Digital Trust Management SL (EN ADELANTE 'la empresa'), con domicilio social en
Torre Europa
Paseo de la Castellana 95
Planta 16. 28046, Madrid ((España)). Spain, want to inform to the user of the website Lottosphoto.com and its different mobile applications (or apps) its policy regarding the treatment and protection of personal data of those persons who voluntarily (i) communicate and relate to 'the company' through the channels indicated on the aforementioned website or app and (ii) complete data collection forms or use any other service present on the website or app that involves the communication of your personal data to 'the company ', including but not limited to the registration and authentication process on the website or app and the participation of the registered user in the games of 'the company'..
'the company' is committed to maintaining the privacy of the personal data of the users of the gaming services available on the website or app, the payment of the prizes and the economic transactions carried out in accordance with the provisions of the protection regulations. of data, the rules of the game and that which complements and develops both.
'the company' informs the user of the website or app that this data protection policy contains all the aspects related to the processing of personal data that 'the company' carries out as responsible for it through the website or app. If the user - after reading this document - continues browsing and using the web services or the apps, he / she will be expressing his / her express acceptance of this data protection policy and the processing of personal data. Otherwise, the user must leave the website or remove the app from their device. Likewise, the user is informed that these conditions will be of subsidiary application to those others that on the same matter are established with special character and are communicated to the user without limitation through the registration forms and / or game contract, remaining the present policies as complementary to the previous ones in what is not contradicted.
The user is informed that any processing of personal data will fall within the scope of the current legislation in Spain regarding data protection, as well as by the legislation in force regarding gambling, constituted fundamentally by Law 13/2011 , of May 27, regulation of the game and its development regulations (among them, Royal Decree 1613/2011, of November 14, by which Law 13/2011, of May 27, is developed to regulate the game , regarding the technical requirements of the gaming activities, Royal Decree 1614/2011, of November 14, which develops Law 13/2011, of May 27, on the regulation of gambling, with regard to Licenses, authorizations and game records; Resolution of November 16, 2011, of the Directorate General for the Regulation of Gambling, approving the provision by which the technical specifications that technical gaming systems must comply with are developed object of licenses granted under Law 13/2011, of May 27, regulating gambling; Resolution of November 16, 2011, of the Directorate General for the Regulation of Gambling, by which, in accordance with the provisions of article 36 of Royal Decree 1614/2011, of November 14, by which Law 13 is developed / 2011, of May 27, of regulation of the game, with regard to licenses, authorizations and registers of the game, the test of responsible game and of prevention of addictive behaviors of the game is established).
For such purposes, personal information, without limitation, shall be understood as any information concerning identified or identifiable natural persons and, by user, any identified or identifiable individual who communicates their personal data to 'the company' through the channels of communication with 'the company' such as sms, apps, email, telephone, completing forms for data collection, registration and / or, in any case, use of any service present on the website or app that involves the communication of your personal data to 'the company' and / or any other form of data communication to the aforementioned entity.
2.MINORS OR INCAPABLESThe websites, apps and mobile of 'the company' are aimed at users over 18 years. Through the websites, apps and mobile phones of 'the company', no personal information of children under 18 is collected or required. It is therefore forbidden to register on the websites, apps and mobile phones of 'the company' to minors under 18 years of age.
3.IDENTIFICATION OF THE SOCIAL REASON OF THE RESPONSIBLE OF THE FILE'the company' informs the user of the website or app of the existence of various treatments and personal data files whose responsible is Digital Trust Management SL, with registered office in
Torre Europa
Paseo de la Castellana 95
Planta 16. 28046, Madrid ((España)). Spain, where the personal data that the user communicates to 'the company' is collected and stored through this website, app and the various communication channels indicated therein.
The user who merely accesses the website of 'the company' is not obliged to provide personal information for the use of the site or app, therefore, any communication of data for this purpose will be because the user has voluntarily decided on a navigation or use personalized services as well as carry out some game activity.
However, in case the user has an interest in accessing particular services conditioned by the previous registration, such as participating in online games and / or receiving information from 'the company', as well as contacting the company ', you must complete the personal data request forms or those other means for the user to join the conditions of use of the services and game contract that in each case are offered through the web or app. Notwithstanding the provisions of these conditions, in the above cases, the data processing conditions in each case established and communicated to the user by the company through the registration forms and / or game contract will be preferentially applied. in its case, conditions of other particular services, leaving the present policies as complementary and of subsidiary application of the previous ones in what does not contradict.
'the company' will not ask the user for specially protected data. However, in certain circumstances, and always in accordance with the applicable gambling regulations, 'the company' should consult the records of gambling access bans maintained by the competent authorities.
