Privacy Policy
“Circuscasinoresort.com”
CIRCUS CASINO RESORT is concerned about the protection of personal data. This is why we do everything we can to protect the privacy of the visitors and users (hereinafter the “Users”) of the website www.circuscasinoresort.com (hereinafter the “Site”).
The Users will find below all the provisions related to personal data processing that are applicable during all visits to or uses of the Site by the Users (hereinafter the “Privacy Policy”).
Regarding the processing of personal data within the casino, please refer to Gambling Management SA’s privacy policy.
Plan1. General information 2. Processing of personal data not requiring Users’ consent 2.1. The processing of the personal data necessary for the use of the Site 2.2. Other processing not requiring Users’ consent 3. Processing of personal data subject to Users’ consent 3.1. Nature of the personal data processed 3.2. The processing 3.3. Purposes of personal data processing 4. User rights 4.1. Right of access 4.2. Right to rectification 4.3. Right to opposition 4.4. Right to be forgotten 4.5. Right to restriction 4.6. Transfer of data to a data controller 4.7. Terms and conditions 4.8. Notification 5. Location, storage and duration of storage of personal data 6. Responsibility of CIRCUS CASINO RESORT – Subcontractor 7. Other 7.1. Personal data register 7.2. Entirety – modification of the Privacy Policy 7.3. Probative value 7.4. Data protection authority 7.5. Contact — Information relating to the identity of the data controller and the data protection officer |
1. General information
CIRCUS CASINO RESORT processes the personal data of the Site’s Users, for the purposes and within the limits of the Privacy Policy, during all visits to or uses of the Site.
CIRCUS CASINO RESORT ensures to conform, during the processing of this personal data, to the laws and regulations in force and, notably, to the European Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter “the Regulation”).
Regarding this, and conforming to the aforementioned Regulation, CIRCUS CASINO RESORT:
- Processes personal data for the purposes of allowing Users to use the Site and, furthermore, for the necessary and legitimate purposes outlined in article 2 of the Privacy Policy;
- Processes, subject to the User’s prior, free and explicit consent, personal data for the purposes described in, and according to the purposes defined in article 3.
By accessing and using the Site, Users are deemed to have read and accepted the Privacy Policy. Furthermore, they guarantee that the data and information communicated to CIRCUS CASINO RESORT is correct.
2. Processing of personal data not requiring Users’ consent
2.1. The processing of the personal data necessary for the use of the Site
The use of the Site and the provision of the associated services by CIRCUS CASINO RESORT or its partner may require the processing of the Users’ personal data by CIRCUS CASINO RESORT. This processing of personal data carried out by CIRCUS CASINO RESORT does not require Users’ consent under article 6.1.b) and c) of the Regulation.
The personal data communicated by the User is saved on a register, as is outlined in article 7.1, which is controlled and remains under the responsibility of CIRCUS CASINO RESORT at all times.
a. What data is processed?
The personal data processed is the following:
- Last name, first name, date of birth, language, home/postal address, email address, landline or mobile telephone number, information about the order;
- The User’s navigation and activity history on the Site, including connection data (browser data, IP address), notably by using the following cookies:
| Name | Duration | Objective |
| axeptio_cookies | 12 months | Axeptio. Contains all the information about the visitor’s consent, such as the date, their unique anonymous identifier, and if they have already consented or not |
| axeptio_all_vendors | 12 months | Axeptio. Contains the list of all the cookies declared in the Axepito widget |
| axeptio_authorized_vendors | 12 months | Axeptio. Contains the list of cookies accepted by the visitor. |
| Wp-wpml_current_language | Session | WPML. Memorizes the current language on the site |
| wpml_browser_redirect_test | 24 hours | WPML. Tests if cookies are active on the site. |
| _icl_visitor_lang_js | 24 hours | WPML. Memorizes the language that was redirected. |
| wp-settings-time-# wp-settings-# |
12 months | WordPress. Personalizes your WordPress admin interface as well as the whole site’s interface. |
| wordpress_test_cookie | Session | WordPress. Checks if cookies can be installed. |
| wordpress_logged_in_# | Session | WordPress. Once logged in, WordPress installs this cookie which shows that you are logged in and who you are. |
| temp_cp_id_# | 24 hours | WordPress. Collects internal information display via banners. |
| _GRECAPTCHA | 179 days | Google. This cookie is used to distinguish humans from robots and limit fraudulent or unwanted contact forms. |
| ai_user | 12 months | This cookie is defined by the Microsoft Application Insights software. This cookie is used to collect the usage and statistic telemetry data for the apps constructed on the cloud platform Azure. |
| session-id | 1 day | Resengo. Unidentified use. |
b. What processing is carried out by CIRCUS CASINO RESORT?
