PRIVACY POLICY
INFORMATION ON THE COLLECTION OF PERSONAL DATA
1.1. Thank you for your interest and for taking the time to visit our website. This webpage encompasses the information and policies regarding the handling of your personal data. Personal Data includes all data that can be used to individually identify you. (“Personal Data”)
1.2. The owner of this website is Pro Wagering, Inc., a Delaware Corporation, with its registered agent at 251 Little Falls Drive Wilmington, DE 19808 (Herein after referred to as the “Company”, “We”, “Us”, or “Our”); which can be contacted at its e-mail: info@prowagering.com
1.3. This website uses SSL or TLS encryption for security reasons and to protect the transmission of Personal Data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
DATA COLLECTION
2.1. When using our website for information only, (if you do not register or otherwise provide us with information,) we only collect data that your browser transmits to our server. When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
(1) Our visited website Date and time at the moment of access;
(2) Amount of data sent in bytes Source/reference from which you came to the page;
(3) Browser used Operating system used IP address used (if applicable: in anonymized form)
(4) Data processing is carried out as required by law and on the basis of our legitimate interest in improving the stability and functionality of our website.
The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
COOKIES
3.1. In order to make your visit to our website attractive and to enable the use of certain functions, we use “cookies” on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (“session cookies”). Other cookies remain on your terminal and enable us or our partner companies (“third-party cookies”) to recognize your browser on your next visit (“persistent cookies”). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.
3.2. In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out for (1) the execution of the contract or (2) to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit. We work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (“third-party cookies”). You will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following sections.
3.3. Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
Internet Explorer:
o https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox:
o https://www.mozilla.org/en-US/privacy/websites/#cookies
Chrome:
o https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
Safari:
o https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Opera: http://help.opera.com/Windows/10.20/en/cookies.html
3.4. Please note that the functionality of our website may be limited if cookies are not accepted.
CONTACTING PRO WAGERING, INC.
4.1. In the context of contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. These data are stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request.
Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided that there are no legal storage obligations to the contrary.
DATA PROCESSING
5.1. When Opening a Customer Account and for Contract Processing, personal data will continue to be collected and processed if you provide them to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. It is possible to delete your customer account at any time. This can be done by sending a message to the above-mentioned address info@prowagering.com. We store and use the data provided by you for contract processing/performance of contract and our legitimate interests. After complete processing of the contract or deletion of your customer account, your data will be blocked in consideration of tax and commercial retention periods and deleted after the expiry of these periods, unless you have expressly consented to further use of your data or a legally permitted further use of data has been reserved by our site, about which we will inform you accordingly below.
USE OF YOUR DATA FOR DIRECT ADVERTISING
6.1. If you subscribe to our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The indication of additional possible data is voluntary and is used to be able to address you personally. We use the so-called double opt-in procedure for sending the newsletter.
This means that we will not send you an e-mail newsletter, unless you have expressly confirmed to us that you agree to the sending of the newsletter. We will then send you a confirmation e-mail asking you to confirm that you wish to receive future newsletters by clicking on an appropriate link.
6.2. By activating the confirmation link, you give us your consent to the use of your personal data. When you register for the newsletter, we store your IP address entered by the Internet Service Provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your e-mail address at a later time. The data collected by us when registering for the newsletter will be used exclusively for the purpose of advertising by means of the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the responsible person named above. After your cancellation, your e-mail address will immediately be deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use data in excess thereof, which is permitted by law and about which we inform you in this declaration.
6.3. While you are subscribed, we may further use your e-mail address on the basis of our legitimate interest to send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us at any time). For such purpose, we partner with eg. TikTok Technology Limited (TikTok) which handles personal data in accordance with their privacy policy (https://www.tiktok.com/legal/ privacy-policy) and Snap Inc. (Snapchat) under their privacy policy (https://www.snap. com/privacy/privacy-policy/).
