Privacy policy

1. General information

Happening d.o.o., (hereinafter referred to as "Happening", "we", "us", "our") is a company registered for computer and related activities that is providing sports betting technical solutions for a market-leading operator and acting as part of Superbet Group.

Happening d.o.o., (hereinafter referred to as "Happening", "we", "us", "our") is the Data Controller of this website and personal data you are sharing with us in accordance with the provisions of EU General Data Protection Regulation no. 679/2016 on the protection of individuals with regard to the processing of personal data ("GDPR"), the Data Protection Act 2018, as amended by Brexit legislation ("UK GDPR") and any other data protection applicable laws.

The term "Candidate" is used in this Notice to refer to any individual who applies for a job opening, or who otherwise seeks to work with or for us (whether on a permanent or non-permanent basis).

What personal information do we collect about you?

As used in this Privacy Notice, personal data means any information that can be used to individually identify you, directly or indirectly, alone or along with other information.

The categories of personal data that we collect about you are dependent upon the way in how you interact with our website and its functionalities:

• Contact us - We have provided you with a number of email addresses for which you can use in order to contact us for different reasons, directly through your email provider. If you wish to contact us in this manner, we expect to collect the following information from you: full name, email address, country, company name, your signature and any information you wish to include in your message to us that could directly or indirectly identify you.
• Cookies - When you visit our Website, we process your data collected through cookies. The cookies used on our website do not collect directly identifiable personal data such as name, address, email address etc. However, certain cookies may collect information which relate to details about the device used, journal information like IP, searches, browser, browser's language, hardware settings, date and time of the request, method used to send requests to the server, file capacity obtained in response, and other parameters regarding the user's operating system, which, when combined with other information, it becomes personal data and can indirectly identify you. For more information on what are cookies and how we use them, please read our Cookie Statement below.
• Recruitment process - if you apply to any of our job openings posted on our website or through external professional and social media platforms, we process the following personal data: information contained in your CV and application form, contact details and information related to your performance of your current profession provided during the recruitment interview.

We do not collect nor is our intention to collect personal data regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. We recommend you avoid sending such personal data. In instances where we receive such personal data, we will immediately and securely delete it from our IT ecosystem.

What is the purpose and legal basis for collecting your personal data?

We use your personal data only for the following purposes:

Where we have a legitimate interest, provided that Happening`s interests are not overridden by your data protection rights, we use your data to:

• Respond to your messages and provide you with the requested information;
• Present our business and associated products;
• Enable business development;
• Understand your interaction with our website in order to enhance your navigation, customize your experience and obtain statistical information which helps us to improve website functionalities;
• Recruit the best suitable candidate for our job openings, assess your suitability for a role and keep records about our hiring processes;
• Establish or defend our rights and interests against any legal claims.

4. With whom do we share your personal data with?

We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you and you have given us explicit permission to do so. In certain circumstances described below, we will share a minimum amount of personal data about you with:

• Other group companies for the purpose of internal administrative matters in line with this Notice;
• Service providers authorised to process personal data who are acting as our contractors, for the purpose of managing our activities, for technical support, analytics such us email distribution services, hosting providers, IT service providers, etc.;
• Recruitment agencies;
• Local authorities or other competent authorities where we have an obligation to share such data if required by applicable laws. We may also share your personal data in good faith in order to protect, secure or prevent the loss of our rights or in the legitimate interests of Happening, its customers or the general public, or to respond to complaints from others;
• Other entities upon your request.

5. Where is your personal data stored?

Your personal data will be kept, processed and stored by us and our service providers in the following territories: the EEA and UK.

Each of our service providers who process and store your personal data have an obligation to keep it protected and secured, in accordance with applicable industry standards and whether less stringent legal provisions apply in their jurisdiction.

Where such recipients of data are located in third countries for which the European Commission has not issued an adequacy decision, Happening has in place contractual relationships with each such recipient that include standard contractual clauses as approved by the European Commission or other supervisory authority where required, intended to ensure an adequate level of protection and will always conduct rigorous due diligence to ensure there are no risks to such transfers. A copy of the standard contractual clauses used by Happening can be found at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj.

