1. SCOPE OF APPLICATION - CONTENT
The present application for mobile devices aims at informing its visitors-users on OPAP S.A. Group games, as well as on their ability to participate in the eventual games of chance that are supported through the application. In particular, the visitors-users are given the option to be informed of previous KINO, TZOKER, LOTTO, EXTRA 5, SUPER 3, PROTO games’ draws, as well as of available versions of SCRATCH Instant Lottery, to electronically submit tickets for any of the aforementioned games of chance (including the games of PAME STOIXIMA), as well as to participate in KINO, PAME STOIXIMA and PAME STOIXIMA VIRTUALS games of chance, or in any game of chance that will be supported in the future through the application, provided that the application user is solely and exclusively found within an OPAP store (Type-A and Type-F agency). The winnings deriving form winning tickets of games of chance, in which the user participates through the application, may either be added to the digital wallet that the user holds in the application, or he/she may issue a barcode and receive the respective amount by showing it to an agency of OPAP S.A. Especially regarding KINO, the said application provides the user with the option to watch live all draws of the said game of chance. Regarding PAME STOIXIMA, the option is provided that the coupon and the PRE GAME & LIVE games program therein included be displayed, and that early bet closure (early cash-out) be conducted based on the relevant terms of the service. The application also gives users the option to be informed of the results and their successful or not participation by scanning the barcode of KINO, TZOKER, LOTTO, EXTRA 5, SUPER 3, PROTO, PAME STOIXIMA games’ tickets or the barcode of the instant SCRATCH ticket or of the lottery tickets “....”. Finally, smart notifications allow the ongoing information of the users pertaining to commercial communications and automated notifications regarding the update of games’ results and the completion of draws, inter alia, as well as the tracking of, the nearest to the user, OPAP S.A. network agency.
Any kind of indicative feature, data, software, audiovisual material, etc. (hereinafter called “content”), included in the present application for mobile devices of the Company (with the exception of eventual intellectual property rights of third parties), constitutes an original creation and, consequently, intellectual and industrial property of the Company, and is, therefore, protected, in accordance with all applicable provisions of national, European and international law in force.
Any act of reproduction, distribution, modification or use for commercial purposes, with or without financial consideration, without the Company’s prior written consent, is expressly and unreservedly prohibited. OPAP S.A. reserves all intellectual property rights of use and property titles relating to the content, all copies therefrom created, as well as the entirety of intellectual rights and other property rights relevant to it.
The Company reserves the right to modify the application content in any way, to add to or remove items and/or information from it, at its absolute discretion, as well as to cease the provision, for any reason and/or without any reason, of the application to the public, without any prior notice.
2. LOYALTY PROGRAM OPAP REWARDS
All slips submitted or all slips/tickets/lottery tickets that are being scanned through the application are provided with the option of participating in Loyalty Program “OPAP REWARDS” (hereinafter the “Program”).
A prior registration in the Program is required in order to participate therein. At the stage of registration in the Program, a Greek mobile phone number shall be obligatorily declared, and terms and conditions governing the Program shall be obligatorily accepted.
Information on the games of chance participating in the Program is available on the website https://www.opap.gr/opap-rewards.
The Program does not include the entry slips that relate to the games of chance offered in the Republic of Cyprus by OPAP Cyprus Ltd.
More information on the Program is available here: https://www.opap.gr/en/loyaltyterms
3. COST OF USE OF APPLICATION. This application is provided to visitors-users for free, without any charge imposed by the Company. The only cost burdening the user-visitor is the eventual mobile operator’s data charge, and concerns the details of the conclusion of a contract between the user and the respective provider.
4. LIMITATION OF LIABILITY - DISCLAIMER
The Company takes all appropriate and reasonably expected measures, in order for the data and information provided in this application to be complete, accurate and reliable. In any case, the Company does not guarantee the completeness and correctness thereof and shall not be held liable towards the visitors-users for any damage due to eventual incorrectness or inaccuracy thereof.
In particular, in relation to KINO game live draws, it is noted that OPAP S.A. has the necessary technical means and takes all suitable measures in order to ensure the operation of the application without errors. In case of delay in displaying the draw in the application and/or in case of inconsistency, for any reason, between the numbers drawn and those displayed in the application, OPAP S.A. shall not be held liable for any damage that may be caused by or is in any way related to the direct or indirect use of the application.
The use of the random number generator, as well as any creation of automated tickets via the application, do not constitute an encouragement on behalf of OPAP S.A. to choose these numbers or tickets to be used for OPAP S.A. products.
The purpose of the generation of random tickets is not the encouragement for their use for profitability purposes via OPAP S.A. products.
