This Privacy Policy explains how SIA “Alfor” and SIA “Admirāļu klubs” as the controller of personal data processing (hereinafter referred to collectively as the Controller) process personal data and provides information about the data subject’s rights under the Personal Data Processing Law and General Data Protection Regulation 2016/679 (hereinafter referred to as the Regulation).

The purpose of this Privacy Policy is to inform the customers, employees, business partners and visitors of the website about the processing of personal data, its purposes and personal data protection measures.

Data controller contact information

Controller: SIA “Alfor”, registration No 40003512913, registered and actual address Plieņciema iela 12, Mārupe, Mārupes novads, LV-2167, e-mail address: , telephone number: 67301000.

Controller: SIA “Admirāļu klubs”, registration No 40003249010, registered and actual address Plieņciema iela 12, Mārupe, Mārupes novads, LV-2167, e-mail address: , telephone number: 67301000.

E-mail of the Data Protection Officer:  un .

Information on the processing, acquisition, transfer and protection of personal data

The Controller shall comply with the following data processing principles in order to ensure adequate data protection measures:

  • personal data is collected from the data subject on the basis of consent;
  • the processing of personal data is based on a contractual obligation for the purposes set out in the contract;
  • processing of personal data is necessary to ensure the performance of obligations under laws and regulations;
  • inform the data subject for what purposes the personal data are collected and used;
  • process personal data in accordance with the Regulation and other applicable laws and regulations;
  • process and collect personal data:
  • for accounting and human resources purposes;
  • to protect their legitimate interests;
  • to comply with laws and regulations;
  • to join the Fenikss Club loyalty program;
  • for marketing purposes;
  • take precautions to prevent the loss, misuse and unauthorized access, disclosure, alteration and destruction of personal data;
  • take appropriate technical and organizational measures to protect the data systems on which personal data are stored;
  • personal data are collected, processed, stored and transmitted in automated and/or document-based processing systems;
  • ensure that access to personal data is restricted to appropriate authorized persons who need such access in order to carry out their official duties;
  • personal data are processed lawfully and fairly;
  • personal data are not stored for longer than required by laws, regulations or for the purpose of the processing;
  • personal data may be disclosed to law enforcement authorities, state and local authorities upon a legally substantiated request from the relevant authority;
  • the data is processed in a member state of the European Union (EU) or the European Economic Area (EEA). Personal data is not transferred to or processed in a country outside the EU/EEA.

The Controller does not process special categories of personal data concerning data subjects.

Purpose of processing of personal data

The Controller processes personal data for the following purposes:

  • to identify a customer whose transaction amounts to EUR 2 000 or more, the customer must provide the following information: name, surname, personal identification number, date of birth, identity document and copy thereof, telephone number, e-mail address, nationality, source of funds, employment details;
  • for the payment of winnings of EUR 3000 or more, the customer must provide the following information in order to complete the prize payment record: name, surname, personal identification number, current account number (if the prize is paid by bank transfer to a bank account specified by the player);
  • to ensure public order and compliance with laws and regulations, continuous video surveillance is carried out inside and outside the gambling halls;
  • to ensure the lawful operation of the Controller in relation to the recruitment, employment, dismissal of employees, provision of social security benefits, determination and calculation of salaries and other payments;
  • to ensure the Controller’s lawful activities in relation to the receipt, consideration and decision-making of applications for employment or the rejection of an applicant for employment;
  • to ensure the performance of the contract, the keeping of records and the administration of payments for services provided or received;
  • to maintain and improve the website;
  • to ensure customer participation in the Fenikss Club loyalty program.

Legal basis for processing of personal data

The Controller processes personal data on the following legal grounds:

  • for the conclusion and performance of a cooperation agreement
  • to comply with laws and regulations – to fulfil an obligation under laws and regulations;
  • in accordance with the data subject’s consent;
  • for legitimate interests – to fulfil contractual obligations and achieve contractual objectives or legitimate interests deriving from laws, regulations or administrative provisions;
  • for the vital interests of the data subject or another natural person – to ensure the physical safety of employees and visitors of the Controller.

Reimbursement of expenses

The Controller shall not be entitled to claim reimbursement of expenses under the Regulation, except where the data subject requests more than one copy of the data, including where there are multiple requests for the same personal data. In such a case, the Controller may charge a reasonable fee based on administrative costs incurred.

Storage of personal data

The Controller shall store personal data in accordance with the purposes of processing personal data and the legal grounds for processing personal data set out in this Privacy Policy for as long as at least one of the following circumstances exists:

  • there is a legal obligation to keep the data for a certain period of time in accordance with the requirements of laws and regulations;
  • it is necessary to pursue the legitimate interests of the Controller;
  • it is necessary to fulfil the contractual obligations.

Rights of the data subject

The data subject shall have the right to obtain information on what personal data the Controller holds and for what purpose they are processed, to request correction, supplementation or deletion of data, to transfer data (data portability), as well as to withdraw their consent to data processing if the data processing is carried out on the basis of consent, by submitting an application to the Controller, Plieņciema iela 12, Mārupe, Mārupes novads, LV-2167, or an application signed with a secure electronic signature, sent to the e-mail address:  or 

The Controller shall communicate with the data subject using the contact details (telephone number, e-mail address, address) provided by the data subject. The data subject may receive the requested information within one month from the date of receipt of the request by post, which will be sent to the address indicated in the application by registered post or e-mail, or in person at the Controller’s office at Plieņciema iela 12, Mārupe, Mārupes novads, LV-2167.

In case the data subject is not satisfied with the response received, the data subject shall have the right to lodge a complaint with the Data State Inspectorate at Blaumaņa iela 11/13-11, Riga, LV-1010.


The website uses cookies to help improve the user experience and ensure the functionality of the website.

When visiting the Controller’s website, the user is presented with a window with a message that the website uses cookies. If the website user accepts cookies, the legal basis for the use of cookies is the user’s consent, by which the user confirms that he or she has read the information about cookies, the purposes of their use, and the cases in which information is passed on to third parties.

The Controller uses cookies on its website ( An “internet cookie” is a small file consisting of letters and numbers that will be installed on a visitor’s computer, mobile device or any other device from which the data subject accesses the internet.

The cookie is set via a request sent to the web browser (i.e. Internet Explorer, Firefox, Chrome) by the web server and is completely “passive” (it does not contain software, viruses or spyware and cannot access information on the hard drive of the data subject’s device).

Cookies allow the Controller to obtain valuable feedback in relation to the devices from which the data subject visits websites on the Internet, thereby facilitating the data subject’s access to the websites and integrating applications or features into the website that may provide the data subject with a better website navigation experience, making it more useful and enjoyable.

For more information about cookies, including how you can find out what cookies are set on your device and how to manage or delete them, visit:

Contact us in case of any questions

If you have any questions about the processing of your personal data, please contact the Controller or its Data Protection Officer by one of the following means: e-mail:, telephone: 67301000.

The Controller has the right to unilaterally amend or supplement this Privacy Policy. The current version of the Privacy Policy is published on the Controller’s website