Last updated 19th October 2020
1. Who We are:
2. What information do We collect from you, for which purposes and what is Our legal ground to do so?
In the first place, We need to collect and process information that you provided to Us during the registration process, when you deposit funds, or throughout your use of the Service. This is necessary in order to open/set up your account and enable you to use the requested Services. This information is collected and processed based on your acceptance of Our Terms and Conditions (based on the Agreement with Us). The following is the minimum necessary information that We process based on the specific function of the Services that you use:
- Contact information: your name, surname, address, age, birth date, gender, email address, phone number, zip code;
- Financial information: in order to operate online payments also based on the Agreement with Us. Depending on the payment method you use, We collect your payment account details such as your account number, registered name of account owner, and billing address;
- Furthermore, due to Our obligations under applicable gaming and Anti Money Laundering (AML) legislation, We are required to ask you for supplementary documents such as identification documents including your identity card or relevant document, your photo, copies of the relevant credit card/s, documents regarding your source of wealth, utility bills and other documents depending on the relevant jurisdiction as well as the transactions executed. Please note that as per our data sharing agreements, your Personal Data is shared between various brands which Betsson Group operates to meet Our AML obligations.
- Finally, We need to keep track of self-excluded customers in order to fulfil Our legal obligations related to responsible gambling (RG). The way of verification of self-excluded customers depends on the specific jurisdiction. Please note that for the purpose of fulfilling Our obligations coming from relevant gaming laws, We need to share and check data about self-excluded customers and customers with gambling issues among Betsson Group companies and local authorities in order to enable cross-network exclusion and similar measures where necessary.
The above-mentioned points are the minimum necessary information that we collect in order to register you as Our customer and set up your account. Please be aware that if you do not want to provide this information to Us, We will not be able to provide you with the requested Service.
Moreover, We also collect and process data that We produced based on your activity while you are using Our Services. Such data are processed for the following purposes:
- On the first place We need to collect these data in order to provide you with requested Services;
- Our customer support is working 24/7 to resolve any potential technical or other issues while using Our Services. In order to help you with your requests they will need to use data you provided for registration as well as data about your activity to enable you to use Our Services without any interruptions, in accordance with our Terms and Conditions. Please note that calls with our customer support may be recorded for the purpose of potential legal disputes;
- We need to analyse complete customer activity, gambling patterns, including bets placed in order to provide you with requested Service as per Agreement with Us (data necessary for provisioning of the Service). This data is processed for the following purposes:
- We are required to implement measures to identify and investigate any suspected unlawful or fraudulent activity connected with the Services, including possible money laundering, the use of proceeds of crime, terrorist financing and fraud. Hence, in order to comply with Our obligations arising from the relevant AML and gambling license regulations We need to analyse your transactions/bets/behaviours and create a risk profile. This includes identity verification, as well as other measures depending on jurisdiction and facts of the case (for suspicious/risky activities we need to apply additional measures of verification);
- We need to analyse your activity and gambling patterns in order to prevent, detect and manage responsible gambling matters (RG) and to ensure that your use of Our Services is responsible and in accordance with relevant gambling regulations. In line with Our RG procedures, We carry out risk assessments on players by analysing behaviour, transaction, usage, and other data such as communications;
- To protect Our business, ensure fairness based on Our Terms and Conditions and prevent and detect fraud, We need to oversee compliance with Our Terms and Conditions and Our internal policies e.g. to refuse, terminate or limit any bet, wager or account, to manage Our risks and odds, etc. In order to do so We need to process data about your activity and betting history;
- In some cases, We may use automated or semi decision-making processes to help Us to execute certain actions. For example, Our systems will automatically prevent you from depositing funds beyond limits set by you; or you will not be able to register from countries that are on the sanction list (or with IP address that is on blacklist due to fraud) or if you are on the list of Politically Exposed Persons (PEPs); or self-excluded players will not be able to access Our Services (e.g. games). Please note that any decisions which produce legal or significant effects are not taken without human intervention unless this is allowed by law, or this is necessary to enter into an Agreement with you;
- Also, all the above processing operations that include an analysis of betting patterns/behaviour and other customer related information rely on profiling. Tools and procedures followed are backed up by rigorous research and are regularly audited and fine-tuned to ensure that they are fair, effective and unbiased. Please be aware that information about these profiling activities, especially the logic behind profiling activities for these purposes (based on AML, RG law, for fraud detection, risk analysis of risky bets) cannot be revealed since that would allow customers to bypass these mechanisms aimed at the protection of Our business and compliance with legal obligations.