Moreover, the Company does not in any way guarantee that the pages, contents, services and options will be provided without interruption, errors, or that any errors, failures, malfunctions and/or delays will be promptly fixed. The Company reserves its right to temporarily or permanently interrupt the present application, in part or in full, with and/or without prior notice to the users, since its availability may be dependent upon the communication networks, the large amount of visitors and other causes. In any case, the Company shall not be held liable in case users cannot connect to the application.
The Company makes all possible efforts to protect the application from malware; however, it cannot guarantee that the application or any other related website or the servers via which the content is made available to visitors-users are free from viruses or any other harmful components. Therefore, the Company shall in no way be held liable for any loss, damage or other malfunctions that may occur in the users-visitors’ mobile software due to viruses and/or other harmful components.
The Company shall not be held liable for any direct or indirect damage to visitors-users, which may arise from the option to connect to another webpage through the use of links or the use of data and information contained in any such website.
The present disclaimer does not intend to limit the Company's liability, in a way contrary to the provisions of the national, European law and the respective provisions of international law.
5. PERSONAL DATA PROTECTION
6. APPLICABLE LAW - OTHER TERMS
The aforementioned terms and conditions of use of the application for mobiles devices, as well as any renewal, amendment or modification thereon are governed by the applicable, per case, national, European and international law.
Non-exercise by the Company of its rights arising from the present terms shall not constitute a waiver from these rights. The Company shall not be held liable for a breach of the present terms due to force majeure.
7. OBLIGATIONS OF USERS
The user of the present application is obliged to lawfully and duly use the application, and to adhere to the present terms and conditions. The user is obliged to refrain from any illegal, contrary to the transactional practices in place, unfair and abusive use of the content and services of the application.
PRIVACY NOTICE OF “OPAP STORE APP”
With the present notice, “OPAP S.A.” and “HELLENIC LOTTERIES S.A.”, having their registered seat at 112, Athinon Ave., in Athens (hereinafter “the Company”) and acting as Joint Data Controllers, in relation to the mobile application available under name OPAP Store (hereinafter “OPAP Store app”), provide information on the personal data collected from users while using the OPAP Store app. The information refers to the nature of personal data, the means and purposes of collection, any third parties with which these data are shared, as well as the rights that you have, according to Regulation 2016/679 of the European Union [General Data Protection Regulation], and the applicable personal data protection legislation (Law 4624/2019).
- Categories of Personal Data we Process
In the framework of operation of OPAP Store app, we collect and further process the following personal data, generated upon its installation and use:
- User’s main registration details, such as mobile number, “wallet” identifier and other user's device unique identifiers (UUID, MSISDN).
- E-mail (optional)
- Facebook log-in data (e-mail address, username/name), when 3rd party log-in is enabled.
- Geographical location data, using Bluetooth technology and optionally GPS.
- Transactional data, such as bet placement, redeeming of winnings, “wallet” top-up amount, identifier of OPAP store in which the bet was placed.
- Following a manual activation of the mobile device camera, data of scanned or submitted slips/tickets and “wallet” top-up coupons.
- User communication and push notifications preferences.
- User loyalty indication and correlation during user’s registration in the OPAP Store App with already existing loyalty data, user participations and points that may exist from OPAP’s “OPApp” application, if the user registers with the same mobile phone number.
- “Quick login” data, such as an extra PIN code and a token in the context of FaceID use (optional).
It is noted that the application does not store nor has any other way to have access to the biometric data of your face, but rather keeps a code confirming that the application has been properly unlocked. Your biometric data may only be found on your device.
- Page visit activity and behavioral data, such as location, time, log-in/log-out activity and connection duration data, sessions, actions and clicks, screen viewed, average time spent, categorization based on the transactional/behavioral profile.
- Technical data, such as IP address, device and software type, error reports, application performance statistics, application response time, device identifiers.
- Photos and audiovisual material in case you are a prize winner.
- In addition to the above, for PLAY players who enter their details in the PLAY Section of the application: full name, PLAY Individual Player Card details, Personal Identification Number (PIN) of the Individual Player Card, details and information regarding the User's Player's Electronic Account or the credits received from the PLAY Loyalty Program.
- Use of Bluetooth Technology
The use of OPAP Store app for betting purposes is only allowed within OPAP Stores, due to legislation restrictions. In order for your participation to be lawful, we shall each time confirm that you are within an OPAP store. This is feasible by combining advanced Bluetooth and Beacons technology. More specifically, OPAP stores wherein you may bet using the OPAP Store app, are equipped with special technology (Beacons) that receives and reads Bluetooth signals transmitted by electronic devices.
Therefore, if you have activated Bluetooth on your device, the Beacons placed within the OPAP store will recognize it. Further on, the Beacons will transmit an electronic signal to the OPAP Store app that you have installed in your device, allowing you to validly place a bet, since you are within a specific OPAP Store.
