Updated: 01.10.2022.

Privacy policy

We want you to understand how we protect your privacy when we obtain personal data from you, how we use that information, what your rights are in this respect, and how we safeguard that. By reading this Privacy Notice, you hereby acknowledge and agree that the personal data you provide to us is supplied at your own free will and will be used in accordance with the purposes described in this Privacy Notice. If you do not understand this Privacy Notice, please do not share your personal data with us.We reserve the right to change and/or update our Privacy Notice at our discretion and at any time. You will be notified accordingly and in advance about these changes and or updates, which we kindly ask you to read carefully and make sure you understand and agree with.

1. General information

Happening d.o.o. (hereinafter Happening ) is a company registered for computer and related activities that is providing sports betting solutions for a market-leading operator and acting as part of Superbet Group.

Superbet Group (1) and all affiliates is a betting & gambling organizer, trading under the brand name Superbet and part of the Superbet group of companies.

Happening d.o.o. is a Controller of the personal data we process about you.

The term “employee” refers to all employees, directors, officers and Board members of Happening . For the purposes of this privacy notice, it also refers to other consultants and individual contractors engaged by Happening , even though they are not otherwise employees.

The term “Candidate” is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to work with or for us (whether on a permanent or non-permanent basis).


2. What personal information we collect?

As used in this Privacy Notice, personal data means any information that can be used to individually identify you, directly or indirectly, alone or along with other information, or contact you online or elsewhere.

The purpose of processing your personal data is to carry out specific recruitment activities and to provide you with information on various employment opportunities within Superbet.

The legal basis for processing your personal data is the possibility of taking steps at your request prior to entering into a contract for a job within Superbet and subsequently your consent in accordance with the requirements of GDPR.

You have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent before its withdrawal.

The categories of personal data that can be processed are those provided by you in your CV. Sometimes, you may be asked for other categories of data, based on which a possible employment decision can be made such as:

  • name, surname, date of birth;

  • postal address, telephone, an email address;

  • sex, marital status, citizenship;

  • professional occupation, data related to education, professional training, hobbies;

  • information relating to previous applications you have made to Happening and/or any previous employment history with Axilis;

  • any other information you voluntarily provide throughout the process, including online, through interviews, or other forms of assessment;

  • information provided by recruiting or executive search agencies;

  • information collected from publicly available sources, including any social media platforms you use or other information available online.

During the recruitment process, we generally do not collect or process any “Sensitive Personal Information”. Sensitive Personal Information includes the following: information that reveals your racial or ethnic origin, religious, political, or philosophical beliefs, or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health, sex life, or sexual orientation

At the same time, according to our internal policies and local legal provisions, we may collect information about you from open sources. We can also ask you for recommendations/references about your current or previous professional activities.

3. How we collect your personal information?

We solely collect your personal data with your informed knowledge and when you voluntarily submit it to us.

Collection of data occurs in various ways such as by filling in forms and documents by you or by members of the HR department and, sometimes, by special technologies (cookies, IP address registration, log files, online applications) as explained below:

  • recruiting purposes — to determine your qualifications for employment and to make a hiring decision (This includes assessing your skills, qualifications, and background for a particular role, verifying your information, carrying out reference and/or background checks (where applicable), and generally managing the hiring process and communicating with you about it)

If you are accepted for a role at Happening , the information collected during the recruiting process will be processed in accordance with applicable law, including any Employee Privacy Notice, a copy of which will be provided when you are on-boarded as an employee if applicable.

If you are not successful, we may still keep your application to allow us to consider you for other suitable openings within Happening in the future.

Once collected, we shall at all times ensure that any processing of your personal data is carried out in compliance with applicable laws, with this Privacy Notice, and for the purpose for which you submitted your data to us.

4. What we use your personal information for?

By law, we must have a lawful reason for processing your personal information. The data we collect about you will only be used for the purpose for which you submitted it to us, to perform our legal obligations and our legitimate interests in specific circumstances. Such purposes are made clear to you at the point of collection or in this Privacy Notice. Thus, we process your personal data for the following purposes:

  • Processing is necessary for the performance of the contract to which you are a party or in order to take action at your request prior to entering into a contract; (Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work

  • Based on your prior consent for different purposes (e.g. retention of CV information and related documents for potential job opportunities)

  • In our legitimate interests which we or a third party may have, except when such interests override by your interests or fundamental rights and freedom (e.g. such as general HR administration, our global directory of employees and external staff, general business management and operations, disclosures for auditing and reporting purposes, internal investigations, management of network and information systems security and business operations. We may also process your personal data to investigate potential violations of law or breaches of our internal policies.);

Also, we make sure that all our employees which have access to your personal data will process them only according their job responsibilities and in compliance with all laws, regulations or with your consent and these requirements are stated in their labour contract and the undisclosed agreement they signed with Happening .

5. What happens if you do not provide or allow us to use your personal data?

You can decide at any time not to provide us with the requested personal data. However, if you refuse to share your personal data with us when requested, we may not be able to fulfill and undergo our recruitment procedures and potentially provide you with job opportunities. Your refusal to share your personal information with us in order to benefit from certain services may also limit the services and benefits we may offer you. For example, if you do not give us your consent to sign up for our sports and relaxing programs, you will not be able to receive such benefits. You can decide at any time not to provide us with the requested personal data.

6. Who do we share your personal data with?

We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you and you have given us explicit permission to do so. In certain circumstances described below, we will share a minimum amount of personal data as follows:

  • Data processors authorized and contracted by us to process personal data such as our contractors (i.e. recruiting or executive search agencies involved in your recruiting; shared services and recruiting platform providers, IT developers and support providers, and providers of hosting services in relation to our careers website; and third parties who provide support and advice including in relation to legal, financial / audit, management consultancy, insurance, health and safety, security and intel and whistleblowing/reporting issues;

  • Internally with managers, HR and recruitment teams, systems administrators, and other members of Superbet’s group for our recruitment

  • Based on consent in cases where your personal data is transferred to any other third party where you have consented or requested that we do so (advertising field or market research companies, for various polls, statistics, or to present to you some online commercials or to help us to evaluate some on-line services, viewing creatives or other contents

  • Also, we can use or disclose information that we consider are suitable, to the extent that the records were quoted or related to ongoing or potential disputes, or to impose or protect the rights or safety of others.

Usually, when we disclose this personal information to other companies and institutions, we are properly taking care to share the only minimum amount of personal needed to fulfill their functions, making them aware that these data can be used only when services are performing on our behalf or to comply with legal requirements. If the case, we apply security measures to request our services’ suppliers to protect your personal data. In case we share your personal data outside the EU, Superbet has in place contractual relationships with each such recipient that include standard contractual clauses intended to ensure an adequate level of protection and will always conduct rigorous due diligence to ensure there are no risks to such transfers