“APPROVED”
Order № 2/1-1 dated 2/1/2024
Director of LLC NATIVE APPS
Shaldzhain V.V.
PRIVACY POLICY
OF LIMITED LIABILITY COMPANY NATIVE APPS
LIMITED LIABILITY COMPANY NATIVE APPS, identification code of the legal entity 43488489, registered office: 35 Svitlytskoho str., office 108/4, Kyiv, 04123, Ukraine (hereinafter referred to as "the Company", or "We", or "Our") puts the personal right of a person to information privacy in the first place and strives as much as possible to process the personal data of the Users of the https://supergra.ua portal (hereinafter referred to as "the Portal") and/or the SuperGra Mobile Application, taking into account the requirements of the Applicable Laws of Ukraine and generally recognized principles of law.
In this Privacy Policy of the Company (hereinafter referred to as "the Policy"), information about personal data is provided to the following categories of personal data subjects:
1. "User" — for the purposes of the Policy, this category is used and applied to anyone who accesses and uses the SuperGra Portal/Mobile Application, regardless of registration.
2. "Client" — a category for registered Users who have created a Client account and for personal data subjects who register on the SuperGra Portal and/or Mobile Application.
In this Policy, we share the following information with you, Users and Clients as data subjects:
- Our contact details as the personal data owner;
- the categories of personal data that We collect and process;
- the purposes for which the personal data is processed;
- the aim of processing the personal data;
- the legal basis for processing the personal data;
- third parties who may receive your personal data;
- your rights as a data subject and the procedure for their realization.
In this Policy, We use the general term the Portal to refer to the Portal and the SuperGra Mobile Application together, except for exclusive clauses relating to the SuperGra Mobile Application and personal data processed when using the SuperGra Mobile Application.
All terms used in this Policy should be interpreted in accordance with the Applicable Laws of Ukraine, the Rules of the Gambling Organiser of the LIMITED LIABILITY COMPANY NATIVE APPS (hereinafter referred to as "the Rules"), except for cases when they have a different meaning in accordance with this Policy.
WHO PROCESSES PERSONAL DATA?
The Company administers and owns the Portal.
The Company is the owner of personal data and has full legal responsibility for the processing of your personal data in the context of using the Portal and in the process of receiving services from the Company for organizing and conducting Online Casino Gambling (hereinafter referred to as "the Services") in accordance with the provisions of the Law of Ukraine "On Protection of Personal Data" (hereinafter referred to as "the Law").
When the Company transfers your personal data to the managers and third parties, We share responsibility with them (partially), but, at the same time, we impose on them contractual obligations to ensure the security and confidentiality of your personal data.
Please, contact Us by email at [email protected] or with a letter to our official address in case any questions about processing personal data arise when using the Portal.
WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?
The Company collects different categories of personal data when you use the SuperGra Portal/Mobile Application and Our Services. In this section, we provide you with detailed information about the data collected and processed by Us.
We automatically collect data contained when you visit the Portal, in particular, we collect the following data from your browser or cookies (for the categories "User" and "Client"):
- your user-agent string: data about your device, operating system, etc.;
- your IP address;
- data about your visit to the Portal: the pages you visited and how long you stayed on each page, information about the source that led you to the Portal (Referer), etc.;
- other data collected automatically: information about your geolocation, data on your authorizations on the Portal (for Clients), etc.
Also, if you create a Client Account on the Portal, the Company shall implement proper identification regarding you, in order to do so, We may collect the following data (which can be received directly from you) in particular:
- your last name, first name and patronymic (if any);
- your age (date of birth);
- information about your passport or another identity document, which, in accordance with the Applicable Laws of Ukraine, can be used on the territory of Ukraine to conclude transactions: number, series (if any), date of issue and issuing authority, and photographs of this document;
- registration number of the taxpayer's account card;
- your telephone number and email address;
- for persons who are residents of states other than Ukraine (hereinafter referred to as a "non-resident") — information about your citizenship;
- information about your place of residence or place of stay (for residents), place of residence or place of temporary visit to Ukraine (for non-residents);
- data on your electronic signature, BankID, MobileID, Diia.Signature in case you use these methods for your identification;
- unique entry number in the Unified State Demographic Register (if any) for non-residents.
We may obtain the following identification data from official and/or reliable sources:
- information about your status in the Register of persons with restricted access to gambling establishments and/or participation in gambling games;
- information about your status on the list of terrorists, the sanctions list of the National Security and Defence Council of Ukraine (NSDCU), and your affiliation with politically exposed persons.