- Why we Collect Personal Data
In the context of OPAP Store app installation and use, we process the aforementioned data of yours, according to the following purposes and legal bases:
In order to proceed to winnings redeeming or “wallet” top-up, we ask for access to your device camera and we process the QR code that you scan, as well as the relevant data of the transaction that derive therefrom.
Furthermore, if you activate the functionality of spotting the closest OPAP store, in order for that service to be provided we request and process the exact location of your device (GPS).
Participation in OPAP Loyalty program:
If you wish, you may participate in the OPAP Loyalty program (“OPAP Rewards”). In this case you must submit your contact information (mobile phone number and/or e-mail address) in order to register to the program via the OPAP Store App.
For the implementation of the OPAP Loyalty program, OPAP S.A. and Hellenic Lotteries S.A. process as Joint Controllers the following personal data for these respective purposes:
- The contact information you provide in order to receive communications for the prizes awarded in the context of the OPAP Loyalty program. If you have chosen to join the OPAP Loyalty program, but have not consented to receiving commercial communications (as described below), you will be receiving simple communication (Push Notification, SMS) about the winnings/rewards associated with your loyalty activity, without further promotional character (e.g. information on how many points you have accrued or notifications that you won a prize due to the points you have accrued).
- Data related to your playing behavior, which are collected when depositing / submitting participation slips, lottery tickets or when placing bets, in order to record your participation in draws and other rewards program features/benefits.
- Data related to your participation in PLAY games, in case you have registered your details in the PLAY section of the app.
The processing of the above data is contractually necessary under the OPAP Loyalty Program General Terms and Conditions, which are provided upon your personal data submission and selection of the respective tick boxes during your registration at the OPAP Loyalty program.
Please note that during your registration with the OPAP Store App and provided that you were already a member of the loyalty program in the Company’s application “OPApp”, this will result in correlating the loyalty data of both your accounts, based on the (same) mobile phone number that you have declared, and therefore, the transfer of all of your loyalty data from the “OPApp” application to the OPAP Store application.
B. Legislative Obligation
OPAP Store app offers users the option to bet on games (e.g., KINO, PAME STOIXIMA), which, according to the applicable legislation, are allowed to be conducted only inside OPAP stores (agencies). Therefore, in order for a user to legally place a bet on these particular games via their device, we are obliged to ensure that the user is located inside an OPAP store at that specific moment. For this reason, it is mandatory that we collect data on your location while placing a bet via the application. The said location is confirmed with the use of Bluetooth technology, as previously explained. Therefore, we request permission for access to your device’s Bluetooth and we further process your location data as a necessary requirement for the lawful use of the OPAP Store app for betting purposes.
C. Legitimate Interest
The Company has a legitimate interest to conduct internal analyses for business development purposes, product and services improvement, as well as for better understanding of the preferences and needs of the OPAP Store app users. More specifically, based on the use and transactional data (including playing behavior through the app and/or in PLAY stores for users who enter their details in the PLAY section of the app), the Company also creates, at the same time, a general profile as regards different OPAP Store app user categories, in an aggregate, statistical format.
Moreover, the Company has a legitimate interest to analyze, via automated means (without significant consequences for the users), data relevant to the accuracy, debugging and efficiency of the position tracking system via Bluetooth, so that the relevant algorithm is constantly improved in terms of speed and validity.
Following your prior explicit consent, the OPAP Group companies (OPAP S.A., Hellenic Lotteries S.A., Horse Races S.A., TORA DIRECT S.A., TORA WALLET S.A.) will be sending you generic commercial communication, to the channels you have selected (Push Notification, e-mail, SMS, Viber/Whatsapp, call, social media in which your profile is identified on the basis of your email address or mobile phone number).
Furthermore, following your explicit consent, the OPAP Group companies (OPAP S.A., Hellenic Lotteries S.A., Horse Races S.A., TORA DIRECT S.A., TORA WALLET S.A.) will be sending you personalized commercial communication to the channels you have selected (Push Notification, e-mail, SMS, Viber/Whatsapp, call, social media in which your profile is identified on the basis of your email address or mobile phone number), on the exclusive games, as well as other non-gaming activities and services of the said companies, based on your transactional profile, your loyalty-based activity (“OPAP Rewards” program, PLAY Loyalty program), your ordinary use of the application, your favorite games and OPAP stores. In the context of this personalized commercial communication, a user profile is created about you, through the processing of all such activity on the OPAP Store app and in the PLAY games, with fully automated means, without such processing producing any legal or similarly significant outcomes. The above communications will be sent to the contact details you have registered in the OPAP Store App and through the channels you have selected. You may withdraw this consent at any time and proceed with selecting different communication channels through the relevant fields in the "Communication Settings” menu or choose not to receive any communication from the OPAP Group. Especially for the users who activate the PLAY Section, the consent regarding the communication for PLAY games is provided in the PLAY stores.
