Privacy Policy

This Privacy Policy (the “Policy”) explains how the Company manages the information and Personal Data you supply to us or that we collect. This information enables us to administer our relationship with you.

The Policy covers

websites, applications, products, and services that refer to it or do not have their own privacy policy, collectively referred to as our “services”.

It describes:

• The information we collect.
• Our reasons for collecting it.
• How we process it.
• The parties with whom we share it.
• Your rights concerning its collection, processing, and disclosure.
• Other relevant privacy and security matters.

References to the “Company”, “we”, “us”, and “our” mean the Data Controller described in this Policy.

By reading this Policy, you acknowledge and understand that your Personal Data may be processed as explained here. If you disagree with its provisions, please do not use the Website or supply us with Personal Information.

All processing described in this Policy is carried out in accordance with:

• The National Ordinance on the Protection of Personal Data (the “DPA”), together with subsidiary legislation issued under it, as amended from time to time.
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons in relation to Personal Data processing and the free movement of such data, repealing Directive 95/46/EC, known as the General Data Protection Regulation (the “Regulation” or “GDPR”).

The DPA and GDPR are collectively called the “Data Protection Laws”.

The Company decides why and how Personal Data is processed and therefore acts as the Data Controller under the applicable Data Protection Laws.

Definitions

Data Controller: A natural or legal person, public authority, agency, or other body that determines, independently or jointly, the purposes and methods of Personal Data processing. Where Union or Member State law determines those purposes and methods, that law may also identify the controller or establish the criteria for appointing one.

Data Processor: A natural or legal person, public authority, agency, or other body that processes Personal Data for the Data Controller.

Personal Data: Information that identifies you individually or concerns an identified or identifiable natural person, also referred to as a “data subject”.

Security Measures

The Company uses the TLS 1.2 secure internet communication protocol to protect remittances. This protocol encrypts your Personal Data while it travels over the internet. We also store Personal Data digitally on encrypted hard drives, providing an additional layer of protection.

Our services are registered with website identification authorities, allowing your browser to verify our identity before transmitting personally identifiable information. Advanced firewall technology provides further protection on our secure servers.

Protection of Personal Data

We safeguard the Personal Data we hold through security procedures and systems meeting the highest industry standards.

Our commitment includes both maintaining high-quality security measures and applying the law effectively. We process Personal Data only where there is a genuine, legitimate reason supported by one of the legal grounds established by the GDPR.

Processing Based on Legitimate Interests

A legitimate interest arises where we have a business or commercial reason to process Personal Data. When relying on this basis, we undertake to protect your information and ensure that our processing is not unfair to you or your interests.

If we choose to rely on legitimate interests, we will explain those interests, notify you of the processing, and provide a way for you to raise questions or objections.

An objection does not necessarily require us to stop processing. We may continue where our grounds outweigh your right to object. This may apply, for example, to processing required for anti-money laundering purposes. It also applies when we follow binding requirements of Curaçao law, as operating lawfully forms part of our legitimate interests.

Processing Based on Consent

Your consent is not the only basis that may permit or require us to process Personal Data. We rely on consent where we cannot, or choose not to, use another legal ground, such as a legal obligation or legitimate interests.

Where consent is the basis for processing, you may withdraw it at any time using the same method by which you originally gave it.

If you withdraw consent, we will assess whether another legal basis permits or requires continued processing. Where such a basis exists, we will inform you.

Withdrawing consent does not invalidate processing completed before the withdrawal.

Retention of Personal Data

We protect the Personal Data we retain as effectively as possible and use it only for purposes consistent with the Data Protection Laws and other applicable legislation.

Personal Data is kept only for as long as necessary, taking into account its original purpose. What is considered necessary depends on the particular information and the nature and duration of our relationship with you.

Our usual approach is to establish whether specific legislation, such as tax or company law, permits or requires retention for a particular period. Where it does, we retain the information for the maximum period specified by that legislation. For example, information classified as transactional data must be retained for at least five (5) years.

We also consider whether you or a third party could bring an action against us under legislation or contractual provisions, and the applicable limitation period, which is generally five (5) years. Relevant Personal Data may be retained for as long as necessary to defend against those claims, challenges, or proceedings.

When information is no longer needed, we securely erase or anonymise it.

If you do not provide necessary Personal Data, we may be unable to:

• Meet legal or regulatory requirements.
• Fulfil our contractual responsibilities.
• Deliver the services needed to administer and maintain your account.

Consequently, certain products or services may be unavailable to you.

Categories of Personal Data We Collect

The categories below describe the Personal Data we process. A single category may serve several purposes and be processed under more than one legal basis.