The user's personal information will only be used for limited purposes. The purpose of processing personal data will be in any case indicated in this policy as well as in the conditions and legal notices of the services and contents through which the information is communicated to 'the company'.
'the company' informs that it will process the personal data for the following purposes:
In accordance with the above, if the user is not satisfied with the treatment of their data by 'the company', they must refrain from communicating or sending their personal data to 'the company' through any means such as, without limitation, email, sms, registration and registration where appropriate in the services offered through the websites, apps and mobiles or filling in forms, making a navigation not registered by websites, apps and mobile.
In the framework of the provision of services and content offered through websites, apps and mobile phones, 'the company' may at any time request personal data from the user through forms or other means, in which case the intended in this Data Protection Policy.
5.IDENTIFICATION OF THE ADDRESSEES WITH RESPECT OF THOSE 'the company' HAS INTENDED TO CARRY OUT TRANSFERS OR DATA COMMUNICATIONS'the company' has foreseen the realization of assignments or data communications that by reason of article 11.2.c. of the Organic Law 15/1999, of December 13, of Protection of Personal Data must be made to meet its obligations with the Public Administrations in the cases that are required in accordance with the current Legislation on the matter of gambling as well as any another that is applicable and, where appropriate, also to other bodies such as State Security Forces and Bodies, Judges, Public Prosecutor's Office, Courts, Court of Accounts or Ombudsman.
Likewise, 'the company' informs the user that any other transfer of data that must be made will be brought to their knowledge when provided for or authorized by the applicable regulations on data protection, informing them in an express, precise and unambiguous way. the recipients of the information, the purpose for which the data will be used, and the nature of the data provided, or where appropriate, when applicable data protection regulations establish, previously unequivocal, specific and informed consent will be requested to user.
6.OTHER INFORMATION RECIPIENTS'the company' warns the user that this entity is only responsible and guarantees the confidentiality, security and treatment of data in accordance with this policy, with respect to personal data collected by the user through this website, not having no responsibility whatsoever with respect to the treatment and subsequent use of personal data that could be made by third party service providers of the information society that could access such data. 'the company' warns the user that this entity is only responsible and guarantees the confidentiality, security and treatment of data in accordance with this policy, with respect to personal data collected by the user through this website or app , not having any type of responsibility with respect to the treatments and later uses of the personal data that could be carried out by third party service providers of the information society that could access such data due to the provision of their services or exercise of their activity. By third party service providers of the information society shall be understood - without limitation - those natural or legal persons who provide the following services: (i) transmission by a communication network of data provided by the recipients of the service; (ii) access services to said network; (iii) data storage or hosting services; and (iv) the provision of content or information. Also, 'the company' is not responsible for data processing carried out by third parties who establish hyperlinks with 'the company' or those responsible who through hyperlinks 'the company' refers to the users of your site Web. os by reason of the provision of their services or exercise of their activity. By third party service providers of the information society will be understood, without limitation, those natural or legal persons who provide the following services: (i) Transmission by a communication network of data provided by the recipients of the service. (ii) Access services to said network. (iii) Data storage or hosting services. (iv) Provision of content or information. Also, 'the company' is not responsible for data processing carried out by third parties who establish hyperlinks with 'the company' or those responsible who through hyperlinks 'the company' refers to the users of your site Web.
7.DATA QUALITY'the company' warns the user that, except for the existence of a legally constituted representation, no user can use the identity of another person and communicate their personal data, so the user at all times must take into account that, if it communicates personal data through any means to 'the company', can only include personal data corresponding to their own identity and that are appropriate, relevant, current, accurate and true.
For such purposes, the user will be solely responsible for any damage, direct and / or indirect caused to third parties or 'the company' by the use of personal data of another person, or their own personal data when they are false, erroneous, not current, inadequate or irrelevant.
Similarly, the user who communicates to 'the company' the personal data of a third party must have the informed consent of the third party in accordance with this Data Protection Policy and will respond to 'the company' and the third party for this obligation, without company 'must carry out any additional action, and exonerating' the company 'from all liability.
8.EXERCISE OF THE RIGHTS OF OPPOSITION, ACCESS, RECTIFICATION AND CANCELLATION OF DATA, OR ANY OTHER RIGHTS'the company' informs the user of the possibility of exercising their rights recognized by law by written request addressed to Digital Trust Management SL, attention 'Data Protection', at the following address: Digital Trust Management SL, atención “Protección de Datos”, en la siguiente dirección:
Torre Europa
Paseo de la Castellana 95
Planta 16. 28046, Madrid ((España)). Spain, clearly indicating the petition or right exercised as well as your name, surname and mailing address, and attaching a copy of your ID or valid legal document proving your identity, in order to unequivocally identify it.
