Last updated: September 14, 2026
The service for assisting us with 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 brand operating by different affiliated companies within a group of companies of Vincent Group Limited and its related companies across various countries. The specific entity responsible for managing your Personal Data depends on the country of recruitment and may be either VG Estonia OÜ (Registration Number 14591789, address Kai 4, 10111 Tallinn, Estonia) or StayCool OÜ (Registration Number 12814989, address Kai 4, 10111 Tallinn, Estonia) or Juegos a Distancia S.A.C. (Registration Number 15461866, address Calle Jorge Guillermo Leguía No. 488, Piso 1 Urbanización Residencial, Miraflores, 01, Lima) (jointly or separately further referred to as "Coolbet", “we”, “us”). 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 Notice (“Privacy Notice”) 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”), Peruvian Law No. 29733 on the Protection of Personal Data.
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?
Coolbet is the controller of your Personal Data for the purposes described in this Privacy Notice, 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 Notice apply to?
2.1. This Privacy Notice applies at every stage of recruitment process, including when:
2.1.1. individuals applying for employment with Coolbet;
2.1.2. individuals who connect with us through our careers site to receive information about current or future employment opportunities;
2.1.3. individuals whose professional profiles we identify through publicly available sources for recruitment purposes;
2.1.4. individuals referred to us by employees or recruitment partners;
2.1.5.individuals acting as references for candidates; and
2.1.6. 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 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 LinkedIn;
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 LinkedIn;
4.1.3. provide Personal Data in the chat or via email to us, or to our service providers contacting you on our behalf, including via email, SMS or via other communication and messaging platforms/channels and such data is of relevance to the application procedure;
4.1.4. during testing, offsite and/or online (video) interviews for your evaluation on suitability for vacancy made by our recruitment team and hiring managers;
4.1.5. after you are identified as the preferred candidate for a specific role, during reference checks, verification and screening where relevant to the role;
4.1.6. provide additional personal data upon being selected for the role as may be necessary to prepare your employment contract;
4.1.7. provide any data and documents when connecting through our careers site to receive information about current or future employment opportunities.
4.2. We may collect your Personal Data indirectly:
4.2.1. from third parties, such as recruitment agencies, compliance and risk management platforms, 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 Notice 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 (“AI”) assisted functionality is enabled, your Personal Data provided directly during any stage of the recruitment process may be processed by such AI-driven solution(s) to assist our recruiters with tasks such as summarising applications, generating interview questions, assisting in communications and supporting candidate evaluations. Please, note that neither of the tools independently selects, ranks, or rejects candidates, every decision to progress or reject an application is made by a human member of our recruitment team. For instance, to assist us in reaching our candidates via communication and messaging platforms/channels we may use AI-driven solutions of JuttAI OÜ. You will be told beforehand that you are communicating with an automated AI assistant, and you may exit or stop the conversation at any point. The conversation proceeds only with your consent. Before or at the start of the chat, you will see a link to this Privacy Notice and either an explicit consent checkbox or a clear statement that continuing the conversation constitutes your consent to the processing described here. If you do not consent, it shall not influence our decision to contact you by the use of an alternative communication solution. Please refer to the relevant Privacy Notice of JuttAI OÜ for further information about how such a provider processes Personal Data.
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 via Service: 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, if you are not currently living in the city and/or country (if applicable and required for the vacancy) are you open to relocating, your monthly gross salary expectation, when could you start working with us, how did you hear about the opportunity, details of your referral, what motivates you to join us, link to apply with your LinkedIn profile, other additional questions as may be applicable for particular position (like, list tools and technologies you have used in a professional capacity, indicating your level proficiency with each).
5.1.2. Any additional data which you may have provided to us or to recruitment agencies in your application documents (curriculum vitae (CV), cover letter and any additional documents). The scope of such data depends fully upon you and may include, but is not limited to: date of birth, photo, work experience and employment history, job titles, qualifications, suitability and competence, educational background, language(s) and other skills, your contact details,
5.1.3. Any additional data which you may have provided otherwise within the recruitment process). The scope of such data may depend from the position you apply for or may be necessary for preparation of your employment contract with successful candidates, and may include, but is not limited to: document verifying your identity, or confirming your eligibility for vacancy, right to work stay in the country (like, visa, residence permit, work permits), background checks, national identification number, personal data related to criminal convictions and offence. Such data shall not be processed by TeamTailor AB and will be requested separately via a dedicated communication solution.
