Owner and Proprietor
The Burman Hotel is located at Rataskaevu Street TN 7, 10123, Tallinn, Estonia (referred to as “The Burman”). The Club is owned and operated by the Bombay Group OÜ, (Company Number:16132057), registered at Harju maakond, Tallinn, Kesklinna linnaosa, Rataskaevu tn 5, 10123.
For the purposes of data control and processing in accordance with applicable laws and regulations related to your use of our services, both Bombay Group OÜ acts as the Controller of your personal data. Within the context of this notice, these entities will be collectively referred to as “The Burman”, “we”, “our”, or “us”.
We value our guests (“you”) and your privacy, ensuring the highest standards to protect your personal data.
Compliance with Data Protection Laws
We process personal data in accordance with applicable personal data protection laws, including the Regulation of the European Parliament and the Council (EU) 2016/679 (“GDPR”) and the Personal Data Protection Act of Estonia.
Bombay Group OÜ respects your right to privacy and ensures that you can exercise your rights. Further details on how to do so are provided below.
Please note that we may update this Privacy Policy from time to time, and we will notify you of any changes. The latest version will always be available on our website.
Terms and Definitions
Data Subject: Identified or identifiable natural person whose data is processed.
Personal Data: Any information concerning an identified or identifiable natural person (“data subject”). An identifiable natural person is someone who can be identified, directly or indirectly, using attributes such as name, personal identification code, location information, network identifier, or physical, physiological, genetic, mental, economic, cultural, or social characteristics.
Processing of Personal Data: Any automated or non-automated operation or set of operations performed on personal data, including collection, documentation, organisation, structuring, storage, modification, querying, reading, use, transfer, distribution, joining or combining, restriction, deletion, or destruction.
Profiling: Any automated processing of personal data to evaluate certain personal aspects of an individual, particularly regarding performance, financial status, health, personal preferences, interests, reliability, behaviour, location, or movements.
Controller: A natural or legal person, public entity, agency, or body that determines the purposes and means of processing personal data.
Processor: A natural or legal person, public entity, agency, or body processing personal data on behalf of the controller.
Special Categories of Personal Data: Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as processing genetic data, biometric data for unique identification, health data, or data concerning an individual’s sex life or sexual orientation.
Third Party: A natural or legal person, public entity, agency, or body, other than the data subject, controller, processor, or those authorised to process personal data under the direct responsibility of the controller or processor.
Consent: A voluntary, specific, informed, and unambiguous statement by which a data subject agrees to the processing of their personal data.
Data Controller:
Company Name: Bombay Group OÜ (16132057)
Address: Suur-Patarei 13, 10415 Tallinn, Estonia
Contact Email: [email protected]
Cookies
Our website utilises cookies, which are small data files exchanged between your computer’s browser and our web server. Some cookies are essential for the website’s functionality and cannot be opted out of, while others can be controlled by you. You may change your cookie preferences at any time. Further details can be found in our Cookie Policy.
Categories of Personal Data
We collect and retain personal data according to the following categories and retention periods:
- Guest Services — Name, Date of Birth, Identity Documentation (Image), Gender, Nationality, Citizenship, Ethnicity, Biometric Data, Address, Email Contact, Telephone Contact, Visits, Interactions with us (including Digital, Social Media, Emails and Phone Calls), Names, dates of birth, and citizenship of accompanying spouse or minors — Retention Period 7 years
- Finance — Name, Date of Birth, Identity Documentation (Image),,,, Biometric Data, Address, Invoices, Financial Transaction History, Bank Account Details, Bank Card Details, Payment Services, Complaints. — Retention Period 7 years
- Marketing — Personal data and preferences. — Retention Period 7 years
- Preferences and Activity — Visits, Service Interactions, Complaints and Disputes, Financial Transactions, Gaming Behaviour. — Retention Period 7 years
- Complaints & Issues — Complaints and evidence of unlawful activities.— Retention Period 7 years
- AV Recordings — Audio Recordings within operational areas, CCTV of the Premises, Facial Recognition and Incident Management. — Retention Period 7 years
AV Recordings: CCTV, Facial Recognition as well as audio recording software is active upon entry to the Burman and throughout the casino premises, to enable the effective monitoring and traceability of individuals.
We do this in order to prevent and investigate any crime, and under the legitimate interest of protecting our premise, employees and guests. We also use CCTV across premise perimeters.
Data we may process under a legal obligation
Basis: We have a legal obligation to collect and process specific Personal Data on each Guest and/or Entrant, such as the Tourism Act, and other legal basis where the processing activities include processing such information as necessary to comply with public safety obligations, our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others.
Type of Data: Guest Services; Finance and AV Recordings.
When Data is Processed: We may collect and process this Personal Data in circumstances including, but not limited to, the following:
- When you apply for membership / access to services, enter the Club, use its facilities, or when you update your personal details or ID documents with us.
- When we verify your identity and personal details, or when we conduct security, due diligence, gaming dispute and/or compliance checks.