USE OF YOUR DATA TO PROVIDE INFORMATION REQUESTED BY YOU.
7.1. For some products or services, we offer you the possibility to receive related information on a running basis. If you give us your consent thereto, we will process your personal data to the extent necessary to provide such information, e.g. e-mail address, phone number, information related to the product or its location, or other personal data as directed by you. You can opt out of receiving such information at any time, and we will cease our processing of your relevant personal data upon such opt-out.
PROCESSING OF DATA FOR THE PURPOSE OF ORDER HANDLING
8.1. To process your order, we work together with the following service provider(s), which support us wholly or partially in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.
8.2. The personal data collected by us will be passed on to the transport company commissioned with the delivery within the scope of contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment data to the commissioned credit institution within the framework of payment processing, if this is necessary for payment handling. If payment service providers are used, we explicitly inform you of this below.
Use of Third-Party Platforms
9.1. USE OF VIDEOS; USE OF YOUTUBE VIDEOS
9.1.1. This website uses the Youtube embedding function for display and playback of videos offered by the provider Youtube, which belongs to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
9.1.2. To this end, the extended data protection mode is used to ensure, according to provider information, that user information will only be stored once the playback function of the video is started. When the playback of embedded YouTube videos is started, the provider sets “YouTube” cookies in order to collect information about user behavior. According to indications from Youtube, the use of those cookies is intended, among other things, to record video statistics, to improve user friendliness and to avoid improper actions. If you are logged in to Google, your information will be directly associated with your account when you click on a video. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place on the basis of the legitimate interests of Google in the insertion of personalized advertising, market research and demand-oriented design of its website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.
9.1.3. Regardless of whether the embedded video is played back, a connection to the Google network “double click” is established when visiting this website. This may trigger further data processing beyond our control.
9.1.4. Google LLC, based in the USA, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU in relation to all services related to this policy. Further information on YouTube data protection can be found in the provider’s data protection statement at: www.google.com/policies/privacy/
9.2. ONLINE-MARKETING DoubleClick by Google
9.2.1. This website uses the online marketing tool DoubleClick by Google of the operator Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
9.2.2. DoubleClick uses cookies to serve ads relevant to users, improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to track which ads are displayed in which browser and to prevent them from being displayed more than once. Processing is based on our legitimate interest in the optimal marketing of our website.
9.2.3. In addition, DoubleClick may use cookie IDs to collect conversions related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later visits the advertiser’s website with the same browser and buys something there.
According to Google, DoubleClick cookies do not contain any personal information.
9.2.4. Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and the further use of the data collected by Google when using this tool and we therefore inform you according to our level of knowledge: By integrating DoubleClick, Google receives the information that you have accessed the corresponding part of our internet presence or clicked on an advertisement from us. If you are registered with a Google service, Google may associate your visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may obtain and store your IP address.
9.2.5. If you do not wish to participate in this tracking process, you can disable cookies for conversion tracking by setting your browser to block cookies from the www.googlead-services.com domain, https://support.google.com/ads/answer/2662-856?hl=en-GB, which will be deleted if you delete your cookies. Alternatively, you can contact the Digital Advertising Alliance at www.aboutads.info to find out how to set cookies and to make the relevant settings. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited. For more information about DoubleClick by Google’s privacy policy, please visit https://policies.google.com/privacy?hl=en
9.3. Google AdWords Conversion Tracking
9.3.1. This website uses the online advertising program “Google AdWords” and the conversion tracking within the framework of Google AdWords, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use the program of Google Adwords to draw attention to our attractive offers with the help of advertising materials (Google Adwords) on external websites. We can determine, in relation to the advertising campaigns data, how successful the individual advertising measures is. We are interested in showing you advertisements that are of interest to you. We want to make our website more interesting for you and to achieve a fair calculation of advertising costs.
