Πολιτική Απορρήτου — TOROTIPS

The website https://torotips.com (hereinafter referred to as the “Website”) is intended for Internet users (businesses – companies and individuals) conforming consistently and responsibly to the European and national personal data protection legislative framework, for the purposes of your safety when using our website. For more information about the website’s legal and regulatory framework of operation and use, please read the Terms and Conditions of Use and the Cookies Policy.

Protection of your personal data is of primary importance and is treated with the utmost seriousness by our Company. Our main priority is respect for the personal data we manage and ensuring their proper processing. In the following terms you will find important information about the type of personal data we collect and process, the necessary and legitimate purposes of collection and processing, the duration of their use, as well as the significant rights that you have as subjects and the means to exercise them.

For any clarification or enquiry about the data use or the exercise of your rights, you may contact us at: support@torotips.com. A specialized partner of our Company carefully monitors the legislation course in terms of personal data protection and adapts our website’s functions accordingly, always within the strict framework of the law, to ensure your personal data protection

About Us

The torotips.com is the official website and digital environment of the TOROTIPS platform.

Ownership of the platform—and all related operational, technological, and intellectual property elements (including source code, structural components, and IP rights)—belongs exclusively to InteradSoft LLC, a company registered at 30 N Gould St, Ste N, Sheridan County – WY 82801, Wyoming, USA, EIN 33-4047963.

INTERAD S.A. (Tax ID/AFM: 997839117, G.E.MI. Reg. No. 121735601000) serves as the local representative and support services provider in Greece, pursuant to a granted right of use and management from InteradSoft LLC.

Scope – Legal Framework

This Personal Data Protection Policy applies to all personal data protection processing belonging to individuals within the operation framework of the website https://torotips.com. The Privacy Policy applies to our website’s visitors. Each user is referred to as the subject of the data provided to our website upon his/her absolute consent. Therefore, the words “you”, “yours” and generally the use of b’ plural refers to the visitors of the webpages in our website https://torotips.com. The use of a’ plural refers to the Company’s actions

Sometimes, we may need to share your personal data with third parties providing a specific service (such as an external contractor). This transfer is exclusively made for the purposes of fulfilling our contractual obligations and completing the services provided to you, the satisfaction of your wishes or needs, problem-solving, as well as contacting you within the framework of our contractual relationship.

The Privacy Policy applies to all entities that access and use the https://torotips.com services, simple visitors (quests), clients and partners (tipsters), as well as to all those who generally interact with the Company’s website in social media (comments and reviews in accounts, profiles, pages and channels of the website), who evaluate the website’s services in third-party applications and websites, who contact the Company through the website and/or other means. In any of the said cases, our Company may collect and process your personal data which is specific in terms of content, purpose and time frame (as described below).

For these reasons we take all reasonable technical and organizational steps to protect the personal data we process, to ensure that their processing conforms to the requirements of the effective legislation and mainly the General Data Protection (EU) 2016/679 and the Law 4624/2019, as supplemented by the instructions, decisions and opinions of the Hellenic Data Protection Authority.

Visiting the https://torotips.com webpages and using the website presupposes and confirms that you accept this Privacy Policy

Please read the Privacy Policy carefully. This policy sets out the fundamental principles, warranties and purposes, according to which the Company collects, stores and processes your personal data.

Legal terms you need to know before accepting our privacy policy:

What Does Personal Data Mean?

The term “Personal Data” or “Personal Character Data” or “Data” refers to all information referring to an identified or identifiable individual (“Data Subject” or “Subject”, such as full name, email, VAT No. etc.). The term “identifiable” refers to the individual whose identity can be verified, directly or indirectly, using identification means such as name, identity card number, location data, online identifiers (IP address, email address etc.) or one or more factors describing the physical, physiological, genetic, psychological, financial, cultural or social identity.

What Is Personal Data Processing?

Processing of Personal Data” or “Personal Character Data” refers to the act or series of acts implemented with or without using automated means, such as collection, registration, filing, layout, storage, adjustment, modification, recovery, information search, usage, communication to third-parties, diffusion, comparison, combination, limitation, deletion and destruction of personal data.

Definitions

For the purposes of this Privacy Policy, the following definitions apply:

“Processing responsible”: The legal or physical person, public authority, service or other institution that, alone or jointly, set out the personal data processing purposes and means.

“Processing performer”: The legal or physical person, public authority, service or other institution that processes personal data on behalf of the processing responsible

“Recipient”:The legal or physical person, public authority, service or other institution to whom the personal data is communicated, whether it is a third party or not.

“Third party”: Any legal or physical person, public authority, service or institution, excluding the data subject, the processing responsible, the processing performer and the persons which are authorized to process personal data under the direct supervision of the processing responsible or the processing performer.

