Privacy Policy

1. Purpose

For the purposes of this Privacy Notice, the data controller Digify International Limited, a company with registered address Unit 41/42, Level 4, Pendergardens Business Centre, Triq Sant’ Andrija, San Giljan, STJ 9023, Malta (the ‘Company’ or ‘we’). The data controller is committed to protecting and respecting your privacy (“We”, “Us”, “Our”).

This Privacy Notice (“Notice”) describes how We collect, share and use any information that, alone or in combination with other information, relates to you (“Personal Data”) when you (“you” and “your”) use the website betanofuturestars.bg (“Website”). The services on this website are offered by Us using Our software applications available for use on or through computers and mobile devices. We take compliance with privacy obligations seriously. This is why we have developed this Notice, which describes the standards that we apply to protect Personal Data. The current Notice sets out how we ensure that processing of Personal Data complies with applicable data protection laws.

2. How we protect your privacy

The processing of your personal data will be governed by the following principles, as per the applicable law:

Principle of Lawfulness, Fairness and Transparency: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law. We will process Personal Data only on lawful grounds;
Principle of purpose limitation: We will process Personal Data for specified and legitimate purposes and will not process it in a manner that is incompatible with those purposes, unless permitted by applicable data protection laws;
Principle of Data Minimization: Personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
Principle of Data Accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. a change of address);
Principle of Storage Limitation: We keep your Personal Data in a form that allows us to identify you for as long as necessary to achieve the purposes for which we are processing your data and do not store your data for longer, unless we comply with applicable laws.
Principle of Data Security: We use appropriate technical and organizational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing.

3. Types and usage of information We collect

Purposes of processing your data	Personal data involved	Possible consequences of failure to provide the personal data	Legal basis for processing your data
Application & Eligibility	Name, surname, age, gender, city of residence, contact details (phone, email), education, sports profile, motivation text, educational background, sport experience	Application cannot be accepted or evaluated; you cannot be considered for selection.	Performance of a contract (pre-contractual steps: processing your application)
Program Delivery	Identification and contact details; Program-related preferences; engagement data; attendance records, educational background, sport experience	You may not be able to participate in sessions, receive mentorship, or obtain a certificate	Performance of a contract (fulfilling Program participation)
Communication	Contact details (phone, email), name	We may not be able to inform you about selection, Program activities, or changes.	Legitimate interest (effective communication and Program administration)
Compliance & Integrity	Identification and contact details, application data, complaint correspondence	We may not be able to investigate issues, enforce rules, or protect Program integrity	Legitimate interest (Program integrity, complaint handling, fraud prevention)
Improvement & Reporting	Attendance, engagement, non-identifiable feedback	No impact on your participation	Legitimate interest (program evaluation and reporting)

4. Disclosure of Personal Data

4.1 We will not transfer, disclose, or lease your personal data to any third party/entity in ways other than those described in this Privacy Notice. We will share your data only with the following recipients:

Kaizen Digital Services Single Partner SA Software Application Promotion and Support Services a Greek company of the Kaizen Gaming Group, based at Nerantziotissis 111, Marousi, 15124, which is not authorized to process your information except where necessary to provide services on our behalf or comply with legal requirements, and it does so only according to our instructions as data processor.

We also reserve the right to disclose your personal data to third parties in the event of the sale or purchase of any business, asset, or share, in which case we may disclose your personal data to the prospective seller or buyer of the business, asset, or share. We may disclose or share your personal data if we are required to do so in order to comply with any legal or regulatory obligation, to enforce or apply our terms and conditions, or to protect our rights, property, or safety, as well as those of our customers or others.

4.2 Finally, we reserve the right to disclose certain personal information to third-party/independent service providers, agents, or independent contractors who assist us in carrying out the Program and related administrative tasks (including, but not limited to, processing and fulfilling our obligations, data maintenance and analysis). We ensure that these third-party/independent service providers will not use your personal data for any purpose other than providing the services for which they are contractually obligated. We also establish contracts with these third parties requiring them to comply with data protection standards mandated by law and to use the data solely for the purposes for which it was shared. Third parties provide public details regarding how they process data via their websites or other appropriate means.

