual has such influence;
      • - information about the members of the family, namely the full name and date of birth of the spouse, father, mother, adult children.

  6. User Rights

    1. The user, in addition to the rights provided for by the legislation of the Republic of Belarus in the field of handling personal data, shall have the following rights when using the virtual gambling establishment:
      • - the right to set restrictions on personal data processing;
      • - the right to receive information regarding the processing of personal data and change of personal data;
      • - the right to receive personal data held by the Operator in a structured form in the form of typewritten text;
      • - the right to demand from the Operator to correct errors (inaccuracies) in personal data;
      • - the right to withdraw consent. When a user exercises such a right, if such a right, taking into account the use of the virtual gaming establishment, is provided for by the current regulatory legal acts of the Republic of Belarus, including legislation in the field of preventing Legalization, financing terrorist activities and financing the proliferation of weapons of mass destruction, the Operator restricts the user’s possibility Operator limits the user's ability to place bets and retains the possibility of exclusively returning the user's funds, after which the user is deprived of the right to access their personal account, conduct transactions and perform other actions outside the virtual gambling establishment, after which the user is deprived of the right to access the personal account, and the contract between the Operator and such user is considered terminated;
      • - the right to receive information about the provision of personal data to third parties;
      • - the right to receive information about authorized persons in the event that the processing of personal data is carried out by such persons;
      • - the right to demand notification of third parties to whom the Operator has transferred personal data about the facts of correcting errors (inaccuracies) in it and the fact of its deletion;
      • - the right to object to the processing of personal data;
      • - the right not to be exposed to a decision made only on the basis of automated processing of personal data;
      • - the right to receive transparent information on the procedure for exercising the above rights.
    2. The user has the right to exercise the above-mentioned rights during the entire period of the contract and after its expiration, taking into account the period of storage of personal data. The exercise of the above-mentioned rights is carried out by the user by means of sending a message with a corresponding request to the Operator's e-mail: privacy@zfcasino.by.
    3. A message containing a user's statement in order to exercise their rights must contain:
      • - last name, first name, patronymic (if any) of the user, address of their place of residence (place of stay);
      • - user's date of birth;
      • - user identification number, in the absence of such a number - the number of the identity document, in cases where this information was indicated by the user when giving their consent to the Operator or the processing of personal data is carried out without the user's consent;
      • - description of the user's request;
      • - personal signature or electronic digital signature.
    4. The response to the application is sent to the user in the form corresponding to the application form, unless otherwise is indicated in the application itself.
    5. If the user exercises their right to demand to withdraw consent or the right to delete personal data held by the Operator in the cases and in the manner provided for by the current legislation of the Republic of Belarus, In this case, the user stops using the virtual gambling establishment, services, services of the Operator and, in some cases, the website. Due to the fact that the Operator is obliged to store information about the user for at least 5 years after its elimination in accordance with the legislation of the Republic of Belarus, then when exercising the user's right to withdraw consent or the right to delete personal data held by the Operator, the Operator undertakes not to process the corresponding personal data in any other way than storing.

  7. Action of the Operator and user consent

    1. The Operator notifies that it can report, disclose, transfer the user's personal data at the request of law enforcement agencies or other government agencies, if a request for this information is sent within the framework of legal proceedings, as well as in other cases provided for by the law. The User agrees to the disclosure and transfer of information in accordance with the provisions of this Policy of the Operator and/or to the Authorized Person, if applicable, by filling in and/or sending the user consent to the processing of personal data independently through special forms located on the website.
    2. The user's consent applies to the following actions of the Operator with respect to the user's personal data: collection, processing, storage, clarification, correction of data, updating and other use, as well as the subsequent transfer of personal data to the extent necessary for the purpose of ensuring the proper and effective use of the website, service and tools by the user, cross-border transfer of Specific Personal Data for the purpose of subsequent processing by a third legal entity for identification and verification of the user's digital photo portrait.
    3. In cases determined by the law, the processing of personal data is carried out without the consent of users, with the exception of Specific Personal Data.
    4. The processing of the data defined as Specific personal data is carried out when taking a set of measures aimed at preventing risks that may arise when processing such personal data for the performance of rights and freedoms of users.

  8. Purposes of personal data processing

    1. The purpose of processing the user's personal data is the conclusion, execution and termination of contracts between the Operator and the user, providing the user with access to the services, services, information and / or materials contained on the Operator's website, in order to comply with the requirements of labor legislation in relation to employees in the recruitment process candidates for open positions, for statistical reporting, in order to maintain a register of true owners, affiliates, interdependent persons, to comply with the requirements of the current legislation governing the activities of the Operator, in accordance with which the Operator is obliged to collect and store information about the user for a certain period. The operator processes user data, including for marketing and advertising purposes to promote its services to users.
    2. The Operator processes Special personal data of users in order to comply with the requirements for the Operator as an organizer of gambling in the Regulations on the implementation of activities in the field of gambling in the Republic of Belarus, approved by Decree of the President of the Republic of Belarus of August 7, 2018 № 305.