“Processing limitation”: The labeling of stored personal data for the purposes of limiting its processing in the future. .

“Consent”: Of the data subject is the indication of willingness, free, specific, express and informed permission, according to which the data subjects state that they agree with the processing of their personal data, upon declaration or express positive act.

“Client”: The user who visits the website as client and proceeds to transactions concerning our services.

“Tipster”: The user who visits the website in the capacity of partner – sports analyst, who will make predictions for future or current sports events.

“Tips”: The betting predictions on the website for sports events

“Credits”: Money credits to the client’s personal account, so that he/she may unlock tips – predictions for the sports event of his/her choice.

“The Company”: INTERADSOFT LLC and/or INTERAD AE.

“Personal Data Protection Policy or Privacy Policy or Protection Policy for Data of Personal Character”: This Privacy Policy.

“Website”: The website https://torotips.com.

“Visitor”: The Internet user who enters and browses the website https://torotips.com and uses its services.

Types of Personal Data We Collect and Process

The personal data we collect from you and process depends on our website’s purpose of use. We expressly, clearly and specifically inform you about the personal data we collect and process per case, so that you unequivocally understand and know about their collection and processing. If you disagree with this policy, please refrain from using our website.

On our part, we bear no responsibility if you disagree with any term but still use our website and its services.

In case you visit our website simply for informational purposes concerning the services we provide (simple VISITOR – GUEST) without using any of our services (e.g., creation of personal account, newsletter subscription), we only collect personal data that your internet browser sends to our server. This data is necessary for technical reasons and their collection aims to display our website in your device’s browser and ensure its stability and security. This data includes visit date and time, duration of stay on the website, website content accessed by the visitor, URL through which the visitor was guided to the website, IP address and domain through which the website was accessed, browser used, operating system used, as well as technical information about the visit (http method, http version, https status code, length of data transferred).

In case you proceed to signing up as a CLIENT or TIPSTER who will make predictions about current or future sports events) or signing up to our newsletter to receive informational material from us or request contact through our website’s contact form, then you will be asked to provide personal information (e.g., name and surname, residence address, contact phone, email) for your request to be fulfilled.

Indicatively, in case you sign up as a CLIENT you will be asked to create an account on our website by registering your email address and creating a password, to sign in on the website and access your services-actions-transactions history.

In case a CLIENT wishes to proceed to a transaction (tip unlock, participation to betting prediction and similar services), he/she will be asked to provide the following data: name and surname, country and mobile phone number

In the case of PARTNER - TIPSTER and for the purposes of creating an account on our website and starting a partnership, the data required to provide is the following: name and surname, country of origin, email, residence address and password creation. He/she will be asked to accept specific collaboration contractual terms. At the same time, during all these steps, each user category will be asked to accept the respective privacy policy and the terms of use, that we suggest you read carefully.

Furthermore, we collect data for the following specific purposes:

- To contact our Company through the respective contact form, we collect and process the name, phone number and email you register, as well as the information you mention in the respective field (your message).

- Your personal data (profile name, comments, mentions and other information about you that you share with us) collected and processed by us during your visits in accounts, pages and channels of our website on social media, such as Facebook, Twitter, Instagram, YouTube etc. when you follow them, when you sign up as subscribers, when you contact us and when you use the services offered by these websites to contact us, to submit requests, enquiries, reviews and to acquire our services so that we respond to messages, requests, enquiries, reviews etc.

- We may process personal data of social media users interacting with our website within a social media environment in view of promoting our pages / accounts, within the framework set out by the Law.

- We collect and process information you provide when you contact our Company in any way (email, phone, contact forms, fax, social media etc.) to make our communication possible and feasible.

- Cookies: the website accesses and stores cookies, as well as similar technologies to your computer. Cookies are installed by our website and third parties. Data is processed for the purpose of providing access to our website in the most efficient way possible. For more information about the definition, collection and use of cookies from our website, please read the Cookies Policy

In Specific, We Collect:

• personal identifiers (name, surname, residence address, date of birth),
• contact information (phone number, mobile or landline phone, email),
• fiscal identifiers (VAT No., Identity Card No.),
• financial information (debit/credit card information),
• connection data (IP) and location tracking information,
• gambling activity
• activity about the manner you play

We Do Not Collect: a) any credit – debit card data and generally information you provide to payment service providers, that you type when creating your account and browsing on the website. This data is used and processed by the payment service provider and our company bears no responsibility about their personal data protection policy (e.g., credit institutions), b) sensitive personal data.

