Security & Privacy
PRIVACY POLICY OF UAB “NESĖ”
- Taking care of the security and privacy of your personal data, UAB “Nesė” has prepared this Privacy Policy, which sets out the data and information we collect about you, the principles we follow, the rights you have, as a personal data subject, as well as other important information related to the processing of personal data.
- This Privacy Policy sets out the full terms and conditions of privacy that apply to all persons who visit our website, social media accounts or otherwise interact with us.
- When you visit our website or social media pages, you may find links to other websites, such as those of our business partners or other websites that advertise our services. Please note that other websites and accounts have their own privacy policies and we are not responsible for the collection and processing of personal data on other platforms.
- We recommend that you read this Privacy Policy carefully, as each time you visit our website or social accounts held by the company you agree to the terms of this Privacy Policy.
- We note that when processing your personal data, we comply with the applicable legislation of the European Union and the Republic of Lithuania, the General Data Protection Regulation 2016/679 (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, this Privacy Policy and other legal requirements for the protection of personal data.
- UAB “Nesė” has the right to change and update this Privacy Policy at any time, so we recommend that you visit our website from time to time to read the most recent, current version of this Privacy Policy.
- “Personal Data” means any information or set of information from which we can directly or indirectly identify you (e.g. name, surname, email address, telephone number, address and other personal information).
- “Processing of personal data” means any action, whether or not automated, which involves operations or sequences of operations (collection, alteration, recording, organisation, storage, use, transmission, erasure, destruction, etc.) concerning personal data.
- “Personal data subject” means a natural person who is identified or identifiable from his or her personal data.
- “Services” means gambling and other gambling and gaming related services provided by UAB “Nesė”.
- “Profiling” means the use of personal data to assess certain characteristics relating to an individual, such as personal preferences, interests, behavioural aspects.
A personal data controller who lays down rules for processing personal data: UAB “Nesė” Company code: 140222629 Registered office address: Turgaus g. 1, LT-91247, Klaipėda E-mail: [email protected] Website: www.twinsbet.lt If you have any questions regarding the processing of personal data or the provisions of this Privacy Policy, you can contact us at the above-mentioned contacts.
- Personal data is collected for legitimate purposes, avoiding the collection of excessive personal data.
- The processing of personal data is carried out in accordance with the principle of lawfulness, in accordance with applicable legislation, including the GDPR and the Personal Data Protection Act.
- Personal data is processed in accordance with the principles of fairness and transparency. We make all information about the processing of personal data publicly and clearly available.
- Personal data is collected only for specified, clearly defined, legitimate purposes and is not processed in a manner incompatible with those purposes.
- If personal data are not clear or accurate, all necessary measures shall be taken to correct, supplement or delete such data.
- Personal data shall be collected and processed for no longer than is necessary and for no longer than is required by law. Personal data is kept for an average of ten (10) years.
- Personal data shall only be collected by those employees or authorities to whom this right has been granted.
- Personal data is collected in accordance with all confidentiality requirements.
- We use all technical and organisational measures to keep your personal data secure, including protection against unauthorised or unlawful processing of personal data, or against accidental loss or destruction of data.
- Enhanced identification is applied on persons who perform political duties or engage in public activities or who have contact with such persons.
- UAB “Nesė” collects and processes personal data on the following lawful grounds:
- On the basis of consent – when a person consents to the processing of personal data, the use of cookies, etc.
- Contractual – in the case of a contractual obligation under a contract between our company and a specific person;
- On the basis of legitimate interests – to improve the services we provide;
- For UAB “Nesė” to comply with a legal obligation under EU or national law or where the public interest requires.
For a more detailed description of the personal data, the purposes, terms and grounds for processing, please see the table below:
Purpose of processing personal data
Personal data processed
Time limits for processing personal data
Legal basis for processing personal data
Registration, provision of services, user identification
Registration details, including the following information: name, surname, username, password, email address, telephone number, information about the services ordered and changes to them
During the period during which the account is used and 10 years after the last login to your user account.
Article 6(1)(b) GDPR – for the purpose of entering into and carrying out a contract.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
Service quality assurance, service ordering and service renewal
Name, surname, username, password, email address, telephone number, information about the services you have ordered and used, changes to services, history of use of services, phone records and correspondence
During the period of a given issue and for 5 years after the end of the administration of the issue.
Article 6(1)(a) of the GDPR – with the data subject's consent to such processing.
Article 6(1)(b) GDPR – for the purpose of entering into and carrying out a contract.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
for the Service Provider's compliance with the relevant agreements and for internal administrative purposes
Name, surname, email address, telephone number
During the period of service and for 10 years after the end of the service.
Article 6(1)(b) GDPR – for the purpose of entering into and carrying out a contract.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
To ensure financial operations, manage accounting and information on debts
Name, surname, email address, phone number, workplace, job title, bank account number, credit institution, information on services used, payment information, debts, other financial information.
In accordance with the governing legislation.
In all other cases, for the duration of the contract and for 10 years after its expiry.
Article 6(1)(b) GDPR – for the purpose of entering into and carrying out a contract.