9.3.2. The conversion tracking cookie is set on a user’s browser, if he clicks on an AdWords ad delivered by Google. Cookies are small text files that are stored on your computer system. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits a certain page of this website and if the cookie has not yet expired, Google and we will be able to recognize that the user clicked on the ad and was forwarded to this page. Each Google AdWords customer gets a different cookie. Thus, cookies cannot be traced via the website of AdWords customers. The information collected by the conversion cookies is used to provide aggregate conversion statistics to AdWords customers who have opted-in for conversion tracking. Customers are informed about the total number of users who clicked on the ad and were forwarded to a conversion tracking tag page. However, they do not get any information enabling them to identify users personally. If you do not want to participate in the tracking program, you can refuse the use of this program by deactivating the Google Conversion Tracking cookie via your Internet browser through the user settings. In this case, you will not be included in the conversion tracking statistics. We use Google Adwords on the basis of our legitimate interest in targeted advertising.
9.3.3. Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU. Google’s privacy policy can be found at: https://privacy.google.com/intl/en-GB/take-control.html?categories_activeEl=signin
9.3.4. You can permanently deactivate cookies for advertising preferences by blocking them via a respective setting of your browser software or by downloading and installing the browser plug-in, available under the following link:
https://support.google.com/ads/answer/7395996
9.3.5. Please note that certain functions of this website may not be used or only to a limited extent, if you have deactivated the use of cookies.
9.4. WEB ANALYTICS SERVICES Google (Universal) Analytics
9.4.1. Google Analytics This website uses Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
(“Google”). Google Analytics uses cookies, which are text files stored on your computer, to help the website analyze how users use the site. The information generated by the cookies about your use of this website (including the shortened IP address) is generally transmitted to a Google server in the USA and stored there.
This processing is carried out on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes.
9.4.2. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, we should point out that in that case you might not be able to use the full functionality of this website. You may permanently refuse Google to collect data generated by cookies regarding the use of the website (including your IP address) and to process them. You can download and install the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
9.4.3. Information on how Google Analytics handles user data can be found in Googles privacy policy at: https://support.google.com/analytics/answer/6004245?hl=en
9.5. Facebook Custom Audience via the Pixel Process
9.5.1. This website uses the “Facebook Pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). If the user has given us his explicit consent, his behavior can be tracked after he has seen or clicked on a Facebook advertisement. This process is designed to evaluate the impact of Facebook ads for statistical and market research purposes and may help to optimize future advertising efforts. Data collected shall remain anonymous and cannot be used to draw any conclusion about the identity of the user. However, those data are stored and processed by Facebook to enable a connection to the respective user profile and to allow Facebook to use those data for its own advertising purposes in accordance with the Facebook Privacy Policy (https://www.facebook.com/about/privacy/). You may allow Facebook and its partners to place ads on and outside of Facebook. A cookie may also be stored on your computer for these purposes. These processing operations only take place if express consent is given.
9.5.2. Consent to the use of the Facebook pixel may only be given by users who are older than 13 years of age. If you are younger, please ask your legal guardian for permission.
9.5.3. Facebook Inc., based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
9.5.4. If you want to disable the use of cookies on your computer, you can set your Internet browser so that cookies can no longer be stored on your computer in the future and/or cookies that have already been stored will be deleted. However, when disabling all cookies, some functions of our internet pages may no longer be able to be executed. You can also disable the use of cookies by third parties such as Facebook on the following Digital Advertising Alliance website:
http://www.aboutads.info/choices/
9.6. Google AdWords Remarketing
9.6.1. Our website uses the functions of Google AdWords Remarketing, which enable us to advertise our website in Google search results, as well as on third-party websites. Provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043,
USA (“Google”). To this end, Google places a cookie in the browser of your terminal device, which automatically uses a pseudonymous cookie ID on the basis of pages you visited to allow interest-based advertising. Processing is based on our legitimate interest in the optimal marketing of our website. Any additional processing will only take place if you have agreed with Google that your Google Internet and app browsing history will be linked to your Google Account and information from your Google Account will be used for personalized ads you view on the web. If you are logged in to Google while visiting our website, Google will use your data in connection with Google Analytics data to create and define target group lists for cross-device remarketing. To this end, Google temporarily links your personal data with Google Analytics data to create target groups.
9.6.2. You can permanently disable the setting of cookies for advertising preferences. You may download and install the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/
9.6.3. Alternatively, you can contact the Digital Advertising Alliance at www.aboutads.info to find out how to set cookies and to make the relevant settings.
9.6.4. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited.
9.6.5. Further information and the data protection regulations regarding advertising and Google can be viewed at: https://www.google.com/policies/technologies/ads/
9.7. Zendesk Customer Service
9.7.1. We use Zendesk by Zendesk Inc. 989 Market Street, San Francisco, CA 94103, United States for handling customer support emails. The types of data collected by Zendesk is specified in Zendesk Inc.’s privacy policy, https://www.zendesk.com/ company/ agreements-and-terms/privacy-policy//.
TOOLS AND MISCELLANEOUS
10.1. Google Maps
10.1.1. Our website uses Google Maps (AP’I) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for displaying interactive (country) maps in order to display geographical information visually. Using this service will show you our location and will make it easier for you to find us.
10.1.2. When you access the sub-pages that contain the Google Maps map, information about your use of our website (such as your IP address) is transmitted to and stored by Google on servers in the United States. This is regardless of whether Google provides a user account that you are logged in with or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on Google, you must log out be- fore activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place according to the legitimate interests of Google in the insertion of personalized advertising, market research and/or demand-oriented design of its website. You have the right to object to the creation of these user profiles. If you want to do so, you must contact Google to exercise this right.
10.1.3. If you do not agree to the future transmission of your data to Google in the context of using Google Maps, you may completely deactivate the Google Maps web service by switching off the JavaScript application in your browser. In this case, Google Maps as well as the map display on this website cannot be used. The Google terms of use can be found at: https://policies.google.com/terms?hl=en. The additional terms of use can be found at: https://www.google.com/intl/en-US_US/help/terms_maps.html.
10.1.4. You can find detailed information on data protection in connection with the use of Google Maps on Google’s website (“Google Privacy Policy”) at: https://policies.google.com/privacy?hl=en.
10.2. Trusted Shops Trustbadge
10.2.1. The Trusted Shops Trustbadge is included on this website to display our Trusted Shops seal of approval and to offer Trusted Shops membership to buyers after placing an order.
10.2.2. In this way, our legitimate interests in an optimal marketing of our offer are protected, within the meaning of Art. 6 (1) point f GDPR. The Trustbadge and the services advertised with it are a service of Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne.
10.2.3. When the trust badge is called up, the web server automatically stores a server log file, which contains e.g. your IP address, date and time of the call, transferred data volume, the requesting provider (access data) and it documents the call. This access data is not evaluated and is automatically overwritten at the latest seven days after the end of your page visit.
10.2.4. Further personal data will only be transferred to Trusted Shops if you decide to use Trusted Shops products after completing an order or if you have already registered for use. In this case, the contractual agreement between you and Trusted Shops applies.
RIGHTS OF THE DATA SUBJECT
11.1. The applicable data protection law grants you comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the Company with regard to the processing of your personal data, about which we inform you below:
11.2. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information.
11.3. Right to Deletion
11.3.1. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Delete your personal information from our records; and Direct any service providers to delete your personal information from their records.
11.3.2. Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
11.4. IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED.
HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS. IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
DURATION OF STORAGE OF PERSONAL DATA
12.1. The duration of the storage of personal data is determined by the respective legal retention period (e.g. commercial and tax retention periods). After expiry of this period, the corresponding data will be routinely deleted, provided they are no longer necessary for the performance or initiation of the contract and/or there is no longer any legitimate interest on our part in the further storage.
and then