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Privacy Policy

Candidates Privacy notice

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

Axilis d.o.o. (hereinafter Axilis) 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.

Axilis 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 Axilis. For the purposes of this privacy notice, it also refers to other consultants and individual contractors engaged by Axilis, 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 Axilis and/or any previous employment history with Axilis;
  • information concerning your application and our assessment of it;
  • 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)
  • For the enrolment in Code Cadets project;
  • For the purposes of candidates’ assessment within Code Cadets project

If you are accepted for a role at Axilis, 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 Axilis 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. for enrolment into projects such as Code Cadets, 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 Axilis.

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. Also, as part of our CodeCadets projects, if you do not provide us with the required info for your enrolment in such a project, we will not be able to provide you with participation in such an event.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. 

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

7. Where is your personal data stored?

Your personal data will be kept, processed and stored by us and our service providers in the following territories: the European Union, EEA and the USA.

Each of our service providers who process and store your personal data have an obligation to keep it protected and secured, in accordance with applicable industry standards and whether less stringent legal provisions apply in their jurisdiction.

Where such recipients of data are located in third countries for which the European Commission has not issued an adequacy decision, Axilis 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. A copy of the standard contractual clauses used by Axilis can be found at: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087.

8. How we keep your personal information up to date?

It is important that the information contained in our records about you is both accurate and current. We offer various self-help tools that will allow you to update certain of your personal data in our records.

If your personal data changes during the course of your employment, please use these self-help tools to update that data, where available, or let HR Ops [email protected] know of those changes.

9. How long we keep your personal information for?

Your personal data will only be stored for a necessary and strict period of time in accordance with the purpose for which it is collected and applicable laws or regulatory requirements. Generally, this means we will keep your personal data until the end of your employment with us, plus a reasonable period of time after that where necessary to respond to any employment inquiries, deal with legal, tax, accounting, or administrative matters, or to provide you with ongoing pensions or other benefits. Your personal data will be retained as documented in our corporate data retention schedule and applicable riders and supplements.The duration of the processing of your personal data will be done for a limited period, in accordance with the legal requirements, as follows:

  • For recruitment purposes, your personal data will be stored during the recruitment process
  • In case of successful employment, your personal data will be stored in the HR personnel file permanently in accordance with the Ordinance on the content and method of maintenance of the Employees’ registry (Official Gazette No. 73/2017).
  • In case of rejection to your application, your personal data will be stored for a period of 1 year if you provided us  your consent for such storage 
  • for the duration of your consent (your explicit consent to the processing of personal data), i.e. until the moment of modification or withdrawal thereof,
  • during the existence of our legitimate interests in preserving our rights, security and protection of property, as well as responding to any complaints, requests or other questions regarding our services, 

Upon expiration of the set retention periods, your personal data will be deleted or anonymized. If, at any time, you wish us to discontinue the use of your personal data, please contact us in the manner described in the “How to access, modify, delete or object to the use of your personal data” section.

If your requests to delete your personal data violate our legal or regulatory obligations or the data related to the request for deletion are necessary to exercise or defend our legal claims, we may not be able to act upon your request and we will notify you of this decision. 

10. How we keep your personal data secure?

Axilis has implemented all necessary technical and organizational measures, whether physical, electronic or procedural, to protect the confidentiality and security of the personal data you share with us. These measures have been implemented to protect data against unauthorized access, destruction, loss, alteration, access, disclosure or use. Our security controls are designed to maintain an adequate level of confidentiality, integrity and data availability. Information transmitted and received through the Superbet site and in our applications is encrypted using Secure Socket Layer (SSL) technology. Superbet has a 24/7network traffic monitoring system to detect signs of attacks or intrusions and prevent fraud.

11. Automated decision making and profiling

Your personal data will not be profiled, and currently, we do not have automated decision-making processes that affect you.

12. Your rights

At any given time, you will have the following rights regarding your personal data processed by us. Please note, other than your right to object to us using your information for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute in case of other applicable laws.

  • The right to information: you have the right to be provided with information on the identity of the personal data controller, on the reasons for processing your personal data and other relevant information necessary to ensure the correct and transparent processing of your personal data.
  • The right of access: you have the right to make a request for details of your personal information and a copy of that personal information.
  • The right of rectification: you have the right to have inaccurate information about you corrected or removed without undue delay.
  • The right of erasure ("right to be forgotten"): you have the right to have certain personal information about you deleted from our records.
  • The right to restriction of processing: you have the right to ask us to use your personal information for restricted purposes only.
  • The right to data portability: you have the right to ask us to transfer the personal information you have given us to you or to someone else in a format that can be read by computer.
  • The right to object: you have the right to object to us processing (including profiling)your personal information in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your information for our or a third party’s legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing.
  • The right in relation to automated decisions: you have the right not to have a decision which produces legal effects which concern you or which has a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorised by law or you have given your permission for this.

In order to exercise any of the above rights, you can send a signed and written request to our postal address or in writing to [email protected] Your request will be reviewed and answered within 1 month of receipt, in accordance with the GDPR. If we receive a large number of requests, or particularly complex requests, the deadline can be extended by a maximum of another two months. In certain circumstances as prescribed by data protection law (i.e. excessive requests), we might refuse to act upon your request.

In the event your personal data is processed based on your consent, 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.

You also have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing:

Agencija za zaštitu osobnih podataka

Selska cesta 136, 10000 ZAGREB

[email protected]

13. How you can access, modify, delete or object the use of your personal data

In order to exercise the Rights mentioned above, you can contact us by emailing [email protected] At any time, you can refuse to share your personal data or object to our processing of your personal data. However, you should understand that if you choose this option in certain situations, we may not be able to fulfil our contractual obligations to you, as stated in "What happens if you do not provide or allow us to use your personal data” section above.

If you have consented to receive marketing communications from us and subsequently decide that you no longer wish to benefit from these, you can stop receiving such communications by unsubscribing at any time.

14. How to contact us

If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process information about you, please contact our Data Protection Officer by emailing [email protected]