Once the identification is done, the verification process begins, i.e., the Company verifies the accuracy of the identification data provided by you. For this purpose, the Company may collect data that includes, but is not limited to, the following (for the category "Client"):
- a photograph of your passport or another identification document which, in accordance with the Applicable Laws of Ukraine, can be used on the territory of Ukraine to conclude transactions;
- your own image (photograph) with your passport or another identification document which, in accordance with the Applicable Laws of Ukraine, may be used on the territory of Ukraine to conclude transactions, in particular using your photo fixation with such document;
- a photograph of your payment instrument and your image (photograph) with the payment instrument;
- documents that verify your place of residence, and for non-residents — information about the place of temporary visit in Ukraine ;
- with your unambiguous consent, the Company may conduct video verification. In this case, the Company will process audiovisual information and photo fixation data;
- if you are a politically exposed person (PEP) or a family member of a politically exposed person, data or documents may also be collected to prove the source of your funds (wealth), the source of funds related to financial transactions, or other information about your income, wealth, etc.;
- other documents that may be necessary to fulfill the requirements of the Applicable Laws of Ukraine;
- any information from official and/or reliable sources in accordance with the Applicable Laws of Ukraine.
When you use bonuses on the Portal, the Company collects information about the bonuses, which includes, without limitation, the following information (for the category "Client"): the name of the bonus, the date and time of activation, and the entire history of your use of bonuses, etc.
If you place a bet on the Portal, the Company collects, processes and analyzes information about bets etc., which includes, without limitation, the following information:
- details of your bets and your gambling activity within the Gambling Games;
- the sum of the bet you placed;
- the history of all your bets while using the Services.
Information about payments. We do not process your payments/transactions directly. Such operations (payments/transactions) are processed by banks or third-party financial institutions that transmit information about Your payments/transactions to Us. This information (data) includes (for the category "Client"): transaction information, including, without limitation, details of the payment method used for the payment, transaction amount, and other transaction information. Additionally, the Company collects and compiles all your transaction/payment history. The Company collects and processes data about communications with you and the history of communications with you, which includes (for the categories "User", "Client"): the content of all messages, correspondence data (email, via the Portal interface, paper correspondence) and call recordings (both audio and video).
WHAT ARE THE PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
The purpose of processing personal data: ensuring the implementation of relations in the field of organizing and conducting Online Casino Gambling, providing players with services for organizing and conducting Online Casino Gambling: providing players with access to participate in Online Casino Gambling, verifying players, accepting bets, processing payments, paying out winnings, accruing bonuses, involving in loyalty programs, etc.;
The composition of personal data processed in accordance with the specified purpose.
Basis for the processing of personal data:
- consent of the personal data subject to the processing of their personal data;
- conclusion and performance of a legal act, in which the personal data subject is a party or which is concluded for the benefit of the personal data subject or for the implementation of measures preceding the conclusion of a legal act at the request of the personal data subject;
- the necessity to fulfill the obligation of the personal data controller prescribed by law;
- the necessity to protect the legitimate interests of the personal data controller or a third party to whom the personal data is transferred, except in cases when the needs to protect the fundamental rights and freedoms of the personal data subject in connection with the processing of their data outweigh such interests.
|
Purposes of processing |
Personal data contents |
Legal basis for processing |
|
Providing access to the Portal functionality. |
Data is collected automatically. |
According to clause 6, part 1, art.11 of the Law, the Company's legitimate interest is to provide you with full access to the functionality of the Portal, to save your choices on the Portal and to provide you with the possibility to log in to the Client Account. |
|
Maintaining the correct operation of the Portal and ensuring its security. |
Data is collected automatically. In certain situations, if necessary, other categories of personal data may be used. |
According to clause 6, part 1, art.11 of the Law, the Company's legitimate interest is to protect the Portal from any cyber attacks and cyber threats and diagnose and prevent problems in the work of the Portal. |
|
Protection from fraud, unfavorable or illegal activities. |
Data is collected automatically. In certain situations, if necessary, other categories of personal data may be used. |
According to clause 6, part 1, art.11 of the Law, the Company's legitimate interest is to protect the Company from possible fraud, unfavorable activities, violations of the Rules and various types of misuse of the Portal, abuse of the Services or errors that may occur on the Portal. |
|
Registration of your Client Account on the Portal. |
Identification data. Verification data. Social network data. |
Concluding transaction in accordance with clause 3 p. 1 art.11 of the Law. |
|
Verifications (checks):
|
Identification data.
