Terms and Conditions
Pursuant to the provisions of the Gaming Act (Official Gazette No 87/09, 35/13, 158/13, 41/14, 143/14) and the Casino Interactive Online Gaming Ordinance (Official Gazette No 78/10), ADRIA CASINO d.o.o., Zagreb, VAT No.: 90180501899, represented by Dražen Jablan, adopted the revised text with all amendments on 02/03/2025. year, in Zagreb
GENERAL RULES
OF PARTICIPATING IN INTERACTIVE ONLINE GAMES OF CHANCE
GENERAL PROVISIONS
Article 1
These General Rules of Participating in Interactive Online Games of Chance (hereinafter referred to as the Rules) define and regulate the contractual relationship between Adria Casino d.o.o. as the organizer of games of chance (hereinafter referred to as the Organizer) and natural persons registered in the Organizer’s online system as participants in interactive online games of chance (hereinafter referred to as the Players).
Article 2
As the organizer of interactive online games of chance, Adria Casino d.o.o. uses the homepage of its website (www.senator.hr) to present all information required to be provided under the applicable regulations such as the company name and registered office, list of games and game rules, prohibition of participation for persons under the age of 18, the ref. and class of the authorization to organize interactive online games of chance received from the Ministry of Finance, information about responsible playing, protection of customers’ personal data, etc.
Article 3
The contractual relationship between the Organizer and the Player starts as of the time the Player is successfully registered, provided that, during the registration process, the Player accepts these Rules by clicking “I Agree” as appropriate.
By accepting these Rules, the Player confirms that he has read and understood them and that he accepts them in their entirety.
DEFINITIONS
Article 4
These Rules use the terms appearing and defined in Article 2 of the Casino Interactive Online Gaming Ordinance:
- “Interactive online organization of casino games of chance” means the organization of games where players use or may use for performing the required actions means of electronic communication (the internet). A player may play a game alone, by interacting with the system, with no direct representative of the organizer being present;
- “Online games” are games played by players by interacting with the system, which is a simulation of games played by players against the casino or against each other on gaming tables with balls, cards or dice, in accordance with the applicable international rules thereof;
- “Online gaming system” is a system used to organize games via interactive sales channels, including operating systems and applications, all software, databases or other contents downloaded, accessed or used by the player on the website;
- “Player registration” means the receipt and storage of data about the player pursuant to the contract entered into at the casino or via the organizer’s website;
- “Player identification” is a process to verify the authenticity of the player’s particulars and to establish that the player is an adult natural person, by verifying such information using Tax Administration’s electronic services or the relevant electronic payment system, and by verifying the identity of the debit or credit card holder;
- “Electronic payment receipt” is an electronic record of a payment made for a game, identified by player’s identifier appearing in the player’s account maintained within the organizer’s central system. Such electronic receipt may be printed using the user interface;
- “Virtual player account (i-Account)” is an account made available by the organizer, where the player deposits his funds to pay for participating in interactive online casino games of chance;
- “Casino room” is a room where live gaming takes place in real time, in which the player participates via interactive online channels;
- “Activation voucher” is a certificate purchased from the Organizer, indicating the amount of the funds to be remitted to the player’s virtual account after he enters the activation code on the organizer’s website;
- “Card data” is an integral set of data appearing on the payment card, required to conduct a payment card transaction; and
- “Outlet” is a Senator casino or gaming club, a physical location where Adria Casino d.o.o. organizes games of chance.
PLAYER REGISTRATION AND IDENTIFICATION
Article 5
Persons under the age of 18 are prohibited from participating in games of chance organized by Adria Casino d.o.o..
Article 6
Players are registered via the Organizer’s website and this process includes the receipt and storage of Player’s data in the Organizer’s system.
To be valid and successfully completed, all required fields must be completed correctly. For the purposes of registration and participating in games of chance, the Player must provide the following particulars: e-mail, username, password, name and surname, address, PIN, date of birth, bank account number and telephone number, type of identity document, document issuer’s country, document number, document issuer, residence and nationality.
The bank account number provided by the Player shall only be used to make payments from the Player’s online account and the Organizer is not allowed to dispose of funds in such account. As of the time of registration and entering his bank account number, the Player guarantees that the IBAN inserted is owned by him and registered in his name.
In case the Player forgets his password, he may seek Organizer’s assistance by sending his request to podrska@senator.hr.
The Player must promptly notify the Organizer of any changes to his particulars specified in this Article.
According to its obligations under the Anti-Money Laundering and Terrorist Financing Act, the Organizer is required to collect further personal data specified in the published Privacy Policy, which also defines their treatment.
