The service for handling recruitments and simplifying the hiring process (the "Service") is powered by Teamtailor AB (Registration Number 556936-6668, Address Östgötagatan 16, 116 21, Stockholm, Sweden) on behalf of Coolbet ("Controller" “we” “us” etc.). It is important that you, as an individual using the Service, feel safe with, and are informed about, how we handle your Personal Data in the recruitment process. Striving to maintain the highest possible standard regarding the protection of Personal Data we process and protect your Personal Data in accordance with this Privacy Policy (“Privacy Policy”) and Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).
Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
1. Who are we?
1.1. Coolbet is the controller of your Personal Data for the purposes described in this Privacy Policy, in accordance with applicable data protection legislation. As the controller, we determine the purposes and means of processing your Personal Data. Teamtailor AB provides and hosts the recruitment platform on our behalf and acts as our data processor, processing Personal Data only in accordance with our instructions and applicable data protection laws.
2. Who does this privacy policy apply to?
2.1. This Privacy Policy applies to:
● individuals applying for employment with Coolbet;
● individuals who connect with us through our careers site to receive information about current or future employment opportunities;
● individuals whose professional profiles we identify through publicly available sources for recruitment purposes;
● individuals referred to us by employees or recruitment partners;
● individuals acting as references for candidates; and
● visitors to our careers site where Personal Data are collected through the operation of the website.
3. How may we process your Personal Data?
3.1. We are responsible for the processing of the Personal Data that you directly contribute to the Service, or for the Personal Data that we may indirectly in other ways collect with regards to the Service.
3.2. “Processing” refers to any action or set of actions we perform on your Personal Data, and according to the General Data Protection Regulation (GDPR) encompasses a broad range of operations, which could be performed manually or automatically and include collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, erasure or destruction.
4. When and how do we collect your Personal Data?
4.1. We collect your Personal Data directly from you when you:
4.1.1. make an application through the Service or otherwise, adding personal data about yourself either personally or by using a third-party source such as Facebook or LinkedIn; and
4.1.2. use the Service to connect with our staff, adding your Personal Data either personally or by using a third-party source such as Facebook or LinkedIn.
4.1.3. provide Personal Data in the chat (provided through the website that uses the Service), via email, or other communications and such data are of relevance to the application procedure.
4.2. We may collect your Personal Data indirectly:
4.2.1. from third parties, such as Facebook, Linkedin and through other public sources; this is referred to as “Sourcing” and can be manually performed by our employees or automatically in the Service;
4.2.2. when our existing employee(s) make recommendations about you as a potential applicant and provide us your Personal Data for the recruitment purposes; in the cases where this is made, you are considered as the applicant of Services in the context of this Privacy Policy and you will be informed about the processing.
4.3. We also automatically collect specific technical details during your visits to our careers site. This includes your IP address, browser type and version, operating system, and device details, alongside session data and pages visited. Such data collection is essential for the operation, security, and enhancement of our recruitment Service.
4.4. During the recruitment process, we may also generate Personal Data relating to your application, including interview notes, assessments, communications, recruitment status updates and other records created throughout the recruitment process.
4.5. Where artificial intelligence assisted functionality is enabled within the Service, Personal Data contained in your application and related recruitment materials may be processed by such functionality to assist our recruiters with tasks such as summarising applications, generating interview questions, drafting communications and supporting candidate evaluations. All recruitment decisions remain subject to meaningful human review.
5. What Personal Data about you may be collected and processed?
5.1. Personal Data means any information about you we may collect and process through the recruitment process from which you could be identified, which includes, but is not limited to:
5.1.1. Data which you have provided to us in your candidate application form: your first name and last name, your place of residence (country, city), email address and phone number, data about the position being applied for, are you at least 21 years old, country (countries) citizenship/residence permit you own, your monthly salary expectation, when could you start working with us, how were you referred to us, what is the main reason you want to join us, link to your LinkedIn profile.
5.1.2. Additional data which you have provided to us in your application documents (curriculum vitae CV, cover letter and any additional documents), including, but not limited to: date of birth, photo, work experience and employment history, job titles, qualifications, suitability and competence, educational background, language skills and other skills, your contact details (such as postal address).
5.1.3. Data generated during the recruitment process, such as interview video, assignments, tests and notes, answers to questions asked through the recruiting, data related to personal and suitability assessments, and data related to the progress of the recruitment process and selection, information on whether your application can be used in other our recruitments.
5.1.4. Data obtained from social networks and other publicly accessible sources, including but not limited to LinkedIn and Facebook accounts.
5.1.5. Data provided to us by your referees (if applicable).
5.1.6. Technical information relating to your use of the Service, including IP address, browser type, operating system, device identifiers, pages visited and session information.
5.1.7. Data generated through candidate communications, including emails, messages submitted through the Service, communications relating to interview scheduling and, where applicable, audio or video recordings of interviews.
5.2. Please, bear in mind that:
5.2.1. if your identity has been removed from the data it will become anonymous data and that will not be your Personal Data;
5.2.2. we collect and process only your Personal Data that is relevant for the recruitment process and to the extent it is necessary;
5.2.3. your Personal Data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable and it cannot be used to identify you, and thus such data are not considered as Personal Data.
