Latest update: 19.05.2021
1. In general
Pafer aims to offer customers safe and socially responsible, personalised gaming service for fun and entertainment. In order to provide the gaming service www.noaccountbet.ee and related products and services (hereinafter referred to as the "Gaming Service"), Pafer needs to process your personal data. Pafer protects your privacy and undertakes to protect your personal data when you use and visit the Gaming Service.
Pafer complies with applicable laws and regulations on data protection, including the Data Protection Regulation, (EU) 2016/769.
1.1 Data controller
Pafer is the controller and is responsible for all personal data collected by Pafer and for the processing activities of that personal data.
(Company Reg. No. 10017059)
Email: [email protected]
Data protection officer
Email: [email protected]
In order to fulfill legal age requirements and for responsible gaming reasons, Pafer applies a strict age limit for using the Gaming service. Hence, Persons under the age of 21 (except for betting where the age limit for playing is 18 years) may not submit any personal data to Pafer.
4. Data collected by Pafer
4.1 Data you provide to Pafer
Pafer collects the personal data that you provide to Pafer in connection with your registration of a gaming account. In order to participate in online gaming, you must have a registered gaming account on the Gaming Service. When you register a gaming account, you will need to enter information such as your name, personal identity number, email address and country of residence.
4.1.2 Administration of the Gaming Service
Pafer also collects personal data that you provide to Pafer in connection with administration of the Gaming Service, including for the purpose of administering payments to your bank account, e-wallet or other registered payment method you have with Pafer. Pafer may also request that you verify your identity.
You may also provide data to Pafer when you contact Pafer or participate in Pafer’s activities or otherwise provide information to Pafer.
4.2 Data that Pafer collects from other sources
4.2.1 From third parties
In addition to the data you provide to Pafer, Pafer may collect and/or update your personal data through third parties, for example from various authorities and public records.
Data that Pafer collects from third parties comprises:
- Identification data such as name, personal identity number and address details from public records to ensure that Pafer has accurate data about you.
- Information from the national gambling exclusion register (HAMPI) - Pafer is obligated to check against the HAMPI register and if you are listed in the register, Pafer cannot accept you as a Gaming Customer.
- Income data from the tax office, partly to comply with Pafers obligations in accordance with the Act on Preventing Money Laundering and Terrorist Financing, and partly to enable Pafer to detect and take action in the event of any gambling problems.
- Data from gaming providers who provide Pafer with games on the Gaming Service that indicate whether cheating, fraud or other violations have occurred in breach of the Agreement, the gaming rules or applicable laws. Pafer also collects data generated by you from playing the games provided by the gaming provider which includes segmented data as well as profiled data.
- Data that Pafer must examine by law, for example, if you are a person in a politically exposed position under the Act on Preventing Money Laundering and Terrorist Financing. Pafer uses subcontractors to examine such data.
- Pafer uses subcontractors that offer solutions for the detection and prevention of fraud, other offences and improper conduct against Pafer and/or you as a gaming customer. These business services involve the examination of devices connected to the internet in order to evaluate the risk level of fraud and whether there is a history of fraudulent conduct so that Pafer can protect its business from persons who wish to commit crimes against Pafer or you as a gaming customer.
4.2.2 Use of the Gaming Service
Pafer also collects data generated through your use of the Gaming Service, including transactions to and from your gaming account. This means that Pafer stores and processes data on how you use the Gaming Service, for example the games you play, the tools you use, the Club Paf events in which you have participated, transfer of gaming funds between your external payment providers and Pafer’s bank accounts, and correspondence between you and Pafer.
5. Objectives of Pafer's processing of personal data
Pafer’s objectives are described below, that is, the purpose of processing your personal data and the legal basis for such processing.