Your Rights: Because the Personal Data referred to above is processed pursuant to a legal obligation, there is no right to erase or object to this data, or have this data made portable.
Data we may process under our contract with you
Basis: When you become a Guest and/or access our services, you enter into a contract with us to provide certain services to you. This contract includes the Hotel Rules and Terms & Conditions. It is necessary for us to process certain Personal Data about you in order to provide those services to you, including to maintain our accounts and records, to support and manage our staff, our customer services, and for the purposes of administration.
Type of Data: Guest Services; Finance; Preferences and Activity; Complaints & issues and AV Recordings.
When Data is Processed: We may collect and process this data:
- When you apply for Accommodation, access our Services, use our Facilities, or when you update your personal details or ID documents with us;
- When we verify your identity and personal details;
- When you contact us, request services, report a problem, or wish to make a complaint.
Your Rights: You have the right to ask us to erase such Personal Data collected pursuant to our contract with you, and we will delete any such Data (other than data we are required to retain in accordance our Legal Obligations). In relation to this Data, you also have the right to data access and data portability.
Data we may process with your specific consent
Basis: When you Access our Services, we will ask your express permission to contact you in relation to some of our additional services, events, general updates about the Burman or other marketing materials (“Global Marketing Communications”). You do not have to give your consent, and we will not contact you with Marketing Communications unless you do so.
Type of Data: Marketing.
When Data is Processed: We may collect and process this data:
- If you give us your express permission to do so when you either applying for Accommodation or accessing our Services, or you ask us to update your marketing preferences;
- In the event that we, or one of our entities, or substantially all of its assets are acquired by a third party, Personal Data held by Us may be one of the transferred assets.
Your Rights: You are entitled to qualify, vary or withdraw your consent in relation to Marketing whenever you want to. You also have the right to ask us to erase such Personal Data collected with your consent. In relation to Data obtained in this way, you also have the right to data access and data portability.
Data we may process for a legitimate interest
Basis: We process specific data in order to protect the legitimate interests of our Company, our employees and Guests. Our legiti-mate interests include securing our premises, counter-fraud measures and investigations, conducting and managing our business, the maintenance of records, such as gaming, hospitality and financial details obtained throughout the course of our relationship.
Our Guests, Service users and employees, have a legitimate interest in feeling safe and secure whilst on our premises in accordance with the Hotel Rules and Terms and Conditions.
Type of Data: Guest Services; Finance; Preferences and Activity; Complaints & issues and AV Recordings.
When Data is Processed: This Data is used upon entry to one of our premises, as you transact with us and throughout the casino premises and surrounding areas, specifically the Burman’s perimeter, to enable the effective monitoring and traceability of individuals.
Your Rights: Whilst you are entitled to object to some of this processing and correct, incorrect data, the only way you can exercise an objection to processing is by not entering our Premises. Any Personal Data will be deleted after the expiry of the retention period, provided it is not being actively used in any Legal and/or ongoing investigations.
Where your personal data may be stored
The information that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party. We are based in Estonia and your information will be accessed and used here and elsewhere in the European Economic Area (EEA) where we enable the provision of the contracted services.
While countries within the EEA all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection of your personal data. In each case, your data may, for purposes described in this notice or otherwise approved by you, be transferred to, processed by and stored by persons operating outside of the EEA and the third party may require access to all or some of your data. For example:
- Other Bombay Group trading companies based outside the EEA may need to use data in accordance with this notice;
- Our staff, suppliers or agents located outside of the EEA may need to access and process personal data to fulfil requested and or contracted services or provide other support services;
- We may use cloud-based technology hosted outside of the EEA to host some of our applications;
- We may use service providers based outside of the EEA to help us support some of our information technology infrastructure and these service providers may need to access your personal data in order to provide and support that infrastructure.
When we send personal data outside of the EEA we take steps to put in place appropriate safeguards to protect the information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed in accordance with applicable data protection laws. We protect your personal data, for example, by:
- Transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data;
- Where possible, putting in place standard contractual clauses (SCC`s) in accordance with European Commission decisions on transferring personal data.
- Requiring all Bombay Group, subsidiaries, and sister companies to be subject to group data protection policies, designed to protect data in accordance with EU data protection law;
- Ensuring access controls which limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know;
- Ensuring they will only process your personal information on our instructions, for the reasons we specify.
We may also from time to time rely on one or more of the ‘derogations’ available in applicable data protection laws, for example:
- The transfer is necessary for the establishment, exercise or defence of legal claims; or
- We have the individual’s explicit consent; or
- The transfer is necessary for the conclusion or performance of a contract in the interest of the individual concerned, and we are party to that contract; or
- The transfer is necessary in order to perform a contract between us and the individual concerned, or the implementation of pre-contractual measures taken at the individual’s request.
We may also be compelled by law to disclose your personal data to a third party and will have limited control over how it is protected by that party in such circumstances.
Access to your personal data
When you ask to see a copy of your personal data as permitted under data protection laws we will supply you with all the personal data to which you are entitled, promptly and normally no later than one month after the receipt of your data subject access request. In rare cases, where the requests are complex or contain multiple requests, the period of compliance may be extended by a further two months, but we will write to you and explain why any extension is required within one month of your request.
We will want to ensure that we have properly identified anyone making a data subject access request and may therefore ask to see additional identification.
Any access request is normally free, although in some cases we may charge a reasonable fee based purely on our administrative costs when a request is clearly unfounded, is made excessively, or is made repetitively.
You may also have the right to Data Portability which allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. If you wish to exercise this right, we will transmit such data to you in a machine-readable code where it is technically feasible to do so.
How long do we keep your personal data?
Generally, we comply with the retention periods specified above although there may be exceptions, such as where there is an on-going legal enquiry. Your personal data may also be subject to increased internal restrictions on accessing. For example, personal data may be removed from front office functions and only accessible by senior management with specific reasons.
Who do we disclose your personal data to?
In accordance with this Privacy Policy and for specific purposes, we may share some of your information with the following categories of third parties. Any trading company within the Bombay Group, which includes the Bombay Club, and our sister companies (“other companies with close affiliations to us, owned by the same ultimate parent company”), and their respective subsidiaries and or trading brands for the purposes set out in this notice (for example, information and customer relationship management; software and service compatibility and improvements; and to provide you with any information, applications or services that you have requested):
- Authorised representatives or agents acting on our behalf with respect to the promotion of our services in particular territories;
- Suppliers where necessary, in performance of services which you have contracted, with or through us (which may include sharing data in order to perform and process payments associated with performance of such services);
- Information technology companies undertaking services for us in connection with maintenance, support, development or enhancement of our websites or our other information technology platforms and infrastructure;
- Third parties that we may engage to perform market surveys/client feedback surveys, subject to your selected preferences;
- Third parties which we engage to securely host communication services (emails and SMS) and act as suppliers to distribute our notifications and other marketing communications on our behalf, both where you have requested information and where we believe that information will be of interest to you;
- Companies used to facilitate payment transactions arising from engagement of our services;
- Credit reference agencies for the purposes of supporting mechanisms which assist us in safer gambling and affordability assessments;
- Fraud prevention agencies;
- Recruitment agencies or website recruitment platforms in the context employment;
- Law enforcement agencies, regulators or other applicable third parties, where necessary to enable us to comply with our regulatory and legal obligations (including statutory or regulatory reporting or the detection or prevention of unlawful acts ), or where necessary to assist them in the conduct of their investigations;
- Authorised third parties engaged to support us in performing customer and enhanced customer due diligence checks;
- Our clients (if you are a supplier), in the course of performing any engagement for services;
- Relevant third parties in the context of actual or potential legal proceedings (for example in response to a court order, enforcement of the terms of a contract and debt recovery);
- Our own professional advisors and auditors for the purpose of seeking professional advice or to meet our legal, regulatory and auditing responsibilities;
- Another organisation if we sell or buy (or negotiate to sell or buy) any of our companies, business or assets.
We may compile statistics about the use of our websites including data on traffic, usage patterns, user numbers, and other information. All such data will be anonymised and will not include any data which can be used to identify you either by itself or when combined with other data. We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties, but this will not include information that can be used to identify you.
Your Rights: You have the right to object to this and to correct any incorrect data. Please note that access to our Services may be conditional on allowing us to share this personal data.
Changes to this policy
From time to time we will need to update, change or supplement this Policy, including by altering the types of Personal Data that may be collected, processed or shared. If this happens, we will update this Policy on our website, in our literature before such changes come into effect. If you do not agree to these changes then you will have to inform us and by continuing to access our Services, you consent to those changes.
Your rights
You have the following rights (“Data Rights”):
- The right to be informed: This privacy policy is intended to meet our obligation to provide “fair processing information”.
- The right of access: You have the right at any time to ask to see a copy of the personal data we hold about you.
- The right to withdraw consent: Where you have given your consent to our processing you may withdraw this at any time.
- The right to rectification and data quality: If your personal data is incorrect or incomplete then you may ask us to remedy that.
- The right to erasure including retention and disposal: You may ask us to delete or remove your personal data where there is no compelling reason for its continued processing but this may affect any services we provide to you which relies on that personal data.
- The right to restrict processing: Where you have highlighted an issue with the data.
- The right to data portability: This allows you to request that your personal data be shared with other processors at your request.
- The right to object: Where you have an objection to our processing you may do so.
You may also have the right to lodge a complaint with the Estonian Data Protection Inspectorate if you believe we are in breach of our legal obligations under data protection laws.
Contact us
If you wish to exercise any of your Data Rights, if you have any questions, complaints, or comments regarding this Policy, please contact us:
- by email to: [email protected]
- Contact Us through the Burman Website:
To further query your rights regarding your Personal Data, to lodge a complaint, raise a concern about how your complaint has been handled and / or appeal against any decision made following your complaint, in accordance with your rights, you may contact the Estonian Data Protection Inspectorate.