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Napoleon Social Privacy Notice

Version: 27/11/2023

This Privacy Notice is related to the software extension Napoleon Social only. Our general Privacy Policy is also applicable and can be found on our website.

Napoleon Social is operated by the companies mentioned in the “General Conditions, Art. 1 - Publishers of NAPOLEONGAMES” and is a gambling organizer, trading under the brand name Napoleon (hereinafter: “Napoleon”, “Operator”, “we” or “our”) and is part of the Superbet group of companies.

1. General information

Napoleon respects your right to privacy and is committed to protecting your personal data and using it correctly. With this notice, we want you to understand how we protect your privacy when we obtain personal data from you, how we use this information, which are your rights and how we protect your data

This Privacy Notice only applies to the processing of players' personal data for which Napoleon is a data controller, as described in the General Data Protection Regulation 2016/679/EU.

The NapoleonSocial App is a software extension, that is only available for registered Napoleon customers and can only be accessed through the main Napoleon user interface, being our websites and Mobile Apps. Before submitting any information within the NapoleonSocial App, please read this Privacy Notice carefully. We reserve the right to change and/or update this Privacy Notice at any time and at our discretion. You will be properly and in advance informed of these changes and/or updates, which we ask you to read carefully and make sure you understand and agree to.

2. What personal data do we collect about you?

"personal data" means any information about you that can be used to identify you directly or indirectly through the use of the NapoleonSocial platform, such as:

  • DisplayName editable by yourself;
  • UserID;
  • Information about the created account;
  • Profile picture published by yourself;
  • Short description about yourself, provided and editable by yourself;
  • Details about your account followers;
  • Information you share with other users that can identify you directly or indirectly. At the time of registration in NapoleonSocial, you have the option NOT to use personal information that could reveal your identity directly or indirectly. In this way, your identity can remain anonymous with regards to other users of the platform.

As explicitly stated in the Terms of Use of NapoleonSocial, you are directly responsible for the exposure of your personal data. It is important that you do NOT post/comment on NapoleonSocial information which may affect you!

We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you in advance and you have given us your explicit consent.

3. How do we collect your personal information?

We will process your personal data only with your knowledge, namely when you voluntarily choose to register on the NapoleonSocial platform and when you provide data during the use of the platform.

4. For what purpose do we use your personal data?

The purpose of processing your personal data is to provide an interactive social experience for Napoleon customers through the NapoleonSocial platform and its functionality.

The legal basis for processing your personal data is:

  • fulfilling contractual obligations to provide you with our services within the NapoleonSocial platform or to take measures at your request before entering into such a contract with you;
  • compliance with the various laws that govern our business activities;
  • the legitimate interests of Napoleon, unless these interests exceed your interests or fundamental rights and freedom (for example, to improve the service and experience offered on the platform, for the security of the platform and your personal data),

The data we collect about you will be used exclusively for the purpose for which you submitted it to us, and this purpose is clearly communicated to you at the time of registration, collection and through this Privacy Notice.

5. Who do we share your personal data with and why?

We will never share your personal data with any third party as stated in and accordance with our general Privacy Policy.

6. Where is your personal data stored?

Your personal data will be kept, processed and stored by us and our service providers in the territory of the European Union and in accordance with our general Privacy Policy.

7. How long do we keep your personal information?

We assure you that your personal data will be stored only for a strictly necessary period, in accordance with the purpose for which it is collected. For your information, we will retain your personal data:

  • For the period in which we have the obligation to comply with the laws that apply to us;
  • For the time necessary to provide you with the services and to fulfil our contractual obligations to you;
  • For a period of time provided by the applicable statute of limitations to be able to respond to any potential complaints and requests and to protect our rights and any legitimate interests;
  • For the time required to answer your questions, provide guidance and resolve issues related to the services offered;
  • until the moment you exercise your right to deletion;

Upon expiry of the above terms, your personal data will be deleted. If at any time you wish to stop using your personal data to provide you with services, please contact us as described in the Your Rights section.

If your request to delete personal data violate our legal or regulatory obligations, or the data related to the deletion request is necessary for the exercise or defense of our legal interests and rights, we may not be able to honour your request.

8. How do we keep your personal data secure?

Napoleon has implemented all necessary technical and organizational measures to protect the confidentiality and security of your personal data. More details can be found in our general Privacy Policy.

9. Your rights

Your rights according to the GDPR are:

  • the right to information and access to your personal data;
  • the right to rectify your data;
  • the right to be forgotten / the right for erasure;
  • the right to restrict processing;
  • the right to portability;
  • the right to object;
  • the right to object to automatic processing;

You can exercise your rights by sending an email to privacy[at]Napoleongames.be as described in our general Privacy Policy.

10. How to contact us

If you have a question about our privacy notice or a complaint about the way in which Napoleon processes your personal data, you can address this by:

  • sending an email to our Data Protection Officer via DPO[at]Napoleongames.be; or 
  • writing a letter addressed to the attention of NAPOLEONGAMES’ DPO, Korte Keppestraat 23/6, 9320 Aalst, Belgium. 

Alternatively, you also have a right to address your complaint to the Belgian Data Protection Authority.  Please visit the website of the Belgian Data Protection Authority for further information.