Version: 1.0
Effective Date: [16/01/2024]

Overview

At DATA.BET, safeguarding your Personal Data is a commitment we take seriously. This Privacy Notice is your guide to understanding how we handle information about you when you engage with our website https://data.bet/, as well as any associated apps and our official social media representations (collectively ‘Website’) and use our products, services, and solutions (collectively ‘Services’). It covers the collection, usage, storage, and sharing of Personal Data, ensuring you remain in control. Please keep in mind that this Privacy Notice excludes cases where DATA.BET acts as a Processor on behalf of its Customers, a scenario detailed in the ‘Navigating Our Roles’ section.

Table of Contents

1. Key Definitions
2. Who we are
3. Navigating Our Roles
4. Data We Collect and Process
5. Sensitive Personal Data
6. Data Usage Practices
7. Data Retention Strategies
8. Ensuring Safety and Security
9. Sharing Your Personal Data
10. International Data Transfers
11. Automated Decision-Making
12. Your Privacy Rights and Choices
13. BET and Young Individuals
14. External Links
15. Changes and Updates

Key Definitions

For your convenience and comprehension, the terms commonly used in this Privacy Notice are defined below:

Controller: A party determining the purposes and methods of processing Personal Data.

Cookies: Small files transmitted from web servers to browsers.

Customers: Organizations providing online entertainment services to end users utilizing the Services of DATA.BET.

EEA: European Economic Area – EU member states, Iceland, Liechtenstein, and Norway.

EU: European Union.

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC (General Data Protection Regulation). You can acquaint yourself with the document here.

Personal Data: Information identifying an individual or linked to an identifiable person.

Processor: A party processing Personal Data on behalf of the Controller and according to its documented instructions.

Sensitive Personal Data: Information revealing sensitive aspects like race, ethnic origin, religion, political opinions, philosophical beliefs, or trade union membership, genetic and biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation; Personal Data relating to criminal convictions and offences.

Services: Any services, solutions, and offerings provided by DATA.BET, as described on the Website.

UK: United Kingdom of Great Britain and Northern Ireland.

Who we are

References to ‘DATA.BET’, ‘we’, ‘us’, or ‘our’ specifically pertain to DATA.BET Limited.

Country of Incorporation: Cyprus

Registration Number: HE 399638

Registered Address: Spyrou Kyprianou, 79, PROTOPAPAS Limassol, BLDG, Cyprus 2nd floor, Flat/Office 201, 3076, Limassol, Cyprus

For inquiries about Personal Data processing, reach out to us at [email protected]. We value transparency and are here to address your concerns.

Navigating Our Roles

Depending on the context, DATA.BET plays varied roles – at times as the Controller and at other times as the Processor. Understanding these roles is crucial for grasping the scope of our data processing practices and responsibilities.

DATA.BET as a Controller: Independently determining the purposes and methods of processing Personal Data, particularly that of our Customers and their representatives; or Personal Data of job applicants who are interested in our vacancies.

DATA.BET as a Processor: Handling Personal Data on behalf of our Customers and according to their documented instructions. This is relevant when our Customers provide us with some information related to their end users (such as IP address, information on activity – types, amount, results of bets, etc.) as necessary for delivering our Services. This Privacy Notice does not cover such scenarios which are subject to the data processing agreements with the Customers. If you are an end user of any of our Customers, please address your queries relating to data protection and privacy directly to the relevant Customers.

Data We Collect and Process

DATA.BET deals with various types of Personal Data, which can be grouped into several categories:

Directly Provided Data

Communication Data: Information provided when you fill out contact forms on the Website or communicating with us via email or other available channels.

This information includes your first and last names, your company name, your email address, your phone, and any information voluntarily provided by you in your messages. We keep this information to answer your questions or inquiries.