Participation to Social Media and Third-Party Websites

Our Company also maintains accounts in other social media (such as Google +, Facebook, Instagram, YouTube etc.) yet it is possible that it appears in third-party websites. Our Company verifies the legality of such websites before contacting them. None of your personal data is transferred or disclosed without your express authorization. Our Company is not responsible for the use, collection and processing of your personal data by these websites, and the sole responsible for the data protection policy is the website concerned. You may be informed about the privacy policy of any relevant means by referring to these, as they are exclusively responsible for collecting and managing your personal data.

The Purposes for Which We Collect and Process Your Personal Data

The personal data you provide to our online store is collected for specific, express and legal purposes and they are not subject to further processing that is incompatible with these purposes. In addition, it is proper, relevant and limited to what is necessary for the purposes for which they are subject to processing (“data minimization”).

The purposes for which they are collected and processed are solely and exclusively related to fulfilling our contractual obligations to you, and specifically to satisfying your requests, such as the successful completion of your transactions, payments, invoicing and information through our newsletter in case you sign up in the respective platform.

In the case of sign-up request to our newsletter or contact through telegram, your personal info is collected and processed solely for the necessary and legitimate purpose of your regular information. You may unsubscribe from our newsletter at any time by accessing our website’s respective section and following the deregistration procedure. You follow the same steps should you wish to delete your personal account, either by accessing the respective deregistration section on our website or by sending us a message to the said email address.

If you do not opt for this procedure, you must promptly inform us at our email address. Our Company does not process your personal data apart from the explicit, legal, proper and legitimate purposes.

Therefore, the purposes of data processing consist of the following:

• Completion of your signing in to our website and platform and the verification of identification and contact credentials.
• Management of your account and transactions processing on our platform, as well as management of the service department that is responsible for requests, enquiries, clarifications and complaints.
• Validation of your bank account information
• Crime prevention control (e.g., money laundering from illegal activities) and notification of the competent Supervision Authorities for gambling.
• Your information about our products, campaigns and newsletters.
• Ensuring the quality and constant improvement of our services.

What Is the Legal Basis for Data Processing from Our Company?

The legal basis for processing your personal browsing data on our website is article 6, section 1 cit. f’ of the General Data Protection Regulation (GDPR), as this data is required for our website’s operation, its optimization and for guaranteeing the safety of our informational systems. The processing legal basis for contact through the contact form is the website’s visitors’ consent, in accordance with article 6, section 1 a’ of the Regulation.

The processing of your personal data is implemented in accordance with:

• the terms of our contractual relationship and your consent, where applicable,
• the regulatory framework of the law concerning online gambling
• the legislative requirement relating to the prevention and suppression of money laundering from criminal activities, as we proceed to processing required to conform with our legal obligations,
• the Company’s legal interest (protection against fraud, technical issues, optimization of the client’s experience).

Who Are the Recipients of Your Data?

The recipients of your data are:

• INTERADSOFT LLC as the “Data Controller”, and the company INTERAD S.A., as the “Data Processor” for the specific needs and defined purposes of providing services through the online platform in Greece.
• Should it be required for specific reasons and purposes, the following competent authorities: the Hellenic Gaming Commission in Greece, the Sports Administrative Bodies (namely FIFA), Anti-Money Laundering Organizations (AMLs) or Combatting Financing of Terrorism Organizations (CTFs).
• The representatives and/or subcontractors aiming to support, promote and implement a transactional relationship, who provide platform maintenance services advertising, interconnection with other platforms (namely Skype) for your service, data analysis on the website (Google Analytics), organization of contests.
• Third parties, such as partners’ providers, payment means and other services’ providers
• Providers of identification services, prevention and suppression services of activities related to money laundering from illegal activities, terrorism financing and fraud suppression.

We also communicate data that is required for the purposes of processing in the following categories of recipients:

• Third parties which provide services to us, such as credit institutions, fiscal and legal counsellors, other services providers.
• National or international regulatory, fiscal or other authorities and public organizations and courts, when required by law, regulation or upon their request.
• Clients and/or partners, when required, in terms of communication, management of relations and implementation of transactions required.

How Do We Ensure That Our Partners Respect Your Personal Data?

Our partners have agreed and contractually bound in writing with the Company:

• to maintain confidentiality and bind their staff with the same obligations,
• not to communicate data to third parties without our written consent,
• to take all organizational and technical data security measures, protecting their logical and physical integrity, such as secure software and physical protection,
• to inform us about any incident concerning your personal data violation,
• to delete or return your data upon termination of our contract,
• to conform to the legal framework in terms of protection of your personal data and specifically to the General Data Protection Regulation (GDPR).

How Long Do We Maintain Your Data and When Do We Delete Them?

