TERMS OF USE  

The use of the present application for mobile devices is subject to the terms and conditions presented below. The present application shall be exclusively addressed to adults, whereas minors are prohibited from using its services. The visitor-user, by using the application, is deemed to have perused, comprehended and fully and unreservedly accepted all terms of use thereof. The following terms of use may be reviewed, amended, modified by OPAP S.A. and/or Hellenic Lotteries S.A. (hereinafter briefly and jointly called the “Company”) depending on the eventually applicable legislative framework, without prior notice. Therefore, the visitor-user shall periodically check the present terms, since the uninterrupted use of the application shall mean their full and unreserved acceptance. 

 

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 

The collection and processing of personal data of the application's users-visitors are carried out in accordance with the present terms of use, the privacy policy of the application, as well as the provisions in force of the applicable national and European legislation, particularly the General Data Protection Regulation 2016/679 (EU) and the national law 4624/2019. For more information relating to the processing of your data in the context of the installation and use of the application, please consult the Privacy Notice for OPAP Stores Application Users. 

 

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. 

If, for any reason, any of the aforesaid terms is ruled invalid, such invalidity shall in no case affect the validity of the rest terms of use, which shall remain in force. 

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. 

The user-visitor hereby consents to the submission of any dispute, relevant to or arising from the present terms of use that may occur between him/her and the Company, to the jurisdiction of the Courts of Athens. 
To contact the Company in case of queries relevant to or arising from the present terms of use, please send an e-mail to law@opap.gr

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. 

  

INFORMATION ON PERSONAL DATA PROTECTION OF “OPAPSTORE APP” APPLICATION

  1. Introduction

By the present notice, “OPAP S.A.” and “HELLENIC LOTTERIES S.A.”, having their registered address at 112, Athinon Ave., in Athens (hereinafter “the Company”), jointly acting as Personal Data Controllers as regards the mobile device application that is available under name opapstore app (hereinafter “opapstore app”), provide information regarding the users’ personal data that are collected when they use opapstore app. Such information concerns the nature of the personal data, as well as the means and the purpose of their collection, the third parties to which such data are notified, as well as your rights, in accordance with Regulation 2016/679 of the European Union (General Data Protection Regulation) and the applicable legislation on personal data protection (L. 4624/2019).

  1. Categories of personal data we process

In the framework of operation of opapstore app, we collect and further process the following personal data, generated upon its installation and use:

  • The user’s main registration details, such as mobile number, “wallet” identifier and other user's device unique identifiers (UUID, MSISDN).
  • E-mail address (optional).
  • Facebook login credentials (e-mail address, username/name), when there is the option of third-party login.
  • Geographical location data, using Bluetooth technology and optionally GPS.
  • Transactional details, such as bet placement, redeeming of winnings, “wallet” top-up amount, identifier of OPAP store in which the bet was placed.
  • Following 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 to already existing loyalty data upon user registration in opapstore app, user participations and points that may exist from OPAP’s application, “OPApp”, if the user registers themselves with the same mobile phone number.
  • Quick login data, such as extra PIN code and token in the framework of use of FaceID funtion (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.

  • Website’s visitor activities and behavioral data, such as location, time, login/ logout activity and data on the duration of staying logged-in, sessions, activities and clicks, screens having been viewed, average stay time, categorization based on 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 the prize winner.
  • Apart from the above, as regards PLAY players entering their data in PLAY Section of the application: full name, PLAY Individual Player Card (IPC) details, personal identification number (PIN) of the Individual Player Card, data and information concerning the User’s Electronic Player Account, or the credits received by PLAY Loyalty Program.
  • Especially for FreeWin winners, as eventually offered through the application, the attribution of winnings exceeding the amount of 1.000 EUR presupposes the provision of additional personal data and evidencing documents that allow the secure identification: Declaration of acceptance, mobile provider certification, copy of ID verification document (ID Card/Passport), document from which the TIN and the bank account number (IBAN) occurs. Additionally, regarding the Freewin winners of big gifts, which shall be attributed in the framework of an Event, according to the terms of Freewin, the Company shall also process the Event’s audiovisual material (videos, photos). 
  • Your identity verification details, (such as ID Card Number, mobile provider certification), which may be collected in the framework of OPAP's compliance with the obligations deriving from the legislation on the combating money laundering and terrorism financing, including fraud risk deterrence.
  • Other information that may contain personal data, such as: submission of complaints or remarks regarding the services provided, for which a file of recorded phone calls with our call center and a file of written communication (e-mails, chat sessions) is kept.
  • A Νickname and other information included in your profile (bets, points, statistics, members that you follow and members that follow you) in the context of the “PAME STOIXIMA Tipsters” service.