Processing consists of collection, recording, storage, consultation, organization, use, merging or any other operation deemed necessary or useful for the purposes of allowing the User to access the services promised on the Site or provided by CIRCUS CASINO RESORT’s partners such as those linked to the casino or the horeca, wellness or events (rooms & events) services.
Processing may consist of transferring personal data to CIRCUS CASINO RESORT’s partners responsible for providing the aforementioned services, such as SA GAMBLING MANAGEMENT (Circus Grand Casino Namur) or their subcontractors and ICT infrastructure providers.
c. What are the purposes of this processing?
CIRCUS CASINO RESORT processes the personal data referred to in article 2.1.a) for the purposes of i) identifying Users as part of the services provided by the Site or by CIRCUS CASINO RESORT’s partners through the Site and ii) allowing them to access and use the aforementioned services and iii) collecting their consent to the processing of their personal data.
2.2. Other processing not requiring Users’ consent
CIRCUS CASINO RESORT also processes personal data for the legitimate purposes outlined below. This processing of personal data carried out by CIRCUS CASINO RESORT does not require Users’ consent under article 6.1.f) of the Regulation.
The personal data communicated by the User is saved on a register, as is outlined in article 7.1, which is controlled and remains under the responsibility of CIRCUS CASINO RESORT at all times.
a. What data is processed?
The personal data processed is the following:
- Last name, first name, date of birth, language, home/postal address, email address, landline or mobile telephone number;
- The User’s navigation and activity history on the Site, including connection data (browser data, IP address), notably by using cookies. This is notably the case for the following analytical cookies:
b. What processing is carried out by CIRCUS CASINO RESORT?
Processing consists of collection, recording, storage, consultation, organization, use, merging of the personal data outlined in article 2.2.a). It consists of transferring this personal data to third parties, the list of which is available upon request made to the Contact mentioned in article 7.5.
Processing may consist of transferring personal data to CIRCUS CASINO RESORT’s partners responsible for providing the aforementioned services, such as SA GAMBLING MANAGEMENT (Circus Grand Casino Namur) or their subcontractors and ICT infrastructure providers.
c. What are the legitimate purposes of this processing?
CIRCUS CASINO RESORT processes the personal data referred to in article 2.2.a) for the following legitimate purposes:
- The promotion, advertising and marketing of services offered by CIRCUS CASINO RESORT and its partners on the Site, including sending SMS, telephone calls, paper or electronic newsletters;
- Carrying out satisfaction surveys, statistical surveys, trend analyses and market studies, for the purpose of improving the services offered on the Site.
3. Processing of personal data subject to Users’ consent
By using the CIRCUS CASINO RESORT Site, for whatever reason, the User expresses their free, specific, informed and unequivocal will to expressly authorize CIRCUS CASINO RESORT to process personal data in accordance with the Regulation, within the limits and for the purposes defined below and without prejudice to the processing referred to in article 2.
The personal data communicated by the User is saved on a register, as is outlined in article 7.1, which is controlled and remains under the responsibility of CIRCUS CASINO RESORT at all times.
The User also benefits from rights, including the right to withdraw their consent at any time, according to the terms and conditions defined in article 3.4.
3.1. Nature of the personal data processed
The data processed by CIRCUS CASINO RESORT is the following:
- Last name, first name, date of birth, language, home/postal address, email address, landline or mobile telephone number, information about the order;
- The User’s navigation and activity history on the Site, including connection data (browser data, IP address), notably by using cookies.