Article 6(1)(c) GDPR – for the controller to comply with a legal obligation.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
For the purposes of tracking and recording suspicious customers and transactions in accordance with the AML policy
Name, surname, email address, phone number, payment history and all monetary transactions.
In accordance with the governing legislation, the law on the prevention of money laundering and terrorist financing.
Article 6(1)(c) GDPR – for the controller to comply with a legal obligation.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
For the purpose of transferring data to individual data subjects for verification, payment and fraud prevention services.
Name, surname, email address, telephone number, information on services used and changes to services
In accordance with the governing legislation.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
For improving the quality of our website, social media accounts
IP address, data collected through cookies, browsers, date and time of login, operating system used, password, information collected through social accounts.
Data not included in cookie information is stored for a maximum of 1 year from the date of collection, unless the individual withdraws his or her consent.
The information and data collected by social networks is stored according to the rules set by the owner of the network.
Article 6(1)(a) of the GDPR – with the data subject's consent to such processing.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
For sending a newsletter, direct marketing objectives.
Name, surname, email address, phone number, newsletter subscription information.
The data and information shall be retained for 3 years from the date of consent or until the person withdraws consent.
Article 6(1)(a) of the GDPR – with the data subject's consent to such processing.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
For the purposes of resolving complaints, claims and any disputes
Name, surname, email address, phone number, work address, job title, content of the claim/complaint and information and documents related to the dispute.
The data will be kept for the duration of the dispute and for 10 years after the end of the dispute.
Article 6(1)(c) GDPR – for the controller to comply with a legal obligation.
Article 6(1)(f) of the GDPR – in the legitimate interests of the controller or a third party.
- We note that we process personal data obtained through the following methods:
- When the person presents them;
- When you use the website and/or visit our accounts, certain information (IP address, internet browser used, number of page visits, time spent on the system, information about the device used, language, country and other information) is collected automatically. This information is used to improve the functionality of our website and social accounts.
- After receiving personal data from other persons (third parties) in accordance with the procedure established by law.
- Personal data is processed for specific purposes only and is not collected for undefined purposes.
- We always reserve the right to request the rectification of erroneous or inaccurate personal data or the exercise of other rights of the data subject set out in this Privacy Policy.
- In all cases, personal data shall be collected only where necessary, avoiding the excessive collection of personal data.
- Personal data is collected, processed and stored in accordance with the provisions and requirements of applicable Personal Data Protection Laws.
- Personal data shall only be kept for as long as it is necessary in accordance with applicable laws.
- UAB “Nesė” reserves the right to transfer information and personal data to third parties in accordance with the law.
- Personal data may be transferred to the following data processors:
- State bodies and institutions – law enforcement agencies, bailiffs, notaries, tax administration services, financial crime investigators and other relevant organisations;
- For auditors, legal and financial advisers, accountants;
- Operational supervisors, persons managing gambling prevention services;
- Debt collection companies;
- Other persons connected with the provision of services by UAB “Nesė”, such as archiving and postal service providers;
- For IT professionals;
- To the State Enterprise “Centre of Registers” (VĮ Registrų centras), when the customer identifies himself during registration;
- Gambling operators or gambling app developers and businesses that provide game development, maintenance, supply services to UAB “Nesė”.
- Every data subject has the following rights:
- The right to be informed about the processing of your personal data – all information shall be provided in a concise, transparent, intelligible and easily accessible form, in writing or by any other means, including, where appropriate, in electronic form (Article 12 of GDPR).
- Right of access to collected and processed data – the data subject shall have the right to obtain confirmation from the controller as to whether personal data concerning him or her are being processed and, if such personal data are being processed, the right to have access to the personal data and to obtain a copy of the personal data processed. The data subject has the right to charge a reasonable fee for providing any copies (Article 15 GDPR).
- Right to rectification of data – The data subject has the right to require the controller to rectify inaccurate personal data concerning him or her (Article 16 GDPR).
- Right to delete personal data – The data subject has the right to require the controller to erase personal data concerning him or her (Article 17 GDPR).
- Right to object to processing of data – The data subject may object at any time to processing of personal data concerning him or her (Article 21 GDPR).
- Right to restrict processing of personal data – The data subject has the right to require the controller to restrict the processing of personal data at any time in cases where the processing is unlawful, the data subject contests the accuracy of the data, the controller does not need the personal data for the purposes of the processing, or the data subject has objected to the processing of the personal data (Article 18 of GDPR).
- The right to portability of personal data – the data subject has the right to receive personal data in a structured, plain, computer-readable format and has the right to request the transfer of those data to another controller (Article 20 GDPR).
- Right to withdraw consent – the data subject has the right to object at any time to processing of personal data concerning him or her (Article 21 GDPR).
- The right to opt out of automated individual decision-making, including profiling – The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. (Article 22 GDPR).
- Right to lodge a complaint with a supervisory authority – the data subject has the right to lodge a complaint if processing is carried out in breach of the law (Article 77 GDPR).
- It should be noted that the rights of data subjects are not absolute and may be limited by law.