  1. Use of Bluetooth Technology

The use of opapstore 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 rendered possible through the combination of advanced Bluetooth and Beacons technology. More specifically, OPAP stores, wherein you may bet using opapstore 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 opapstore app you have installed in your device, allowing you to validly place a bet, as long as you are within that specific OPAP store.

  1. Why we collect Personal Data

In the context of opapstore app installation and use, we process the aforementioned data of yours, according to the following purposes and legal bases:

A. Contract

The processing of your data is necessary for the use of the main functions of the application. Specifically, it is necessary in order for us to be able to provide you with the Company’s services, to which you contractually agree via the application’s Terms of Use. Such contractually required functionalities include ticket submission and bet placement, as well as supporting functions, such as mobile number verification, user support, transactional security, and troubleshooting.

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 to you, we request and process the exact location of your device (GPS).

Finally, regarding the Freewin winners of big gifts, which shall be attributed in the framework of an Event, according to what is specified in the terms of Freewin, the attribution of gifts presupposes the acceptance of the Event's terms and their participation in it. The Event will be recorded on video and photos will be taken, which will be published. At the same time, some identifiers of the winners’ identity will be published and, in any case, their first name and/or the first letter of their last name, so that the completion of the said event be completely transparent to the general public, and there be no doubt regarding the awarding of prizes and the designation of winners. The conduct of a public event, as well as the publication of photos and videos that show the participants in social media, radio, and television media and in general through communication to the general public, shall be a condition of the Event, which the winners accept by accepting the terms of the event and their participation in it. The legal basis of the said processing is the implementation of the terms of the contract concluded between the winner and OPAP by accepting the terms of the game.

Participation in OPAP Loyalty Program:

If you wish, you may participate in OPAP Loyalty program (“OPAP Rewards”). In this case, you shall submit your contact details (mobile phone number and/or e-mail address) in order to register yourselves with the program via opapstore app. 

For the implementation of OPAP Loyalty program, OPAP S.A. and Hellenic Lotteries S.A. process, as joint Data Controllers, the following personal data, for the below relevant purposes:

  • The contact details you provide in order to receive communications regarding the prizes awarded in the context of OPAP Loyalty program. If you have chosen to participate in OPAP Loyalty program, but have not consented to receiving commercial communications (as described below), you shall be receiving simple communication (push notifications, text messages) concerning the winnings/rewards related to your loyalty activity, without further promotional nature (i.e. information on how many points you have accrued or notifications that you have won a prize due to the points you have accrued).
  • Data related to your gaming behavior, which are collected when depositing/ submitting participation slips, lottery tickets or when placing bets, so that your entry in draws and other operations/benefits of the reward program be registered. Data related to your participation in PLAY games, provided that you have entered your data in PLAY Section of the application.

The processing of the above data is contractually necessary based on the General Terms and Conditions of OPAP Loyalty Program, which are provided upon submission of your personal data and selection of the relevant boxes during the duration of your registration in OPAP Loyalty Program.

You are kindly asked to consider, that upon your registration in opapstore app and provided that you are already a member of the loyalty program in “OPApp” application of the Company, there will be a correlation of the data of the loyalty programs of your both accounts, based on the (same) mobile phone number that you have registered and, therefore, a transfer of all your loyalty data from “OPApp” application to opapstore app.

Participation in “PAME STOIXIMA Tipsters” community:

If you wish so, you may participate in “PAME STOIXIMA Tipsters” community (hereinafter: “community” or “service”). For your participation in the community, you shall be registered in the application, and then you shall create a profile by selecting a nickname.   

In the context of provision of the service, OPAP S.A. processes in its capacity as Data Controller the following personal data for the below relevant purposes:

•          The contact details you provide in order to be informed regarding the prizes awarded in the context of the service. If you have chosen to join the community, but have not consented to receiving commercial communications (as described below), you shall be receiving simple communication (push notifications, text messages) concerning the winnings/rewards related to your activity, without further promotional nature (i.e. information on how many points you have accrued or notifications that you have won a prize due to the points you have accrued).