6. How long do we keep your personal data for?

Your personal data will only be stored for a necessary and strict period of time in accordance with the purpose for which it is collected and applicable laws or regulatory requirements. Generally, this means we will keep your personal data until the end of the interaction with you, plus a reasonable period of time after that where necessary to respond to any inquiries, complaints or legal claims; or deal with legal, tax, accounting or administrative matters where applicable.

For recruitment purposes, your personal data will be stored during the recruitment process, plus a reasonable limited amount of time to allow us to reflect on our hiring processes. In case of a successful employment, your personal data will be stored in the HR personnel file according to local Labour Law provisions and additional legislation regulating the employment field. In case of unsuccessful application, your personal data will be stored for a limited period of time in accordance with Labour Law provisions and additional legislation regulating the employment field and based on your consent.

Upon expiration of the above-mentioned deadlines, your personal data will be securely deleted or anonymized.

7. How do we keep your personal data secure?

The security and protection of your personal data is crucial for us. Happening has implemented all necessary technical and organizational measures, whether physical, electronic or procedural, to protect the confidentiality and security of the personal data you share with us. These measures have been implemented to protect data against unauthorized access, destruction, loss, alteration, access, disclosure or use. Our security controls are designed to maintain an adequate level of confidentiality, integrity and data availability.

Despite the security measures outlined above, we want you to know that the Internet is not a perfectly secure medium and there will always be the chance that your personal data could potentially be subject to unauthorized acts by third parties. Although we take reasonable steps and employ appropriate security measures to safeguard your Personal Data, no method of transmitting or storing data is completely secure. We cannot guarantee the security of your Personal Data and any transmission of your Personal Data through the Internet is at your own risk. We cannot be responsible for the acts of those who gain unauthorized access to your Personal Data, and we make no warranty, express, implied or otherwise, that we will prevent such access or abuse.

8. What are your personal data rights?

At any given time, you will have the following rights regarding your personal data processed by us. Please note, other than your right to object to us using your information for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute in case of other applicable laws.

1. The right to information: you have the right to be provided with information on the identity of the personal data controller, on the reasons for processing you personal data and other relevant information necessary to ensure the correct and transparent processing of your personal data.
2. The right of access: you have the right to make a request for details of your personal information and a copy of that personal information.
3. The right of rectification: you have the right to have inaccurate information about you corrected or removed without undue delay.
4. The right of erasure ("right to be forgotten"): you have the right to have certain personal information about you deleted from our records subject to exceptions.
5. The right to restriction of processing: you have the right to ask us to use your personal information for restricted purposes only.
6. The right to data portability: you have the right to ask us to transfer the personal information you have given us to you or to someone else in a format that can be read by computer.
7. The right to object: you have the right to object to us processing (including profiling) your personal information in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your information for our or a third party's legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing.
8. The right in relation to automated decisions: you have the right not to have a decision which produces legal effects which concern you or which has a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorized by law or you have given your permission for this.

In order to exercise any of the above rights, you can fill in our webform available by clicking here. Your request will be reviewed and answered within one calendar month from receipt, in accordance with Data Protection laws. If we receive a large number of requests, or particularly complex requests, the deadline can be extended by a maximum of another two months. In certain circumstances as prescribed by data protection law (i.e. excessive requests), we might refuse to act upon your request.

As a rule, you can exercise your rights for free. However, we reserve the right to charge a reasonable fee if your requests are manifestly unfounded or excessive, in particular because of their repetitive nature.

We pay the utmost attention to the confidentiality of all personal data and reserve the right to verify your identity if you submit a request for personal data and such identification is needed.

In the event your personal data is processed based on your consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent before its withdrawal.

You also have the right to notify the local Data Protection Authority or competent courts from your jurisdiction. The list of all local Data Protection Authorities can be found here.

9. Contact

If you have any questions, comments, complaints or suggestions relating to this Notice, or any other concerns about the way in which we process personal data about you, please contact our Data Protection Officer by emailing gdpr@superbet.com

10. Protection of children

Our Website and services are not intended for individuals below the age of 18. We do not want nor is our intention to solicit and collect personal information for this type of audience.

We do not intentionally collect Personal Information from individuals below the age of 18. If you are the parent or guardian of a child below the age of 18, and believe your child has provided us with personal information, please contact us to request the deletion of these personal data. If we confirm that we have collected this kind of personal information, we will delete that information as soon as possible.