|Purpose||Justification of the necessity of data processing||Legal basis|
|Registration of gaming account||Processing is necessary for you to be able to open a gaming account with Pafer. All online gaming requires that you as a gaming customer register a gaming account at the Gaming Service.||Performance of legal obligations - Processing is necessary to fulfil one or more legal obligations pertaining to Pafer. Performance of contract - Collection and processing of personal data is necessary for Pafer to fulfil its obligations under the Agreement between you and Pafer and for you and Pafer to enter into the Agreement.|
|Administration of the Gaming Service and your personal data||Processing is necessary for the administration of the Gaming Service, including the transfer of gaming funds between your account, accounts of external payment providers and Pafer’s bank accounts, management of customer funds and administration of your data. Administration of the Gaming Service is also necessary to maintain the customer relationship between you and Pafer.||Performance of contract - Collection and processing is necessary for Pafer to fulfil its obligations under the Agreement between you and Pafer.|
|Delivery of a customised and personalised Gaming Service||Processing is necessary for the creation of customised content on the Gaming Service by providing you as a gaming customer, with relevant game recommendations, presentation of specific offers and other similar actions.||Performance of contract - Collection and processing is necessary for Pafer to fulfil its obligations under the Agreement between you and Pafer.|
|Supply and provision of qualitative customer service||Pafer offers customer service by phone, email and chat. Pafer uses the information you provide to investigate, respond to and resolve complaints and issues with the Gaming Service, for example bugs or winner payouts. Pafer also records conversations with customers in order to quality assure Pafer’s customer service and for training purposes, so as to improve and develop Pafer’s customer service.||Performance of contract - Collection and processing is necessary for Pafer to fulfil its obligations under the Agreement between you and Pafer. In the event that a person that is not a customer contacts Pafer customer service, processing is based on legitimate interest. Processing is necessary to meet both Pafer’s and your interests in solvning of your issue.|
|Deliver and provide chat services in connection with certain games||Processing is necessary for the provision to you of chat features, to enable you to contact Pafer and other players in connection with certain games. Processing is also necessary to ensure that the content and your behaviour in the chat feature are appropriate, which means that the content may not be offensive, discriminatory or encourage crime.||Performance of contract - Processing is necessary for Pafer to fulfil its obligations under the Agreement between you and Pafer.|
|Prevention of abuse of the Gaming Service and prevention, preclusion and investigation of violations against Pafer and/or you||Processing is necessary for prevention and investigation of any fraud or other offences. Processing is also necessary for the prevention and investigation of harassment, attempts to unlawfully log in to your gaming account or any other actions prohibited by law or by the Agreement between you and Pafer, as well as Pafer’s or the gaming provider’s gaming rules. Furthermore, processing is necessary to provide a safe and secure Gaming Service, improve and develop Pafer’s IT environment, and to protect you and your gaming account from attacks and intrusion.||Performance of contract - Processing is necessary for Pafer and you, as a gaming customer, to fulfil your obligations under the Agreement between you and Pafer. In cases where processing is not necessary to fulfil the Agreement between you and Pafer, processing is based on a legitimate interest in protecting, preventing and precluding abuse of the Gaming Service and preventing and investigating any offence against Pafer or you as a gaming customer.|
|Responsible gaming •Provide socially responsible Gaming Service •Counter, prevent and preclude problem gambling •Offer customers tools and services that help customers make informed decisions about their gambling||Pafer processes your personal data when you as a customer use: •Pafer’s tools and services to make informed decisions about your gambling, such as deposit limits, freezing of the gaming account or receiving reminders about how long you’ve been playing. •Pafer’s questionnaire and/or self-test to get information about your gaming habits. Pafer also processes your data that has been generated by your use of the Gaming Service, including the profiling of your gaming behaviour to detect, counteract and prevent problem gambling. Pafer also processes your personal data to verify that you are not registered in a self exclusion registry and to accommodate your request in the event you wish to be suspended from the Gaming Service. Pafer reserves the right to suspend you from the Gaming Service if your gaming pattern strongly indicates that you may have problems with your gambling and may not take control of your gambling yourself or do not take the steps recommended by Pafer. Pafer has a Yearly Loss Limit to ensure that customers cannot lose more than €200,000 during a twelve month period (measured over a calendar year). This is an automated system that calculates a customer’s stakes minus their winnings. Once stakes exceed winnings by €200,000 the customer will be unable to make further bets until the beginning of the next calendar year or until a win changes the loss. . If you choose to use Pafer’s gaming insurance, Pafer will process your personal data to investigate whether you are entitled to the insurance and to provide the insurance to you. Pafer also processes anonymous data in order to contribute to research in the field of gaming responsibility||Performance of legal obligations - Processing is necessary to fulfil one or more legal obligations pertaining to Pafer. Consent - In the event that you as a gaming customer choose to use Pafer’s gaming insurance or to take Pafer’s survey or self-test, Pafer needs your consent to provide these services. In cases where there is no legal obligation or consent, processing is based on a legitimate interest of Pafer being a gaming company that takes responsible gaming seriously, preventing and protecting you from unhealthy gaming habits and problem gambling.|
