PRIVACY POLICY

1. INTRODUCTION

The protection of privacy is extremely important for Capecod Gaming.
Our objective is to allow users to consult our website without fear of any security-related issues. In general, our website can be used without the need to disclose personal data. The privacy notice included below provides an overview of the procedures through which Capecod Gaming ensures - including for the companies that it controls - that users’ privacy is protected, as well as the type of data gathered and the main purpose for doing so.
Specific privacy notices will be provided when users register on the website (where applicable) or sign up for the newsletter service (where available).
Capecod Gaming, with registered office in Castel Bolognese - Ravenna (Italy), Via Maestri del Lavoro, 97, is the data controller with regard to users’ personal data.

2. IP ADDRESS

During normal operation, the IT systems and software processes in place for running the website gather some personal data, the transmission of which is implicit in the use of internet communication protocols. This information is not gathered in order to be associated with identified parties, but by its very nature it could, through processing and association with data held by third parties, be used to identify users. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the addresses of the requested resources in URI (Uniform Resource Identifier) notation, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the data response from the server (success, error, etc.) and other parameters relating to your operating system and IT environment. The IP address is transmitted every time a request is submitted to the server, in order to allow the server to correctly address the response. Upon connection, users are assigned an IP address by the Internet Service Provider (ISP), which is able to trace the specific client to which a certain IP address has been assigned at any time. Provided that the IP address has been stored, it is possible, in theory, to identify the owner of the internet connection through the ISP. For this reason, neither our company nor its suppliers of statistical services store user IP addresses permanently, rather they are stored only on a temporary basis in order to identify the session, and for security reasons (to prevent cyber attacks, for example). Subsequently, the IP address is deleted immediately, and any data gathered is thus anonymised. Therefore, it will no longer be possible to identify the user, not even through the Internet Service Provider.
Without prejudice to what is provided for in paragraph 3 below, in relation to the use of cookies on the website, the navigation data is used for the sole purpose of obtaining anonymous statistical information on the use of the website and to check that it is functioning correctly, and is deleted immediately after processing. The data could be used to establish liability in the event that any computer crimes are carried out against the website. The navigation data is processed for the purpose of our legitimate interest in ensuring the security of the website, checking that it is functioning correctly and obtaining statistics in relation to its use (Article 6( 1)(f) of the Regulation).

3. COOKIES

Cookies are used on this website. For more information about cookies and to manage your preferences with regard to them, please consult our Cookies Policy.

4. PRIVACY 

The protection of user privacy and the security of users’ personal data are both of fundamental importance for our company.

The use of data by Capecod Gaming takes place in compliance with the provisions of the General Data Protection Regulation (GDPR) issued by the European Union, as well as the other relevant legislation. Pursuant to Article 5 of the GDPR, all employees are obliged to process users’ personal data in a lawful, correct and transparent manner in relation to the data subject, and in compliance with confidentiality obligations.

4.1 Processing activities

In accordance with the provisions of Article 30 of the GDPR, Capecod Gaming has a so-called “record of processing activities”, which documents the use of the data by Greentube GmbH Group, Digital Gaming and Entertainment division of NOVOMATIC, as well as the related processing activities. This record must be updated constantly in accordance with the provisions on data protection set out in Article 30 of the GDPR.

4.2 Special categories of personal data

Capecod Gaming does not process any special categories of personal data on its own website, as defined in Article 9(1) of the GDPR.

4.3 Guaranteed Data Protection

In principle, our company will not process users’ personal data without the prior consent of the user him/herself and, in any case, the processing will be carried out within the limits of the existing contractual relationship with the user, for the agreed purposes.
If we are contacted using our addresses provided on the website or through the contact form on our website, we will gather and store the user’s data for the sole purpose of following up their requests (Article 6( 1)(b) of the Regulation). Users are free not to provide such data. However, if it is not provided, it may be impossible to obtain what is being requested.
MARKETING: subject to the user’s optional consent (Article 130 of Legislative Decree 130/2003; Article 6( 1)(a) of the Regulation), which can be given by selecting the relevant check-box at the bottom of the contact form, we will transmit the user’s personal data for marketing purposes (direct sales, sending advertising material, market research, commercial communications, surveying the level of customer satisfaction) and for sending advertising information, offers and promotions relating to our products and services by post, email, SMS/MMS, WhatsApp and telephone with an operator. If consent for the processing of personal data for marketing purposes is not given, the ability to navigate the website and obtain what is being requested will not be affected in any way. In any case, users may withdraw their consent to the processing of their personal data for marketing purposes freely and without charge at any time, including on a selective basis (e.g. communicating their desire not to receive any more communications via email, but only to receive communications via SMS/MMS or other means), by submitting request in this regard in accordance with the procedures specified in paragraph 5.10 below. In relation to promotional communications sent via email, users may withdraw their consent to the processing of their own email address for marketing purposes by clicking on the opt-out link included in each promotional email.

