PRIVACY POLICY

1.WHO WE ARE?

Be Universal is a subsidiary company under the Universal Group.

Be Universal is committed to protect the personal data of Players, Customers and Investors of products and services of the various companies of the Universal Group. Also, even when the personal data is proceeded by the rest of the companies and entities of the Universal Group, that is accounted in the present Policy, which underpins the commitment of Universal Group to respect the rules for the protection of personal data.

When this privacy policy referred to Universal Group, we are referring to Universal Holding Ltd, as well as to each of the companies comprising the Group and its subsidiaries.

2. WHY THIS PERSONAL DATA PROTECTION POLICY?

The purpose of this Policy is to inform the Players, Customers and Investors of the general rules for the processing of personal data, which are collected and processed in strict compliance with the provisions of the personal data protection legislation in force at all times, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (”GDPR”).

Universal Group respects best practices in the area of ​​security and personal data protection, taking the necessary technical and organizational measures to comply with the RGPD and ensuring that the processing of personal data is lawful, fair, transparent and limited to the authorized purposes.

Universal Group and Be Universal, mainly, are committed to the protection and confidentiality of personal data, and has adopted the measures it deems appropriate to ensure the accuracy, integrity and confidentiality of personal data, as well as all other rights that the respective holders enjoy.

The rules foreseen in this Data Protection Policy complement the provisions on the protection and processing of personal data provided in the contracts that Players, Customers and Investors enter into with Universal Group companies, as well as the rules set forth in the terms and conditions that regulate the offer of various products and services and are duly advertised on their websites.

3. WHAT IS COVERED UNDER THIS DATA PROTECTION POLICY?

This Data Protection Policy applies exclusively to the collection and processing of personal data for which Universal Group is responsible for its treatment.

4. WHAT ARE PERSONAL DATA?

Personal data is any information of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person.

Any identifiable person, directly or indirectly, identified by reference to a name, identification number, location data, identifiers by electronic means or one or more specific elements of his or her physical, physiological, genetic, mental, economic, cultural or social status.

5. WHAT IS THE PROCESSING OF PERSONAL DATA?

The processing of personal data consists of an operation or set of operations carried out on personal data or personal data sets, by automated means or not, namely collection, registration, organization, structuring, preservation, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, limitation, erasure or destruction.

6. WHO IS RESPONSIBLE FOR DATA PROCESSING?

The Data Protection Officer plays a relevant role in the processing of personal data, ensuring, among other things, the compliance of data processing with current legislation, verifying compliance with this Data Protection Policy and setting clear rules of processing of personal data, ensuring that all those entrusted with the processing of their personal data are aware of how Universal Group and Be Universal treat them and what rights they have in this matter.

The entity responsible for the processing of personal data is Be Universal, or Universal Group, which will determines the purposes and means of treatment of the same.

Thus, the owners of personal data, if they wish, can address a communication to the Data Protection Officer, regarding matters related to the processing of personal data, using the following contact for this purpose:

Contact: gdpr@be-universal.com

7. WHAT KIND OF PERSONAL DATA ARE COLECTED?

Universal Group, within the scope of its activities, processes the personal data necessary for the provision of services and/or supply of products, as well as, at the level of social intervention, processing data such as name, address, phone number and e-mail address, according to the most detailed information available to the holders of personal data.

Personal data, traffic data, geographic location, profile and/or consumption are also processed for marketing purposes or for the dissemination of offers of goods or services by Universal Group, if the respective holder has authorized it.

Personal data will also be processed if the respective holder has authorized it for the purpose of disseminating information services and lists within the scope of the universal service. No information will be shared with third parties (outside Universal Group).

8. WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?

Be Universal and Universal Group collect your personal data, in particular via telephone, in writing, through its websites and through the Customer area, guaranteeing, where necessary, the prior consent of the holder of the personal data.

The personal data collected can be processed in a computerized way, in an automated or non-automated way, guaranteeing in all cases strict compliance with the legislation for the protection of personal data, stored in specific databases created for this purpose and, in no case, the data collected will be used for a purpose other than that for which it was collected or given the consent of the data subject.

9. WHO ARE THE DESTINATORS OF PERSONAL DATA?

Without causing prejudice to the addressees indicated throughout this Data Protection Policy, Universal Group may communicate the personal data of the Client, for the purpose of complying with legal obligations in particular to police, judicial, tax and regulatory entities.

10. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

The length of time during which personal data are stored varies.

Effectively, there are legal requirements that require you to retain the data for a minimum period of time. Thus, and whenever there is no specific legal requirement, the data will be stored and kept only for the minimum period necessary for the pursuit of the purposes that led to their collection or subsequent processing, under the terms defined by law.

11. WHAT ARE YOUR RIGHTS AS A HOLDER?

As holders of personal data, Players, Clients and Investors are guaranteed, at any time, the right to access, rectify, update, limit and erase their personal data (except as to the data that are indispensable for the provision of services by Universal Group duly identified in the Form as being mandatory supply or to comply with legal obligations to which the controller is subject), the right to oppose the use of the same for commercial purposes by Universal Group and the withdrawal of consent, without this compromising the lawfulness of the treatment under this consent, as well as the right to data portability.

12. HOW CAN I ACCESS, RETIFY, UPDATE, LIMIT, DELETE, OPPOSE TO THE TREATMENT OF MY PERSONAL DATA, OR REMOVE CONSENT?

Without causing prejudice to the provisions of the GDPR, the holder of the personal data may do so, directly or through a written request, addressed to the person responsible for the treatment, through the contacts made available for this purpose in this document, as well as other contacts made available by Universal Group.

13. HOW CAN YOU OPPOSE TO RECEIVE CONTACTS FOR MARKETING PURPOSES?

Universal Group may promote actions to disseminate to its Players, Customers and Investors, new products or services, namely through telephone, e-mail, SMS, MMS or any other electronic communications service, if the holder of the personal data has given the consent.

If the holder of personal data does not intend to continue to receive such communications, he may at any time withdraw his consent to the use of his data for marketing purposes.

14. WHAT ARE THE MEASURES ADOPTED BY UNIVERSAL GROUP TO ENSURE THE SAFETY OF YOUR PERSONAL DATA?

Universal Group is committed to ensuring the protection of the personal data that is made available to it, and has adopted and implemented strict rules in this regard. Compliance with these rules is an obligation of all those who legally access them.

Taking into account the concern and commitment that Universal Group reveals in the defense of personal data, a number of technical and organizational security measures have been adopted in order to protect the personal data made available to it against its dissemination, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of illicit treatment.

In this sense, on all Universal Group websites, personal data collection forms require encrypted sessions of the Browser and all personal data transferred are stored securely in system.

15. HOW DO WE USE COOKIES?

”Cookies” are small labels of software that are stored on the computer through the browser, retaining only information related to preferences, not including personal data.

Last updated: February 28, 2019

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