Verification data. |
The necessity to fulfill the requirements in accordance with clause 5 p. 1 art. 11 of the Law. |
|
Accepting bets, processing payments, paying out winnings, awarding bonuses, and attracting to loyalty programs. |
Identification data. Betting data. Payment data. Bonus data. |
Concluding transaction in accordance with clause 3 p. 1 art.11 of the Law. |
|
Performing analytics and research on your interactions with the Portal. |
Data is collected automatically. |
According to clause 6 p. 1 art. 11 of the Law, the Company's legitimate interest is to improve the Portal and the quality of Services according to your preferences. |
|
Analyze the effectiveness of advertising campaigns. |
Data is collected automatically. Portal data. |
According to clause 6, p. 1, art. 11 of the Law, the Company's legitimate interest is to correctly attribute users and evaluate the effectiveness of mobile advertising campaigns. |
|
Sending promos and other marketing and promotional materials. |
Betting data. Bonus data. Communication data. |
Your consent in accordance with cl. 1 p. 1 art. 11 of the Law. |
|
Support communication with you concerning your use of the Portal and the Services. |
Communication data. In certain situations, if necessary, other categories of personal data may be used. |
According to clause 6, p. 1, art. 11 of the Law, the Company's legitimate interest is to communicate with you both on general issues of using the Portal and on specific issues of providing you Services. |
|
Defending the Company's interests in legal disputes. |
Depending on the situation, any personal data may be used. |
According to clause 6, p. 1, art. 11 of the Law, the Company's legitimate interest is to protect its interests in any legal disputes in case of claims (e.g., if your data needs to be disclosed within the framework of legal proceedings to form the Company's legal position). |
The Company collects and processes data about your social network account if you register or log in using a social network.
The SuperGra Mobile Application data. Our SuperGra Mobile Application uses third-party services, particularly analytics providers (Adjust Analytics, Google Analytics for Firebase, Telegram, WhatsApp) that may collect your personal data through the installed SDKs. When you use Our SuperGra Mobile Application, the following data may be collected and used:
- encrypted IP address;
- unique device identifier of advertisers (subject to your permission or non-objection in accordance with the rules of the mobile app store);
- information about the installation and first opening of the SuperGra Mobile Application on your mobile device;
- information about your interaction with the SuperGra Mobile Application;
- information about which adverts you have seen and clicked on;
- information about your device's technical characteristics and the operating system version.
For more information on what data analytics providers may collect, please see Adjust's Privacy Policy, Google Analytics for Firebase Privacy Policy, Telegram’s Privacy Policy, WhatsApp’s Privacy Policy.
The Portal data. Our Portal uses third-party services, particularly analytics providers (Google Analytics for Firebase, Telegram, WhatsApp, Facebook, etc.), which may collect your personal data through installed SDKs. If you use Our Portal via a personal gadget (a smartphone, a tablet, a laptop and other PCs), the following data may be collected:
- encrypted IP address;
- unique device identifier — IDFA (with your consent);
- information about your first visit to the Portal using your personal gadget;
- information about your interaction with the Portal;
- information about the advertisements you have seen and clicked on;
- information about the technical characteristics of your personal gadget and operating system version etc..
For more information on what data analytics providers may collect, please see KYCAID's Privacy Policy, Google Analytics for Firebase Privacy Policy, Telegram's Privacy Policy, WhatsApp's Privacy Policy, Facebook's Privacy Policy (by Meta Platforms, Inc.).
PROCEDURE FOR PROCESSING PERSONAL DATA BY THE COMPANY, BASIS FOR DELETION OR DESTRUCTION OF PERSONAL DATA
The personal data collected by the Company will be used exclusively for the purpose specified in this Policy and in accordance with the Applicable Laws of Ukraine.
The Company processes personal data only with the consent of the personal data subject, except in cases where such consent is not required by law.
The Company performs actions or a set of actions with personal data (including the use of information (automated) systems) necessary for the purpose mentioned above, including (but not limited to):
- collection;
- registration;
- accumulation;
- storage;
- adaptation;
- changing;
- updating;
- use and dissemination (distribution, implementation, transfer);
- clarification (updating, changing);
- sending by mail and/or electronic means;
- transfer, depersonalization, destruction, including with the use of information (automated) systems.
Personal data is collected when visiting the Portal, using the SuperGra Mobile Application, registering on the Portal, in the SuperGra Mobile Application, and communicating with the Company's employees.
In case of identifying information about an individual that does not correspond to reality, such information must be promptly corrected or destroyed.
The personal data subject has the right to submit a reasoned request to the Company regarding the prohibition of processing their personal data (or its part) and/or change its composition/content. The Company considers such a request within 10 days from the date of receipt.
If the results of consideration of such a request reveal that the subject's personal data (or its part) is processed unlawfully, the Company ceases the processing of the subject's personal data (or its part) and informs the subject of personal data about it.