The information referred to in this Article of these Rules is considered to be confidential information and the Organizer shall not make it available or provide it to any unauthorized persons, unless otherwise defined by the applicable law.
Article 6a
Based on the obligations of the Law on Prevention of Money Laundering and Financing of Terrorism, the Organizer is obliged to collect information on whether or not the Player is a politically exposed person, a scan/photo/copy of an identification document and, for politically exposed persons, information on the manner of exposure, type of public duty and source of assets.
A politically exposed person is any natural person who acts or in the past 12 months has acted in a prominent public office in an EU member state or a third country, including members of his immediate family and persons who are known to be close associates of a politically exposed person.
Data from para. 1. of this article are collected in the last step of registration or before a certain payment or disbursement of funds to or from an online account in accordance with the risk assessment, when a legal obligation arises in accordance with legal regulations.
The organizer has the right to temporarily or permanently, in whole or in part, limit the disposal of the player's online account, as well as deny payment, payout or play, and until additional data is collected, the analysis procedure is performed, until it is determined that the submitted data is true or for the time of determining the true owner of a potentially defective account. The player is obliged to submit the data from para. 1 of this article before continuing to use the Online account.
Article 7
During the registration process, the Organizer identifies the Player using Tax Administration’s electronic services, including the process of verifying the Player’s information and establishing that he has reached the age of majority. Such age and Player’s particulars may also be verified using the relevant electronic payment system by identifying the debit or credit card holder. The Player may also be identified based on data appearing in a valid identity document provided by the Player (identity card or passport).
The registration process may not be resumed before the Organizer has successfully completed the Player data verification process and has established that he has reached the age of majority.
For successful registration, the player will confirm that he/she has read these General Terms and Conditions and the Privacy Policy and that he/she agrees with them by clicking on the corresponding mark. Without confirmation, player registration is not possible or valid.
A player is not registered until he has successfully completed his registration. The Player will receive notification of successfully completed registration in the last successfully completed step.
After successful registration, the Organizer shall assign the Player a unique player identifier within the gaming system.
Article 7a
Adria Casino d.o.o. based on the Ordinance on the remote introduction of the party and the minimum conditions that must be met by the solution that determines and checks the identity of the party at a distance, conducts video identification on its online casino website.
Video identification is done through the Jumio platform by uploading an image of an official ID followed by video identification of the person by collecting a facial scan to verify the match of the player's identity. You can read the way data is processed in the Privacy Policy.
ONLINE ACCOUNT (I-ACCOUNT) MANAGEMENT
Article 8
The Player may only open and manage one virtual account (i-Account) which he accesses by entering his username and password. If the Player attempts to open several online accounts, all accounts he attempts to open may be blocked or closed and all online games may be invalidated. The Organizer shall not be held responsible for preventing the registration of several accounts, but reserves the right to take action in connection with Players who open several accounts, including their blocking or closing.
The Player shall safeguard such data with particular care and shall be held fully liable for any pecuniary or non-pecuniary damage incurred as a result of negligent keeping or any other form of negligence which allowed an unauthorized person(s) to obtain his username, password or any other personal data, such abuse resulting in pecuniary or non-pecuniary damage to the Player. The Organizer shall not be liable to the Player for any pecuniary or non-pecuniary damage resulting from the abuse, unauthorized use or any use in violation of these Rules by an unauthorized person or any other third party.
Article 9
The Player may deposit funds for playing at the Organizer’s online casino using any of the following options: standard bank payment order (general or online payment order), debit or credit card, activation voucher or any other electronic payment option, or personally at any Organizer’s outlet. Once completed, a transaction cannot be canceled.
In case the Player is paying such deposit using a payment card, the Organizer shall conduct the card authorization process in compliance with the applicable regulations of the Republic of Croatia, requiring the application of and compliance with appropriate security standards and protocols in communication with the bank. In this process, the Organizer only records performed and unperformed transactions, including the card type and amount paid.
The Organizer does not apply any fee to Player’s payment. In case the payment is made using any other electronic payment system, the Organizer reserves the right to charge a transaction processing fee.
After making the relevant payment, the Player is free to dispose of the funds after the Organizer records them in the Player’s virtual account (i-Account).
The Player is allowed to view all financial transactions performed, his payments to and from the virtual account (i-Account), including the time of completion and any limitations, and to create payment/withdrawal orders. The Player is allowed to print an electronic receipt for the payment for a particular game within the Organizer’s system, which also includes its identifier appearing in the Player’s account within the Organizer’s central system.