4.4 Transferring and Surrendering Data

The user’s personal data will only be transferred to third parties with the user’s prior consent, with the exception of obligatory transfers of data pursuant to law, for example if we have to disclose data on our users at the request of a public authority, where provided for by law.
Our employees and workers responsible for maintaining and managing the website may have access to the personal data. Moreover, our third-party suppliers which, acting as data processors, provide us with IT and consultancy services, may also have access to the personal data, without prejudice to the fact that those entities must provide sufficient guarantees that they will implement adequate technical and organisational measures to ensure that the personal data is processed in accordance with the GDPR and that the data subject’s rights are protected.

4.5 Data Security

The technologies used by Capecod Gaming for processing users’ personal data (hardware, software, networks, infrastructure) are state of the art with regard to security. Appropriate technical and organisational measures have been adopted for those procedures, in order to ensure compliance with GDPR requirements.

5. INFORMATION TO BE PROVIDED

In this section, we provide a notice regarding the personal data processed on the website, the rights that user have and the requests that they may make with regard to data protection.

5.1. Categories of personal data

Personal data provided voluntarily through completing the “Contact Us” form is processed on the website.
Capecod Gaming will process the user’s personal data exclusively for the purposes for which said data has been voluntarily entered during the user’s exercise of his/her right of informational self-determination.
The optional, explicit and voluntary sending of the user’s personal data to the postal and email addresses or fax numbers published on the website, or the communication of the user’s personal data during calls to our telephone number initiated by the user, entails the subsequent acquisition of such data, as necessary in order to respond to requests sent by the user in relation to the website (Article 6( 1)(b) of the Regulation).
Users are free not to provide such data. However, if it is not provided, it may be impossible to obtain what is being requested.
We will keep the personal data that users have provided when making requests for a maximum period of 12 months.

5.2. Right of access to personal data

According to the provisions of the GDPR, the data subject has the right to receive information, at any time, in relation to the data processed within Capecod Gaming, the origin of that data, and any parties to which the data could be disclosed, as well as the purposes of the processing. The information will be received, following a written request from the user, by the relevant office at Capecod Gaming, the details of which are stated in paragraph 5.10.
Once all the legal requirements for processing the user’s request for access to his/her personal data have been met, we will process the request, giving the user access to the personal data within a period of 1 month.

5.3. Right to erasure

According to the provisions of the GDPR, the data subject has the right to obtain the erasure of his/her personal data processed by Capecod Gaming at any time, provided that the request for erasure is not in contradiction with any record-keeping requirements imposed by the law or other legal obligations. Once all the requirements necessary for accepting the request for erasure sent by the user have been met, we will process the request and erase the data within a period of 1 month.

5.4. Right to object

According to the provisions of the GDPR, the data subject has the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her pursuant to point (e) or (f) of Article 6(1) of the Regulation, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

5.5. Right to restriction of processing

According to the provisions of the GDPR, the data subject has the right to obtain the restriction of the processing of his/her personal data where certain special conditions are met. Once all the legal requirements have been met, we will restrict the processing of the user’s personal data within a period of 1 month.

5.6. Categories of recipients

The transfer of personal data to recipients in third countries (outside of the European Union) or international organisations is not envisaged.
There is no automated decision-making process.

5.7. Right to data portability

The right to data portability is not provided for.

5.8. Revocation of consent

According to the provisions of the GDPR, the data subject has the right to withdraw his/her consent to the processing of his/her personal data at any time, without any obligation to provide reasons. In such cases, we will interrupt the processing of the personal data concerning the data subject and erase it, taking account of any record-keeping requirements established by the law, within a period of 1 (one) month.

5.9. Complaints to the Italian Data Protection Authority (Garante per la protezione dei dati personali)

According to the provisions of the GDPR and the Italian legislation on privacy and the protection of personal data, if the data subject believes that the processing of personal data concerning him/her breaches the GDPR or the Italian legislation on privacy and the protection of personal data, he/she has the right to submit a complaint to the Italian Data Protection Authority [Garante per la protezione dei dati personali] (www.garanteprivacy.it) or the competent authority of the EU Member State in which the data subject lives or works.