If the results of consideration of such a request reveal that the subject's personal data (or its part) is unreliable, the Company ceases the processing of the subject's personal data (or its part) and/or changes its composition/content and informs the subject of personal data about it.
If the request is not subject to satisfaction, the data subject is provided with a reasoned response regarding the absence of a basis for its satisfaction.
Deletion and destruction of personal data are carried out in a manner that excludes the further possibility of their restoration.
Personal data is subject to deletion or destruction in the following cases:
- expiration of the data storage period determined by the consent of the personal data subject for the processing of this data or by law;
- termination of legal relations between the personal data subject and the controller or processor, unless otherwise provided by law;
- issuance of a relevant order by the Ukrainian Parliament Commissioner for Human Rights (hereinafter referred to as "the Commissioner") or by designated officials of the secretariat of the Commissioner;
- entry into legal force of a court decision on the deletion or destruction of personal data.
METHOD OF COLLECTING PERSONAL DATA
The company obtains the personal data of Users and Clients in the following ways:
- obtaining data from registration forms filled in by Clients, including copies of documents provided by them to the Company for registration, identification (verification) and checking procedures;
- obtaining data from cookies if used by the Company;
- obtaining data by configuring the settings of internet browsers (User-agent).
The Company collects only the information that was consciously and voluntarily provided by the User, Client, as the subject of personal data, in order to use the services on the Portal, in the SuperGra Mobile Application, receive advertising offers and fulfill the Company's duties as a subject of primary financial monitoring in accordance with the Applicable Laws of Ukraine.
SO WHO CAN THE COMPANY SHARE YOUR DATA WITH?
With the Company's employees, contractors, and third parties who help provide the Services. To maintain Our Portal, Services and online system, We may employ various individuals under employment contracts or as independent contractors. Therefore, such persons may have access to your personal data to run their activities. However, the Company would like to assure you that all persons engaged by Us will process your data in accordance with the Policy and the Applicable Laws of Ukraine and have appropriate contractual obligations for the security and confidentiality of your personal data.
With legal entities authorized to operate in banking, financial services, etc. Since the Company does not process your financial transactions, they are processed by third-party financial institutions. Consequently, these legal entities are the managers of your personal data.
With business entities that provide analytics and IT services. We use third-party analytics providers, which are sometimes subject to change. Currently, the main providers are as follows:
Google. The Company uses Google services provided by Google LLC. 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA and Google Ireland Limited, Gordon House Barrow Street Dublin 4, D04E5W5 Ireland, which include Google Analytics, Google Tag Manager (does not process personal data), Google reCAPTCHA and Google Analytics for Firebase. There is a Google Analytics browser app that allows you to opt out of the collection and use of Google Analytics data. To install a browser app that will block Google Analytics, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en. If you want to know how Google processes your personal data, please check Google’s Privacy Policy or the Google Analytics «Data Privacy and Security» help section.
Facebook. The Company uses the Facebook services provided by Meta Platforms, Inc., 1601 Willow Road Menlo Park, CA 94025, United States, to authorize you in your Portal profile and similar purposes. If you would like to know more about Meta Platforms, Inc. data processing, please refer to the Facebook Privacy Policy.
Telegram. Telegram Messenger Inc. (Vistra Corporate Services Centre, Wickhams Cay II VG 1110 Road Town, Tortola Virgin Islands, British) provides web communication services that the Company uses to improve communication and protect the Portal. For more information about Telegram Messenger Inc. data processing, please refer to Telegram's Privacy Policy.
WhatsApp. WhatsApp LLC, 1601 Willow Road Menlo Park, California 94025, USA, provides web communication services that the Company uses to improve communication and protect the Portal. To learn more about WhatsApp LLC's data processing, please refer to WhatsApp's Privacy Policy.
KYCAID Limited. KYCAID Limited, 71-75 Shelton Street, Covent Garden, Covent Garden, England, London, WC2H 9JQ helps users to interact with the Portal and to obtain user information from the Company. For more information about KYCAID Limited's data processing, please refer to KYCAID Limited's Privacy Policy.
With partners (providers) of games. The Company may use contractual services from various game partners (providers) to provide you with a better experience on the Portal. To enable you to play games by partners (providers), we may share minimized personal data with them. They cannot identify you using this data. Besides, game partners (providers) have contractual obligations to the Company for the security and confidentiality of the data transferred to them.
With state authorities of Ukraine. The Company may transfer your data to state authorities of Ukraine, namely:
- Commission for Regulation of Gambling and Lotteries of Ukraine;
- other state authorities of Ukraine if requested in accordance with the Applicable Laws of Ukraine.