- We will also analyse your betting patterns and activity in order to investigate and identify any possible issues related to integrity, malpractice and other seriously improper conducts in sport, such as match-fixing based on Our legitimate interest and/or legal obligation. Where We have a suspicion about such activities or We receive a well-grounded legitimate request to share information about such activities from a relevant body (including sports bodies and associations), We are required to disclose this information to them;
- Based on Our legitimate interest to carry out surveys and market research in order to: evaluate customer experience and identify how We can improve Our Services and products, prioritise Our product features and improve product designs or to evaluate creative campaigns to ensure that communication is relevant and appropriate. In order to do so, We make use of the data you provided at registration and also the data that We collect from surveys. You can always object to this kind of processing. Please note that most of Our surveys as well as our market analysis will be anonymous (i.e. this will not involve any processing of personal data), hence such will be out of scope of this Policy;
- We will use details of the products you have previously used, information about your preferences and use of the Services, based on Our legitimate interest to make suggestions to you for other products/promotional offers which We believe you will also be interested in (you can be subject to targeted advertisements). Please be aware that based on this logic for specific brands We might use different types of profiling, in order to offer you with the relevant information and promotions. If specific types of profiling might produce legal or similarly significant effect on you, We will ask for your consent before taking such action. Please note that you can always object to this kind of processing and we will stop profiling for marketing purposes where we use it;
- We collect information from the devices you use for Our products and services in order to ensure that we provide Our Services in a secure manner and that We can solve any technical issue. This includes, but is not limited to your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data.
- We also collect server logs, which include information such as your logins (first log in, last login, last failed login), duration of log ins, the app features or pages you view, app crashes and other system activity.
- All your data may be analysed for business insight and intelligence purposes, where mostly anonymised data will be used, so this will not affect your privacy and personal data;
- All your data will be retained and may be used for potential legal claims, in order to defend Our company business based on Our legitimate interest.
In addition to the above, your contact details or profile ID will be used:
- To communicate offers and other promotional materials to your registered phone number, email address or other direct contact based on your consent to send direct marketing messages. Kindly note that you can, at any time and free of charge, change your direct marketing communication settings from your account, or by sending Us an email, or via the unsubscribe button in order to opt out from receiving any direct marketing communication to your phone number and email address;
- To send you on-site/in-app marketing messages to your profile, based on Our legitimate interest to inform you about important updates/promotions related to all Our brands. You will only be able to see these messages when you log-in to your profile (app). Whilst static in-game advertising forms part of Our Services (i.e. it is not direct marketing as adverts are not based on any user characteristics but are common for all users), dynamic in-game advertising is tailored for the user therefore you can always object to this specific kind of processing by sending an email to Us;
- To send you push notifications in order to keep you updated about important events/promotions related to all Our brands while you are browsing Our or other websites, only upon your consent that you can revoke at anytime;
- To pass on Service communications regarding your account and the Services through different communications channels. This is based on Our legal obligations, Our agreement with you and/or in Our legitimate interest to keep you informed as well as your legitimate interest to be informed about important updates that affect how you will use Our Services. In order to inform you about these We will use your contact details (email, SMS, or phone where feasible) or We will send you these messages to your profile. Please be aware that these are not marketing messages, but Service information that you need to be aware of as Our customer. Please note that where Service communications are sent in Our or your legitimate interests, you can always object to this kind of processing.