The personal data communicated by the User is saved on a register, as is outlined in article 7.1, which is controlled and remains under the responsibility of CIRCUS CASINO RESORT at all times.
| Name | Duration | Objective |
| ga | 13 months | Google Analytics. Distinguishes unique users by attributing a randomly generated number as a customer identifier |
| _gat | 1 min
|
Google Analytics. Reduces the number of requests |
| _gid | 24 hours | Google Analytics. Stores and updates a unique value for each page visited |
3.2. The processing
Processing consists of collection, recording, storage, consultation, organization, use, merging of the personal data outlined in article 3.1.a). It consists of transferring this personal data to third parties, the list of which is available upon request made to the Contact mentioned in article 7.5.
Processing may consist of transferring personal data to CIRCUS CASINO RESORT’s partners responsible for providing the aforementioned services, such as SA GAMBLING MANAGEMENT (Circus Grand Casino Namur) or their subcontractors and ICT infrastructure providers.
3.3. Purposes of personal data processing
The personal data is collected and processed by CIRCUS CASINO RESORT for the following purposes:
- The promotion, advertising and marketing, related to the services offered by third parties, including sending SMS, telephone calls, paper or electronic newsletters, not within the scope of article 2.2.c);
- The offer of participation in competitions and promotional offers from third parties;
- The development of new products and services, such as games and bets;
- Execution of satisfaction surveys, statistical studies, trend analysis and market studies, for the purposes of management, marketing and reporting, including profiling, not part of the purpose outlined in article 2.2.c).
4. User rights
Without prejudice to articles 2 and 5, Users have the right to exercise a right of rectification, opposition and restriction, according to the terms and within the following limits.
4.1. Right of access
- CIRCUS CASINO RESORT makes the following information available to Users:
- The identity and contact details of the data controller;
- The contact details of the Data Protection Officer;
- The personal data processed;
- The purposes of the personal data processing, as well as the legal base for processing;
- The recipients or categories of recipients of personal data, if applicable;
- And, if applicable, the fact that the data controller intends to transfer personal data to a country located outside the European Union and: either the existence (or absence) of an adequacy decision made by the European Commission, or, in the absence of such a decision, the guarantees offered by the third country and the measures implemented to get a copy of the personal data.
- The possibility of opposing automated processing of their data, such as profiling, unless proper reasons make this processing by CIRCUS CASINO RESORT necessary, as well as the possibility of opposing all processing of their personal data for market research.
- Users have the right to request, at any time, access to all the information stated in this article and in article 3.1, by getting in touch with the Contact referred to in article 7.5. CIRCUS CASINO RESORT shall respond to these information requests within one month.
- Users have the right to obtain a copy of the personal data being processed. CIRCUS CASINO RESORT reserves the right to demand payment for the potential costs induced by this request; these costs will be calculated on the basis of administrative costs induced by the request; they will not exceed 20 euros.
- Users have the right to obtain, in a structured format, this access or said copy, in such a way that the personal data they are provided is in a format that conforms to the technical standards in force when requesting access; this format will therefore allow them to be machine readable.
4.2. Right to rectification
CIRCUS CASINO RESORT guarantees and obliges the Users to update and rectify the personal data concerning them, as soon as this data is incorrect or incomplete.
This right to rectification can be exercised by request to the Contact referred to in article 7.5.
4.3. Right to opposition
CIRCUS CASINO RESORT authorizes Users to oppose the processing of all or part of personal data concerning them, for the following reasons:
- Their data is inaccurate;
- The processing is no long necessary for the purposes the data was collected for;
- The User withdraws their consent;
- The data has been subject to illegal processing.
CIRCUS CASINO RESORT also authorizes Users to oppose to:
- Automated processing of their data, such as profiling, unless proper reasons make this treatment by CIRCUS CASINO RESORT necessary;
- Any processing of their personal data for market research, including profiling, if it is linked to this market research.
This right to opposition can be exercised by request to the Contact referred to in article 7.5.
Regarding non-essential cookies, Users have the option to manage their preferences in terms of consent to the cookies used by the Site and its partners by configuring the cookies via the tab proposed for this purpose.
Furthermore, most browsers are configured to automatically accept cookies. It is possible to set your browser so it sends a notice when a cookie is used and therefore you can accept it or not.
