Technical Reporting


The Operator is required on a regular basis to report to CEG on the status of its technical infrastructure. It is also required the report to CEG in the event of any incidents. For the purpose of maintaining a proper technical infrastructure, the Operator shall appoint a Data Protection Reporting Officer, (hereinafter: the “DPRO”) who as the Non-Executive Director shall be responsible for the filing of a Quarterly preformatted Data Protection Report (hereinafter: the “DPR”) on matters of Data Protection with the designated authorities.

The Executive Director shall be responsible for the drafting of the DPR and shall timely present a properly filled out DPR to the DPRO for approval and filing with the authorities as meant in Both the Executive Director as well as the Non-Executive Director are required to sign the DPR prior to its filing.

Minimum DPR reporting requirements

The DPR shall at minimum include the following information:

(i) an overview of used Hardware and Software, including proof of licensing;

(ii) key figures on disputes between the Operator and Third Parties, including however not limited to Complaints received by the Operator regarding licensing;

(iii) actual overviews of:

(a) website Seal displays;

(b) operational Aliases;

(c) geo-blocking measures;

(d) Disaster Recovery Procedures;

(iv) results on testing methodologies;

(v) any Incidents.

The DPRO is required to reside, as a resident, within Curaçao. The DPRO is allowed to combine other duties, if this may be deemed appropriate. Notwithstanding the obligation to file reports on a regular basis as defined in the IP Agreement, for which purpose CEG has made a template available, the Operator is also required to Report Incidents to CEG at the time these Incidents transpire. Failure to timely and properly do so, shall result in a Material Breach of the IP-Agreement.

The said obligation to file an Incident Report shall always exist in the following circumstances:

(i) Any notification of infringement regarding Territory or other Regulatory Infringement;

(ii) Violations of Good Industry Practice.

No special circumstances in the event of dormancy

The Operator that has been granted Dormancy Status as referenced in Article A.7.10., shall not be exempt from any of its obligations deriving from Article A.6. and shall therefore remain fully responsible for the Operation during the time of dormancy