Finally, We may combine the information We collect from you with the information that We create or receive from other sources, such as public databases, providers of demographic information and other third parties (such as, data brokers). These include the following:
- For the processing purposes of the prevention or detection of crime, fraud as well as responsible gambling as described above based on Our legal obligations and legitimate interest, We supplement the information that you provide to Us with information that We receive from third parties or collate by accessing third party sources, including (without limitation) information published on the internet about or by you, information provided by third party providers such as KYC agencies, providers of verification services/tools, etc.;
- Data brokers to whom you provided your data in order to share with their business partners, or any other company that has permission to share your data. We will use these data brokers/companies when we want to enrich Our customer information with additional information that they have about your other activities. Also, We can use these brokers as well as other companies (social media platforms, etc.) for prospective marketing – creating prospective audience segments that may be interested in Our products, and exposing them to marketing campaigns via the technologies available (DPSs, real time biding, etc.). Please be aware that when We use your data for these purposes, We will only cooperate with partners that can assure Us they collected data from you in accordance with the GDPR (i.e. based on your consent). Moreover, We will make sure that We process your personal data in accordance with GDPR principles and We do not obtain information about your behaviour that would reveal special categories of your personal data.
We also collect certain information about Our customers as well visitors of Our websites via cookies. For more information about cookies that We use, please read Our Cookies Policy.
3. With whom might We share your information?
Your Personal Information will be transferred or disclosed (for the purposes described in this Policy) to any EEA company within the Betsson Group for business and operational purposes based on our intra-group data processing agreements.
Apart from that, We share your data with Our business partners (recipients) in order to provide you with the Services requested. In general, these partners are Our data processors that act only based upon Our instructions. However, in some cases, they can act as joint/separate controllers (like payment providers or social media platforms). We always share your data with them in accordance with the GDPR and subject to appropriate agreements. Categories of recipients with which We share data are:
- Gaming and software providers;
- Third-party suppliers that provide technical support, and maintain your account with Us;
- Analytics and search engine providers that assist Us in the improvement and optimisation of Our site;
- Vendors for communication purposes such as Our marketing platforms or voice call and SMS mobile communication service providers;
- Partners carrying out surveys and market research on Our behalf;
- Interactive media platforms (social media platforms and similar);
- Organisations that enable Us to place interesting and relevant promotions on third party websites and platforms you visit;
- Payment service providers and payment facilitators;
- Cloud service providers;
- Analytics tools;
- Anti-fraud, risk and compliance service providers (KYC verification providers and similar);
- Suppliers of information verification services for the purposes of validating the information you provide to Us in the course of interacting with Us or entering into a contract with Us;
- Professional advisers such as lawyers, auditors, consultants and insurers, providing Us with legal, advisory and insurance services;
- Other partners that are helping Us to create a better experience for you.
Please note that Our internal processing operations are conducted within countries in the European Economic Area (EEA) which are bound by the General Data Protection Regulation (GDPR) and in Kenya where the Data Protection Act of 25th November, 2019 applies. With regards to service providers or partners located outside the European Economic Area (EEA) in a third country, territory or sector that has not been found to provide for an adequate level of data protection by the European Commission (see here the list of third countries offering an adequate level of data protection as per the European Commission), We ensured that the data transfers are subject to appropriate safeguards, such as the Standard Contractual Clauses.
Please be aware that the list of providers (recipients) may differ depending on the brand and country where you make use of Our Service. Hence, on your request, We can provide you with the categories of recipients whom we share data with, and also specific information about data transfers to third countries.
Where required by law, your Personal Information may be disclosed to an applicable governmental, regulatory or enforcement authority for the purpose of prevention and detection of different type of crimes or in response to any court subpoena, order or similar official request. In certain cases, relevant laws may oblige Us to disclose your Personal Information to financial institutions such as banks and insolvency services. Your Personal Information may also be disclosed to any regulatory or sporting body in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and where there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game. Those bodies may then use your Personal Information to investigate and act on any such breaches in accordance with their procedures.
We may share some or all of your Personal Information with any subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all Our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization. Alternatively, We may seek to acquire other businesses or merge with them. In the event of a change to Our business, We will inform you in accordance with applicable law.
