CCTV privacy notice

The close circuit television cameras (“CCTV”) have been set up as part of undertakings of the Evolution Gaming group (to which Ezugi companies are part of) and this privacy notice contains information about how we carry out your personal data processing obtained through the CCTV devices. The video-surveillance system complements other typical security and access control purposes by monitoring specific areas.

This privacy notice is issued for the information of all employees, consultants, contractors, visitors and volunteers, as per the provisions of Art. 13 and Art. 14 of General Data Protection Regulation (GDPR).

This is an up-to-date version of the CCTV privacy notice. With this we reserve the right to make changes unilaterally to this privacy notice. For this reason, we are inviting you to re-read this privacy notice from time to time to be aware of the current information on the personal data processing.

The language of this privacy notice is English. Upon your request on e-mail: [email protected]  we will provide you this CCTV privacy notice in the national language of the country or your location where data processing through video surveillance takes place, if we are obliged to do so according to statutory requirement.

In addition to the above, in the particular case of EZUGI RO SRL the purpose of this privacy notice is also to ensure that a transparent environment exists within Ezugi regarding video surveillance and that Ezugi complies with the requirements of the applicable workplace surveillance legislation in force (Law No. 190/2018) and with the GDPR. The privacy notice describes the measures taken by Ezugi to protect personal data, privacy and other fundamental rights and legitimate interests of individuals filmed by surveillance cameras. Video surveillance is only used when the conventional means used are considerably less effective in achieving those objectives, according to the risk analysis carried out at the institution level.  Employees are required to be notified prior to the commencement of the surveillance. This privacy notice is notification in accordance with the Law No. 190/2018 and GDPR.

Controller

In this section is information available about where to apply in case of any questions you may have. CCTV warning signs have been placed in each of the Evolution Gaming group locations with warnings regarding video surveillance in operation and with identity of each undertaking of the Evolution Gaming group and contact information about where to apply in case of any questions.

In any case, if you have any questions, requests or objections related to video surveillance performed by each undertaking of the Evolution Gaming group, please e-mail us on: [email protected].

Personal data processing purposes and legal basis

Our CCTV system is located on the walls of the buildings to monitor the entrances to our premises/offices (applicable depending on jurisdiction), including at the emergency exits, at the areas considered as publicly accessible such as stairwells, corridors and vestibules, gyms and others (except in areas expected to have privacy, for example, bathrooms, changing rooms, rest rooms). In areas mentioned above we perform video surveillance keeping video recordings for the following purposes:

to ensure the security of our employees (our legitimate interests);
to protect our premises and assets (our legitimate interests);
to prevent pilfering, malingering, deliberate damage or other misconduct (our legitimate interests);
to ensure – and record – that Evolution’s procedures are being followed (our legitimate interests);
to use CCTV footage as evidence for disciplinary investigation and take any disciplinary action, which may include termination of employment (our legitimate interests).

Who we may disclose personal data

We take all necessary measures to ensure that your personal data are not disclosed to any third party without any legal basis.

To fulfil our personal data processing purpose, your personal data can be disclosed to following recipients:

Evolution Gaming group;
Law enforcement authorities, supervisory authorities, national security authorities and other public authorities upon reasoned request.

Transfer of personal data outside the EU/EEA

Your personal data may be transferred outside the EU/EEA only within the Evolution Gaming group. If we do so, you can expect a similar degree of protection in respect of your personal data as in EU.

How long we store personal data

We will retain your personal data obtained through video surveillance devices for the period necessary to fulfil our processing purpose.

We have taken into account our needs to fulfil our legitimate interests and statutory requirements applicable to our business activity in determining period of retention in our data repositories of your personal data acquired through video surveillance devices.

Generally, we may retain your personal data for no longer period than 30 days due to necessity to identify or investigate later detected incident as well as depending on type of area surveilled and requirements of national regulation of actual location of video surveillance.

In case of infringement or other misconduct, dispute, or any legal proceedings, we will keep the video recording in question till expiration of possible challenging period of the settled case, usually not longer than 2 (two) years after the settlement.

Your data subject rights

You have right to request access to your personal data in our possession, request the rectification, erasure, restriction of processing, object to processing as well as rights to data portability following cases and in accordance with a procedure prescribed by the GDPR.

Your requests regarding your data subjects rights you can exercise by contacting to us via e-mail: [email protected].

We will evaluate your request and our possibilities to carry out your personal identification and execute your request and depending of current circumstances we keep the rights to request additional information from you or data for your identification and to clarify details necessary for exercising your request with aim to ensure safety of your personal data, no-disclosure to the third party and possibility to provide to you an adequate reply.

With this we are asking you to take into account the fact that it may be impossible to exercise some of your data subject rights laid down in GDPR related to personal data processing through video surveillance devices, for example, to modify your image captured in video recordings, to erase video footage before expiration our determined retention period of the video recordings, to object against such processing entering in surveillance area of the surveillance cameras. Therefore, we do not grant that we will be able always satisfy your request on exercising your data subject rights.

Your rights to lodge the complaint to supervisory authority

In case of any question, objection or complainant related to the personal data processing through video surveillance devices we are calling you preliminary refer to us.

However, if you consider that we infringe your data subject rights, you always have rights to lodge your complaint to the relevant supervisory authority.

List of national supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

Why and how we obtain your personal data

We obtain your personal data with circuit television cameras devices when you enter surveilled areas. Your personal data is necessary to fulfil our determined processing purposes. If you would like not to provide your personal data to us, you won’t be able to get into our premises or surrounded area. For that reason, it may constitute real obstacles to exercise some rights you may have or fulfil particular obligations applicable to you.

Automated decisions

We do not use personal data obtained through video surveillance devices to make automated decisions, including profiling.

Processing of your personal data for other purpose

We do not intend further processing of your personal data obtained through video surveillance devices for other purpose incompatible with the original purpose.