The funds deposited by the Player in his online account may only be used to participate in online playing on the Organizer’s website and the Organizer may for such purpose make the payment from the Player’s account conditional upon the satisfaction of specific requirements defined by the Organizer and deny its authorization thereof until such requirements are satisfied, for the purpose of ensuring that the payment was made exclusively for the purpose of participating in casino games.
Player’s funds are held in a separate account, opened exclusively for the purposes of online gaming, separately from Organizer’s other funds, and shall not be used for any other purposes.
Article 10
Such payment for participation in a game and playing games available at the online casino shall be made on the Organizer’s website where the Player interacts with the Organizer’s gaming system. The Player may not participate in any online casino games offered unless the funds in his virtual account (i-Account) exceed the minimum payment required for the game he wishes to play.
Each payment for a game is recorded as a financial transaction which reduces the balance in the Player’s virtual account by each amount paid for the game. The Player confirms his participation in a game through multiple payment authentications. Once completed, a game payment transaction may not be canceled.
The Player may hold in his virtual account funds recorded by the Organizer’s system after he deposits them, any bonuses granted to him by the Organizer’s system subject to specific requirements or earned by him by satisfying specific requirements defined by the Organizer, and prizes won by playing. In such situation, the Organizer’s systems first use the bonuses, then the funds paid, and then the prizes.
Each prize earned by the Player shall be recorded as a financial transaction whereby the amount of each prize earned in a game is paid in favor of the Player’s account.
Article 11
The Organizer’s system shall automatically allocate any prize earned by the Player in online games to the Player’s online account (i-Account). The Player may only transfer funds available for withdrawal from his virtual account (i-Account). Any funds remaining in the Player’s virtual account (i-Account) may become funds available for withdrawal subject to specific requirements defined by the Organizer.
Such payment from Player’s account shall be made at Player’s request which he creates in his profile and the relevant amount may be paid to Player’s bank account (checking account), disbursed at the casino cash desk, or paid using the electronic payment system. The organizer is obliged, at the written request of the registered player, to pay the funds from the online account immediately, and within four days at the latest, to the player's transaction account.
The minimum amount that may be deposited in the Player’s bank account is EUR 10.00.
The Organizer reserves the right to delay or cancel a financial transaction whereby a prize is paid to the Player’s online account (i-Account) if it is found by additional verification of compliance that the prize was won by mistake or as a result of a technical error for which the Organizer is not responsible and the incorrectly remitted funds shall in such case be refunded. The Organizer shall not be liable for any damage or expenses incurred by the Player as a result of an error on the part of his internet service provider or telecom operator. The Organizer shall also not be liable for any damage that may result from the use of computing equipment personally selected and used by the Player, his selected telecom service or the service to access the relevant interactive online channels he uses.
The Player shall at Organizer’s request present additional documents to demonstrate the authenticity of his information and, in particular, his right and authority to use the bank account for receiving payments.
In case the Player has been inactive for more than one year and no deposit transaction in his virtual account is recorded, the Organizer shall refund the money to the Player’s bank account.
REQUIREMENTS FOR PARTICIPATION AND RULES OF PLAYING ON THE ORGANIZER’S WEBSITE
Article 12
Only persons above the age of 18 are allowed to participate in games simulating slot games or table games in the Organizer’s online casino.
All Organizer’s online interactive casino slot games and table games have been certified by a laboratory licensed by the Ministry of Finance of the Republic of Croatia.
These Rules are available to the Player on the homepage of Organizer’s online casino, generally define all requirements for online participating in and playing slot machines and tables, and were prepared in compliance with all laws and regulations concerning this industry.
The graphic presentation of the slot machines and tables include the rules and instructions for playing which describe how each slot machine game is played, explain the role and meaning of each symbol in the game, and provide other information to be used by the Player to better understand and participate in a game. A prize scheme is available to Players at each slot machine and table.
The slot machine offers Players different options of real playing for money and trial games used by Players to become better acquainted with and to demonstrate the game. The Player does not win the prizes earned in a trial game and they are not credited to his virtual account (i-Account). When selecting a real option of playing for money, the Player may freely choose a stake for participating in the game, ranging from the minimum to the maximum stake (price) offered for participation in a specific game in accordance with the defined denomination for each game. The Organizer reserves the right to define the minimum and maximum stakes (prices) offered for each game.
The Player shall be deemed to have won a prize if he chooses a combination among those appearing in the prize scheme as winning combinations, which is available to the Player at the slot machine or table. The result of a slot or table game is graphically displayed on the slot machine as a winning combination of symbols in accordance with the prize scheme. The prize won is automatically credited to the Player’s virtual account (i-Account).