4. How long do We retain your information?
We will retain your information only for as long as is necessary for the purposes set out in this Policy. Where Your information is no longer required by Us, We will either securely delete or anonymise the Personal Data in question.
The criteria we follow in determining what is ‘necessary’ depends on the nature of data; the purpose of processing; the legal basis in place including but not limited to consent; whether there are any applicable statutory obligations or industry codes of practice; and other relevant circumstances.
After closing your account, We will retain your information to the extent necessary to comply with Our legal obligations such as applicable tax/revenue laws, AML and gambling laws and other applicable regulatory requirements as well as to resolve any potential legal disputes. Please be aware that due to applicable AML and gambling regulations as well as for the purpose of any potential legal claims, We need to store all your personal data for specific retention periods defined in these laws. Since retention periods are jurisdiction specific, for further information about data retention terms relevant to your jurisdiction, please contact Our data privacy team at email@example.com.
5. Your rights:
You as the data subject have certain rights with respect to the Personal Data, We hold on you. These include the following:
- Right to obtain confirmation that We are processing your data and have access to or obtain a copy of the same. Kindly observe that as a general rule, subject to exemptions provided by applicable laws, We reserve the right not to disclose:
- Information which is likely to prejudice either an internal ongoing investigation (for example in relation to fraudulent behaviour, bonus abuse etc.) or one conducted by the relevant authorities in relation to other offences;
- Our AML/TF and RG risk assessments and monitoring information pursuant to applicable laws, since this disclosure is likely to prejudice the operation of the business by enabling customers to bypass mechanisms specifically set for the prevention and detection of such activities;
- Information relating to ongoing negotiations with the data subject if such disclosure is likely to prejudice any negotiations to settle disputes/issues;
- Information relating to Our internal processes including customer and risk management procedures which are strictly confidential, and disclosure would disrupt internal business operations;
- Information including third party personal data since such disclosure may adversely affect the rights and freedoms of the third parties in question; and
- Information subject to Legal Professional Privilege (LPP).
- Right to request correction or completion of your incorrect or incomplete personal data to the extent allowed by law;
- Right to erasure where:
- Your personal data are no longer necessary for the purposes which they were collected;
- The lawful basis for processing is consent and you withdraw your consent;
- You object to processing based on legitimate interests and there is no overriding interest to continue processing;
- Data processing is done for direct marketing purposes and you object to such processing;
- Data processing is unlawful; or
- Personal data must be erased for compliance with a legal obligation.
Kindly note that right to deletion is not absolute and may be limited e.g. due to Our legal obligations, such as AML laws, or for the establishment, exercise or defence of legal claims (meaning We will not be able to exercise this right in relation to the data that We need to keep based on these retention periods for their duration);
- Right to restrict processing where:
- You have asked Us to rectify your data and We are in the process of verifying the accuracy of such data;
- Personal data processing has been unlawful and ask for restriction instead of deletion;
- Your personal data is no longer needed for the Services but you request Us to retain it in order to establish, exercise or defend a legal claim; or
- You have objected to Our processing of your data based on legitimate interest and We are evaluating whether Our legitimate interests override yours.
Kindly observe that your data will be stored for the time of restriction and shall be processed only if you gave your consent or in order to establish, exercise or defend legal claims, protect the rights of another natural or legal person and for the reasons of important public interest;
- Right to data portability i.e. right to transmit personal data you have provided Us with in a structured, commonly used and machine-readable format to another controller where the processing is based on consent or contract and carried out by automated means;
- Right to object where processing is based on legitimate interests, tasks carried in public interest and/or where your personal data are processed for direct marketing purposes, including profiling for these purposes. The latter is an absolute right while the first one will require a balance assessment of your interests, rights and freedoms against Our legitimate interests;
- Right to obtain human intervention, express your point of view and contest the decision where it is based on solely automated decision making, including profiling, which produces legal effects concerning you or similar significant effects.
Please note that We will respond to any of your requests about your rights within 30 days at the latest (this period may be further extended in line with applicable law).
Finally, please note that you have a right to lodge a complaint with the Data Commissioner, as per the applicable data privacy regulations.
6. How to contact Us: