1. About the Privacy Policy

1.1. AMUSNET INTERACTIVE LTD., Unified Identification Code 203773449, with seat and registered address at Garitage Park, Office Building No. 4, floor 2, 2 Donka Ushlinova Str., Vitosha District, Sofia 1766, Bulgaria, telephone number: +359 87 983 17 11, e-mail: [email protected] (hereinafter referred to as the “Amusnet Interactive” or the “Company”) is a data controller and as a data controller complies with the rules and requirements of the Bulgarian and European legislation on personal data protection.

1.2. The present Privacy Policy aims to inform you about how Amusnet Interactive Ltd. processes the personal data related to the persons specified below, for what purposes Amusnet Interactive collects and processes personal data, what are the grounds for processing personal data, the term of processing personal data, what are the rights of data subjects in relation to this processing, as well as other information aimed at ensuring transparent and conscientious processing of personal data by Amusnet Interactive.

1.3. With respect to the processing of personal data relating to individuals who apply for employment with us, this Privacy Policy is applicable in addition to the Privacy Notice for Job Applicants available here.

2. What types of information do we collect and why?

Amusnet Interactive processes various categories of personal data that are necessary for the lawful and normal conduct of the Company's business; for the conclusion and execution of various contracts between the Company and third parties; for the provision of services to the Company by suppliers; for the fulfilment of obligations established by law; for the communication and provision of information and documents to national and foreign public and regulatory bodies; as well as for other lawful purposes related to the business activities carried out by the Company.

Which are the persons whose personal data is processed?

We process personal data related to the following persons (“You”):

2.1. Legal representatives, proxies, subcontractors, associates, and employees of our suppliers and business partners ("Contractors"), as well as personal data of data subjects of legal representatives, proxies, subcontractors, associates, and employees which may become our business partners.

2.2. Visitors of our Website and users of its information resources;

2.3. Persons making inquiries, requests, and other messages to us by mail, e-mail, telephone, and other means of communication;

2.4. With technical means for video surveillance, we process personal data of data subjects who visit, pass through, or otherwise are in the designated video surveillance zones in the offices of the Company.

2.5. The processing of personal data about the abovementioned data subjects is necessary for Amusnet Interactive for the conclusion, execution, and/or termination of contracts; identification of beneficial owners of legal entities – our suppliers and business partners, in view of our internal policies and rules. Without processing of the said personal data, Amusnet Interactive cannot enter into contracts with its Contractors or fulfill its obligations under them.

3. Contractors 

The personal data that may be collected and processed by Amusnet Interactive within our relations with Contractors might be the following: 

• - Identification data of Contractors, their legal representatives and proxies - name, Personal Identification Number (PIN) or another identification number/code, date of birth, citizenship, ID card, and/or passport details, as well as identification data about the ultimate beneficial owners and representatives of the companies with which We are to enter into contractual relations;

• - Business contact details - address, contact phone, e-mail;

• - Other personal data that may be provided by our business contacts when filling out client/partner questionnaires;
• - Other information related to the Contractors, their employees and representatives, provided or created in the context of our business relations and activities, including in negotiations and legal disputes.

4. Website visitors

4.1. When you visit our Website, we may process personal data relating to you through the use of cookies or similar technologies. For more information, please see our Cookie Policy here.

4.2. When you make requests, inquiries, and other communications to us, we may process your personal data, such as names and contact details, which you have provided to us voluntarily for the purposes of carrying out communication with you and to respond to your inquiry.

5. Video surveillance

Amusnet Interactive provides video surveillance in the common areas and entrances to the offices of the Company, as well as in other commercial sites, such as warehouses. The video surveillance is carried out for the purpose of self-protection of the Company's property, and protection of the life and health of our employees and visitors.

6.  For what purposes do Amusnet Interactive process your Personal Data?

Amusnet Interactive processes personal data for the following purposes:

6.1. Processing of personal data necessary for taking actions before concluding a contract, as well as for concluding, performing, and terminating a contract with Contractors

• - Identification of legal representatives, proxies, employees, and beneficial owners through publicly available channels, as well as when these data are provided by the Contractors of Amusnet Interactive before the conclusion of the contract;
• - Preparation of offers, contracts, and all other documents accompanying the contract, as well as any other documents created in the context of business relations with the business partners of the Company;
• - Notices related to our products and services.