KYC Data: When engaging with us for the provision of our Services and/or entering into a contract, you will be required to provide KYC data by completing the relevant form(s). In this process, we collect the data you submit through these forms, which may include:

• Personal data of directors and ultimate beneficial owners (UBOs);
• Personal data of signatories (if applicable);
• Additional information, such as details about politically exposed persons (PEPs);
• Any additional information outlined in the respective form(s) or privacy notices issued and provided to you.

Job Application Data: Information provided when you fill out the career form on the Website, information from your CV, and any other information provided by you via email or other available channels to apply for the position at DATA.BET and go through the recruitment process.

This information includes your first and last names, your email address, your phone, and any information voluntarily provided by you in your CV (e.g., information about your education, specialization, professional experience, etc.), as well as your cover letter/email, and any additional communications with DATA.BET, including audio, video, and in-person interviews.

Note that sharing your Personal Data with DATA.BET is not mandatory. However, certain information is essential for the delivery of our Services in a manner that fulfills your requirements best; when it comes to processing Job Application Data, if you do not provide such information, we may not be able to process your application properly or at all.

Usage-Derived Data

We process information from the Website interaction, device usage, and Services use.

Performance Data: We obtain some information on how you engage with our Website and Services. This may encompass details such as the referring webpage, access time, pages visited, duration on each page, your actions, viewed content, clicked links, download errors, performance, and other diagnostic data.

Device Details: Information pertaining to the device you use to access our Website and Services is collected, including your IP address, device type, operating system type and version, browser type and settings, device identifiers, location data, time zone settings, and more.

Usage Statistics: We monitor the services and features utilized by you, purchase history, billing details, performance metrics, your comments, and feedback, along with any other information pertinent to the provision of Services.

Third-Party Sourced Data

We may obtain some information from our partners.

Analytics Providers: We engage analytics providers to analyze your engagement with the Website and evaluate its effectiveness. As a result, we may receive specific data from these providers, referred to as ‘Analytics Data’.

Marketing Provider: We may obtain information about our potential Customers from marketing providers.

Payment Providers: To facilitate payment processing for our Services, we may receive very limited payment details from payment providers. This may include information such as bank account numbers, the last four digits of cards, transaction amount, currency, payment date, and time (‘Transactional Data’). It’s important to note that all payment transactions are securely conducted through the payment service providers’ protected servers.

Publicly Sourced Data

In the course of our business, we may obtain some information about you from publicly available databases and sources (websites, social media, search engines, government registries, etc.).

Cookie and Tracking Data

We may passively collect some Personal Data through technologies like cookies. To find out more about our cookie usage practices, please read our Cookie Notice.

Sensitive Personal Data

We consciously refrain from intentionally collecting Sensitive Personal Data unless voluntarily provided or legal grounds align with data protection laws. Where allowed by law, DATA.BET may carry out criminal records checks to satisfy itself and legal requirements that there is nothing in your criminal convictions history that makes you unsuitable for the role.

Please be assured that we will not use your Special Personal Data for any purpose other than the recruitment exercise for which you have applied.

Data Usage Practices

Following the requirements of data protection laws, we can only use your Personal Data for specific reasons (purposes) and relying on the appropriate legal basis.

The following are the purposes for which we process your Personal Data:

Website Functionality: It is essential for us to handle certain Personal Data to guarantee the smooth operation of the Website and for internal procedures, encompassing troubleshooting, testing, and data analysis.

Personal Data used: Usage-Derived Data.

Legal basis: DATA.BET’s legitimate interest (e.g., providing content on the Website free of errors).

Service Management: This includes managing Customer’s use of the Services, processing and completing payments, tailoring our Services, and addressing inquiries, comments, and feedback.

Personal Data used: Communication Data, KYC Data, Usage-Derived Data, Analytics Data, Transactional Data, Publicly Sourced Data.

Legal basis: Performance of a contract; Compliance with the law (e.g., KYC legal obligations); DATA.BET’s legitimate interest (e.g., delivering relevant Services to the Customers).

Security of DATA.BET: This includes prevention, detection, and elimination of any illegal activity on the Website or in relation to the Services.