The exercise of this right is very personal, so that the interested party may exercise such rights personally by proving his identity; through a legal representative, in which case it will be necessary to prove that condition; and / or through a voluntary representative, expressly designated for the exercise of the right.
In the cases of representation, the identity of the represented party must be clearly evidenced, by means of the contribution of a copy of his National Identity Document or equivalent document, and the representation conferred by him.
9.USER RIGHTS REGARDING COMMERCIAL COMMUNICATIONSUsers who have expressly authorized 'the company' to send commercial communications by e-mail, SMS or other means of electronic communication equivalent are informed that the user has the right to object to the processing of their data for promotional purposes. for the reception of commercial communications, as well as the right to revoke at any time the consent given to the effect with the simple notification of its will to 'the company'.
To do this, the user can direct their opposition by sending an email to the address: info@lottosphoto.com with the subject 'BAJA COMUNICACIONES COMERCIALES'.
10.COOKIES AND BEACONSIn order to obtain information about the devices of storage and recovery of data in terminal equipment of the users of the websites, apps and mobile phones of 'the company' you can visit our Cookies Policy
11.PERSONAL DATA PUBLISHED IN THE WEB AND MOBILE SITES OF 'the company'Sometimes some people consent to the publication of personal data on the website or app of 'the company'. In relation to the personal data of those persons who have consented to the publication of their data that may be published on this website, the user is informed that said data is part of one or more data processing rights owned and responsibility of the company 'in which they have been incorporated with the prior informed consent of the interested parties and can not be freely treated and reproduced by third-party users of the website or app -not even when reference is made to the origin thereof- unless obtain the prior authorization and informed consent of the interested party. The personal data published on the website or app may consist, without limitation, in any numerical, alphabetical, graphic, photographic, acoustic or any other information concerning identified or identifiable natural persons, such as name, surname, address IP, postal and / or email address, photos, videos, and images of events held by 'the company'. Therefore, all personal data - including the images, videos, texts, data and any other information published on this website about identified and / or identifiable individuals - may only be used by the user who owns them. the purpose of participating in the services and content in the manner established in the policies of use of the website or app and these privacy policies, for private purposes and within the framework of current legislation, and without profit or commercial purposes of any nature, being expressly prohibited any other uses than those indicated, including the incorporation of the images or data to files or treatments and / or creation of databases of people and / or sending of advertising or cession to third parties, without the prior informed consent of the user, not being responsible 'the company' for the uses that third-party users of the website or app perform in contravention what is established in this clause.
12.KEEP OF PERSONAL DATAPersonal data will be actively processed by 'the company' while the hiring procedure, registration or subscription process is being managed and while the aforementioned relationship between the 'company' and the user is in force. After the previous period, the Personal Data will be kept blocked by 'the company' for an additional period of 6 years or, exceptionally, for a longer period if a period of prescription of possible contractual or regulatory responsibilities for 'the company' is applicable. higher than the aforementioned term.
13.UPDATING OF POLICIESOccasionally, 'the company' will update this data protection policy of the users of the website or app. Any modification of this policy will be published and warned on the website or app of 'the company' and in the policy itself taking into account the user that, the treatment of the data that had been communicated to 'the company' will be governed by the policies and conditions of the treatment of the data in force and published at the time you have provided your personal data to 'the company', without prejudice to the preferential application of the specific legal texts for the purpose, such as informative texts inserted in collection forms of data and / or conditions of particular services.
In any case it will be the responsibility of the user to periodically access the privacy policy of 'the company' published at all times in order to know the latest version in force.
14.SOCIAL GROUPSSocial networks are services provided by third-party providers that allow the user to participate in a virtual community with other users through which they can generate their own public profile where they can create and share content, information and personal data with other users of the network. In a social network users can create an account or profile for professional purposes or for personal purposes. The operation of the social network is regulated firstly, by the conditions established by the owner and / or provider of the network and secondly, when it comes to accounts or profiles for commercial purposes, by the terms and conditions established by the responsible for the profile or commercial account.
'the company' has profiles on some social networks such as, without limitation, Facebook and Twitter. The user can follow us and become a fan of 'the company' in the mentioned social networks and in the different social networks that we indicate through the websites, apps and mobile phones of 'the company'.
Our official sites and pages on social networks are aimed at people over 18 years old, so if the user wants to be part of our official sites and pages he must be over 18 years old and read carefully the conditions and policies published by 'the company' .
'the company' is responsible for the administration of the sites and the official pages on social networks as long as they are the original official sites and pages and therefore have been created by 'the company'.
If the user becomes a follower of the sites and the official pages of 'the company', their use and the processing of their personal data that is made through them will be regulated by the specific conditions provided and published in each site or official website . The fact of becoming a 'friend' or 'follower' of our official sites and pages in social networks implies that the user consents to the processing of their data as established in the policies and conditions that in each case regulate their use.