VIRTUAL ACCOUNT (i-Account) CLOSING
Article 13
The Player may at any time, without giving his reasons, submit a written request for the closure of his online account to the Organizer’s address or by e-mail to podrska@senator.hr. If the request to close the account is submitted via e-mail, it must be sent from a registered e-mail address and contain the player's first and last name, OIB and nickname.
Before closing the online account, the player is obliged to play or pay out all available funds. Available funds that the player cannot pay independently will be paid in agreement with the player based on his request or to the player's registered bank transaction account.
The Organizer shall act on such Player’s request as soon as it receives it. Pursuant to the applicable legislation, the Player must confirm his request within the next three weeks. The online casino website allows the Player to individually edit the settings and determine the maximum amount he is allowed to pay within a specific period of time (stake limit) or determine the maximum amount of loss he is allowed to suffer over a specific period of time, and to limit the deposit amount.
After closing his online account, the Player may request from the Organizer in writing or by e-mail to reopen it.
The Organizer reserves the right to take action, including blocking or closing the Player’s online account, to prevent any attempt of opening multiple online accounts.
PLAYER'S VIRTUAL ACCOUNT INACTIVITY
Article 14
The Organizer is required to transfer the money from the player's virtual account to the player's transaction account if it becomes inactive, which occurs when no payment transaction has been recorded from the player's virtual account for more than a year.
If the proceeds from this item are less than or equal to one euro, they will be automatically withdrawn from the player's transaction account because processing the return would cost more than the proceeds themselves.
TECHNICAL DEFECTS AND LIABILITY
Article 15
In case the gaming system or the electronic support system becomes defective, all pending payments and deposits shall be canceled. The Organizer reserves the right to withhold payments of all prizes if they were won as a result of a technical error, subject to refunding the stake to the Player. The Organizer shall not be liable for any damage incurred or caused as a result of a defect for which it is not responsible or which is beyond its control, such as defects in communication, systems or equipment, or any damage resulting from force majeure.
The Player shall be exclusively liable for any errors, damage or losses resulting from or caused by the use of computing equipment or telecom services selected by him and for any damage resulting from his own choice of the service used to access online interactive gaming channels
RESPONSIBLE ORGANIZING
Article 16
The Organizer shall implement measures to protect Players against excessive participation in games of chance in accordance with the applicable legislation and its own principles of responsible organizing.
The Player may use his setting to exclude himself for 24 hours or up to 365 days. If the Player wishes to exclude himself for a longer period, he must submit to the Organizer a written self-exclusion request available on the Organizer’s website.
The self-exclusion is initiated by the player individually on his user profile and is effective right away for up to 365 days.
The organizer will exclude a Player who confirms his request for self-exclusion within the three-day window if it is for a term greater than 365 days. The Player may also ask the Organizer to revoke the aforementioned via chat, written communication, or email.
BONUSES AND PROMOTIONS
Article 17
For game promotion purposes, the Organizer reserves the right to grant different types of bonuses, points, free turns or other similar benefits to Players, subject to predefined terms and conditions applicable to each type of promotion. The Organizer’s website provides information about the terms and conditions governing the Player’s right to each type of bonus, points, free turns or other similar benefits.
To inform Players of its promotional activities, the Organizer shall also send e-mails and text messages to Player’s e-mail addresses and mobile phone numbers specified by them in the process of registration. A successfully completed registration process implies that the Player voluntarily agrees to receive promotional messages and information from the Organizer by e-mail and mobile phone. The online casino website allows the Player to opt for or opt out of receiving promotional e-mails and text messages by checking the designated box. The Organizer reserves the right to contact the Player by e-mail in case a message is relevant to his personal use of the system.
To enlarge its online casino service range, the Organizer reserves the right to define and implement various kinds of Jackpots.
All promotions and bonuses at Senator online casino are valid only when the Player receives them directly from the Organizer. The bonus is void if the Player requests a withdrawal or payout from the online account before playing the amount for which the bonus was awarded. This means that the player must use the bonus money that was awarded to them a certain number of times before the money can be withdrawn. Only regular bets count toward the amount that needs to be played for the money to be eligible for withdrawal; bets with doubling options or similar features are not included. While the bonuses have not been fully converted to cash or removed from the account, the terms for that bonus still apply. This includes any outstanding deductions from the Player's account.
The Organizer reserves the right, through Customer Service, to request email confirmation for receiving bonus promotions.
The Organizer reserves the right, when processing a payout to the Player, to review the games played, and any suspicious or unusual Player activity may lead to the possibility of canceling or holding all winnings and bonuses, and it will be considered a violation of the bonus terms and conditions.