Personal Data used: Communication Data, KYC Data, Usage-Derived Data, Analytics Data.

Legal basis: DATA.BET’s legitimate interest (e.g., upholding the Website’s integrity and security, safety of the Services, as well as protecting our business interests and rights of end users).

Customer Assistance: This includes addressing communications, informing you about Services updates, and resolving issues through preferred communication channels.

Personal Data used: Communication Data, Usage-Derived Data.

Legal basis: DATA.BET’s legitimate interest (e.g., making the Customers’ experience with the Website and Services as convenient as possible).

Enhancing DATA.BET: This includes undertaking surveys and market research campaigns, assessing the performance of the Website and Services, developing new features, and revising strategies for business growth.

Personal Data used: Communication Data, Usage-Derived Data, and Analytics Data.

Legal basis: DATA.BET’s legitimate interest (e.g., maintaining the high quality of Services and attracting new Customers).

Conducting recruitment for our team: This includes processing the Personal Data of the job applicants to find the specialists we need by assessing relevant experience, knowledge, and skills, as well as conducting appropriate background checks.

Personal Data used: Job Application Data, Publicly Sourced Data.

Legal basis: DATA.BET’s legal obligations (including in the field of employment, social security, and social protection law); Taking steps prior to entering into a contract; DATA.BET’s legitimate interest (e.g., managing the recruitment process, assessing and confirming your suitability for employment, and deciding to whom to offer a job).

Promoting DATA.BET: This includes distributing relevant promotional content and other marketing messages associated with our Services in accordance with your preferences and needs, alongside assessing the performance of our marketing campaigns.

Personal Data used: Communication Data, Usage-Derived Data, Analytics Data, and Publicly Sourced Data.

Legal basis: Your consent; DATA.BET’s legitimate interest (e.g., gaining insights into improving the marketing and sales of our Services).

Data Retention Strategies

We ensure you that retaining your Personal Data aligns with the original purpose of collection and our legal obligations to keep Personal Data.

The determination of the suitable retention period relies on factors like the scope, type, and sensitivity of the Personal Data, the potential risks linked to unauthorized use or disclosure, the feasibility of achieving processing objectives through alternative methods, and adherence to applicable legal requirements. Rest assured, we give considerable importance to these factors to ensure the adequate safety and security of your Personal Data.

Ensuring Safety and Security

Prioritizing your Personal Data security involves, among others, encryption, firewalls, strict access controls, and physical security. We regularly review and update measures to maintain robust data protection.

Where we engage third parties to process Personal Data on our behalf, they are under a duty of confidentiality and obliged to implement appropriate technical and organizational measures to ensure the security of Personal Data.

Sharing Your Personal Data

We enlist the support of third parties to facilitate our business and Services provision. It is essential for us to share your Personal Data with these entities to ensure the smooth functioning of the Services. Additionally, there might be instances where we disclose your Personal Data to public authorities, our affiliated companies, or potential business successors.

The following provides an overview of the entities with whom we might share your Personal Data and purposes of data sharing:

Be assured that in any case, we implement essential measures to guarantee that any sharing of your Personal Data with third parties adheres to relevant laws and regulations, ensuring a method that prioritizes the protection of your privacy and security. These measures include data processing agreements requiring third parties to adhere to applicable data protection laws and implement appropriate organizational and technical safeguards, and, if necessary, international data transfer tools as described in this Privacy Notice.

International Data Transfers

Some recipients of your Personal Data are located outside the EEA or UK. It prompts us to use international data transfer tools such as Adequacy Decisions and Standard Contractual Clauses to ensure that data protection standards guaranteed in the EEA are not undermined when your Personal Data is transferred.

Adequacy Decisions: An ‘adequacy decision’ is issued by the European Commission when it determines that a third country or international organization maintains an adequate level of data protection. The list of countries recognized as offering an adequate level of data protection can be found here. If an adequacy decision applies, there is no other international data transfer tools are required.