With postal services, courier companies, etc. In case of communication by paper mail or if correspondence or other physical items are sent to you, your data will be transferred to the party involved in the delivery of the correspondence or item.
The Company may cooperate with different entities, and the list of third parties that your personal data is shared with may also vary. For detailed and up-to-date information on such third parties, contact Us by email at [email protected] or with a letter to our official address.
Access to personal data is not provided to a third party if the specified person refuses to undertake obligations to ensure compliance with the requirements of the Law of Ukraine "On Protection of Personal Data" or is unable to ensure them.
YOUR RIGHTS AS A DATA SUBJECT
The Company guarantees the inviolability of all your rights as a data subject in accordance with art. 8 of the Law of Ukraine. You have the right to:
- know about the sources of collection, the location of your personal data, the purpose of their processing, the location or place of residence (stay) of the owner or processor of personal data, or to give an appropriate order to obtain this information to authorized persons, except in cases established by law;
- receive information about the terms of providing access to personal data, including information about third parties to whom your personal data is transferred;
- access your personal data;
- receive a response on whether your personal data is processed, and receive the content of such personal data no later than thirty calendar days from the date of receipt of the request, unless otherwise provided by law;
- submit a reasoned request to the personal data controller with an objection to the processing of your personal data;
- submit a reasoned request for the change or destruction of your personal data by any controller and processor of personal data, if such data is processed unlawfully or is unreliable;
- protect your personal data against unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision or untimely provision, as well as protection from providing information that is unreliable or discredits the honor, dignity and business reputation of an individual;
- file complaints about the processing of your personal data to the Commissioner or to the court;
- apply legal remedies in case of violation of the law on personal data protection;
- caution regarding the restriction of the right to process your personal data when giving consent;
- withdraw your consent to the processing of personal data;
- know the mechanisms of automatic processing of personal data;
- be protected against an automated decision that has legal consequences for you.
If you want to enforce any of these rights, please contact Us with a request at [email protected] or our official location address.
PERSONAL DATA PROTECTION
The Company's processing of personal data is inseparably linked to the protection of the confidentiality of the information obtained by the Company unless it contradicts the Applicable Laws of Ukraine.
Personal data protection involves measures aimed at preventing their accidental loss or destruction, unlawful processing, including unlawful destruction or access to personal data.
The Company provides regular training for employees on the protection of personal data.
The Company restricts the number of individuals who are granted access to personal data.
The computers used by Employees to access personal data contain periodically updated passwords. These computers are stored at the Company's location.
Employees who have access to personal data provide a written commitment of non-disclosure of personal data entrusted to them or which became known to them in connection with the performance of their professional, official, or work duties.
TERMS AND CONDITIONS OF PERSONAL DATA STORAGE
The Company takes measures to protect against unauthorized access to personal data. Personal data is stored in the Company's information and telecommunication system.
Personal data is stored by the Company within the period specified by the Applicable Laws of Ukraine.
The term of personal data storage is set for at least five years after the termination of business relations with the personal data Subject or the completion of a one-time financial transaction without establishing business relations with the subject of the relevant category in accordance with the Law of Ukraine "On Preventing and Counteracting to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction".
After the expiration of the personal data storage period, they are subject to deletion.
CHANGES AND AMENDMENTS TO THE POLICY
If necessary, and in order to comply with the requirements of the Applicable Laws of Ukraine, the Company has the right to amend and supplement the Policy at any time. The current version of the Policy is always posted on the Portal.
CONDITIONS OF USING COOKIES FILES
The Company uses cookies and web-storage files on the Portal. Cookies and web-storage files are small files integrated (installed) on your personal gadget. With the help of these files, the Company can distinguish you from other users of the Portal, remember your choice on the Portal, and provide all the functionality of the Portal. Some cookies are used to protect the Portal.
Many browsers provide the ability to control the placement of cookies. The "Help" and "Settings" tab will provide you with the proper functionality. You can find instructions on how to manage cookies in your browser below:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=ru&p=cpn_cookies
Opera: https://help.opera.com/en/latest/web-preferences/
Firefox: https://www.mozilla.org/en-US/privacy/websites/
Internet Explorer: https://support.microsoft.com/ru-ru/help/278835/how-to-delete-cookie-files-in-internet-explorer
Safari for Mac: https://support.apple.com/ru-ru/guide/safari/sfri11471/mac
In addition, we inform you that if you have disabled or blocked cookies, the Company won't be able to provide you with the Portal with all its functionality, or the Portal may not work properly (for example, we will not remember your selection on the Portal, and you will not be able to authorize in the Client Account).