5.1.4. Data generated during the recruitment process, such as interview video or audio recordings and transcripts, 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.
5.1.5. Data obtained from social networks, state registers and other publicly accessible sources, including but not limited to LinkedIn accounts.
5.1.6. Data provided to us by your referees (if applicable), vendors for reference checks and screening, or recruitment agencies (if applicable).
5.1.7. Technical information relating to your use of the Service, including IP address, browser type, operating system, device identifiers, pages visited and session information.
5.1.8. Data generated through candidate communications, including emails, messages submitted through the Service and communications relating to interview scheduling.
5.1.9. Data and documents which you have provided to us when subscribing through our careers site to receive information about current or future employment opportunities.
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 is not considered as Personal Data.
5.3. 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.
5.4. Special Category Data
5.4.1. When you apply for a role with us, we only request the Personal Data that is necessary to assess your application. We do not ask you, and you are not required, to include in your CV, cover letter, or any supporting document: racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric data, health information, including disability status, data concerning sex life or sexual orientation, (together “Special Category Data”, as defined in Article 9 GDPR).
5.4.2. Please, mind that if you choose to include Special Category Data in your CV, cover letter, or any other document you submit, and provide it to us, such documents including Special Category Data shall be immediately deleted from our records and we will contact you and request to remove such Special Category Data from your documents and re-submit your application within Service. Such measures are necessary to ensure that we do not Process your Special Category Data which is not required for the position. Deletion occurs at the file level, no separate deletion, redaction, or review process is applied to individual data elements, including any Special Category Data, prior to the scheduled deletion.
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 (including personally, via LinkedIn, email, communication and messaging platforms/channels directly or via our service providers) and, where applicable, contacting your referees, conducting interviews and assignments, performing interview recording or taking notes, and preparation of employment contract with successful candidates.
Legal basis: Taking steps at your request prior to entering into an employment contract and, where applicable, our legitimate interests in identifying, assessing and recruiting suitable candidates. Where required by applicable law for a specific processing activity, we may rely on your consent.
6.1.2. Considering your application with all documents provided by you 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. Conducting background or criminal record checks, verification and screening where required or permitted by applicable law and where necessary for the position applied for.
Legal basis: Compliance with a legal obligation or other applicable legal basis under applicable law permitting the processing of personal data relating to criminal convictions and offences, subject to the safeguards required by such law.
6.1.4. Maintaining, securing, operating and improving the Service and recruitment process, including analysing the performance of our careers site, detecting, investigating and preventing misuse, fraud or other illegal activities.
Legal basis: Legitimate interests where applicable, or legal obligation in ensuring security of recruitment platform and process.
6.1.5. Using third party service providers and AI assisted functionality to support recruitment activities, including involving recruitment agencies, use of Teamtailor AB Platform, summarising applications, assisting with interview preparation, drafting and performing recruitment communications, translating, improving the efficiency and consistency of recruitment processes.
Legal basis: Your consent, or our legitimate interests where applicable in operating an efficient, consistent and secure recruitment process.
6.1.6. Establishing, exercising or defending legal claims, disputes, responding to requests from competent authorities and complying with applicable legal and regulatory obligations, as part of our affiliates’ regular reporting activities, to protect our rights and property, in connection with an actual or potential merger, sale of company assets, financing, or acquisition of all or part of our business to another company.
Legal basis: Compliance with legal obligations, or our legitimate interests where applicable in protecting our legal rights and interests.
6.2. If we rely on legitimate interests as the legal basis for processing, where it is applicable and permitted as per legal framework, 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. For example, statistics of internet traffic or the geological location for the use of the Service. 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.
6.5. We may collect and use information about you that you have made or is publicly available through social media, websites or other publicly accessible sources as part of our recruitment activities, including for identifying potential candidates, assessing their professional qualification or experience, and further contacting you regarding our employment opportunities.
6.6.Where we rely on your consent as the legal basis for processing, you may withdraw your consent at any time via our Data&Privacy board or by contacting us at privacy@coolbet.com. Withdrawal of consent will not affect the lawfulness of processing carried out before the consent was withdrawn.
7. How long your Personal Data will be retained?
7.1. We retain your Personal Data only for as long as necessary to fulfil the purposes described in this Privacy Notice, 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 or you have requested to remove your Personal Data earlier, or you have requested to extend the retention period for further 18 (eighteen) months, Personal Data relating to unsuccessful applicants will generally be retained for 18 (eighteen) months following the conclusion of the relevant recruitment process.
7.2. Personal Data of individuals who connected with us through our careers site to receive information about current or future employment opportunities will be retained for 18 (eighteen) months, unless you have requested to remove your Personal Data earlier, or you have requested to extend the retention period for further 18 (eighteen) months.
7.3. We will contact you via email informing about the possibility to extend your permission for retention of your data upon expiration of 18 (eighteen) months retention period, and if you have not extended such permission within 1 (week) your personal data will be automatically deleted.
7.4. 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.
7.5. 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. It will be deleted immediately by us following the date of termination of employment.
7.6. Your Personal Data related to criminal record checks will be deleted immediately following the completion of the selection process in case:
7.6.1. you were selected for the position you applied for, and the performed criminal record check showed that you have criminal records;
7.6.2. 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.
7.7. Personal Data collected during the recruitment process about successful candidates with whom the employment contract has been concluded will become part of their employee profiles.
8. Your legal rights and what we may need from you
8.1. You have certain rights in relation to the use of your personal data. They are;
8.1.1. The right to request access to your Personal Data that is processed by us.
8.1.2. 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.
8.1.3. 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.
8.1.4. 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.
8.1.5. 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.
8.1.6. 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.
8.1.7. 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.
8.1.8. Where available, you may also exercise certain privacy rights directly through your Teamtailor candidate profile or the Data&Privacy board available on our careers site.
9. Security
9.1. 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 is processed safely and in accordance with this Privacy Notice and applicable legislation.
9.2. 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.
9.3. While no transmission of information over the internet can be guaranteed to be completely secure, we implement appropriate technical and organisational measures designed to protect Personal Data transmitted to and processed by us. We also encourage candidates not to provide unnecessary sensitive information through unsecured communication channels.
10. Who may we share your Personal Data with?
10.1. We do not trade, share, transfer, or disclose any of your Personal Data, except as is otherwise provided in this Privacy Notice or as otherwise required by and in accordance with applicable law. 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.
10.2. We may share your Personal Data for the purposes set out earlier with the following parties:
10.2.1. Staff of our Human Resource department involved with respect to a particular job role you have applied for or requested to include you in our talent pool, subscribed to current and future vacancies;
10.2.2. our parent or subsidiary companies;
10.2.3. 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;
10.2.4. our service providers acting as independent controllers, or as processors or sub-processors on our behalf, including, but not limited to recruitment agencies, LinkedIn, providers of recruitment platforms, AI-driven recruitment functionalities service providers, email, server and cloud hosting providers, information sourcing companies, communication and messaging platforms/channels, recruitment assessments, analytics, technical support and other services necessary for the recruitment process;
10.2.5. authorities or legal advisors in case criminal or improper behavior is suspected, or in case of any dispute or claim; and
10.2.6. authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.
11. Transfers of your Personal Data
11.1. As part of our global operations, your Personal Data may be transferred to countries outside the European Economic Area ("EEA") and Peru. Where such transfers take place, we ensure that appropriate safeguards are implemented in accordance with Chapter V of the GDPR and Peruvian Law No. 29733 on the Protection of Personal Data. Where applicable, these safeguards may include:
11.1.1. the recipient or importer of the Personal Data is located in a country that has an adequate level of data protection; or
11.1.2. the European Commission's Standard Contractual Clauses; or
11.1.3. participation in recognised international data transfer frameworks, such as the EU-US Data Privacy Framework; or
11.1.4. Model Contractual Clauses, approved by Resolución Directoral No. 074-2022-JUS/DGTAPID;
11.1.5. any other lawful transfer mechanism recognised under applicable data protection legislation.
12. Cookies
12.1. Our careers site uses cookies and similar technologies to operate the website, improve user experience, analyse website performance and maintain security. When you visit our Website for the first time, we seek your consent to use cookies, with the exception of those strictly necessary for the website’s operation. Further information regarding the cookies used, their purposes and how you can manage your preferences is available in our Cookie Policy.
12.2. You can at any time disable the use of cookies by changing the local settings in your devices or via our Data&Privacy board. Disabling cookies can affect your experience of the Service, for example disabling some functions in the Service.
13. Do we change the current Privacy Notice?
We may update this Privacy Notice from time to time to reflect changes in our recruitment practices, applicable legal requirements or the services we use. We encourage you to frequently check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated. Check the date at the top of the notice for the latest version.
14. How can you contact us?
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.
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