EU Standard Contractual Clauses: The ‘EU Standard Contractual Clauses’ are model clauses issued by the European Commission and governing international data transfers. If Personal Data is transferred to a third party in a country outside the EEA and UK that is not considered to offer an adequate level of protection for Personal Data, we ensure that we have in place a binding contract with them containing the current version of the EU Standard Contractual Clauses. Find out more about the EU Standard Contractual Clauses here.

Where necessary, we supplement EU Standard Contractual Clauses with the UK’s International Data Transfer Addendum (‘IDTA’). Find out more about the IDTA here.

Automated Decision-Making

Automated decision-making refers to the process of making decisions using computer algorithms and automated systems without direct human intervention (e.g., profiling). We do not use any algorithms and automated systems to make any decisions that would significantly affect you without the opportunity for human review. If we decide to do so, we will definitely inform you.

Your Privacy Rights and Choices

Privacy rights: Following the applicable data protection laws, DATA.BET is obliged to respect and uphold your privacy rights listed below. Please be aware that certain legal limitations or exemptions might impact the implementation of these rights. In such instances, we will offer a transparent explanation, providing a rationale in accordance with relevant legal obligations.

If you wish to exercise any of these rights, please contact us at [email protected]. Rest assured that exercising your rights will not result in any charges. Upon receiving your request, we are dedicated to providing a response within a one-month timeframe.

You have the right to:

• Get information about what Personal Data we process, how and on what legal grounds, and other data processing details;
• Access and obtain a copy of your Personal Data on request;
• Require us to change incorrect or incomplete Personal Data;
• Require us to delete or stop processing your Personal Data, for example where the data is no longer necessary for the purposes of processing for which it was collected;
• Require us to delete or stop processing your Personal Data if processing is unlawful;
• Object to the processing of your Personal Data where we are relying on our legitimate interests as the legal ground for processing;
• Ask us to restrict the use of Personal Data for a period if Personal Data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing Personal Data;
• Object if we process your Personal Data for the purposes of direct marketing based on our legitimate interest;
• Require us to transfer your Personal Data to another data controller;
• Not be subjected to automated decision-making that significantly affects you;
• Lodge a complaint with a supervisory authority if you believe that we have not complied with applicable data protection laws. The list of the EU member states supervisory authorities can be found here.

Privacy choices: There are some options and decisions you can make regarding the processing of your Personal Data by DATA.BET.

You can choose to:

• Refuse to provide your Personal Data to DATA.BET. Should you opt for this, you can still navigate the Website, but the provision of our Services may be limited without the inclusion of certain Personal Data; also, we are unable to proceed with your recruitment without some information about you;
• Turn off your cookies by activating a setting on your browser allowing you to refuse cookies, or by using the cookie tool on our Website;
• Prohibit us from using your Personal Data for marketing purposes by withdrawing your consent previously given to us. You can make it any time by just contacting us at [email protected] or by following respective opt-out instructions contained in our communication.

DATA.BET and Young Individuals

DATA.BET works in a B2B segment, and our Services no way are aimed at children. We do not knowingly collect any Personal Data from individuals under the age of 16. If you are a parent or guardian and believe that we are inappropriately processing the Personal Data of a minor, please reach out to us at [email protected].

External Links

Links to third-party websites may be available on our Website for your convenience or reference. It’s important to note that DATA.BET has no control over these external websites, and their privacy practices may differ from ours. Consequently, we cannot assume responsibility for safeguarding the privacy of any information you disclose while visiting such websites. We recommend exercising caution and reviewing the privacy statements of any website accessed through links on our Website.

Changes and Updates

To maintain your privacy practices transparent and compliant with data protection law, we keep this Privacy Notice on regular review. Thus, we can change and amend the Privacy Notice whenever we consider it necessary for legal or business purposes. You can always find the latest version of the Privacy Notice on the Website. Please check it from time to time.