5.3. Although we have no intention to collect and do not ask you to provide, in the course of Services (for instance, in your CV) you may disclose to us your sensitive Personal Data, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation are considered as sensitive categories of personal data. Such sensitive Personal Data will be processed with extra care and security.
5.4. It is important that you provide us with up-to-date and accurate Personal Data in order to enable us to process your application. We may need to reject an application on the basis that insufficient, irrelevant, or false information has been provided to completely assess the application.
6. What is the purpose and legal basis for the processing of your personal data?
6.1. We process your Personal Data for the following purposes and on the following legal bases:
6.1.1. Managing and administering the recruitment process, assessing your suitability for current employment opportunities, communicating with you throughout the recruitment process and, where applicable, contacting your referees.
Legal basis: Our legitimate interests in recruiting suitable candidates and, where applicable, taking steps at your request prior to entering into an employment contract.
6.1.2. Considering your application for future employment opportunities where you have agreed to remain in our talent pool.
Legal basis: Your consent, where required by applicable law.
6.1.3. Recording interviews or carrying out other optional recruitment activities where your participation is voluntary.
Legal basis: Your consent.
6.1.4. Conducting background or criminal record checks where required or permitted by applicable law and where necessary for the position applied for.
Legal basis: Compliance with a legal obligation and, where applicable, our legitimate interests in ensuring the suitability, integrity and trustworthiness of candidates for regulated or sensitive roles.
6.1.5. Maintaining, securing, operating and improving the Service, including analysing the performance of our careers site, preventing misuse and ensuring the security of our recruitment platform.
6.1.6. Using artificial intelligence assisted functionality within the Service to support recruitment activities, including summarising applications, assisting with interview preparation, drafting recruitment communications and improving the efficiency and consistency of recruitment processes. Such functionality is used solely as a support tool and does not replace human decision making.
Legal basis: Our legitimate interests in operating an efficient, consistent and secure recruitment process.
6.1.7. Establishing, exercising or defending legal claims, responding to requests from competent authorities and complying with applicable legal and regulatory obligations.
Legal basis: Compliance with legal obligations and our legitimate interests in protecting our legal rights and interests.
6.2. Where we rely on legitimate interests as the legal basis for processing, we have carried out a balancing assessment and concluded that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
6.3. We may use non-personal information (which is non-identifiable information that, when taken alone, cannot be used to identify or contact you). As such, we are not aware of the identity of the user from which the non-personal information was collected. We use such information for different purposes, such as improving the Service, performing web analytics, maintaining the security of the Service and producing aggregated statistical information. We may gather such information either independently or through the assistance of our third-party service providers.
6.4. We do not make recruitment decisions based solely on automated processing. Artificial intelligence assisted functionality is used only to support recruiters in carrying out recruitment activities. All decisions regarding candidates are made or reviewed by appropriately authorised personnel.
7. Your consent on collection and processing of Your Personal Data
7.1. Certain processing activities carried out through the Service may rely on your consent where required under applicable law. This may include retaining your application for future recruitment opportunities, recording interviews or other processing activities that are optional or otherwise require your consent.
7.2. Where you voluntarily provide Personal Data, including special categories of Personal Data that we have not requested, we may process such information only to the extent necessary to evaluate your application and where permitted by applicable law.
7.3. Where we rely on your consent as the legal basis for processing, you may withdraw your consent at any time by contacting us at privacy@coolbet.com. Withdrawal of consent will not affect the lawfulness of processing carried out before the consent was withdrawn.
8. How long your Personal Data will be retained?
8.1. We retain your Personal Data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including satisfying legal, regulatory, accounting and reporting requirements. In determining the appropriate retention period, we consider the nature, sensitivity and volume of the Personal Data, the purposes for which it is processed, the risks associated with the processing and applicable legal requirements. Unless a longer retention period is required or permitted by law, Personal Data relating to unsuccessful applicants will generally be retained for up to 18 months following the conclusion of the relevant recruitment process.
8.2. To provide more information, when we choose the ideal candidate, before making the offer we will be doing the background check. After the background check is successful, we will continue with the offer. If you were selected for the position you applied for, but either you have not provided us with the criminal record check or the performed criminal record check showed that you have criminal records, then we will not be able to make you a job offer.
8.3. In order to comply with our legal obligations and for the due diligence process, to be able to ensure and demonstrate that our employees have not been convicted of any crimes, and are trustworthy and responsible, we will store your Personal Data related to the criminal record checks during the period of your employment if you were successfully selected and recruited for departments that can make decisions that affect carrying out gambling.
8.4. Your Personal Data related to criminal record checks will be deleted immediately following the completion of the selection process in case:
8.4.1. you were selected for the position you applied for, and the performed criminal record check showed that you have criminal records;
8.4.2. you were selected for the position you applied for, provided us with the criminal record check showing no criminal records, offered a job you applied for, but you have not accepted our job offer.
8.5. In case you were employed for the positions listed in clause 8.3. of this Privacy Policy, your Personal Data related to criminal record checks will be stored during the entire period of your employment and will be deleted immediately by us following the date of termination of employment.
8.6. We might keep your Personal Data for a longer period of time with your explicit consent, for example, for the purpose of future recruitment processes to consider you for future job roles which may come available at a later stage.
9. Your legal rights and what we may need from you
9.1. You have certain rights in relation to the use of your personal data. They are;
9.1.1. The right to request access to your Personal Data that is processed by us.
9.1.2. The right to request correction of inaccurate or incomplete Personal Data concerning you. Although we may need to verify the accuracy of the new data you provide to us.
9.1.3. The right to request the erasure of your Personal Data enables you to ask us to delete or remove your Personal Data where there is no good reason for us continuing to process it.
9.1.4. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing, where we may have processed your Personal Data unlawfully, or where we are required to erase your Personal Data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or regulatory reasons which will be notified to you, if applicable, at the time of your request.
9.1.5. Where processing is based on your consent, withdrawal of consent may affect our ability to carry out the specific processing activity for which consent was requested.
9.1.6. Under certain circumstances, a right to data portability, which means a right to get your Personal Data and transfer it to another controller as long as this does not negatively affect the rights and freedoms of others.
9.1.7. The right to lodge a complaint to the supervisory authority regarding the processing of your Personal Data, if you consider that such processing of Personal Data infringes the legal framework of privacy and data protection laws.
9.1.8. Where available, you may also exercise certain privacy rights directly through your Teamtailor candidate profile or the privacy functionality available on our careers site.
10. Security
10.1. We prioritize personal integrity and therefore work actively so that your Personal Data is processed with utmost care. We take the measures that can be reasonably expected to make sure that your Personal Data are processed safely and in accordance with this Privacy Policy and the GDPR.
10.2. We are committed to safeguarding the Personal Data you provide to us. We take appropriate levels of security to protect your Personal Data from accidental or unlawful access, use, disclosure, alteration, loss, or destruction. We also take steps to ensure ongoing confidentiality, integrity, availability and resilience of our networks and systems.
10.3. However, transfers of data over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that you also take responsibility to ensure that your Personal Data are protected and kept in secret. Although we will do our best to protect your Personal Data, we cannot guarantee the security of any Personal Data that you disclose online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have failed in our obligations under data protection legislation. For your own privacy protection, we encourage you not to include sensitive Personal Data (such as credit/debit card numbers) in any emails you may send to us.
11. Who may we share your Personal Data with?
11.1. We do not trade, share, transfer, or disclose any of your Personal Data, except as is otherwise provided in this Privacy Policy or as otherwise required by and in accordance with applicable law.
11.2. We may share your Personal Data for the purposes set out earlier with the following parties:
11.2.1. Staff of our Human Resource department involved with respect to a particular job role you have applied for;
11.2.2. our parent or subsidiary companies;
11.2.3. any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction in which information is required to be transferred to one or more third parties as part of such transaction;
11.2.4. our service providers acting as processors or sub processors on our behalf, including providers of recruitment platforms, artificial intelligence assisted recruitment functionality, cloud hosting, communications, recruitment assessments, analytics, technical support and other services necessary for the recruitment process;
11.2.5. authorities or legal advisors in case criminal or improper behavior is suspected, or in case of any dispute or claim; and
11.2.6. authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.
11.3. We will only transfer your Personal Data to third parties that we have confidence in. We carefully choose partners to ensure that your Personal Data is processed in accordance with current privacy legislation. We cooperate with the following categories of processors of personal data: Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regards to supplying the Service.
12. Aggregated data (non-identifiable personal data)
12.1. Aggregated data may be derived from your Personal Data but is not considered as Personal Data as this data does not directly or indirectly reveal your identity. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. We may collect, use and share aggregated data for any purpose (such as statistical or demographic).
13. Transfers of your Personal Data
13.1. As part of our global operations, your Personal Data may be transferred to countries outside the European Economic Area ("EEA"). Where such transfers take place, we ensure that appropriate safeguards are implemented in accordance with Chapter V of the GDPR. These safeguards may include:
● an adequacy decision adopted by the European Commission;
● the European Commission's Standard Contractual Clauses;
● where applicable, participation in recognised international data transfer frameworks, such as the EU-US Data Privacy Framework; or
● any other lawful transfer mechanism recognised under applicable data protection legislation.
14. Cookies
14.1. Our careers site uses cookies and similar technologies to operate the website, improve user experience, analyse website performance and maintain security. Further information regarding the cookies used, their purposes and how you can manage your preferences is available in our Cookie Policy.
14.2. You can at any time disable the use of cookies by changing the local settings in your devices. Disabling cookies can affect your experience of the Service, for example disabling some functions in the Service.
15. Do we change the current Privacy Policy?
15.1. We may update this Privacy Policy from time to time to reflect changes in our recruitment practices, applicable legal requirements or the services we use. The most recent version will always be available through our Service.
16. How can you contact us?
16.1. If you have a concern or any questions about our handling of your Personal Data, please contact our appointed Data Protection Officer (DPO) to try to resolve your query using the email privacy@coolbet.com.
Version 3.0
July 2026