  9. Informing users

    1. The Operator has the right to send to the user and/or the client notifications about new products and services, special offers and various events. The Operator can use the services of third parties for notification, in case of a granted appropriate level of protection of personal data.
    2. The User can always refuse to receive informational messages by sending to the Operator an email to the address privacy@zfcasino.by marked as "Refusal of notifications". The Operator reserves the right to send certain types of information messages to users and/or clients despite the latter's refusal to receive notifications in cases where such notification serves the interests of the user and/or client or is mandatory by law.

  10. Cookies

    1. In the pursuit of greater transparency and convenience the Operator has prepared this cookie policy.
    2. What cookies are. Cookie (cookies – plural) is a small text file that a website stores on your computer or mobile device when you visit it. This allows the website to remember your actions and preferences (such as login, language, font size) for a certain amount of time, so that you do not have to log in again when you return to the website or switch from one page to another. Cookies differ in type. Our website uses following types of cookies: technical, functional, analytical, targeting and advertising.
    3. How the Operator uses cookies. The website uses cookies to save your IP address and download history, username and password for your account, site language. Such cookies can be classified as functional. Analytical, targeting and advertising cookies allow the Operator to monitor traffic on the website and user interaction with it - the Operator uses this data to study user behavior and improve the quality of their experience in interacting with the website. These cookies are placed and used by advertising networks. Cookies are stored on your device only if you allow this unless cookies are required directly for the technical functioning of the website. However, it should be noted that if you do not accept the use of cookies, some functions of the website may not work correctly or even stop working at all. Cookies are used basing on the legitimate interest of the Operator in ensuring the functionality of the website. Cases, where cookies are used to remember your choices or your statistics are based on your consent, which is requested during first visit to the website.
    4. How to manage cookies. Cookies are stored in the browser of your computer or mobile device, you can delete them in the browser history in whole or in part, and configure most browsers to prevent cookies from being saved. However, if you do this, you may have to manually adjust some of your preferences each time you visit a website; A website visitor using the F12 key or the fn + F12 key combination can open the developer dashboard in their browser, then open the corresponding tab, in which the Cookies section is available, here a user can see the full list of cookies used on the website page they have opened at a given time. The section includes the names and source (domain) of cookies, as well as their storage period. In the control panel of your browser you can see the cookies used and also configure general rules for their application there. Detailed information on managing cookies is available in English at https://allaboutcookies.org/ and https://www.youronlinechoices.com/ . The websites do not belong to the Operator and have their own rules of use. At the moment, the user of the website does not have the technical ability to give permission for the use of certain types of cookies. The user agrees to the use of cookies in general or refuses such consent. If the user does not accept the use of cookies, they must immediately stop using the website. The Operator is constantly working on the improvement of its website and plans to add such an opportunity (the use of certain types of cookies) in the future.
    5. Who has access to your data. Employees of the Operator may have access to data on users of the Operator's website in connection with the performance of their official duties. Either the owners of the host server or partners of the Operator in the sphere of creation and placement of content on the website have access to the technical records on the website's host server.
    6. Cookies storage period. According to the storage period, cookies may be classified as session and persistent. Session cookies are cookies that are stored while visiting a website. For example, they allow you to remember the selected language. Session cookies are never stored for a long time and are deleted when you close your browser. Persistent cookies are stored in the user's browser for a long time - this type of cookie has a validity period. Persistent cookies allow websites to remember users' personal information the next time they visit the website. The Operator stores information from persistent cookies for 5 years, information from cookies, used by the services of our partners, may have its own storage period.
    7. Website user rights. The website user has the right to:
      • - get information about cookies on the Operator's website;
      • - update the cookies used on the website of the Operator;
      • - delete information received from cookies and allow to identify the user;
      • - withdraw the consent to the use of cookies;
      • - complain to us and/or to the competent authority.
    8. When visiting the website for the first time, the user must either accept the use of cookies by clicking on the pop-up banner on the word accept, or reject the use of cookies.
    9. If the user wishes to withdraw consent to the use of cookies or change the scope of consent, they must send a request to privacy@zfcasino.by indicating:
      • - surname, first name, patronymic (if any) of the user, address of their place of residence (place of stay);
      • - date of birth of the user;
      • - user identification number, in the absence of such a number - the number of the identity document, in cases where this information was indicated during registration;
      • - the IP address of the browser for which it is necessary to withdraw the consent to the use of cookies;
      • - the request must be signed in person or using an electronic digital signature.
    10. The user can change the settings for the use of cookies in the browser independently. For the Google chrome browser, one needs to go to Settings> Privacy & Security> Cookies and other website data.