6.2. Processing of personal data needed for compliance with a legal obligation

• - Personal data necessary for compliance with a legal obligation of Amusnet Interactive, including, but not limited to, legal obligations established in the tax and accounting legislation; gambling legislation; whistleblowing legislation; customs legislation, etc.

6.3. Processing of personal data based on legitimate interest

• - Video surveillance in our commercial and administrative sites;
• - Provision of data by you in our client/partner questionnaires, such as data about politically exposed persons;
• - Verification of the existence of licenses, permits, concessions, and/or other rights related to the exercise of regulated activities by our business partners;
• - Client satisfaction survey regarding the use of our products;
• - Exercising and protecting the legal rights and interests of the Company. 

7. То whom may Amusnet Interactive disclose your Personal Data?

Amusnet Interactive may use third parties to support certain contractual activities or with regard to the performance of a legal obligation. Amusnet Interactive does not provide personal data to third parties before the requirements for disclosure of personal data to third parties provided for in the applicable legislation are met.

Recipients of personal data may be third-party legal and individuals, such as:

• - service providers and their subcontractors;
• - postal and courier service providers;
• - external consultants in various fields providing services to the Company, such as, but not limited to banks, financial auditors, legal advisers, advertising agencies, security companies, and other service providers;
• - service providers which on assignment and on behalf of the Company maintain equipment, software, and hardware used to support the activities of Amusnet Interactive, as well as hosting companies and sales agents, etc.;
• - state and municipal bodies, including, but not limited to, regulatory bodies, state commissions, institutions and agencies, gaming regulators and laboratories, NRA, NSSI, courts, prosecutor's office, and others, to which Amusnet Interactive should provide information that may contain personal data under the applicable legislation.

8. What technical and organizational measures for data protection do we apply?

In accordance with applicable law, Amusnet Interactive implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.

In addition, Amusnet Interactive implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.

9. When do we delete your Personal Data?

Amusnet Interactive stores personal data within the statutory time limits, and if there are not explicitly defined statutory time limits, within the time limits set by the Company in order to achieve the purposes of the personal data processing listed above. The Company deletes personal data after the expiration of the statutory deadlines for their storage and/or achieving the purposes of data processing, but in any case, not before the final settlement of all our financial relations. 

Amusnet Interactive stores personal data for the following periods:

• - Invoices and other financial information - 10 /ten/ years, starting from the beginning of the year following the year in which the payment of the debt for the respective year is due;
• - Information contained in contracts and work orders - for the period of the contract and up to 5 /five/ years from the termination of the contract, except in cases where this information is related to tax and social security control - then the term is 10 /ten/ years, starting from the beginning of the year following the year in which the payment of the debt for the respective year is due;
• - Information contained in correspondence with you - up to 5 /five/ years from the end of the correspondence. In cases where the correspondence relates to a valid contract, the term begins from its termination;
• - Surveillance camera recordings – 60 /sixty/ days from the moment of recording.

The personal data may also be processed for a longer period than the above-mentioned terms, if such processing is necessary to achieve the purposes set out therein or to protect the rights and/or legitimate interests of Amusnet Interactive, or if the applicable legislation provides for the processing of such data for a longer period.

10. Do we transfer personal data outside EU/EEA?

The transfer of personal data is secured by modern technical means. In principle, Amusnet Interactive does not transfer personal data outside the EU / EEA. In the event that such transfer is necessary for the fulfillment of some of the above purposes, the transfer will be carried out in compliance with the requirements of applicable law including but not limited to adopted adequacy decision by the European Commission, standard contractual clauses, binding corporate rules etc.

11. What are Your rights in relation to the protection of your Personal Data?

11.1. In order to fulfill the obligations of Amusnet Interactive as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.

11.2. You have certain rights related to the processing of your Personal Data provided in Regulation (EU) 2016/679 (hereinafter referred to as the “GDPR”), including:

• - Right to information and free and open access to your Personal Data, as well as the right to request a copy of your personal data stored or otherwise processed by Amusnet Interactive;
• - The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete;
• - In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your Personal Data or the restriction of their processing, as well as to exercise your right to the portability of your Personal Data (when applicable);
• - Right to object, as well as rights related to automated decision-making - you have the right to object at any time, on grounds relating to your specific situation against the processing of your Personal Data, including in the event that your Personal Data is used for profiling;
• - Right to request for the restriction of the processing of your Personal Data in cases explicitly provided for by law;
• - If you have any doubts that your Personal Data is not being processed lawfully by Amusnet Interactive, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Notice, or to seek the protection of your rights judicially.

