Privacy

1. WHEN TAKING CAMERA IMAGES

What do we use camera images for? 

• There are cameras in our casinos. We use them to record images of visitors. We do this for the following reasons:
• We monitor your safety;
• We monitor the safety of our employees;
• We monitor our properties.

Is that allowed under privacy law? 

We are permitted to use camera footage because we have a "legitimate interest" in doing so. To determine this, we weighed two factors against each other:

• Your right to privacy;
• Everyone's interest in safety.

In making this assessment, we must consider our interest in protecting the safety of visitors, employees, and our property on the one hand. On the other hand, we must consider the privacy interests of the individuals whose camera images are temporarily stored. 

What do we do to guarantee your privacy as much as possible?

We have taken various measures to ensure that the invasion of privacy is as minimal as possible:

• The stored camera images can only be viewed by a very limited number of people;
• The camera images only record images. They do not record sound (voices).
• In principle, the camera images are stored for a maximum of four weeks and then deleted. The only exception to this rule is when an incident has occurred. In that case, the camera images of that incident may be stored for longer and will only be released at the written request of the police.

2. WHEN ASSESSING YOUR GAMING BEHAVIOR

What do we use data about how and how often you play for?

As a provider of high-risk games of chance, we are legally obliged to monitor and record your gaming behavior and to intervene if necessary. To do this, we store certain personal data. This is done carefully and in compliance with privacy legislation. This data is properly secured by us. The aim is to detect excessive participation and risks of gambling addiction at an early stage, to prevent them as much as possible, and to be able to take appropriate measures in a timely manner.

3. WHEN REGISTERING WITH CRUKS

Since October 1, 2021, players can not only register on the so-called white lists (see below), but also deregister or exclude themselves from games of chance nationwide. They can do this by registering in the Central Register of Excluded Gamblers (Cruks). This register was designed by the government with the aim of preventing and combating gambling problems. At the entrance, your ID and social security number will be checked to ensure that you are not registered in Cruks. If you are registered, you will be denied access to our casino. After mandatory identification and verification of your identity, the employee in our casino who performs the access control will enter the requested information into our software system to check whether you are registered in Cruks. This verification is done by scanning your ID or entering your social security number at the entrance desk.

The Citizen Service Number will be immediately and automatically deleted from our system after consultation of the Cruks register and after receipt of the (encrypted) Cruks code created by the Gaming Authority. See also:https://kansspelautoriteit.nl/veilig-spelen/gokproblemen/inschrijven-in-cruks/

4. IN THE ANALYSIS OF AGGREGATED DATA

Why do we analyze certain data?

The government regulates what casinos are and are not allowed to do. To do this, they make policies. In order to make policies, the government needs to know what is happening in casinos. We have to analyze all the data for the government. This way, the government knows how many people become addicted to gambling, how many and what kind of complaints are received, and what we do about them.

Is that allowed under privacy law?

We do not use personal data for these analyses, but rather aggregated data. This means that only data such as the total number of visitors or a specific (sub)group of visitors is used for analysis. This data cannot be traced back to an individual player or person. The government cannot therefore deduce from our analyses that you visit our casino or who has submitted a complaint. Your privacy is therefore not at risk.

5. WHEN LISTED ON THE SO-CALLED "WHITE LIST"

What is the "white list"?

Are you addicted to gambling or is there a high risk that you will become addicted? If so, you can ask us to refuse you entry to one or more of our casinos. We will then put you on our 'white list'. We will sign an agreement together. This agreement states that you have voluntarily decided that you do not want to be admitted. And that we will do our utmost to comply with this. If one of our employees recognizes you, he or she will not allow you to enter. 

What personal data do we use?

We use the following data:

• A passport photo of you;
• A copy of your passport or driver's license;
• Your address;
• Your signature.

What do we use this data for?

We require this information for a number of reasons. Our employees must be able to recognize you, and we must be able to contact you. We also have an agreement together, which only applies with your and our information. We only use your personal information within the casino or casinos to which the agreement applies. 

Is that allowed under privacy law?

We may use your personal data to perform an agreement with you. To do so, we need to be able to recognize you and contact you. 

What do we do to guarantee your privacy as much as possible?

Is the agreement ending? And are you no longer on the "white list"? Then we will delete all your personal data. We may retain statistical data, but no one will be able to deduce that it concerns you. We do this in order to be able to analyze the data of all visitors together. And to be able to produce our annual report, for example. See section 4 for more information.

6. IN CASE OF DANGEROUS SITUATIONS

We do everything we can to keep our casinos safe. If something happens that puts visitors, employees, or the organization at risk, and you are involved, we can record this. We can even prohibit you from entering a casino. In these cases, we use your personal data because we have a "legitimate interest."

7. IF YOU FILL OUT OUR CONTACT FORM

Do you have any questions, complaints, or would you like to receive information from us? Then please fill in ourcontact form. Before you submit the contact form, we ask you to give your consent for us to process your personal data.

The following data is involved:

• Your name;
• Your email address;
• Your phone number;
• Which casino is it?
• Your question/complaint.

We need your details in order to respond. We will retain your personal data for as long as necessary to handle your question or complaint. After that, we will delete your personal data. Our employee may ask you for additional personal data. He or she will only do so if this is necessary to handle your question or complaint.

8. WHEN YOU VISIT OUR WEBSITE

When you visit and use our website, data is stored. For more information, seehttps://www.fairplay.nl/cookies.

9. WHAT ARE YOUR RIGHTS AS A VISITOR OR PLAYER?

As a visitor or player, you have the right to submit a written request to:

• The personal data we hold about you can be viewed;
• Request correction of inaccurate or incomplete personal data;
• Request data deletion;
• Submit a request to restrict the personal data we process about you;
• Have your personal data sent to someone else;
• Request that we no longer process your personal data;
• Submit a complaint to us. 

The request should be addressed to the Data Protection Officer, who can be contacted at fg@fairplay.nl.

We will then assess your question/request and consider whether we can comply with it. Due to third-party rights, our own legitimate interests, or a legal obligation to retain data, for example, it is not always possible to comply with your request in whole or in part.

Please note: Before we can process your request, you must clearly identify yourself to us. Identification and verification (are you who you say you are?) are necessary for this. To do so, you can visit one of our arcades and inform us that you wish to exercise one of your (aforementioned) rights and which email address you will use for this purpose. The location manager or employee will identify you based on your ID and verify that you are who you say you are. The location manager will then send an email to the Data Protection Officer to inform them that:

• you visited him to exercise a right,
• you are identified and verified
• you have sent or will send him an email to exercise your rights, and
• which email address you have used or will use for this purpose.

Without identification and verification, we cannot process your request. After all, we want to avoid modifying or deleting the personal data of the wrong person.