4.4. Right to be forgotten
CIRCUS CASINO RESORT also ensures to respond to any request for deletion of personal data in the shortest possible period (right to be forgotten), when:
- The processing is no long necessary for the purposes the data was collected for;
- The User withdraws their consent;
- The data has been subject to illegal processing, or should be deleted under a legal obligation;
- The User opposes the automated processing of their data, such as profiling, and there are no proper reasons making this processing by CIRCUS CASINO RESORT necessary;
- The User opposes processing of their personal data for market research, including profiling, if it is linked to this market research.
4.5. Right to restriction
The Users also have the right to obtain from CIRCUS CASINO RESORT the restriction of the processing of their personal data when:
- The User considers their personal data to be incorrect, for the time necessary for CIRCUS CASINO RESORT to verify the accuracy of it;
- The processing is illegal but the User does not wish for their data to be deleted but requests a restriction of the data processing;
- The User opposes automated processing, including profiling or processing of their personal data for market research purposes and that it is necessary to verify the legitimate nature of the reasons for which CIRCUS@BELGIUM intends to maintain this processing;
- CIRCUS CASINO RESORT no longer needs the personal data processed but the person concerned wants them to be saved for the observation, exercise or defense of rights in court;
This right to restriction can be exercised by request to the Contact referred to in article 7.5.
4.6. Transfer of data to a data controller
Users are authorized to transfer their personal data to another data controller without CIRCUS CASINO RESORT being able to prevent this.
While such a transfer is technically possible, Users are authorized to request CIRCUS CASINO RESORT to have this transfer carried out directly by their data controller.
4.7. Terms and conditions
The rights granted by CIRCUS CASINO RESORT to the User must be exercised in accordance with the terms and conditions defined in article 7.5.
4.8. Notification
CIRCUS CASINO RESORT will provide the User with a notification of any deletion or rectification of data carried out conforming to articles 4.2 and 4.4, unless such a notification proves to be impossible or imposes disproportionate effort.
This notification will be done by email or mail, based on the details communicated by the User.
5. Location, storage and duration of storage of personal data
5.1. CIRCUS CASINO RESORT stores users’ personal data in a form that allows their identification and availability and follows appropriate and secure methods.
The data is stored and hosted in Belgium at a Data Center; which offers all the necessary and useful security guarantees regarding the technical standards in force.
5.2. Users’ personal data is stored by CIRCUS CASINO RESORT for the purposes defined in articles 2 and 3. It is saved for a period of 5 years (excluding cookies which are saved for the period defined above).
6. Responsibility of CIRCUS CASINO RESORT – Subcontractor
6.1. CIRCUS CASINO RESORT agrees to process Users’ personal data in a legal, loyal and transparent way regarding the User concerned. Any data processing performed by CIRCUS CASINO RESORT will comply with the requirements of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to personal data processing and to this Privacy Policy.
CIRCUS CASINO RESORT implements all reasonable and appropriate methods to ensure confidentiality, integrity and availability of the personal data it processes. These technical and organizational measures, notably those set out in the register which can be accessed via the Contact referred to in article 7.5.
If necessary, CIRCUS CASINO RESORT carries out, with the help of the data protection officer, an impact analysis when processing is likely to cause a heightened risk for Users.
6.2. Users’ personal data is not transferred to third parties other than authorities, CIRCUS CASINO RESORT’S’ providers and partners, except for the purposes outlined in articles 2.1, 2.2 and 3 and, therefore, if:
- The transfer becomes compulsory by law, regulation or injunction of an administrative or judiciary authority;
- The transfer is necessary for the provision of services or maintenance;
- The User gives their consent for such transfer.
It is expressly agreed that the partners and providers of CIRCUS CASINO RESORT remain solely responsible for the processing of the personal data of Users who, through the Site or not, use their services. Under no circumstances will these partners or providers be considered to be processing personal data on behalf of CIRCUS CASINO RESORT, which declines all responsibility in this regard. The partner will not be considered as a subcontractor within the meaning of the Regulation unless it is established that it processes Users’ personal data on behalf of CIRCUS CASINO RESORT. CIRCUS CASINO RESORT declines all responsibility for the processing of the User’s personal details by the partner who provides its own services on its own behalf and for its own account.