11.3. Please note that Amusnet Interactive does not use your Personal Data for profiling or automated decision making.

11.4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the GDPR and the Bulgarian Personal Data Protection Act. You may exercise your rights by making a written request to Amusnet Interactive on the contact details provided in this Notice in accordance with the requirements of applicable law. If necessary, Amusnet Interactive will provide you with full assistance in exercising the rights granted to you.

12. Data Protection Officer 

If you wish to receive additional information on how Amusnet Interactive processes your personal data or you have questions related to the operation and application of the present Transparency Notice in the processing of Personal Data of employment applicants, you can contact our Data Protection Officer, Ms. Desislava Dimitrova, at the following e-mail address: [email protected].

13. Competent national supervisory authority for Personal Data Protection

Commission for Personal Data Protection 
Address: 2 Professor Tsvetan Lazarov Blvd., Sofia 1592
Phone number: + 3592 / 91-53-594
E-mail: [email protected]
Website: www.cpdp.bg

14. Changes to the present Personal Data Protection Policy

This Data Protection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website.

This Notice is effective as of 25.05.2018. It is last amended on 01.11.2023. 

PRIVACY NOTICE FOR JOB APPLICANTS at AMUSNET INTERACTIVE LTD.

1. About the Privacy Notice for Job Applicants

1.1. AMUSNET INTERACTIVE LTD., Unified Identification Code 203773449, with seat and registered address at Garitage Park, Office Building No. 4, floor 2, 2 Donka Ushlinova Str., Vitosha District, Sofia 1766, Bulgaria, telephone number: +359 87 983 17 11, e-mail: [email protected] (hereinafter referred to as “Amusnet Interactive” or “Company”) is a data controller and as a data controller complies with the rules and requirements of the Bulgarian and European legislation on personal data protection.

1.2. The present Privacy Notice for Job Applicants at Amusnet Interactive (hereinafter also referred to as the "Privacy Notice" or just the "Notice") aims to provide information on the processing of Personal Data of individuals (or also "data subjects") who have voluntarily and on their initiative submitted an application for employment at Amusnet Interactive by using the following electronic address (https://careers-amusnet.com/) or in any other way that may be used by Amusnet Interactive for recruitment and selection purposes, e.g. through another electronic address, through a job posting platform maintained by a third-party.

1.3. This Privacy Notice applies also to Personal Data provided by applicants for employment at Amusnet Interactive by sending their application in hard copy to the physical address for correspondence with the Company.

1.4. In the capacity of individuals – applicants for employment, whether you are applying for a specific vacancy advertised by Amusnet Interactive or you are submitting your application without the Company having advertised a current vacancy, you have the right to be informed about how and why Amusnet Interactive, as a data controller, collects, processes, stores and protects your Personal Data which you have provided to the Company in connection with your job application.

1.5. The present Notice is published and is freely available on the separate part of the website of Amusnet Interactive at the following e-mail address: https://careers-amusnet.com/. The notice may be amended and/or supplemented at any time by Amusnet Interactive, if necessary.

1.6. Please, read the Notice carefully to understand how we process your Personal Data in the context of recruitment and selection and what your rights are in relation to this processing. By submitting your job application electronically and clicking on the button provided for this purpose, you declare and state that you have read the terms of this Privacy Notice. In case you need any additional information or have any questions regarding the processing of your Personal Data in the recruitment and selection process, you may contact Amusnet Interactive at the contacts listed below in the Notice

1.7. The present Notice does not restrict your rights related to the processing of your Personal Data by Amusnet Interactive in any way. The purpose of this Notice is to provide you with information that shall ensure the transparent and fair processing of your Personal Data by Amusnet Interactive in the recruitment and selection process. 

2. What types of information do we collect when you submit your job application to us and why?

2.1. Аmusnet Interactive processes the personal data provided by you in its capacity as a data controller. The Company collects and processes only those categories of Personal Data that have been provided to the Company voluntarily and directly by the applicants, or such Personal Data that were additionally provided by the applicants during the recruitment procedure and/or requested by Amusnet Interactive within the procedure for evaluating your application and the decision-making process on whether to recruit you.

