Privacy Notice

1. Data Controller

Estartie Management LTD, a company incorporated under the laws of the Republic of
Cyprus, with registration number HE 449676, and its registered address at Panagias
Chrysopyrgotissas, 2, PANICOS KANARIS FOUR SEASONS, Flat/Office 4, Pyrgos, 4529,
Limassol, Cyprus.

2. Purpose of Data Collection

We collect and process your personal data for the following purposes:
(1) Application Processing
When you submit your personal data through our website to apply for an open position,
we process your data under Article 6(1)(b) GDPR in order to assess your suitability for
the role and take necessary steps before entering into a potential employment contract.
(2) Post-Application and HR Evaluation
If we do not proceed with your application, we may continue to process your data under
Article 6(1)(f) GDPR based on our legitimate interest to:
● Keep your profile on record for potential future opportunities.
● Defend legal claims or ensure compliance in the event of disputes arising from the
recruitment process.

3. Legal Grounds for Data Collection and Processing

We collect and process your personal data on the following legal grounds:
● Consent: You provide us with your explicit consent when you register on our
platform or when you opt-in to receive marketing communications.
● Contractual Obligations: Processing is necessary for the performance of a contract,
such as providing you with betting services or fulfilling your account requests.
● Legal Obligations: We may process your data to comply with legal obligations,
including regulatory requirements.
● Legitimate Interests: Processing may also be necessary for our legitimate interests,
such as fraud prevention or improving services, provided these interests do not
override your rights and freedoms.

4. Data to be processed

Following categories of your personal data shall be processed within the purposes set out
above:
● Your name, contact information (address, phone number, email address, social
profile, messenger ID, Telegram), date of birth, nationality, gender, location,
citizenship status, residency and work permit status, and passport data.
● Your educational and professional background, including your resume, certificates,
cover letter, references, and other application materials you provide.
● Your employment history, including your job title, employer name, and dates of
employment.
● Information about your skills, experience, and qualifications relevant to the job you
are applying for.

5. Recipients of Your Data

Your personal data will be accessible to:
● Estartie Management LTD employees and contractors involved in the
recruitment process.
● All personnel with access are bound by confidentiality agreements and internal data
protection policies aligned with GDPR requirements.

We do not sell or disclose your personal data to third parties for commercial purposes.

6. Data Storage Duration

Your data will be stored as follows:
● Application Evaluation (Article 6(1)(b) GDPR):
○ If no employment agreement is reached: up to 3 months from the date of
data submission, or until the official rejection notice.
○ If employed: for the duration of the employment contract and as legally
required after termination.

● Legitimate Interest (Article 6(1)(f) GDPR):
○ Up to 6 years following communication of a refusal or contract termination
to:
■ Consider your application for other roles.

■ Handle or defend against potential legal claims.

7. Data Retention

((1) Pursuant to clause 2(2) above, we shall retain your personal data enlisted in clause 4,
for the following reasons: (a) Considering yourself for the other role which might be open
in our company within the term of storage, unless you give us the instruction to withhold
from processing them for the purpose hereby; and (b) Ability to defend legal claims which
might be brought by you in association with the rejection to make an agreement, OR any
claims which involve a possible breach of the agreement concluded AND to ensure our
right to bring a claim against your misconduct, accusations, or breach of the
agreement.
(2) Without any prejudice to your rights as data subject under the applicable
laws, we shall be unable to delete your personal data completely in the view of clause
7(1)(b) above.
(3) If we receive your instructions on deleting the personal data
contemplating that you are not willing to be reached out for the reasons explained in clause
7(1)(a), access to your personal data shall be limited to employees and contractors which
might reasonably need it to defend or bring legal claims.

8. Place of Storage

(1) Your personal data shall be stored at the place specified as the registered place of
business for the Controller referred to in clause 1.
(2) Pursuant to keeping your personal
data integrated and safe we may use the external services related to storage of data within
the EU, ensuring that the access to personal data shall be restricted by technical and policy
measures laid down by the following reasons.

9. Data Subject's Rights

You have the following rights regarding your personal data:
● Access: You can request a copy of the personal data we hold about you.
● Rectification: You can request correction of any inaccurate or incomplete data.
● Erasure: You can request the deletion of your personal data, subject to certain legal
conditions.
● Portability: You can request that we transfer your personal data to another
organization, where applicable.
● Objection: You have the right to object to certain types of data processing, such as
for direct marketing purposes.
● Complaint: If you believe that your privacy rights have been violated, you may lodge
a complaint with the relevant supervisory authority.

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10. Supervisory authority

Office of the Commissioner for Personal Data Protection Office address: Kyprianoros 15, 

Nicosia 1061, Cyprus.

Postal address P.O.Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456 Fax: +357 22304565

Email: commissionerdataprotection@gov.cy
Contact form for partners

11. Updates to This Notice

We may revise this Privacy Notice periodically. The latest version will always be available
on our website and will include a “Last updated” date.
Last updated: 12th of June 2025

Cookies Policy

What Are Cookies
Cookies are small text files stored on your device (computer, tablet, or mobile phone) when
you visit a website. They help improve your browsing experience and enable certain
website functionalities.
How We Use Cookies
We use cookies for the following purposes:
● Essential Cookies: Necessary for the website to function properly (e.g., login
authentication, security features).
● Performance Cookies: Collect information about how visitors use our website to
improve functionality.
● Functional Cookies: Enhance your experience by remembering preferences and
settings.
● Targeting Cookies: Used for advertising purposes and to deliver relevant content.
Third-Party Cookies
We may allow third-party service providers (e.g., analytics and advertising partners) to
place cookies on your device to enhance services. These third parties have their own
privacy policies governing the use of cookies.

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