|Administration of events and other occasions, promotions, competitions and tournaments including travel and prize givings.||You have the opportunity to participate in Pafer’s promotions, competitions, tournaments and events and other arrangements organised by Pafer and/or Club Paf. In order for you to participate in these arrangements, it is necessary to process your personal data to administer your participation. Processing is also necessary if you participate in any of Club Paf’s trips as well as processing of your friend’s personal data if you choose to bring a friend on the trip. As a participant, you can invite a friend to most trips and other events organised by Club Paf.||Performance of contract - Processing is necessary for Pafer to fulfil its obligations under the terms of the competition or the promotion. Consent - In cases where the performance of an agreement cannot be applied and Pafer processes your friend’s personal data to administer the trip or some other event in which your friend is participating, Pafer needs your friend’s consent to process the personal data.|
|Marketing of the Gaming Service and Club Paf||Pafer processes personal data to promote its products, services and promotions, including Club Paf events. Pafer also processes personal data through profiling in order to suggest customised offers and marketing to you as a gaming customer. You can at any time choose not to receive personal offers generated through profiling by declining personal offers and marketing on your gaming account. As a gaming customer you can also choose not to receive direct marketing, or only receive direct marketing through certain communication channels through the settings in your gaming account.||Legitimate interest - Processing is based on a legitimate interest in marketing Pafer and the Gaming Service, including various events organised by, or sponsored by Pafer.|
|Communications||Pafer communicates with you through various communication channels, for example, via email, mobile phone, Gaming Service notifications, messages to your inbox at the Gaming Service and other similar ways. Messages from Pafer may contain news about Pafer, availability and security of the Gaming Service, reminders and marketing announcements from Pafer and Pafer’s business partners. You can change your communication settings on your gaming account at any time. Please note that you cannot opt out of Pafer service announcements, which includes customer information, security and legal notices. Pafer also gives you the opportunity to communicate with others in connection with some games, please see "Deliver and provide chat services in connection with certain games".||Performance of contract - Some communications are necessary for Pafer to fulfil its obligations under the Agreement between you and Pafer, such as providing information on security and legal matters. Legitimate interest - Some communications are based on a legitimate interest in being able to send information about Pafer and marketing about Pafer’s services and products.|
|Develop the Gaming Service and conduct surveys as well as perform business analysis and statistical calculations.||Processing is necessary to develop and improve the Gaming Service and to make the Gaming Service user-friendly for you. Pafer analyses usage patterns of the Gaming Service, among other things, in order to be able to take improvement and development measures||Legitimate interest - Processing is based on a legitimate interest in improving and developing the business, including the Gaming Service, and the interest in offering a user-friendly Gaming Service to Pafer’s customers.|
|Performance of legal obligations pertaining to Pafer.||Processing is necessary to fulfil Pafer’s legal obligations under legal requirements, court judgements or official decisions. Pafer has a duty to comply with applicable laws, for example laws regarding the provision of games, the prevention of money laundering and financing of terrorism, accounting and applicable license terms.||Performance of legal obligations - Processing is necessary to fulfil one or more legal obligations pertaining to Pafer.|
5.1 Processing for other purposes
The main rule is that your personal data is only processed for the specific purposes for which your personal data was collected. However, your personal data may be processed for other purposes, provided that these purposes are consistent with the original purposes for which your personal data was originally collected. For example, Pafer may process your personal data for other purposes due to legal reasons.
6. Duration of the data storage
Pafer does not store your data for longer than is necessary for the specified purposes. In general, Pafer stores your personal data until three years after the customer relationship has ended, to provide you with support if needed and for business continuity in case you return to Pafer as a customer, as well as for your right to have any remaining gaming funds in your gaming account paid into your bank account, e-wallet or other payment method that you have registered with Pafer. Note that legal requirements or official decisions may extend this timeframe. Thereafter, the data is deleted or anonymised so that it can no longer be linked to you as a person. However, you may request that Pafer anonymise your personal information earlier, provided that the customer relationship has ended and that Pafer does not need the personal data to fulfil its legal obligations pursuant to law.
Pafer may store your personal data for less than three years after the customer relationship has ended. For example, Pafer stores your personal data in cases where you have attended events or other arrangements, promotions, competitions or tournaments, including travel and prize-givings, until they have been completed and follow-up of the current event has been completed.
Specifically with regard to recorded customer conversations, Pafer store these recorded calls for 90 days.
In the event that you do not wish to receive Pafer marketing, Pafer will discontinue the processing of your personal data for that specific purpose. Note, however that Pafer will process your personal data in order to ensure that you won't receive any marketing. The same also applies to cases in which you withdraw your consent.
