Privacy policy

1. Data controller and contact details

The controller of the personal data collected on this website is INTERCONNECTIONS – Exploração de Jogos, Lda (“InterConnections”, “we” or “us”), tax number (NIF) 5001728490, with registered office at Via S8, Espaço Avenida, Edifício Beta, LPS-015, 1st floor, Talatona, Luanda, Angola.

For any matter relating to your personal data, you can contact us:

By email

geral@interconnections.co.ao TO BE CONFIRMED

By telephone

+244 924 629 247

By post

to our registered office, marked “Data protection”

InterConnections’ processing of personal data has been notified to the Data Protection Agency (Agência de Protecção de Dados, APD) under Law no. 22/11 of 17 June (Personal Data Protection Law), to which the articles cited in this policy refer unless otherwise stated.

2. Scope of this policy

This policy applies to personal data processed through this corporate website, in its Portuguese and English versions, and to the email messages you send us from it (for example, an unsolicited job application sent from the Careers page).

This policy does not apply:

• to the websites, apps and services of InterConnections’ brands (for example, BetJá, once it opens), which have their own terms and privacy policies that you should read before using them;
• to third-party websites linked from this website, whose practices we do not control;
• to the data of InterConnections’ staff, which is processed under separate information.

3. Principles we follow

We process personal data transparently, lawfully and fairly, only for specified, explicit and legitimate purposes, limited to what is adequate and necessary for those purposes, accurately and up to date, and only for as long as necessary, as required by Articles 6 to 11.

We do not use data for purposes incompatible with those for which it was collected (Article 9), we do not sell or rent it, and we do not send you advertising by electronic means without your prior and express consent (Article 19).

4. What data we process and where it comes from

We only process the data you give us or that your browser sends when you visit the website. This website has no user accounts, does not accept bets or payments and does not ask you for identity documents.

Contact form

Your name, email address, telephone number (optional), the subject you choose and your message. The request also carries the language of the page, the page of the website from which you sent it (where your browser provides it) and the record of your consent: confirmation that you ticked the consent box and the date and time the request arrived.

Email

The address, name and content of the messages you send us or exchange with us, including attachments, such as a CV sent from the Careers page.

Technical request data

As with any website, your browser sends technical data that the hosting provider logs to deliver the pages and protect the service: for example, your IP address, browser and operating system (user agent), the address of the page requested, and the date and time.

Visitor statistics

Only if you accept the “Statistics” category: data about visits (page viewed, referring page, country, region and city, device type, operating system and browser), collected by Vercel Web Analytics without cookies and used only in aggregate form, without identifying visitors.

Cookie choice

The categories you accepted, the date of your choice and a random identifier, stored in the ic_consentimento cookie in your browser.

In the contact form, your name, email address, subject, message and consent are required: without them we cannot reply and the request is not sent. Your telephone number is optional.

Please do not send us sensitive data (for example, about health, religious, philosophical or political beliefs, trade union membership or racial or ethnic origin), or other people’s data without their permission. If we receive such data, we do not use it for any purpose and we delete it as soon as possible.

5. Why we use your data and on what legal basis

We use data only for the following purposes, each with its legal basis in Article 12:

Replying to your contact request and following it up

Your consent, given by ticking the consent box in the form (Article 12(1)(a)). Where the request concerns a contract or a proposal you ask us for, steps taken at your request before entering into a contract (Article 12(2)(a)).

Assessing a job application you send us by email

Steps taken at your request before entering into an employment contract (Article 12(2)(a)).

Counting visits and the most viewed pages, to improve the website

Your consent, given in the “Statistics” category (Article 12(1)(a)), which you may withdraw at any time.

Keeping proof of your consent and of your cookie choice

InterConnections’ legitimate interest in respecting your choice and in demonstrating that it obtained your consent (Article 12(2)(e)).

Delivering the pages, keeping the website running and protecting it against abuse and attacks

InterConnections’ legitimate interest in a secure and available website (Article 12(2)(e)).

Complying with legal obligations and responding to requests from authorities

Compliance with a legal obligation to which InterConnections is subject (Article 12(2)(b)).

Establishing, exercising or defending InterConnections’ rights

InterConnections’ legitimate interest (Article 12(2)(e)), provided that your interests, rights, freedoms and guarantees do not prevail.

6. Who receives the data

Data is processed only by the InterConnections staff who need it for the purpose in question and who are bound by professional secrecy (Article 32). We do not disclose data to third parties for commercial purposes.

We use the following processors, which process data on our behalf, on our instructions and without being able to use it for their own purposes (Article 23):

Vercel Inc. (United States of America)

Hosts the website and the function that sends the contact form, delivers the pages from its global server network and, if you allow it, provides visitor statistics (Vercel Web Analytics).

InterConnections’ email service provider

Carries and stores contact-form messages and the emails you exchange with us.

We only use processors that provide sufficient security guarantees and with whom we have a written contract requiring them to comply with the law, follow our instructions and delete or return the data at the end of the service.

We may also disclose data to judicial, police or supervisory authorities (such as the APD or the Instituto de Supervisão de Jogos), where required by law or by a lawful order, and to our lawyers and advisers, who are bound by confidentiality, where necessary to defend our rights.

7. Transfers outside Angola

The website is hosted by Vercel Inc., whose head office and main data processing facilities are in the United States of America. To deliver pages faster, Vercel uses a global server network: a request to the website may be served from a server outside Angola. Contact-form messages pass through the sending function hosted by Vercel and, if you allow them, visitor statistics are also processed by Vercel. If the email service provider processes data outside Angola, the same rules apply.

These operations are international transfers of data. The law makes them subject to notification to the APD where the destination country ensures an adequate level of protection (Article 33), or to authorisation by the APD where it does not (Article 34). InterConnections handles these transfers in accordance with those rules.