2.2. In certain cases, the Personal Data processed by Amusnet Interactive in connection with your application is not collected or received directly from you, but from third parties such as recruitment agencies - e.g. when you apply through such agencies.

2.3. Amusnet Interactive processes the following categories of Personal Data related to your job application, which you have provided voluntarily as part of your application and recruitment process:

• -  Identification data about you (name, contact details - address (current and/or permanent address), telephone number, e-mail address), date of birth, photograph (but only if you have voluntarily provided one as part of your job application);
• -  Information on education and acquired professional qualifications - completed education, acquired professional qualifications, scientific degree; completed educational courses, trainings, seminars, and/or other information related to acquired education and qualifications; knowledge of foreign languages and previous professional experience, as well as other information related to your skills and qualifications;
• -  Information on current and/or previous employment - details of employment; work experience; posts/positions held; roles and responsibilities performed; current and/or previous employers; length of service/experience; references and references from employer(s) where these have been volunteered by you;
• -  Information concerning the possession of a driving license or other certificates of acquired competence (where and to the extent that such competence is necessary and required for the performance of the duties included in the scope of the position for which you are applying or when you have voluntarily provided such information);
• -  Information on remuneration, including expected remuneration for the position you are applying for, additional social benefits, and/or other data of a financial and economic nature related to the position you are applying for;
• -  Information that you have voluntarily provided on your initiative in the process of your job application and that is not included in the above (e.g. information provided through a CV, cover letter, and/or another document that you have provided or has been additionally requested from Amusnet Interactive within the recruitment procedure);
• -  Information collected and prepared by recruitment agencies and employment intermediaries to whom Amusnet Interactive has assigned recruitment activities, including collecting, reviewing, and evaluating applications, conducting interviews, and preparing reports and recommendations;
• -  Other information relating to your application that you have provided voluntarily during the recruitment process.

2.4. Amusnet Interactive does not process special categories ("sensitive") of Personal Data as part of the recruitment process. By way of exception, such categories of Personal Data could be processed only and insofar as they are necessary for the assessment of your application in view of the particularities of the specific job position and the decision to appoint you to a specific job/position, as well as for the fulfillment of certain statutory obligations which shall be observed by Amusnet Interactive in its capacity as an employer, or if there is another reason for processing this category of Personal Data, with your explicit consent for their processing.

3. For what purposes does Amusnet Interactive process your Personal Data?

3.1. As a potential employer, within the recruitment and selection procedure, Amusnet Interactive processes your Personal Data only insofar as it is necessary for the Company to conduct the procedure for selection of potential employees, evaluation of your application, taking a decision on your appointment as an employee of the Company, preparation of a proposal for starting work (offer) and/or preparation of a draft employment contract. In particular, Amusnet Interactive processes the Personal Data you provide for the following purposes:

• - Administration and management of your job application in Amusnet Interactive, including identification, written and oral communication with job applicants during the selection procedure;
• - Carrying out a selection and evaluation of your application and deciding whether to make you an offer of an employment contract;
• - Upon approval of your application, for the preparation of a formal job offer, preparation of a draft employment contract, and other documents necessary to complete the process of appointing you to the position for which you are applying;
• - In case you have not been offered an employment contract or it has not been accepted, Amusnet Interactive may process the Personal Data of your application for other current or future vacancies, provided that you have given us your explicit written consent that your application can be considered for this purpose.

3.2. Amusnet Interactive may process your Personal Data in the presence of at least one of the following legal grounds, laid down in the General Data Protection Regulation ("GDPR"):

• - In the presence of your consent to the processing of your Personal Data;
• - To take the necessary actions to enter into a contract (employment contract) if your application is successful and you have accepted our offer of employment with Amusnet Interactive;
• - Existence of a legitimate interest of Amusnet Interactive, as our legitimate interest is to assess the compliance of your application with the needs of the Company, the necessary requirements for the position, and to recruit personnel in order to fill our vacancies;
• - In order to comply with a legal obligation that applies to us under the GDPR, such as the obligation to respond to your inquiry relating to the protection of your personal data that we process or in order to protect our legitimate interests.

4. When do we delete your Personal Data, provided within the procedure for selection and evaluation of your application?

4.1. Amusnet Interactive will store and process your Personal Data only for the period necessary to achieve the purposes of Personal Data processing set out above. In particular, your Personal Data will be stored for the period from their receipt until the final decision on whether to be appointed to the position for which you are applying, but for no more than 3 (three) months.

