Notice of Consent for the Processing of Biometric Data – Facial Photographs

FAVORIT SPORTSKA KLADIONICA doo is, in accordance with §9.2(15) of the Law on Anti-Money Laundering and Terrorism Financing ("Official Gazette" no. 108/17, 39/19, 151/22) (hereinafter referred to as: ZSPNFT), obliged to implement measures, actions and procedures to prevent and detect money laundering and financing of terrorism.

One of the obligations of FAVORIT SPORTSKA KLADIONICA doo is to conduct client due diligence measures, which, among other things, includes determining the client's identity and verifying their identity on the basis of documents, data or information obtained from a credible, reliable and independent source, all as prescribed in §15.1(1) of the ZSPNFT.

§16.1 of the ZSPNFT stipulates that the obligation to apply client due diligence measures occurs:

• when establishing a business relationship with a client
• for every occasional transaction with a value of 10,000.00 euros and more, regardless of whether it is a one-time transaction or several transactions that are clearly related to each other and which in total reach a value of 10,000.00 euros and more
• in the organizing of games of chance services, when placing bets and receiving winnings, including the purchase or exchange of tokens with a value of 2,000.00 euros and more, regardless of whether it is a one-time transaction or several transactions that are clearly related to each other and that in total they reach a value of 2000.00 euros and more
• if there is doubt about the authenticity and appropriateness of previously obtained data about the client
• whenever there are reasons to suspect money laundering or terrorist financing in connection with a transaction or client, regardless of all prescribed exemptions and the value of the transaction

In relation to point 3 from the previous sentence, §16.3 of the ZSPNFT stipulates that the party obliged to apply the measures (the company FAVORIT SPORTSKA KLADIONICA doo) is obliged to collect the following information from the client: name and surname, place of residence, day, month and year of birth, identification number if visible from the identification document, name and number of the identification document, name and country of the issuer, citizenship/citizenships.

The Ordinance on the introduction of a remote party and the minimum requirements that must be met by a decision establishing and verifying the identity of a remote party ("Official Gazette" No. 9/24), which Ordinance was adopted pursuant to the ZSPNFT, prescribes the conditions for introducing a remote party and establishing and verifying the identity of a natural person.

Since FAVORIT SPORTSKA KLADIONICA d.o.o. organizes games of chance (casino and betting games) through remote (online) channels and is at the same time liable to the ZSPNFT, it is obliged to establish the identity of each individual player when establishing a business relationship, i.e. when registering a user that the company implemented on the basis of the Law on Games of Chance ("Official Gazette" No. 87/09., 35/13., 158/13., 41/14., 143/14., 114/22.), the Ordinance on the organization of remote betting games ("Narodne novine" No. 8/10, 63/10., 22/15) and the Ordinance on the organization of games of chance in casinos through interactive online gaming sales channels ("Narodne novine" no. 78/10.) to carry out measures of in-depth analysis of each individual player, which means checking their identity, or the verification.

For the purpose of verifying the players, FAVORIT SPORTSKA KLADIONICA doo uses video electronic identification/verification technology in accordance with the above-mentioned Ordinance on remote party introduction and the minimum conditions that must be met by a solution that establishes and verifies the party's identity remotely. §3.2(5) of the aforementioned Ordinance stipulates that FAVORIT SPORTSKA KLADIONICA doo is obliged to ensure that the first transaction with a newly introduced party is carried out after the due diligence measures from §15 ZSPNFT have been carried out, which in-depth analysis certainly includes the verification of the identity of each individual party.

Video electronic verification includes three separate procedures that follow one immediately after the other:

• Photographing the front and back of an ID card (other identification document) with a camera, which verifies the authenticity of the document, the so-called "Document Integrity Check"
• Photographing the face of the person undergoing the video electronic identification procedure in order to determine the "liveliness" of the person (when the face of the person undergoing the procedure is turned, the system automatically photographs the person's face from different angles)
• Checking the correspondence of the person's photo from their ID card (other identification document) with the photos taken by the system during the procedure referred to in point 2.

Since the purpose of the aforementioned verification of clients is primarily to confirm their identity and fulfill the obligations arising from the ZSPNFT, which relate to conducting due diligence on clients and the Act on Restrictive Measures ("Official Gazette" No. 133/23), which obligations relate to checking the existence of restrictive measures in relation to individuals with whom a business relationship is established, or the countries from which these individuals originate, and in relation to which restrictive measures have been imposed, the system will, in addition to checking the correspondence between the personal document and the person's face, check through publicly available databases whether the specified person is on any global sanctions list, PEP list, watchlist, blacklist and whether the specified person comes from any of the sanctioned countries.

BIOMETRIC DATA PROCESSING – facial photographs

Biometric data is personal data obtained through specific technical processing relating to the physical, physiological or behavioural characteristics of an individual which enable or confirm the unique identification of that individual, such as facial photographs or dactyloscopic data.

FAVORIT SPORTSKA KLADIONICA doo may process biometric data only and exclusively on the basis of voluntarily given consent, all in accordance with §6.1(a) of the General Data Protection Regulation (hereinafter referred to as: GDPR), in conjunction with §9.1 and §9.2(a) of the GDPR.

FAVORIT SPORTSKA KLADIONICA doo will request consent for the processing of biometric data when verifying your user account or verifying your identity via the website www.favbet.hr Consent is required for the unique identification of the facial photograph as biometric data by comparing it with the photograph on the ID card, all in accordance with the procedure explained above.

It is important to emphasize that consent is voluntary and its granting or withholding is in the exclusive domain of you as a client. Refusal to grant consent will not have any negative consequences for you and will not mean denying the possibility of verifying you as a client.

If you refuse to give consent, you will be able to complete the verification at any branch (betting shop) of FAVORIT SPORTSKA KLADIONICA doo and the verification will be identical to the one completed via the website www.favbet.hr.

CONSENT INFORMATION

You can read all other information about the processing of your personal data in our Privacy Policy.

*Last updated: February 2025