•          Data related to your playing behavior, which are collected when depositing/ submitting participation slips or when placing bets for purposes of recording, accruing points and awarding prizes, based on the points you have accrued in the context of the service.

•          Publication of information in the application regarding your profile in the service, as well as your activity in it, such as your selected nickname, the number of members that follow you and the number of members that you follow, the favorite team that you may have declared, bets that you play through the application, or non-settled tickets that you scan in it, the recent history of settled tickets of land-based games in fixed-odds betting, your statistics for the current month as well as for the entire period of your presence in the community.

The processing of the above data is contractually necessary based on the General Terms and Conditions of “PAME STOIXIMA Tipsters” service, which terms are provided upon your registration in the community.

B. Legal obligation

Opapstore app offers users the option to bet on games (i.e. KINO, PAME STOIXIMA, VIRTUALS & POWERSPIN, EUROJACKPOT), which, according to the applicable legislation, are allowed to be conducted only within OPAP stores (agencies). Therefore, in order for the user to lawfully place a bet in the said games through their device, we are obliged to guarantee that the user is within an OPAP store at that specific moment. For that reason, it is obligatory that we collect data related to your location, while you place a bet through the application. The said location is confirmed with the use of Bluetooth technology, as analyzed above. Thus, we ask for permission to access your device’s Bluetooth and then, we process your location data as a necessary requirement for the lawful use of the opapstore app for betting purposes.

Additionally, OPAP, in the framework of incident investigation for the purposes of limiting the risks of money laundering, fraud and terrorism financing, according to the specific provisions of the relevant regulatory framework (L.4557/2018 and HGC decision 554/5/15.4.2021), may process additional personal data for the purpose of verifying your identity.

C. Legitimate interest

The Company has a legitimate interest in conducting internal analyses for business development purposes, product and services improvement, as well as for better understanding of the preferences and needs of opapstore app users. In particular, based on the use data of the application and on the transactional data (including the gaming behavior through the application and/or in PLAY stores regarding the users entering their details in PLAY Section of the application), the Company also creates, at the same time, a general profile concerning the various user categories of opapstore app, in an aggregate, statistical form.

Moreover, the Company has a legitimate interest to analyze, via automated procedures (without significant consequences for the users), data related to the accuracy, detection and restoration of errors, and efficiency of the position tracking system via Bluetooth, so that the relevant algorithm is constantly improved in terms of speed and validity.

For the purpose of deterrence of fraud and/or violation of the terms of use of the games and application OPAP Store App, the Company may process details that regard the use of the application, the technical characteristics of the used devices, as well as the playing behavior of the application’s user, in order to take the appropriate measures, according to what is specified in the terms of participation in the games and the Terms of Use of application OPAP Store App.

D. Consent

Following your previous, explicit consent, the Companies of OPAP Group (OPAP S.A, Hellenic Lotteries S.A., Horse Races S.A., TORA DIRECT S.A., TORA WALLET S.A.) will be sending you general commercial communications to the channels you will have selected (push notifications, e-mails, text messages, Viber/ Whatsapp, calls, social media, in which your profile will be detected following research based on your e-mail or your mobile phone number). 

Moreover, following your explicit consent, the Companies of OPAP Group (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 communications to the channels you will have selected (push notifications, e-mails, text messages, Viber/Whatsapp, calls, social media in which your profile will be identified based on your e-mail address or mobile phone number), on the exclusive games,  based on your transactional profile, your activity in the context of loyalty programs (“OPAP Rewards” program, PLAY Loyalty program), your ordinary use of the application, the information regarding the use of the application within the store which may be used in real time for the dispatch of personalized communication, your favorite games and OPAP stores and your participation in “PAME STOIXIMA Tipsters” community which is offered through the application. In the context of the said personalized commercial communication, a user profile is created for you, through the processing of all relevant activity in opapstore app and in PLAY games, with fully automated means, without such processing producing any legal or similarly significant result. The above communications shall be sent to the contact details you have registered in opapstore app and through the channels you have selected. You may withdraw your consent at any time by selecting different communication channels through the relevant fields in the "Communication Settings” menu or choose not to receive any communication from OPAP Group. Especially as regards the users activating PLAY Section, the consent regarding the communication on PLAY games is provided in OPAP stores.