We limit the data transferred to what is necessary and require our processors to provide contractual guarantees of an adequate level of protection (Article 34(1)(i)). You can ask us for more information about the transfers and the applicable safeguards using the controller’s contact details.

• Controller’s contact details

8. How long we keep the data

We keep data only for as long as necessary for the purpose for which it was collected, and then delete or anonymise it (Article 11). The retention periods are:

Contact-form messages and emails exchanged

Up to 12 months after the last contact on the same matter.

Requests that led to a contract or a proposal

They become part of the file for that contract or proposal and are kept for the legal periods that apply to it.

Unsolicited job applications

Up to 12 months after receipt, so that we can consider them for vacancies that open during that period. If you ask, we delete them sooner.

Record of consent given in the contact form

For as long as we keep the message it relates to, as it forms part of that message.

Cookie choice

In your browser, for 182 days (about 6 months) from your last choice, or until you delete the cookie.

Technical request data

For the hosting provider’s log retention period, which is short and depends on the plan (from one hour to 30 days). We consult these logs only to resolve technical or security issues.

Visitor statistics

In aggregate form only. Vercel deletes after 24 hours the temporary code it uses to recognise each visit.

These periods are extended where the law requires data to be kept for longer, where a competent authority so orders, or for as long as the data is needed to establish, exercise or defend a right in pending or foreseeable proceedings. In those cases, the data is blocked and used only for that purpose (Article 28(5)).

9. Your rights

Under the law, you have the right to:

Information

Know who processes your data, for what purposes, who receives it and how to exercise your rights (Article 25). This policy provides that information.

Access

Know whether we process data relating to you and obtain that data, together with the purposes, the categories of data, the recipients and its source (Article 26).

Rectification and updating

Have inaccurate data corrected and incomplete data completed (Article 28).

Erasure and blocking

Ask us to delete data whose processing does not comply with the law, except where the law requires us to keep or block it (Article 28).

Objection

Object at any time, on compelling and legitimate grounds relating to your particular situation, to processing based on our legitimate interest (Article 27).

Withdrawal of consent

Withdraw your consent at any time, without affecting processing carried out before. For statistics, simply change your choice under “Cookie preferences” in the footer.

Automated decisions

Not to be subject to decisions based solely on automated processing that produce legal effects concerning you or significantly affect you (Article 29).

10. How to exercise your rights

To exercise any of these rights, write to us at geral@interconnections.co.ao TO BE CONFIRMED or by post to our registered office, stating the right you wish to exercise and the data your request concerns.

To protect your data, we may ask you to confirm your identity before we reply, for example by writing from the same email address or by showing an identity document. We only ask for what is necessary and delete the copy once your identity is confirmed. A request made by a representative must include proof of their authority to act.

We reply without undue delay. Requests for rectification, updating and erasure are fulfilled within a maximum of 60 working days, as required by Article 28(2). Exercising your rights is free of charge.

11. Complaints to the Data Protection Agency

If you believe we have processed your data in breach of the law, you may lodge a complaint with the Agência de Protecção de Dados (APD), the Angolan authority that supervises the application of Law no. 22/11 and decides on the complaints made to it (Articles 44 and 47). You may also use the administrative and judicial remedies provided by law.

We would appreciate the chance to help first: many issues are resolved faster directly with InterConnections.

12. Security

We apply technical and organisational measures appropriate to the risk to protect data against destruction, loss, alteration, disclosure or unauthorised access (Article 30). On this website:

• all connections are encrypted (HTTPS, with TLS 1.2 or 1.3): an unencrypted request is redirected to HTTPS and browsers are instructed to always use secure connections (HSTS);
• the contact form stores nothing on the website: the request goes straight to email, over an encrypted connection with the email server, to the people who handle enquiries;
• we ask only for the data we need (the telephone number is optional), and the form is protected against automated submissions by bots and against submissions from other websites;
• the website has no visitor accounts or passwords, and access to the hosting configuration and to the mailboxes is restricted to authorised people;
• the website sends security headers that, for example, prevent its pages from being displayed inside other websites’ pages.

No system connected to the Internet is completely secure. As the law requires us to state when data is collected over open networks, personal data may travel over the network without security conditions, with the risk of being seen and used by unauthorised third parties (Article 25(7)). Please do not send us, through the form or by email, information you would not want exposed, such as passwords or bank details.

13. Minors

This website is intended for adults and does not knowingly collect data from anyone under 18. If you are under 18, please do not send us personal data.

If you know that a minor has sent us data, ask us to delete it, using the controller’s contact details. We delete it as soon as we have confirmed the request, unless the law requires us to keep it.

• Controller’s contact details

14. Automated decisions

We do not take decisions based solely on automated processing of your data, nor do we create profiles to evaluate aspects of your personality or behaviour.

15. Cookies

This website stores a single cookie, ic_consentimento, to remember your choice, and only counts visits if you allow it. The cookie policy explains everything and lets you change your choice at any time.

• Cookie policy

16. Changes to this policy

We may amend this policy to reflect the law, guidance from the APD or changes to the website and to the services we use. The version in force is the one published on this page, with the version number and the date of the last update at the top of the document. You may ask us for previous versions.

If a change significantly alters the processing of data already collected, we will let you know through a prominent notice on the website and, where we have your contact details and the change justifies it, by email. Where a change requires your consent, we will ask for it again.

17. Governing law and language

This policy is governed by Angolan law, in particular Law no. 22/11 of 17 June (Personal Data Protection Law) and Law no. 23/11 of 20 June (Electronic Communications and Information Society Services Law), which recognises the right to privacy of personal information on the Internet (Article 15).

This policy is available in Portuguese and in English. In the event of any discrepancy between the two versions, the Portuguese version prevails.