Chat services associated with certain games are provided by Pafer’s gaming providers and Pafer does not have access to the logs that the gaming provider saves. Pafer will only be notified if you as a gaming customer have acted improperly and do not comply with the terms set out in the chat service agreement. Therefore, Pafer only stores data relating to breaches of the terms of the chat service.
Pafer may store some of your personal data for more than three years after the customer relationship has ended, in order to fulfil its legal, regulatory, and/or licence terms. For example, Pafer has an obligation to keep some of your personal data for six years from the end of the year when the accounting period has ended in accordance with the Accounting Act and five years after the customer relationship has ended, pursuant to the Act on Preventing Money Laundering and Terrorist Financing. Pafer then only processes the parts of your personal data that are required for these specific purposes.
Pafer may also process your personal data more than three years after the customer relationship has ended if the personal data is included in an ongoing legal process.
7. Automated decisions for individual players
In order to fulfill the relevant legal requirements, Pafer verifies parts of your personal details and makes automated decisions based on those verifications. That includes decisions regarding your rights to use Pafer’s Gaming Service.
Pafer also applies automated decisions in regards to responsible gaming, including blocking customers from depositing further funds into their gaming account when they have reached the Yearly Loss Limit. Automated decisions are also applied when limiting or locking customers’ gaming accounts. The aim of these decisions is to prevent, counteract and prohibit problem gambling, identify gambling problems and make customers aware of their gaming behaviour.
Pafer may also terminate a customer relationship or lock a gaming account based on a customer’s inactivity and the likelihood that the customer in question is not using the Gaming Service.
8. Sharing and transfer of personal data
8.1 Disclosing of personal data
Pafer may disclose your personal data in cases where Pafer is required to do so by law, regulation or as a result of a request from an authority (police, tax office or other authorities) to disclose the data. Pafer may also disclose your data in cases where Pafer suspects that a crime has been committed.
8.2 Data processors
In order to provide parts of the Gaming Service, Pafer uses so-called data processors, companies that process personal data on Pafer’s behalf in accordance with Pafer’s instructions. Pafer uses the following personal data processors:
- Game providers to be able to provide a varied range of games.
- IT companies that provide IT solutions for necessary operation, technical support and maintenance of the Gaming Service and Pafer’s other activities.
- Companies that provide payment solutions such as card payment companies, banks and other payment service providers.
- Companies that provide services to counteract and detect fraud, other crimes and/or other improper conduct.
- Companies that run marketing such as media and advertising agencies and affiliates.
The sharing of personal data to data processors takes place only for purposes that are consistent with the purposes for which Pafer has collected personal data, for example in order to fulfil Pafer’s commitment under the Agreement.
Pafer controls and ensures that each personal data processor provides sufficient guarantees regarding the security, protection and confidentiality of personal data. Pafer has written agreements with alldata processors that regulate the undertakings of the data processors where they, inter alia, undertake to comply with Pafer’s written instructions, security requirements and the restrictions and requirements that apply to the transfer of personal data.
8.3 Within the Paf Group
8.4 Other companies
Pafer shares personal data with other companies with which Pafer is in cooperation, but which do not act as a data processor, i.e. the company is an independent data controller. This means that these companies decide independently how personal data will be processed. Pafer shares personal data with the following companies which are independently responsible for the personal data:
- Companies that provide payment solutions such as card payment companies, banks and other payment service providers.
- Companies that provide booking services for travel, airlines, hotels and similar companies for example to organise Club Paf trips.
- Companies that supply prizes to those who have won a prize by participating in any of Pafer’s activities.
- Certain game suppliers that supply games to the Gaming Service.
- Insurance companies that provide gaming insurance.
- Research institutes. Pafer transfers anonymous data to research institutes in order to contribute to research in the field of gaming responsibility.
For further information regarding the companies that independently processes your personal data , you will find more info here or by contacting Pafer.
8.5 Transfer of personal data
Pafer always strives to process your personal data as far as possible within the European Union (EU) and the European Economic Area (EEA). In cases where it is necessary to transfer personal data outside the EU/EEA, for example, for the sharing of personal data with a data processor who, either himself or through a subcontractor, is established or storing personal data in a country outside the EU/EEA, Pafer has taken the necessary and reasonable legal, technical and organisational measures to ensure that the level of protection is the same as in the EU/EEA. When transferring personal data to a country outside the EU/EEA, the level of protection is guaranteed either by decision of the EU Commission that the country in question ensures an adequate level of protection, or that the company has entered into the EU’s standard contractual clauses. Other appropriate safeguards are approved code of conduct in the recipient country and the application of internal binding company regulations. In the event Pafer transfers personal data outside the EU/EEA, the processing is primarily supported by the EU standard contractual clauses.