'the company' is not responsible for the sites and unofficial pages that other third parties can create on social networks. That's why the user is recommended to always activate the option to 'follow the company' through our websites, apps and mobiles.
The company is responsible for the file and the treatment that it carries out through its official websites and pages in social networks. If the user becomes a friend or follower of our sites and official pages on social networks, your personal data will be treated in order to properly administer the site or the official website, know their opinions and / or comments, as well as inform and make you a participant of the different contests, promotions and / or events that are carried out by 'the company' through the sites and the official pages in their social networks.
In any case the user is informed that 'the company' may remove from the sites and official pages on social networks any information that goes against the rules established in the particular conditions governing their sites and official pages, the general conditions of use established by the provider or owner of the social network as well as against the provisions of the law, morals, public order and / or any policies and manuals of the websites, apps and mobile phones of 'the company'.
In the same way, the owners or providers of social networks may eliminate those contents that, either officially or through a complaint from another user, go against the rules or operating rules imposed by the provider of each of the networks.
To stop following the site or the official page of 'the company' in any of the official sites or pages in social networks, the user must follow the steps indicated in the conditions of operation and use of each network provider without 'the company' can intervene in this process. However, 'the company' reserves the right to create, edit, modify and / or delete sites and / or official pages without the need to inform the user in advance.
To make any inquiry regarding the data processing that is carried out by followers on the sites or the official pages of 'the company' on social networks, the user can contact 'the company' at the address provided. It shows below: info@lottosphoto.com.
'the company' is the owner of several mobile applications that the user can download on their smartphone or tablet. However, in principle mobile applications do not collect personal data of users or treat this type of information. In case they did, the user must previously read the privacy policy of each mobile application in order to accept or not the processing of personal data indicated therein. By default, the installation and use of the mobile application will mean that the user agrees with the privacy policy.
Also, 'the company' informs that some of its applications may contain utilities related to the user's geolocation.
This geolocation can be carried out through the applications if the user has the geolocation function activated on their smartphone or mobile device in which case, it will be understood that the user authorizes such geolocation with the application of 'the company' if to use the application of 'the company' does not disable this function on your device. However, when the geolocation is activated, the user can withdraw their consent at any time and without having to abandon the application.
In addition, 'the company' wishes to send the user notifications regarding products and services of games and promotions of 'the company' through the app. For this, when downloading the app you will be asked for your consent to send these notifications. If you allow the reception of notifications, the user consents to 'the company' to treat the UUID (unique universal identifier) ??of your device for sending notifications in the terms provided in this Data Protection Policy. In any case, the user can unsubscribe at any time and stop receiving notifications without having to leave the app, or sign up, all through the settings of the device used or through the app itself in the section of 'Settings'.
16. RECOMMENDATIONS TO USERSThe user is solely responsible for the adoption of preventive measures that safeguard the storage and storage in his terminal of files and other content that may be affected during the loading, installation, visualization and use of the mobile services application, as well as the custody and secrecy of any types of passwords and passwords of access and use of the application, as well as the consequences of the erroneous or fraudulent use thereof.
'the company' recommends users to use the latest versions of the software for browsing the Internet given the incorporation of greater security measures in these.
Likewise 'the company' recommends users to use the security mechanisms within their reach (secure web servers, cryptography, digital signature, firewall, etc.) to protect the confidentiality and integrity of their data to the extent necessary , given that there are risks of personality impersonation or violation of communication.
'the company' reminds users that the Internet is not secure. However, different means exist and are developed that allow you to improve the protection of your data. So, use any means at your disposal to protect your data and your communications, such as the legally available encryption for confidential email and the access codes to your own device with an Internet connection.
'the company' warns users that whenever they provide personal information over the Internet through email, newsgroups, discussion forums, etc., keep in mind that such information can be collected and treated for purposes unwanted by users , so 'the company' recommends users to inform themselves about the confidentiality and privacy policies of the online sites they visit.
'the company' warns users to keep in mind that, unless they use encryption mechanisms, email on the Internet is not secure. Mail messages and discussion forums may be subject to forgery and personality impersonation, which should be taken into account whenever they are used. If the user does not want to publish their email address, they must configure their browser so that they do not leave their email address on the web servers they access.
Finally 'the company' warns of the importance of reading, understanding and accepting the particular conditions that may be established prior to the contracting of the online products and services of this website and apps.
17.COMPETENT AUTHORITYYou are informed that the owners of the personal data described in this document have the right to seek the protection of the Spanish Agency for Data Protection, an independent authority for monitoring compliance with data protection regulations.