VIDEO SURVEILLANCE POLICY AT ADRIA CASINO D.O.O. COMPANY LOCATIONS – SENATOR

AUTOMATIC CLUBS AND CASINO

1. GENERAL ABOUT VIDEO SURVEILLANCE, THE PURPOSE AND LEGAL BASIS OF THE PROCESSOR

This Video Surveillance Policy at the locations of Adria Casino d.o.o. (Head of personal data processing) – Senator automat clubs and casino (hereinafter: Video Surveillance Policy) refers to video surveillance systems at all facilities of the company Adria Casino d.o.o. in the Republic of Croatia. The aim is to protect facilities, property, staff, guests, and visitors, all in accordance with the Law on the Protection of Financial Institutions.

The processing of personal data through video surveillance is based on valid regulations in the Republic of Croatia and is justified by the legitimate interest of protecting the company’s facilities and personnel and reducing the risk of robberies, burglaries, and other forms of violence, possible dangers, or unauthorized access to protected premises. Each video surveillance system is designed and installed in accordance with valid regulations. By analyzing the legitimate interest, it was determined that in the case of video surveillance in the premises of automatic clubs and casinos, the interests of the data controller prevail over the interests of the data subjects. The goal is to minimize the impact of video surveillance on the privacy of employees and guests. 

The processing of personal data through video surveillance is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, the Law on the Implementation of the General Data Protection Regulation, and other valid regulations governing systems of protection and supervision. 

A system project was created for each individual location of Adria Casino d.o.o. This video surveillance is designed and installed in accordance with the provisions of the Law on the Protection of Financial Institutions, the Act on Occupational Safety, the Act on Physical Protection, and other legal regulations. These projects are confidential and are kept accordingly as planned. They were created by an authorized company. In accordance with the Ordinance on Spatial and Technical Conditions for Holding Games of Chance in Casinos, Adria Casino d.o.o. has an audio-video surveillance system installed at the casino location, as referred to in this Video Surveillance Policy. 

The video surveillance policy consists of 3 (three) documents:

– Basic document – ​​Video surveillance policy, which contains general information that

refers to all locations of Adria Casino d.o.o.

– Appendix 1. – view of the appearance of the notification from the video surveillance, which is set to more locations across all company locations – complex notifications and simplified notifications

– Appendix 2 – project documentation of the video surveillance and audio surveillance system for every single location of the company that is classified as secret and insight into that document have only authorized persons according to the Ordinance on conditions and methods of implementation of technical protection (OG 198/2003). 

2. INFORMATION AND RIGHT TO VIEW RECORDINGS

At all locations of Adria Casino d.o.o., video surveillance was established in accordance with legal regulations. In the casino, both video and audio surveillance systems are installed in accordance with the Ordinance on Technical and Spatial Conditions for Organizing Games of Chance in Casinos. At each location, a notice from Appendix 1 of this Video Surveillance Policy has been posted in several places, especially at the entrance. This notice includes a symbol or image of the video surveillance camera and all other necessary information as required by regulations. 

Signs indicating that the area is under video surveillance are placed wherever possible and, at the latest, when entering the recording perimeter. All persons entering the recording perimeter or the company location itself are considered informed about the processing of personal data by video surveillance conducted by Adria Casino d.o.o. 

This Video Surveillance Policy is published on the company’s website, which can be easily accessed by scanning the barcode on the video surveillance notification. Competent authorities, for the purpose of carrying out tasks within their jurisdiction, may be provided with video surveillance footage upon receiving a written request that contains all the necessary information about the requested recordings. 

3. DATA PROTECTION AND RIGHT OF ACCESS 

To ensure the security of recorded data collected by the video surveillance systems, Adria Casino d.o.o. has implemented technical and organizational measures:

• Digital recorders for video surveillance are located in protected rooms with technical protection measures and appropriate levels of access.
• Access to recorders and recorded content is reserved exclusively for authorized personnel of Adria Casino d.o.o. and employees of companies that perform physical and technical protection activities, such as Klemm Security d.o.o. and ADC-Alarmni Centar d.o.o. (collectively referred to as Data Processors).
• Only the administrator or a company authorized by Adria Casino d.o.o. is permitted to create, change, add, or delete user access levels in accordance with this Policy.
• All employees who have access to live recordings of specific locations have this stipulated in their employment contracts, as well as in the Code of Conduct for the protection of personal data. This includes a prohibition on recording or sharing video surveillance footage or photographs thereof. All video recordings are the property of Adria Casino d.o.o. and are considered trade secrets.

The storage period for video surveillance recordings from slot clubs is 10 days, while recordings from the casino are kept for a minimum of 60 days, in accordance with regulations. These recordings are deleted after the specified period. If there is a need for litigation or any other significant legal process, and recordings need to be retained longer than prescribed, they are kept within the organizational unit until the conclusion of the process. 

4. EXERCISE OF THE RESPONDENT’S RIGHTS AND PROCEDURE IN CASE OF ABUSE 

For all issues related to the processing of personal data and the exercise of your rights, you can contact the Personal Data Protection Officer. If you believe that one of your rights has been violated, you can file a complaint with the Personal Data Protection Agency at Selska cesta 136, Zagreb, or via email at azop@azop.hr. 

Each written request received will be recorded by the head of personal data processing, and a response will be provided in writing within no more than 30 days. 

CONTACT OFFICER FOR THE PROTECTION OF PERSONAL DATA:

E-mail: zastitapodataka@senator.hr

Adria Casino d.o.o., Dubečka 1, Zagreb.

This Video Surveillance Policy shall enter into force on the date of adoption and publication on the Internet website of Adria Casino d.o.o.