4.3 We will not disclose your personal data to third parties outside the European Union, in countries where there is no adequate data protection regime. However, in the event such a data transfer occurs, we will take all reasonable measures to ensure that your data is treated with the same level of security as within the EU/EEA and in accordance with this Privacy Statement and applicable law. Additionally, we will update this Privacy Statement to reflect any cross-border data transfer and the related safeguards for your privacy.

4.4 In cases where our website provides links to other websites created and maintained by other public and/or private sector organizations, we provide these links solely for your information and convenience. We are not responsible for the privacy practices of websites not directly involved in the Program administration.

5. How Long We Retain Your Data

It is our policy to retain your personal data only for as long as necessary for the purpose for which it was originally collected, in accordance with the principles of Data Minimization and Storage Limitation. According to our personal data retention schedule, your data will be kept for a period of three (3) years from the date of collection. In addition, we align data retention with any variations that may arise from the exercise of your personal data protection rights.

6. Profiling

We do not perform automated decision-making or profiling when processing the personal data you provide through this website (betanofuturestars.bg).

7. Your Personal Data Protection Rights

At any point during the retention or processing of your data, you retain the following rights and may submit related requests via email to dpo-office@kaizengaming.com:

Right of access – you have the right to access the personal data we hold about you.
Right of rectification – you have the right to correct any inaccurate or incomplete data we hold about you.
Right to erasure – you can request that the data we hold about you be deleted from our records, and we are obliged to fulfill your request in certain circumstances.
Right to restrict processing – you have the right to request that processing of your personal data be restricted, and we are obliged to comply when specific conditions apply.
Right to data portability – you have the right to request that the data we hold about you be transferred to another organization.
Right to object – you have the right to object to the processing of personal data concerning you under certain conditions.
Right to withdraw consent – in cases where processing activities are based on your consent, you have the right to withdraw your consent at any time by sending an email to dpo-office@betano.bg, without affecting the lawfulness of processing carried out prior to withdrawal based on previous consent.

We will assess your request and reply to you regarding the progress and outcome of the request (granting of request, partial granting of request, rejection of request), as soon as possible and in any case in no longer than 30 calendar days. In the event we refuse your request regarding the aforementioned Data Privacy Rights, we will provide you with a reason as to why. You have the right to lodge a complaint directly with the Competent Data Protection Authority (Commission for Personal Data Protection – CPDP, contact details available here) and with the DPO (via the means described in paragraph 11 of the current Privacy Notice).

We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical efforts or have disproportionate technical consequences, risk the privacy of others, or would be extremely impractical.

8. Security

Protecting your data is of utmost importance for Us and in this regard, we constantly strive to provide all possible means of assuring your personal data’s safekeeping, the restriction of unauthorized access and / or potential alterations. Such means include information security measures consistent with current best practices to protect our customers’ privacy. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction.

9. Cookies

We use Cookies to collect information about your browsing actions and patterns to improve your experience, always following applicable data protection legislation. For more details, please refer to our Cookie Notice. You have the right to manage your cookie preferences at any time by accessing your preferences, and updating your cookie consent.

10. Changes to our Privacy Notice

We strive to constantly review and update our Privacy Notice in order to address potential legislative and regulatory requirements, while providing optimal protection of your privacy. Any updates will be communicated to you via the current web page.

11. Contact us

If at any time you believe that we have not adhered to the provisions set out within this Privacy Notice or for any other Data protection related matter, please contact us through email at dpo-office@betano.bg. Kindly be informed that our Data Protection Officer is Flavia Lamagna.

Governing law

This Privacy Notice is made pursuant to the applicable General Data Protection Regulation (GDPR) as well as the Protection of Personal Data Act 2002 (‘the Act’) and the guidelines issued by the Commission for Personal Data Protection (‘CPDP’). Where any provision of this Privacy Notice is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.

Glossary

„Personal Data“: This means any information relating to an identified or identifiable natural person. An identifiable natural person can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

„Processing“: This means any operation or set of operations that is performed on personal data or sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination; or by otherwise making available alignment or combination, restriction, erasure, or destruction.

„Controller“: This means the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.

„Processor“: This means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

„Data Subject“: This means an individual who is the subject of the relevant personal data.

„Data Breach“: This means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

„Special Categories of Personal Data“: This means any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.