Lastly, the lawful basis of user consent is applicable with respect to enabling concrete location services (i.e. GPS location) on your device, for the purpose of providing even better and faster verification that you are indeed inside an OPAP retail Store. Such an additional layer of location verification is optional and is activated if you enable the respective permission on your device.
Finally, in accordance with the provisions of the legislation on electronic communications, following your consent, we will be using software applications on your device that work as trackers in order to be able to better analyze the application use, use the application usage data for personalised communication purposes, to receive error reports and to be able to send personalized push notifications to your device.
In case we need to process your personal data for purposes other than the ones described above, we will notify you accordingly and in advance and will ask for your consent, if required.
- With whom we share your personal data
In the context of provision of all OPAP Store app functions, the recipients of your personal data are the following categories:
- the company having undertaken the development and maintenance of the application;
- service providers related to sending updates and push notifications;
- OPAP Group companies, provided that you allow the receipt of relevant commercial communications;
- other technology providers, e.g., for the support of location tracking, the conduct of aggregate analyses of use and of application debugging,
- as well as any other administrative, judicial or other public authority, or generally, any legal or natural person to which this data shall or may be disclosed, according to the applicable legislation or a judicial decision.
The aforementioned recipients include our partners, outside of the EU, especially in the US and the UK, even if the UK is considered an adequately safe country. Therefore, some of your data are internationally transferred. To this end, we have taken enhanced diligence measures, such as data minimization, anonymization and encryption methods, as well as the signing of strict standard contractual clauses.
In the context of the OPAP Loyalty program, OPAP S.A. and Hellenic Lotteries S.A. operate as joint data controllers of your data. In that respect, the two OPAP Group companies jointly determine the means and purposes of the respective processing operations, having contractually laid down their obligations. In case you want to address any questions or requests relating to the processing of your personal data in the context of the OPAP Loyalty program, please contact firstname.lastname@example.org .
- How long we keep your personal data
The personal data of yours related to the use of the application in general and the recording of your preferences, are kept for as long as you keep the application installed on your device and in any case, they are deleted or fully anonymized after three (3) years of inactivity.
The aforementioned time periods may by exception be extended, inasmuch as this is deemed necessary for the eventual defense of specific legal claims and other interests of ours.
- Your Rights
In accordance with applicable legislation and in the context of using OPAP Store app, you have and you can exercise the following rights:
- right to access your personal data, as well as the information related to their processing;
- right to correct inaccurate or incomplete personal data of yours;
- right to erasure;
- right to restrict the processing of your personal data, when explicitly provisioned by the legislation;
- right to data portability in a structured, commonly used and machine-readable format (e.g. USB);
- right to have your data (directly) transmitted to a different controller;
- right to object to the processing of your personal data, which is founded on our legitimate interest; as well as
- the right to withdraw any consent you may have given at any time and at no cost.
You may exercise any of the aforementioned rights by submitting a written request to the Company. The relevant request/ application shall include supporting documents verifying your identity.
You may expect a reply to such a request within one (1) month following its receipt by the Company. This period may be extended by two (2) additional months, if the complexity of your request or the overall number of requests received requires so.
OPAP Store app may contain links that fall under the responsibility of a third body. In such case, the Company shall not be held liable for the terms on protection of personal data, implemented by these websites.
The personal data protection terms provided under the present Information may be at any time updated. In such a case, you will be notified accordingly via a notice or a dialogue box when using OPAP Store app.
- Our Commitments
In order to ensure the minimization, the accuracy and the completeness of your personal data, the Company undertakes to periodically review the data, in order to amend them or safely erase the data that are no longer necessary for the purposes of operation of OPAP Store app and the provision of a comprehensive user experience. The Company ensures that it has taken all adequate technical and organizational measures, in accordance with the applicable technological standards and laws and regulations in force, so as to guarantee that the processing of your personal data (by the Company or by any third parties on behalf of the Company) is adequate and secured against any unauthorized or accidental access, disclosure, erasure, modification or other use or processing.
- Contact Details
For any request relevant to the processing of your data, as well as in case you ascertain that we have not observed the principles stipulated in the present Information on the Processing of Personal Data, we kindly ask you to address, the soonest possible, OPAP Group's Data Protection Officer, using the following contact details: Website: www.opap.gr/gdpr | Address: 112 Athinon Ave., 10442, Athens | Telephone: +30 210 5798888 | E-mail: email@example.com
In case you deem we did not sufficiently address your request and the protection of your personal data is affected in any way, you may submit a complaint via the special online portal to the Hellenic Data Protection Authority (Athens, 1-3, Kifissias Ave., P.C. 115 23, tel: +30 210 6475600).| Detailed instructions on the submission of complaints are provided on the Authority's webpage.