Our Company maintains your data for the entire duration of the contract in a physical and electronic file. Post-contractually, they are kept for a period set out by the law concerning the statute on limitations on claims (5 years); after that they are permanently deleted. Any fiscal information or data required for control purposes by supervising authorities, are kept for a period defined by the law at the time, and they can be kept for a longer period according to the decisions of the Ministry of Economy.

According to the legislation in effect in Greece, your documents and details pertaining to adhering to the Hellenic Gaming Commission’s requirements, are kept for a minimum duration of five (5) years, since the termination date of our relationship or ten (10) years since the execution of your transaction, unless a legal provision requires their maintenance for a longer period.

Confidentiality and Safety of Your Personal Data

Your personal data is subject to processing in a manner that guarantees their confidentiality. We never use them for purposes that are different from the ones we communicated to you, and we do not provide any information to third parties, individuals or companies

The only exemption is the case where your personal data is required to be communicated to public authorities, law enforcement authorities and courts, as well as the case where our company is legally liable to communicate it.

Your personal data is subject to processing in a manner that guarantees their security, protection from unauthorized or illegal processing, as well as against loss, destruction or wear, by using proper technical and organizational measures (“integrity and confidentiality”).

However, our Company is not responsible if the website is affected by third parties or in case of force majeure events that we cannot predict.

What Are Your Rights?

-You have the right to information.

During the data collection stage, as well as during any eventual processing stage of your personal data, you have the full capacity to exercise your legal rights as described below.

During the data collection stage, since the beginning of our contractual relationship, you are informed about this both through our website as well as through the Terms of Use, and you may use our website’s main page https://torotips.com about your right to receive information concerning the following details as described in detail below:

• our identity,
• the processing purposes,
• the data recipients,
• any third parties receiving this data,
• your rights.

- You have the right to access your data.

This means that you are entitled to receive information from us about how and what data is processed. You may request to receive information about the processing purposes, the type of data we keep, to whom they are provided, how long we keep them and if an automatic decision-making takes place.

- You have the right to correct personal data that is incorrect

This constitutes the right to correct personal data that is incorrect, in the case where you find out that there is a mistake in your data (e.g., name correction).

- You have the right to deletion

You may ask us to delete data concerning you, if it is no longer required for the aforementioned processing purposes.

- You have the right to data portability

You may request to receive data concerning you in a structured, widely used format that is readable by devices, as well as to communicate your data to another processing responsible.

- You have the right to limit processing.

You may ask us to limit the processing of your data for as long as the examination of your objections concerning processing is pending.

- You have the right to revoke/oppose the processing of your data.

You may oppose the processing of your data or revoke your consent, and we will cease processing them, unless there are imperative and legal reasons for processing which supersede your interests, rights and freedoms.

You may exercise these rights via letter or email. In specific, you may refer to the Data Protection Responsible, free of charge, by sending an email or letter to out address.

The Company will answer via email within one (1) month after the request is received and the applicant’s identification is verified. This deadline may be extended by two more months, if required, considering the request complexity or the number of requests. The Company will notify the data subject concerning the extension within one month after the request is received, as well as concerning the delay reasons.

These rights are exercised without any cost for the data subject. If the data subject’s requests are manifestly unfounded or excessive, mainly due to the fact that there are repeated, the Company may: a) impose a reasonable fee, considering the administrative fees for notification, announcement or execution of the requested action, or b) refuse to carry on with the request.

Furthermore, in case of exercising one or more of the said rights to correction, deletion and limitation of your data processing, the respective requests will also be communicated to any third-party recipients have received such personal data in view of processing purposes, unless this proves impossible or constitutes an excessive effort.

In the case where you deem that your personal data has been influenced in any way, you may contact our Company at: support@torotips.com. Our Company is always by your side, ready to support you in solving the issue in a prompt, just and efficient manner. In addition, if your issue cannot be resolved by the Company, you may contact the competent supervision authority where you can file a complaint. Competent Supervision Authority: Hellenic Data Protection Authority, :www.dpa.gr, Kifisias Avenue 1-3, P.C. 115 23, Athens, tel.: +30 210 6475600, e-mail: contact@dpa.gr.

Authority for Resolution of Disputes – Jurisdiction

For any dispute with the Company concerning this Privacy Policy, we are willing to hear from you and promptly resolve any issue, while respecting your rights.

For all actions or legal proceedings arising or relating to this Privacy Policy, its effectiveness, its implementation, fulfilment and violation or content, the Greek Courts, and in specific the local Courts of Athens, will be competent, the jurisdiction of which you irrevocably acknowledge.

Privacy Policy Amendments

The Company may update or amend this Privacy Policy at any time, so that it is up to date with eventual changes to the website’s functions, the services it provides and the provisions of the law. The amendments will be uploaded to this webpage.