9. YOUR RIGHTS
9.1 Right of access
You are entitled to access your personal data, that is, a record of what personal data Pafer is processing about you, provided that the data does not affect the rights and freedoms of others, or access to personal data is forbidden due to legal requirements, for example the Act on Preventing Money Laundering and Terrorist Financing. Please note that in cases where Pafer receives a request for access to data, Pafer may request further information from you requesting access to your personal data, to ensure effective handling of the request and disclosure of the data to the correct person.
9.2 Right to rectification
You are entitled to have incorrect personal data that concerns you rectified as well as within the stated purpose, to supplement incomplete personal data.
As a gaming customer, you can update your contact details yourself via your gaming account. Other data that may need to be corrected or supplemented is handled by contacting Pafer.
9.3 Right to be forgotten
You are entitled to request that Pafer delete or remove all or some personal data, for example, if the personal data is no longer required for the purposes it was collected or otherwise processed.
Please note that Pafer may deny your request for deletion or removal of your personal data in cases where the processing is performed due to legal obligations which apply to Pafer, such as the Accounting Act or the Act on Preventing Money Laundering and Terrorist Financing. Pafer may also deny your request for deletion and removal of your personal data if Pafer has a compelling legitimate interest for the processing, or if it is necessary for Pafer to determine, claim or defend legal claims.
9.4 Right to restriction of processing
You are entitled to some extent to request that Pafer’s processing of your personal data be restricted, for example, if you contest the accuracy of your personal data or that the processing is illegal but you do not want your personal data to be deleted. The processing of your personal data may also be restricted to establishing, enforcing or defending legal claims and in cases where the processing is based on a legitimate interest to the extent necessary to determine whether Pafer has a compelling legitimate interest which carries more weight than your legitimate grounds.
Please note that Pafer is entitled to store your personal data during the restriction of processing of your personal data and process such personal data in order to determine, enforce or defend legal claims or to protect any other natural or legal person’s rights. Pafer may also process such data in cases where you have given your consent, or for reasons relating to an important public interest.
9.5 Right to object
You are entitled to object to certain types of processing, such as Pafer’s processing of your personal data for direct marketing and processing that is supported by a legitimate interest.
9.5.1 Direct marketing
You may object at any time to processing that relates to direct marketing, including profiling (analysis of personal data collected), to the extent that profiling is connected to such direct marketing.
As a gaming customer, you can select which communications channels Pafer may use to send marketing to you through the settings in your gaming account. If you do not want any marketing sent to you, Pafer will stop sending marketing to you and discontinue such processing of your personal data.
9.5.2 Legitimate interest
In the event that Pafer relies on legitimate interest to support processing, you can object to such processing.
However, please note that Pafer may continue the processing if Pafer has a compelling reason for processing the personal data. That is to say, Pafer’s interests carry more weight than your interests. Otherwise, Pafer may only process your personal data in order to determine, exercise or defend legal claims.
10.6 Right to data portability
If Pafer’s processing of your personal data is based on either your consent or on performance of an agreement between you and Pafer, and that your personal data is provided by you and that the processing is automated, you are entitled to request that your data be transferred to another data controller (right to data portability).
10.7 Withdrawal of consent
In cases where Pafer bases its processing of your personal data on your consent, you can withdraw your consent at any time, at no cost. You can withdraw your consent by contacting Pafer customer service.
Note that the withdrawal of consent does not affect the legality of the processing that takes place before the consent is withdrawn.
10.8 Right to lodge a complaint
If you consider that Pafer’s processing of your personal data does not comply with applicable data protection laws, you may submit a complaint to the Estonian Data Protection Inspectorate.
Pafer uses so-called cookies. Cookies are small text files that are saved on your device (e.g. your computer, mobile or tablet) when you visit the Gaming Service.
Pafer has taken all necessary and appropriate steps to protect your personal data from unauthorised procedures such as unlawful or unauthorised processing, which includes theft, deletion, alteration, disclosure and transfer of personal data. These measures include the greatest possible restriction of the circle of people that has the right to the personal data and limitation of the ability of the authorised persons to make changes, as well as technical barriers to infringement, including encryption during transmission and storage, firewalls, strict requirements for passwords, and alert functions with reporting upon attempted unauthorised infringement. Pseudonymisation is used to the fullest extent during our processing, to further protect your privacy. Pafer is also ISO 27001 certified