- UAB “Nesė” collects personal data with respect for the privacy of all individuals. In the broadest sense, the following personal data is collected: name, address, date of birth, age, telephone number, e-mail address, bank account number, information about political duties performed, occupation of positions of public importance.
- Personal data and all related information are collected in the following cases:
- For the organisation of remote gambling;
- To issue financial documents, transfer and receive funds;
- To determine the identity of gamblers, their age, and their activities;
- For direct marketing purposes;
- In order to properly execute contracts
- To ensure proper implementation of state decisions;
- To ensure proper enforcement of the law;
- Statistical information is collected to improve the website and social accounts in order to provide content that is relevant to gamblers' interests.
- All personal data is stored and processed for no longer than it is necessary. The retention period is set by law and in relation to the type of personal data concerned.
- On average, personal data is stored for ten (10) years.
- In certain cases, other retention periods are set for personal data.
- In the case of state resolutions, the time limits for the retention of personal data are specified in those resolutions.
- Any person has the right to amend or update the personal data and information provided by him or her at any time.
- Everyone has the right to have access to the personal data processed.
- Everyone has the right to request the transfer of his or her personal data and all information about his or her activities.
- Everyone has the right to request the erasure and destruction of their personal data (right to be forgotten).
- Every person has the right to submit to UAB “Nesė” a complaint or claim regarding improper collection, processing or other issues related to violations of personal data processing.
- Upon receipt of a claim, UAB “Nese” undertakes to examine the claim within thirty (30) days from the date of receipt of the claim, unless additional documents or information are required to examine the claim. In such exceptional cases, a longer period of time shall be set for the examination of the claim.
- After the claim/complaint has been investigated, a decision on the validity of the claim/complaint shall be sent to the person concerned in writing, together with a written reply.
- All disputes arising between the parties shall be settled by mutual negotiation, and in the event of failure to resolve the dispute amicably or by any other out-of-court dispute resolution methods, the law of the Republic of Lithuania shall apply to the settlement of disputes and shall be settled in the courts of the Republic of Lithuania.
- UAB “Nesė” has the right to automatically collect and process your personal data and use profiling.
- Automated decision-making systems are designed to enable us to assess your personal preferences, interests, trustworthiness, behaviour and to provide you with personalised offers that are relevant to you – by analysing the data available, we automatically predict which offers would be relevant to your needs.
- You have the right to object to the automatic collection of your personal data. We will automatically review your request upon receipt.
- Automated decision systems are also used to prevent fraud, to identify and assess borrowing history, such profiling is based on the legitimate interests of UAB “Nesė”, the performance of a legal obligation, the performance of a contract or the consent of the Customer.
- The security and privacy of your personal data is very important to us and we process all personal data in accordance with the principle of confidentiality – we undertake not to disclose any of your personal information and not to disclose the data constituting confidential information to third parties, except as provided by law.
- Confidential information does not include data that are publicly available or data that cannot be considered confidential under the law.
Please find below information about our cookie policy. This section sets out what cookies are, how and when we use cookies. By visiting our website, you consent to the use of cookies and similar technologies for the purposes described in this policy.
What are cookies? Cookies are small pieces of data stored in text files that are saved on your computer or other devices (e.g., mobile device) when websites are loaded in your browser. They are widely used to “remember” you and your preferences. Types of cookies we use Essential Cookies Required for Accessing Our Services
These cookies are essential to ensure the proper functioning of our website and cannot be disabled within our systems. They are typically only activated in response to actions you take that equate to a service request, such as configuring your privacy settings, signing in, or completing forms. While you have the option to configure your browser to block or notify you about these cookies, please be aware that doing so may result in certain sections of the site becoming non-functional. Marketing Cookies
Our advertising partners may place these cookies on our website. They enable these companies to create a profile of your interests and display personalized advertisements on other websites. These cookies can distinguish your web browser and internet device. Opting out of these cookies may result in less personalized advertising. Below is a table detailing the specific data we collect and the purposes for which we use that data:
Cookie type
Data collected
Purpose
Strictly necessary cookies
User Session ID
Necessary for the functionality of the website, such as user login and account management
Performance cookies
Pages visited, time spent, errors detected
To improve website performance by understanding user interactions and identifying problems
Functional cookies
User settings (languages, region)
Personalise the user experience according to preferences
Advertising cookies
User interests, demographics, browsing history
To display relevant advertisements and limit the number of times an advertisement is shown
Third-party cookies
Interaction on social networks, multimedia preferences
To integrate third-party features like social media share buttons and video players.
Duration of cookies - Session cookies: these are temporary and expire when you close your web browser. - Persistent cookies: these are valid until they are deleted or expire. The duration varies, but usually ranges from a few days to several years. Managing and opting out of cookies: If you prefer to restrict, block or delete cookies from UAB “Nesė”, you can use your browser settings to do so. Your browser's “Help” feature should guide you. Please note that certain features of our website may not work as intended without cookies.
Sharing with Third Parties We may share the data collected through cookies with third parties for purposes such as analyzing usage of our site and in connection with advertising campaigns.
Policy Updates From time to time, we may make changes to this cookie policy. When we do, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.
