1. General rules
1.3. We have taken technical and organizational measures to ensure the security of your personal data.
1.4. Please note:
1.4.2. However, the transmission of the personal information provided by you to us is a basic requirement for the conclusion of a contract with us (Terms of Service). In addition, you may not use the Website and/or Services or only to a limited extent if you do not provide us with certain data or object to the use of this data.
2. Which personal data we process and from which sources
2.2. Data that we automatically collect when you use our Services:
2.2.1. As soon as you launch one of our Services, you send technical information to our web servers.
2.2.2. In any case, we collect the following access and web access data (which we call "Usage Data"):
18.104.22.168. Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
22.214.171.124. Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
126.96.36.199. Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
2.2.3. We process the Usage Data in order to enable you to use the Services and to ensure the functionality of the Website and Services.
2.2.4. In addition, we process the Usage Data to analyze the performance of the Services, continuously improve the Services and correct errors or personalize their content for you. However, we also process Usage Data in order to guarantee IT security and the operation of our systems and to prevent or detect misuse, in particular fraud.
2.3. Personal Data that you yourself transmit to us, or that we collect ourselves:
2.3.1. Registration details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth data, physical address, ID number, phone number, etc.
2.3.2. Governmental-issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
2.3.3. Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information will be collected from you, such as your debit card number and bank account details.
2.3.4. Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature.
2.3.5. Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device's unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
2.3.6. Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.
2.3.8. Feedback, reviews and testimonials: We also collect and display personal testimonials, reviews and feedback of satisfied Users on the Services in addition to other endorsements. With your consent, we may post your testimonial along with your name, on the Services. If you wish to update or delete your testimonial, you can contact us.
2.3.9. Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
2.4. We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.
2.4.1. Fulfillment of a contract, compliance with a legal obligation It is necessary for us to process your Personal Information where it is necessary for the performance of a contract and complying with any AML and KYC legislation.
2.4.2. Legitimate interests: We also process your Personal Information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) detection and retention of information pertaining to those who violate the Terms; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iv) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (v) adhering to regulatory and statutory requirements; (vi) devising a tailored reward scheme for players; and (vii) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
2.4.3. Consent: Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances, your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
2.4.4. Special Categories of Personal Data: Our processing of your Personal Information may also involve special categories of personal data, such as your racial or ethnic origin. We will process such information, as well as disclose it to competent authorities (such as licensing bodies or law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act, (ii) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes. In addition, we may process and disclose such information where it is necessary for the purposes of safeguarding your (or others') economic well-being.
2.5.1. The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher ("Legally of Age"). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
2.5.2. We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us.
3. The legal basis for processing
3.1. When processing your personal data, we rely on various legal bases in accordance with the so-called General Data Protection Regulation, The Digital Personal Data Protection Bill (2022, India), an EU-wide legal framework for standardizing data protection laws ("GDPR").
3.2. We use your Personal Information for the purposes listed below:
3.2.1. To set up, manage and update your account;
3.2.2. To provide and operate the Services (such as for betting and payment processing);
3.2.3. To communicate with you and to keep you informed of our latest updates to our Services and special offers;
3.2.4. To market our Services, as well as to serve you advertisements, including behavioral advertising;
3.2.5. To promote our Services by displaying Users' testimonials of our Services. The testimonials are displayed on our Services as well as on websites operated by our affiliates and partners.
3.2.6. To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
3.2.7. For Customer Management purposes, and to support and troubleshoot the Services and to respond to your queries;
3.2.8. To enable us to further develop, customize and improve the Services based on Users' common preferences and uses;
3.2.9. To identify and authenticate your access to certain features of the Services;
3.2.10. To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
3.2.12. To investigate and resolve disputes in connection with your use of the Services; and
3.2.13. As required by law or regulation (such as Know Your Customer ("KYC") and Anti-Money Laundering regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.
4. With whom we share your information
4.1. We share Personal Information with any of the following recipients:
4.1.1. White Label Brands, including any replacement service provider that the White Label Brand may engage to operate the White Label Brands (if applicable);
4.1.2. Companies within our group and other affiliated companies;
4.1.3. Subcontractors and third-party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, identity verification and fraud prevention services, and other data verifiers;
4.1.4. Payment service providers, payment processors and banks;
4.1.5. To any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within our group;
4.1.6. To hotels and flight companies (such as in the context of offline events and promotions);
4.1.7. Auditors, contractors or advisers of any of our group's business processes;
4.1.8. To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
4.1.9. Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
4.2.1. Storing such information on our behalf, for example by using cloud computing service providers;
4.2.2. Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
4.2.3. Performing research, technical diagnostics or analytics;
4.2.4. Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy; and
4.2.5. Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies, protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.
5. Transfer of information
5.1. Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the country of your residence. The data protection and other laws of these countries may not be as comprehensive as those in the country of your residence.
6. Data retention periods
6.1. We process and store your personal data insofar as this is necessary to fulfil our contractual or legal obligations. Therefore, we store the data for as long as our contractual relationship with you exists and after termination only to the extent and for as long as required by the law. If the remaining data is no longer required to fulfil legal obligations (e.g. in accordance with licensing, tax or commercial law), it will be regularly deleted, unless further processing is necessary to preserve evidence or to defend against legal claims against us. For the preservation of evidence, for example, your IP address and the exact time of issue are required if you have given us your consent (e.g. to receive a newsletter).
7. Information security
7.1. We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users' information, such as:
7.1.1. Secure network topology, which includes intrusion prevention and Firewall systems;
7.1.2. Encrypted communication;
7.1.3. Authentication and Access Control;
7.1.4. External and Internal audit tests; etc.
7.2. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
8. Your Rights
8.1. You may contact us at any time and request:
8.1.1. To access or delete any Personal Information relating to you;
8.1.2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
8.1.3. That we will restrict or cease any further use of your Personal Information;
8.1.4. That we will provide the Personal Information you volunteered to us in a machine-readable format.
8.2. Please note that these rights are not absolute and requests are subject to any applicable legal requirements. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
10. Vulnerabilities found in Websites
10.1. If you believe you have found a vulnerability in any sub-page of the Website or Service or application, please inform us confidentially through support service.
11.1. When you visit or access our Websites or applications operated by us, or when you interact or engage with our content ("Services"), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other technologies ("Tracking Technologies"). The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
11.2. We also allow third parties to collect information about you through Tracking Technologies.
What are cookies? Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings.
11.4. Storing Tracking Technologies. We store Tracking Technologies when you visit or access our Services (for example when you are visiting our Websites) - these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services - these are called "Third Party Tracking Technologies".
11.5. Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
11.6. There are five main types of Tracking Technologies:
11.6.1. Strictly necessary Tracking Technologies: These Tracking Technologies are essential to enable you to login, navigate around and use the features of our Services, or to provide a service requested by you (such as your username). We do not need to obtain your consent in order to use these Tracking Technologies. These Tracking Technologies can be used for security and integrity reasons - for example to detect violation of our policies and for support or security features.
11.6.2. Functionality Tracking Technologies: These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.
11.6.3. Performance Tracking Technologies: These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
11.6.4. Marketing or Advertising Tracking Technologies: These Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.
11.6.5. Social media Tracking Technologies: Our website includes social media features, such as the Facebook "Like" or "Share" buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.
11.7. Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including "Do Not Track" requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively:
11.7.1. Turning off cookies via your web browser: Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
11.7.2. Turning off third party cookies: you can turn off certain third-party cookies for advertising purposes by visiting the Network Advertising Initiative.