The Organizer reserves the right to deny the Player any earned bonuses if those bonuses were not earned in accordance with the terms of a particular promotion. In the case of abuse, the Organizer reserves the right to end the promotion prematurely and restrict the use of individual or all Player online accounts and bonuses. The Organizer reserves the right to cancel all bonuses and/or winnings obtained through the violation or abuse of the bonus rules.
Article 17a
The Organizer reserves the right to independently rank and assign VIP status to players in different ranks depending on the frequency and amount of their stakes, i.e. deposits, as well as depending on other conditions that the Organizer independently determines. Once assigned VIP status, the Organizer can independently increase and decrease it in accordance with the specified criteria.
RESTRICTIONS AND PROHIBITIONS
Article 18
On its website, the Organizer prohibits Players from:
- participating in online playing if they are under the age of 18;
- using their online accounts in violation of any applicable legislation or these Rules;
- using multiple online accounts;
- participating in online playing on behalf of other persons for the purpose of obtaining illegal gain or certain privileges;
- using proceeds of illegal activities to participate in online playing;
- using computer fraud or otherwise act illegally to obtain gains or other benefits;
- playing and depositing funds in the online account inconsistently with the usual manner of participating in games of chance; and
- paying funds from the online account if they are a result of any errors in the online gaming system.
The Organizer shall carefully monitor each suspicious payment and shall, if there is reason to suspect money laundering or terrorist financing, take all actions necessary as defined in the Anti-Money Laundering and Terrorist Financing Act.
The organizer reserves the right to take measures such as the restriction of disposal and the impossibility of disposal of the Online account for any attempts to manipulate the account that are contrary to these General Rules.
PROTECTION OF PRIVACY AND SAFEGUARDING OF DATA
Article 19
The Organizer shall only use personal data concerning Players and their accounts for the purposes of their participation in games of chance at the Organizer’s online casino and shall carefully safeguard them as confidential information in accordance with the applicable legislation. To this end, the Organizer implements permanent measures to protect Players’ personal data against abuse, loss or destruction, as well as unauthorized alteration thereof or access to the Players database.
The Player shall be exclusively responsible for the safeguarding and secrecy of his password and for any abuse, whereas the Organizer shall not be held liable for any pecuniary or non-pecuniary damage resulting from Player’s irresponsible conduct.
CONTACT AND NOTICES
Article 20
You can get in touch with our customer service by phone, email, or internet chat if you have any questions, concerns, or suggestions.
The ordinance on call recording is available on this link.
MISCELLANEOUS
Article 21
The Organizer shall publish these General Rules, as amended, on its website.
The Players shall be deemed informed as of the time these Rules are published on the website.
If a Player logs into the online system after the effective date of an Amendment to the General Rules, he shall be deemed to have understood and accepted such Amendment.
In case of any dispute arisen from or in connection with these Rules that the Player and the Organizer are unable to resolve amicably through mutual negotiations, they shall submit to the jurisdiction of the relevant court in Zagreb.
The relevant regulations of the Republic of Croatia shall apply to anything not defined in these General Rules.
These Rules shall be authorized by the Ministry of Finance and shall enter into effect as of the date they are published on the Organizer’s website.
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Privacy policy
Adria Casino d.o.o. of Dubečka 1, Zagreb, VAT No: 90180501899, issues, on 5 October 2020, this
PRIVACY POLICY
Introduction
Adria Casino d.o.o. of Dubečka 1, Zagreb, VAT No:: 90180501899 (hereinafter referred to as Adria Casino d.o.o.), is particularly committed to protecting personal data and privacy (hereinafter referred to as privacy protection) of its customers, suppliers, employees and other parties with whom it interacts (hereinafter referred to as customers) in accordance with the applicable regulations and European best practices (Regulation (EU) 2016/679 of the European Parliament). Protecting our customers' privacy is an integral part of our services and how we conduct our business.
This Privacy Policy is intended to provide clear information about the processing and protection of personal data processed by Adria Casino d.o.o. and to allow our customers to easily control and manage their personal data and consents.
This Privacy Policy enters into effect on 5 October 2020 and describes which personal data are collected by Adria Casino d.o.o., how it processes them and for which purposes it uses them, for how long and in which manner it stores them, as well as the rights of customers relating to their personal data.
Controller: ADRIA CASINO d.o.o., Dubečka 1, Zagreb, VAT No.: 90180501899; E-mail: zastitapodataka@senator.hr, 01/2922 390
Data Protection Officer: e-mail: zastitapodataka@senator.hr; phone: 01/2922 390
1. Scope
This Privacy Policy applies to all personal data collected, used or otherwise processed by Adria Casino d.o.o., either directly or through its partners. Personal data is any data relating to a natural person identified or directly or indirectly identifiable.
Data processing is any operation performed on personal data, e.g. their procession, recording, storage, use, transmission, viewing, etc.
Adria Casino d.o.o. is the controller in relation to its customers’ personal data within the meaning of the relevant personal data protection regulations.
This Privacy Policy applies to all natural persons interacting with Adria Casino d.o.o. in any manner.
2. Principles of personal data processing
2.1. Trust
Adria Casino d.o.o. is committed to being completely transparent and clear with regard to the processing of its customers’ personal data, which is the purpose of this Privacy Policy, and is committed to maintaining relationships built on trust with its customers.
2.2. Lawfulness of data processing
When processing personal data, Adria Casino d.o.o. acts in compliance with the law.
2.3. Restriction of processing
Adria Casino d.o.o. only collects and processes personal data for a specific lawful purpose and continues to process them for the purpose they were collected for.
2.4. Data minimization
We always use only those customer data that are appropriate and necessary to fulfill a specific lawful purpose and no more than that.
2.5. Integrity and confidentiality
Personal data are processed in a secure manner, including protection against unauthorized or unlawful processing or accidental loss, destruction or damage (access to personal data is only allowed to employees on a need to know basis).
2.6. Personal data quality
We treat the personal data we process as highly important. The personal data we process must be accurate, complete and kept up to date, which is why it is important that our customers notify us of any change to their data immediately or as soon as possible. Adria Casino d.o.o. is not and cannot be held responsible for any data received from its customer that such customer later modifies without notifying Adria Casino d.o.o.
2.7. Limited retention period
We only retain the personal data we collect, store and process for as long as this is necessary to fulfill a legitimate purpose, i.e. for as long as defined by the applicable regulations or for as long as this is necessary to perform a contract – on elapse of this time, such data are erased.
3. Collection of personal data
Adria Casino d.o.o. primarily collects personal data directly from its customers for the purpose of entering into contract based on the relevant legislation or customer’s consent.
Any processing of personal data is conditional upon the existence of appropriate legitimate interest.
4. Types of data we collect
Adria Casino d.o.o. collects personal data subject to legitimate interest based on the relevant legal grounds or customer’s consent. The application forms we use to collect such data clearly show the purpose of collecting such data, the location of their storage and their retention period.
4.1. Contractual data
For the purposes of performing contracts, expressing its intention to enter into contracts, business negotiations, etc., Adria Casino d.o.o. may collect the following personal data:
- Names and surnames of natural persons who are representatives of corporations, property owners, etc.
- PIN
- Address
- E-mail address
- Particulars of property ownership
- Bank account information
These data are retained for the periods defined in the respective laws, depending on the type of contract and duration of contract performance, and are thereafter erased. In case a customer refuses to provide any data required for contract performance, Adria Casino d.o.o. reserves the right to refuse to enter into a business relationship with such customer.
4.2. Personal data collected as part of organizing online games of chance
In the context of organizing online games of chance, Adria Casino d.o.o. is required under the relevant laws and regulations to collect the following data:
- Password
- Username
- Name
- Surname
- Address
- PIN
- Mobile phone number
- Date of birth
- Gender
- Bank account IBAN
- Type of identity document
- Identity document number
- Expiry date of the identity document
- Name of the identity document issuer
- Country of the identity document issuer
- A scan or image of the identity document
- Nationality
- Particulars of political exposure
- How the customer is exposed
- Type of public function
- Source of funds
These data are retained for the periods defined in the respective laws, but no less than 10 years, and are erased thereafter.
These data are collected based on legal grounds and, in case the customer refuses to provide such personal data, such customer shall not be able to use Adria Casino d.o.o.’s services or take part in games of chance.
4.2.2. For contract performance purposes, Adria Casino d.o.o. uses automated processing of customers’ personal data when organizing online games of chance.
4.2.3. Adria Casino d.o.o. internally processes personal data necessary for the normal functioning of the online and interactive gaming system. Personal data are anonymized and all customer data are processed in anonymized form in daily operations.
Such data are processed for the purposes of organizing online games of chance and certain analyses of customer data are intended to improve our business and the quality and level of service and increase our customers’ satisfaction and are not used for any purposes other than those defined in this Policy.
Personal data may only be accessed directly via the database and logging into it is only allowed to authorized administrators and other specifically authorized employees. Each instance of access is recorded. Access to such data is intended to establish technical functionality, to the exclusion of viewing personal data.
4.3. Data collected under the Monetary Institutions Protection Act
In its gaming clubs, Adria Casino d.o.o. uses alternative methods of monetary institution protection and implements, pursuant to the Monetary Institutions Protection Act (Official Gazette No 56/15) all measures to protect its gaming clubs in accordance with the Project Documentation rendered by ADC – Alarmni Dojavni Centar, Letovanička 22, Zagreb, separately for each gaming club. Video surveillance systems are installed inside and outside these gaming clubs and video recordings are stored in digital format. The controller and ADC communicate via a monitored secure line. Access to the server and monitor for viewing video surveillance records is only allowed to the person designated by the controller. Video surveillance records are retained in accordance with the Monetary Institutions Protection Act.
4.4. Data collected under the Anti-Money Laundering and Terrorist Financing Act
Subject to conducting a prior due diligence investigation as required under the Anti-Money Laundering and Terrorist Financing Act (Official Gazette No 108/2017), we are required to collect the following personal data:
- for natural persons, proxies or legal representatives: name, address, date of birth, national identifier, identity document name and number, issuer’s name and country, and nationality(ies);
- for natural persons for whom the transaction is intended: name, address and natural person’s national identifier, if available;
- for craft businesses and other sole proprietorships: a) name, registered office (street and building number, town/city and country) and identifier of the craft business or other sole proprietorship where a business relationship is being established or a transaction is being conducted for the purposes of operating such craft business or other sole proprietorship; and b) name and registered office (street and building number, town/city and country) of the craft business or other sole proprietorship for whom the transaction is intended and the identifier of the craft business or other sole proprietorship, if available;
- for the customer’s beneficial owner: name, country of residence, date of birth and nationality(ies);
- particulars of the intended purpose and envisaged nature of the business relationship, including information about the customer’s business activities;
- . date and time of establishing the business relationship;
- date and time of performing the transaction, transaction amount and currency, how the transaction is conducted and, where the obliged entity finds high AML/TF risk to exist after making an appropriate risk assessment in accordance with the provisions of this Act and its implementing regulations, the intended purpose of the transaction;
- source of the funds to be involved in the business relationship;
- source of the funds to be involved in the transaction;
- any other particulars of transactions, funds and persons as required under Article 20 in conjunction with Articles 56 and 57 of the Anti-Money Laundering and Terrorist Financing Act.
These data are retained for 10 years following the end date of the business relationship, which period is defined in the Anti-Money Laundering and Terrorist Financing Act.
4.5. Data collected for marketing purposes
Adria Casino d.o.o. only collects the data it uses for marketing purposes, such as creating databases in CRM where customers receive different benefits, based on consent of the natural person whose data are being collected.
If it becomes necessary to collect other personal data or if new legitimate interest arises that requires Adria Casino d.o.o. to collect personal data, Adria Casino d.o.o. shall amend this Privacy Policy accordingly and publish it on its website.
4.5.1. Senator Hit the Jackpot application
The following personal data must be inserted when downloading transferable items (Vouchers) in the Senator Hit the Jackpot application: nickname, full name, date of birth, and identity card number. By entering such personal data and downloading the voucher, you give us your express consent to collect and process your personal data you make available to us.
We will only use such personal data collected via the Senator Hit the Jackpot application for marketing purposes, to measure the success of our promotions, and such personal data will be treated in accordance with the EU General Data Protection Regulation (2016/679).
5. The purposes of collecting personal data
Data are processed in a fair and lawful manner and only to the extent necessary. Adria Casino d.o.o. collects and processes personal data of its business partners, customers, etc. for the purposes of entering into and performing business cooperation agreements, in cases defined by the law, and in cases where it receives customer’s consent, to the extent of the purpose the consent pertains to.
6. Customer’s consent
Customer’s consent means any freely given, specific, informed and unambiguous indication of the customer's wishes by he, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data for specific purposes (e.g. a specific promotion).
The customer manages his own indications of wishes and consents depending on his needs and interests, which means he may at any time, easily and free of charge, withdraw his consent at the business unit where such consent was originally given or using the data protection e-mail address.
7. Publication of customers’ photographs on controller’s official website (www.senator.hr) and official Facebook profile (Senator automat klubovi Hrvatska)
Adria Casino d.o.o. informs all its customers that it has its photographer within each gaming club, who takes photographs of each promotion or birthday party or any other similar event, and customers may tell the gaming club manager at the scene if they do not wish to be photographed and published on the official website and Facebook profile. If they fail to inform the gaming club manager that they do not wish to be photographed and do not wish their photographs to be published, they may contact the Data Protection Officer at: zastitapodataka@senator.hr and the photograph will then be removed as soon as possible.
8. Personal data protection measures
Pursuant to the Personal Data Protection Act, we are implementing the required technical measures and procedures and ensure control of access to personal data, which is only allowed to specifically authorized persons. State-of-the-art security procedures are used to collect and process data, including servers, databases, backup capabilities, firewalls, encryption, surveillance and access control systems, both physical and software-supported, to ensure protection against loss or abuse of personal data.
8.1. Physical data protection
- Company premises are protected by an alarm system and a video surveillance system directly connected to the security firms we deal with, who respond either to our call or to the automated alarms activated at their alarm center, and their security guards are then dispatched to the scene. All our sites are equipped with state-of-the-art sophisticated equipment required under the Monetary Institutions Protection Act;
- The server equipment used to store data is located in server rooms protected as aforementioned, and additionally within lockable server racks inside such rooms;
- All sites containing personal data use access control via electronic verification systems and RfID card readers, both at each site and within each room at each site;
- All sites containing personal data implement appropriate fire protection measures.
8.2. Digital data protection
- Computers/workstations in our offices – the relevant requirements are set separately for each user account through Active Directory and Domain, and through the Group Policy;
- Computers/workstations in our gaming clubs are protected either physically within an anti-burglary safety deposit box which is locked and may only be accessed by gaming club employees or digitally by using a password;
- Mobile devices are protected through the required locking of mobile devices using a password.
Our protection includes systems to prevent viruses and other malware, scripts and source code parts from running, to prevent sending and receiving of such apps, etc.
Where legally required, all business-essential systems are backed up.
Electronic access to all systems is restricted in several ways. Our protection methods include but are not limited to the restriction of the right to access user accounts and allowing access to personal databases to authorized persons only. This is, among other things, intended to protect our systems against unauthorized access, installation of unwanted apps, intentional causing of data loss, etc.
9. Personal data processors
As the controller, Adria Casino d.o.o. has contracts in place with several processors that comply with the Regulation and treat their personal data exactly as defined therein, which is also defined in our contracts with them, including the relevant annexes thereto.
10. Transmission of personal data to third parties
Adria Casino d.o.o. is required to provide personal data it collects pursuant to the applicable legislation to the relevant authority as part of such authority’s official activities (Ministry of Finance, AML/TF Office. etc.).
Data collected by Adria Casino d.o.o. are considered to be confidential business information and may only be disclosed if so permitted by law.
11. Data subjects’ rights (rectification, erasure, objection, access, restriction of processing, portability)
Pursuant to the General Data Protection Regulation, each customer may:
- request from the controller access to his personal data and rectify or erase his personal data in accordance with this Policy and the applicable legislation.
- request from the controller to restrict the processing of data relating to him as a data subject in accordance with this Policy and the applicable legislation.
- object to the processing of his personal data, including the use of personal data for direct marketing purposes and automated decision-making including profiling in accordance with this Policy and the applicable legislation.
- request from the controller to transmit the personal data concerning him in accordance with this Policy and the applicable legislation.
- withdraw his consent to personal data processing at any time.
If the customer withdraws his consent, this shall be without prejudice to the lawfulness of processing his personal data collected based on his consent before its withdrawal.
In case the customer has any questions, complaints or requests, including those for the exercise of his rights under the Regulation or the preceding Article, he may contact the Data Protection Officer or controller at: zastitapodataka@senator.hr or in writing at:
Adria Casino d.o.o. , Dubečka 1, Zagreb.
You may contact us at any time and view, modify, alter or rectify your data in accordance with your rights under said laws.
The customer may at any time lodge a complaint with the personal data protection supervisory authority:
Personal Data Protection Agency
Martićeva ulica 14, 10000 ZAGREB
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PEP info
Politically Exposed Person is any natural person who is or was in the past, at least 12 months, carrying out an eminent public duty in an EU Member State or third country, including members of her immediate family and persons known to be close associates politically exposed persons.
Close family members of Politically Exposed Persons are spouses or cohabitees, children of politically exposed persons and the spouses or cohabitees of those children, parents of politically exposed persons.
Close associate is every natural person which is known to have joint beneficial ownership of legal entity or legal arrangement, or any other close business relations with politically exposed persons, or which is the only beneficial owner of the legal person or legal arrangement which is known to be established for the benefit of politically exposed persons.
Warning
Are you sure you are a politically exposed person? Keep in mind that if you declare yourself as a politically exposed person you will have to go through additional procedures and verifications and will not be able to play until the check is concluded.
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