Finally, the legal basis of user consent shall be in effect as regards the activation of exact location detection (i.e. GPS location) on your device, for the purpose of providing even better and faster verification that you are indeed within an OPAP retail store. The said additional level of location confirmation shall be optional and activated if you opt in for the relevant permission in your device.

Finally, according to the legislation provisions on electronic communications, following your consent, we shall be using software applications in your device, operating as trackers, in order to be able to better analyze the use of the application, to make use of the user data of the application for the purpose of personalized communication, to receive error reports and to send personalized push notifications to your device.

In case we need to process your personal data for another purpose, apart from the above, we will duly inform you in advance, and we will ask for your consent, if this is required.

  1. With whom we share your personal data

In the context of provision of all opapstore 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 the dispatching of updates and push notifications;
  • OPAP Group companies, provided that you have opted in to the receipt of relevant commercial communications;
  • other technology providers, i.e. for the support of location tracking, the conduct of aggregate use analyses and application debugging;
  • advertising agencies, and courier companies for the purpose of attributing and dispatching the prizes provided through the application to the winners;
  • as well as any other administrative, judicial or other public authority, or generally, any legal or natural person to which these data shall or may be disclosed, according to the applicable legislation or a judicial decision.

The above recipients include our partners outside the EU, mainly in the USA and the United Kingdom. More specifically, European Commission issued an adequacy decision for the United Kingdom and the United States (commercial organizations which participate in the EU-US data privacy framework). Therefore, some of your data shall be internationally transferred. For this reason, we have taken enhanced diligence measures, such as data minimization, anonymization and encryption methods, as well as the conclusion of strict standardized contractual clauses.

In the context of OPAP Loyalty program, OPAP S.A. and Hellenic Lotteries S.A. jointly operate as controllers of your personal data. In such context, both OPAP Group companies jointly determine the means and purposes of the relevant processing actions, having contractually set out their obligations. In case you want to address any question or request regarding the processing of your personal data in the context of OPAP Loyalty program, you are kindly asked to contact the e-mail address dpo@opap.gr.

  1. How long do we keep your personal data

All personal data of yours related to the use of the application in general and the recording of your preferences, shall be kept for as long as you keep the application installed on your device and in any case, they shall be deleted or fully anonymized following three (3) years of inactivity.

The above periods may be extended, by means of exception, to the degree deemed necessary for any defense of specific legal claims or other interests of ours.

  1. Your rights

In accordance with the applicable legislation and in the context of using opapstore 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 erase;
  • right to restrict the processing of your personal data, when expressly provided for by the legislation;
  • right to data portability in a structured, commonly used and machine-readable format (i.e. USB);
  • right to (directly) transfer the data to another data controller;
  • right to object to the processing of your personal data, which is founded on our legitimate interest; as well as
  • right to revoke any consent you may have given, at any time and at no cost.

You can exercise any of the aforementioned rights by submitting a written request to the Company. The relevant request/application shall be accompanied by supporting documents verifying your identity.


You can 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 the request or the overall number of requests we receive so requires.

  1. Disclaimer

Opapstore app may include links falling under the competence of third parties. In such case, the Company shall bear no responsibility regarding the terms of personal data protection that such websites implement.

The terms on personal data protection provided with the present Information may be updated at any given moment. In such a case, you will be notified accordingly via a notice or a dialogue box when using opapstore app.

  1. Our commitments

In order to safeguard the minimization, accuracy and completeness of your personal data, the Company undertakes the control of the data at regular intervals, so that it amends or erases safely the data that are no longer necessary for the operation of opapstore app and the provision of a comprehensive customer experience. The Company ensures that it has taken all necessary technical and organizational measures, in accordance with the applicable technological standards and laws and regulations in force, so as to safeguard that the processing of your personal data (by the Company or by any third parties on behalf of OPAP) is adequate and secured against any unauthorized or accidental access, disclosure, erasure, modification or other use or processing.

  1. Contact Details

For any request regarding 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 your Personal Data, we kindly ask you to address, the soonest possible, OPAP Group Data Protection Officer, by using the following contact details: Website: www.opap.gr/gdpr | Address: 112, Athinon Ave., 10442, Athens | Telephone: +30 210 5798888 | E-mail: dpo@opap.gr

 
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, 13, Kifissias Ave., P.C. 115 23, tel: +30 210 6475600). | tel: +30 210 6475600). Detailed instructions on how to submit a complaint are provided on the Authority's website.