4.2. Please note that the retention period of your Personal Data provided in the process of your application may exceed the expiration date of the advertisement published by Amusnet Interactive for the position you are applying for. This is because after receiving the applications of the interested candidates, technological time is needed to carry out additional actions such as internal evaluation of the received applications, conducting interviews with the candidates, discussing and making a decision by Amusnet Interactive to choose the most suitable candidate and concluding a contract with him.

4.3. For the purpose of occupying other current or future vacancies, it is possible that Amusnet Interactive will store your Personal Data even after the completion of the procedure for occupying the position for which you are specifically applying. In this case, Amusnet Interactive will store your Personal Data for a period not exceeding 1 (one) year, provided that you have given us your explicit written consent for this purpose. You can withdraw your consent at any time by notifying Amusnet Interactive.

4.4. In case your application is approved, when concluding an employment contract between you and Amusnet Interactive, the Personal Data provided by you (or part of them, as the case may be) will continue to be processed by Amusnet Interactive and will become part of your employment dossier, which the employer is obliged to compile and maintain. In case you are selected for a relevant position, to conclude the employment contract it may be necessary to provide additional information and documents, in accordance with the requirements of applicable law and the internal rules and procedures of Amusnet Interactive. 

4.5. When concluding an employment contract, Amusnet Interactive will provide you with a detailed privacy notice regarding the processing of your Personal Data in your capacity as an employee of the Company.

4.6. In case your application is not approved and you have not given your consent to Amusnet Interactive to store and process your Personal Data for other current or future vacancies, your Personal Data will be destroyed and/or deleted (depending on the media) after the completion of the selection procedure for the relevant position for which you have applied, but no later than 3 (three) months.

5. To whom may we disclose your Personal Data provided in the framework of the recruitment procedure?

As part of the recruitment procedure, the Personal Data which you provided will not be disclosed by Amusnet Interactive to third parties. Your Personal Data will be brought to knowledge (disclosed) only to employees of the relevant departments of Amusnet Interactive, determined according to the specific position you are applying for, to participate in the process of managing and administering your application, who are directly involved in the process of selection, analysis and evaluation of your application for the position.

6. What are Your rights in relation to the protection of your Personal Data?

6.1. In order to fulfill the obligations of Amusnet Interactive as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.

6.2. You have certain rights related to the processing of your Personal Data provided in Regulation (EU) 2016/679 (hereinafter referred to as the “GDPR”), including:

• - Right to information and free and open access to your Personal Data, as well as the right to request a copy of your personal data stored or otherwise processed by Amusnet Interactive;
• - The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete;
• - In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your Personal Data or the restriction of their processing, as well as to exercise your right to the portability of your Personal Data (when applicable);
• - Right to object, as well as rights related to automated decision-making - you have the right to object at any time, on grounds relating to your specific situation against the processing of your Personal Data, including in the event that your Personal Data is used for profiling;
• - Right to request for the restriction of the processing of your Personal Data in cases explicitly provided for by law;
• - If you have any doubts that your Personal Data is not being processed lawfully by Amusnet Interactive, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Notice, or to seek the protection of your rights judicially.

6.3. Please note that Amusnet Interactive does not use your Personal Data for profiling or automated decision making.

6.4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the GDPR and the Bulgarian Personal Data Protection Act. You may exercise your rights by making a written request to Amusnet Interactive on the contact details provided in this Notice in accordance with the requirements of applicable law. If necessary, Amusnet Interactive will provide you with full assistance in exercising the rights granted to you.

7. Data Protection Officer 

If you wish to receive additional information on how Amusnet Interactive processes your personal data or you have questions related to the operation and application of the present Transparency Notice in the processing of Personal Data of employment applicants, you can contact our Data Protection Officer, at the following e-mail address: [email protected] or by sending your questions to the registered address of the Company, indicated at the beginning of this Notice.

8. Competent national supervisory authority for Personal Data Protection

Commission for Personal Data Protection
Address: 2 Professor Tsvetan Lazarov Blvd., Sofia 1592
Phone number: + 3592 / 91-53-594
E-mail: [email protected]
Website: www.cpdp.bg

9. Changes to the present Privacy Notice

This Privacy Notice may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website. 

This Notice is effective as of 25.05.2018. It is last amended on 31.10.2023.