  11. The procedure for collecting, storing, transferring and other types of processing of personal data

    1. The Operator and/or the Authorized Person, if applicable, processes the user's personal data if they are filled in and/or sent by the user independently through special forms located on the Operator's website and (or) when they are received by e-mail. by ticking the checkbox, with a notification that the user has read its contents.
    2. If Personal Data is processed by an Authorized Person, then the Authorized Person is obliged to comply with the requirements for the processing of personal data provided for by the law. The authorized person is not required to obtain the consent of the users. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection. In addition, the adoption of a set of measures aimed at preventing risks for the security of Specific Personal Data is ensured.
    3. The Operator ensures the safety of personal data and takes all possible measures to exclude access of unauthorized persons to personal data.
    4. The Operator undertakes not to transfer the user's personal data to third parties. An exception is the transfer of personal data to third parties in the process of using the website, service and services of the Operator by the user, where such third parties may be affiliated persons of the Operator, as well as individuals and/or legal entities with whom The Operator has concluded contracts and agreements for the performance of work, provision of services, or partnership agreements necessary to ensure the use of the site, services (including the virtual gambling esteblishment) by the user, banking institutions, payment systems, persons with whom the Operator has concluded agreements advertising and marketing services, as well as persons participating in the same promotional activities along with the subject of personal data, when such transfer is due to the functioning of the loyalty program.
    5. All third parties to whom the Operator provides the user's personal data receive the minimum amount of personal data that is reasonably necessary for them to provide services to the Operator. And also, all third parties listed here keep the user's data in confidentiality and have a level of confidentiality in relation to personal data not lower than that of the Operator.
    6. In order to ensure the protection of personal data, the Operator appoints 1) a person responsible for exercising internal control over the processing of personal data; 2) publishes and updates this Policy; 3) informs the employees of the Operator and/or an authorized person and/or other persons directly processing personal data about the provisions of the legislation on personal data, 4) trains these employees and other persons in the manner prescribed by the law; 5) establishes the procedure for access to personal data; carries out technical and cryptographic protection of personal data; 6) determines the list of foreign states on whose territory an adequate level of protection of the rights of subjects of personal data is ensured.
    7. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to privacy@zfcasino.by marked as “Withdrawal of consent to the processing of personal data”.
    8. The User can at any time request information regarding the processing of personal data by sending a notification to the Operator via e-mail to privacy@zfcasino.by with the note “Receiving information regarding the processing of personal data”.
    9. In case of revealing inaccuracies in personal data, the User can update it independently, by sending a notification to the Operator with the note “Change of personal data”.
    10. The User can at any time request information about the provision of personal data to third parties by sending a notification to the Operator via e-mail to privacy@zfcasino.by with the note “Receiving information about the provision of personal data to third parties”.
    11. All of the above notices containing user statements must contain the information specified in Art. 5 of this Policy. The Operator retains information about the user for at least 5 years after the closure, termination of access to the account, since this period is the period of data storage required in accordance with the legislation of the Republic of Belarus. At the end of the specified period, information about the user's personal data is subject to deletion or may be depersonalized in order to achieve the anonymity of such information by hiding personal characteristics from this information.

  12. Cross-border transfer of personal data

    1. The Operator carries out cross-border transfer of personal data only to the territory of a foreign state, which provides reliable protection of user rights in accordance with the Council of Europe Convention "For the protection of Individuals with regard to Automatic Processing of Personal Data", concluded in Strasbourg on January 28, 1981.
    2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above-mentioned requirements can only be carried out if users are informed about the risks arising from the lack of an adequate level of protection of Personal data in such countries, personal data is obtained on the basis of an agreement concluded (which is in the process of conclusion) with the user, in order to perform the actions established by this agreement; receipt of personal data by any person by sending a request in the cases and in the manner prescribed by the law; transfer of data when it is necessary to protect the life, health or other vital interests of the subject of personal data or other persons, if it is impossible to obtain user consent; processing of personal data in the framework of the execution of international treaties of the Republic of Belarus; obtaining the appropriate permission from the authorized body for the protection of the rights of subjects of personal data.
    3. Cross-border transfer of personal data can also be carried out basing on the availability of a court decision, a legal requirement, the provision of services (as described in clause 10 of the Policy), as well as in other cases that have a legal justification. The Operator notifies users that it does not process personal data for the purpose of selling it.

  13. Final provisions

    1. The user can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail privacy@zfcasino.by in the manner and in the amount specified in this Policy and the legislation of the Republic of Belarus.
    2. This document will reflect any changes in the Privacy Policy of the Operator. The policy is valid for an indefinite period of time until it is replaced by a new version.