5.10. Further Information

Your trust is very important to us. If you have any further questions concerning the processing of personal data by Capecod Solutions Srl, or you wish to exercise your rights as a data subject, please contact Capecod Gaming in writing, by post at our registered office at Via Maestri del Lavoro n. 97 – 48014 Castel Bolognese - Ravenna (Italy), by email at the address privacy@capecod.it.
We inform you that we have appointed a Personal Data Protection Officer, who can be contacted by post at Capecod Gaming registered office at Via Maestri del Lavoro n. 97 - 48014 Castel Bolognese - Ravenna, by email at the address privacy@capecod.it.

COOKIE POLICY

The website “www.capecodgaming.com” uses cookies to allow you to visit it without any restriction. Indeed, they have the aim to improve the functioning of the website and web surfing.
The following policy will provide you information about the current types of cookies and cookies used by this website, specifying the way to change your computer’s personal settings.
Cookies are small text files, which are stored automatically from a browser into the visitor’s computer memory, based on user’s preferences. There are different types of cookies, which are characterised by different functions and durations:

- First and third party cookies
First-party cookies are created by the website that you are visiting. On the contrary, third-party cookies are made by domains from external websites and they are organised and stored by the owner of the third website. This website uses both first and third party cookies. The manager of this website does not check third-party cookies; it is necessary to refer to the policy of each third party’s website.
Privacy policy Google Analytics: http://www.google.com/intl/it/policies/privacy/
Privacy policy Addthis: http://www.addthis.com/privacy/privacy-policy
Privacy policy ScorecardResearch: https://www.scorecardresearch.com/privacy.aspx?newlanguage=7
- Session and persistent cookies
Session cookies (or temporary cookies) appoint to the computer of the users, who are connected to the website, a univocal number of identification, which is randomly created and they are erased when the browser is closed. On the contrary, persistent cookies allow keeping the information between an access to the website and another. In this way, the website can recognise if it is the first visit of the page or if the user has already visited it earlier. The duration of these cookies can change from few minutes to more years.
Technical, profiling and analysis cookies
Technical cookies are necessary to allow the correct running and navigation of the website. They are not used for further purposes and are usually installed directly by the owner of the web site. Without cookies, some operations could not be done or they would be more complicated and/or less safe. This website uses this type of cookies for which it is not necessary to request the user’s consent. Profiling Cookies are used to mark the user navigation and to create profiles according to his/her liking, habits, choises, etc. Due to these cookies, personalized advertisements can be transmitted to user’s devices. This website uses this type of cookies for which it is necessary to request the user’s consent. Analysis cookies can be either technical or profiling cookies. This website uses analytics profiling cookies for which it is necessary to request the user’s consent. Cookies do not allow the website manager to view files on users’ computer.

Following cookies use by this website, for which it is necessary to request the user’s consent:

COOKIE NAME FIRST OR THIRD PARTY DURATION PURPOSE OF USE LINK TO REFUSE CONSENT
__ga First party (Google property) 2 years This is an analysis cookie. https://tools.google.com/dlpage/gaoptout
_gid First party (Google property) 24 hours Used to distinguish users. https://tools.google.com/dlpage/gaoptout
ASP.NET_SessionId Third party (enhanced.it) Session Preserves the visitor's session state across page requests. https://www.enhanced.it/gdpr

Cookies control

Internet web browsers allow modifying cookies settings. Browsers are set up by default to accept cookies, but it is possible to block some or all of them. Each browser has different methods to disallow cookies. The total or partial disabling of technical cookie can threaten the use of certain functionality of websites, reserved to registered users. On the contrary, the usability of public contents is possible even disabling cookies altogether. The disability of third party cookies does not compromise by no means the web surfing.
Please, consult the following websites to disable cookie:

Microsoft Internet Explorer

Choose “Internet Options” from the drop down menu above at the right side. Then choose “Privacy” at pop up window and choose the Personal settings for cookies, or consult the following link:
http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Google Chrome

Choose “Settings” from the drop down menu above at the right side. Then choose “Show advanced settings…” and choose Personal settings for privacy, or consult the following link:
https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Mozilla Firefox

Choose “Settings” from the drop down menu above at the right side. Select “Privacy” in the pop up window and then choose Personal settings for cookies, or consult the following link:

http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies

Apple Safari

Choose “Personal Settings” from the drop down menu above at the right side. Then, select “Security” and choose Personal Settings for cookies, or consult the link:
https://www.apple.com/legal/privacy/it/cookies/

In case the user gives his/her consent to use cookies, the choice will be registered in a specific technical cookie.