In the event that CIRCUS CASINO RESORT acts as the partner’s subcontractor, it is agreed that CIRCUS CASINO RESORT will only be held liable for damage caused by the processing of personal data contrary to the Regulation or this Privacy Policy if it has not complied with the obligations set out in the Regulation that are specifically incumbent on the subcontractors or acted outside of or contrary to the partner’s lawful instructions. Similarly, CIRCUS CASINO RESORT cannot be held liable under any circumstances if it proves that the fact that caused the damage is in no way attributable to it.
- CIRCUS CASINO RESORT ensures that, when processing is carried out by a subcontractor, on behalf of CIRCUS CASINO RESORT, they provide sufficient guarantees for the implementation of appropriate technical and organizational measures and, more generally, regarding compliance with the Regulation’s demands. In particular, it requires the subcontractor to comply with the Regulation and, therefore, to keep a register
- CIRCUS CASINO RESORT undertakes that, in the event of a security problem related to the data processed, likely to affect their confidentiality, CIRCUS CASINO RESORT will notify the incident to the data protection authority referred to in article 7.4 as soon as possible.
CIRCUS CASINO RESORT will also inform the Users concerned, insofar as the violation of personal data presents a heightened risk for Users’ rights and freedoms; they will be informed by email or mail using the contact details communicated by the User.
7. Other
7.1. Personal data register
As the personal data controller, CIRCUS CASINO RESORT has a register of all of their processing activities. This contains all information relating to the type of data processed, the people concerned by the processing of data, the potential recipients to whom the data is, if applicable, communicated, to which end the data is processed as well as the duration the data is stored and a general description of the technical and organizational security measures put in place.
The personal data communicated by the User is saved, as well as the processing carried out and its purposes, in a register that is controlled by and remains under the responsibility of CIRCUS CASINO RESORT at all times. This register includes, in addition to the aforementioned information:
- A description of the purposes of the processing;
- A description of the categories of people concerned and the categories of personal data;
- The categories of recipients that the personal data has been or will be communicated to, including the recipients in third countries or international organizations;
- The periods expected for the deletion of various categories of data;
- A general description of the technical security measures.
7.2. Entirety – modification of the Privacy Policy
The Privacy Policy contains all contractual provisions enforceable against Users, without prejudice to the general provisions contained in the Terms of Use of the Site, of which they form an integral part. The Terms of Use of the site therefore remain applicable for any matter not related to personal data protection.
CIRCUS CASINO RESORT also reserves the right to modify the Privacy policy. Any update is enforceable against Users as soon as it is published on the Site. CIRCUS CASINO RESORT ensures to mention the date of posting of the Privacy policy in force on the Site.
7.3. Probative value
The User recognizes that the electronic documents exchanged and electronic data collected as part of their registration or use of the Site have the same probative value as if the documents and data were communicated or collected on paper. They agree therefore to not contest their probative force or value because of their electronic medium.
7.4. Data protection authority
Conforming to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the law of 30 July 2018, Users have the right to request extra information or make a complaint to the Data protection authority. The Supervisory Authority is the Commission for the Protection of Privacy; their contact details are:
Address: Rue de la Presse, 35, 1000 Brussels
Telephone: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
Email: contact@apd-gba.be
7.5. Contact — Information relating to the identity of the data controller and the data protection officer
CIRCUS CASINO RESORT is a limited company whose head office is located at Av. Baron de Moreau 1, 5000 Namur (TVA – BE0654871150). It can be contacted for all questions regarding the protection of its Users’ personal data as follows:
- By post: Av. Avenue Baron de Moreau 1, 5000 Namur, Belgium.
- By email: privacy@circuscasinoresort.com
The data controller is CIRCUS CASINO RESORT SA.
CIRCUS CASINO RESORT has also appointed a data protection officer within the meaning of article 37 of the aforementioned Regulation; they can be contacted by email: dpo@circus.be. They are responsible for ensuring the monitoring and conformity of the processing of User’ personal data by CIRCUS CASINO RESORT.