1. Contact information: Your first name, surname, residential mailing address and postcode, telephone or mobile number, email address, and a recent utility bill confirming your residential address.
2. Identity information: Your first name, surname, address, date of birth, identity card or passport number, photograph, gender, occupation, marital status, family information, and hobbies.
3. Activity information: Website logins, account activity, and transactions, including bets, winnings, bonuses, deposits, and withdrawals. This may also include analytics, parts of your browsing history, preferred games or bet types, time spent on pages, clicks, actions, cookies, telephone, email or live chat conversations with Customer Service, and whether you have self-excluded.
4. Technical information: Traffic data, GeoIP location, and information supplied by your browser, computer, or mobile device when accessing or using our services, including device and network details.
5. Financial information: Currency, card and banking details, other payment information, and the source of your funds.
6. Marketing and educational information: Your first name, surname, mailing address, telephone or mobile number, email address, records of opt-in consent where required, records of objections to marketing, website data, and online identifiers such as your IP address and other browser-generated information.

Purposes of Processing

We process Personal Data for the following purposes:

1. Creating a record in our systems, registering you as a customer, verifying your identity, and preventing fraud, including attempts by third parties to impersonate you.
2. Providing additional protection for your personal information, credit information, and use of credit cards.
3. Offering support and protection in relation to gambling addiction.
4. Managing and monitoring our ongoing relationship, delivering sports betting and casino services, and providing complete customer care.
5. Registering you for newsletters or campaigns and adding you to mailing lists.
6. Supplying information about your profile and requests, personalising your experience, supporting a responsible gaming environment, and maintaining current records of previous enquiries, complaints, or questions to improve our services.
7. Monitoring deposits and withdrawals and preventing unlawful use by third parties.
8. Sending marketing material you have requested or that we are otherwise authorised to provide, together with educational content, notices of upcoming events, and related information useful in connection with our services or for educational purposes.

Legal Grounds for Processing

We rely on the following grounds and requirements when processing Personal Data:

• Contractual necessity.
• Legitimate interests, including maintaining accurate system records, supplying requested information, and continually developing and delivering innovative betting and gaming experiences.
• Gambling licence requirements.
• Anti-money laundering and Know Your Customer regulations.
• Your consent, where required or when processing information for direct marketing.
• Responsible gaming regulations.

The Company may also obtain Personal Data from public sources, including internet searches, company registers, and broadcast media, where doing so is reasonable and does not harm your rights or freedoms.

Profiling and Automated Checks

Some information is used in checks that contribute to the profiling of your account. Profiling involves automated Personal Data processing to comply with anti-money laundering directives and prevent fraudulent use of your details, including tax evasion or suspicious betting patterns.

We do not make automated decisions, including for marketing purposes. Although the system may automatically check details such as IP addresses or politically exposed person (PEP) status, our staff make the final decision in every case.

We also verify your email address by sending you a confirmation email.

Giving and Withdrawing Consent

In the limited circumstances where we cannot or choose not to rely on another legal ground, such as legitimate interests, we process Personal Data with your consent.

We never assume consent. It must be obtained from you clearly and explicitly. You may withdraw it at any time through the same method used to provide it.

You may also exercise this right by writing to us at the physical or email address referred to below. We will then assess whether another legal basis, such as a legal obligation, allows or requires us to continue processing without consent. If so, we will notify you.

You may refuse to provide Personal Data when requested. However, if that information is necessary to deliver a service, we may be unable to provide it, particularly where consent is our only available legal basis.

As explained above, consent is one of several grounds on which we may process your information.

Cookies and Similar Technologies

When you visit the Website, cookies and comparable technologies automatically collect certain categories of Personal Data. A cookie is stored on your computer when you use the Website.

These technologies generally assign a unique number to your browser or device that has no significance outside our Website. We use them to personalise your experience, remember preferences such as language and currency, and deliver content relevant to your interests.

After you enter your email address and password during a session, we retain that information so you do not need to enter it repeatedly within the same session. With your agreement, this may also support automatic login during later visits.

Most browsers accept cookies automatically. You can control collection through cookies and similar technologies using your browser or mobile device settings. We aim to give you options for managing your privacy and information sharing.

We do not recognise or respond to browser-generated Do Not Track signals because standards, implementation methods, and solutions for these signals have not been fully developed across the internet industry.

Further information is available at All About Do Not Track.

Rejecting cookies may prevent you from using some Website features. We may also use your IP address to identify you, administer the Website, and diagnose server problems.

Other Uses of Personal Information

In accordance with our legitimate interests, we may need to use and retain Personal Information to prevent losses or protect our rights, privacy, safety, and property, or those of other people.

Authorised Disclosures to Third Parties

In addition to the disclosures otherwise described in this Policy, we may share your Personal Data with authorised third parties or competent authorities within or outside the EU/EEA where permitted or required by the Data Protection Laws or other applicable legislation.

Recipients may include:

• Entities within the Company.
• Law enforcement agencies.
• Accounting and auditing firms working with us.
• Regulators and other relevant authorities.
• Digital marketing providers.
• Organisations that introduced you to us.
• Parties you have instructed or authorised us to share information with.
• Other parties whose involvement is necessary to deliver the products or services you request.

The information disclosed depends on the products or services you use.

We may also disclose Personal Information to associated or subsidiary companies, business partners, or successors to our business.

Where information is transferred outside the European Economic Area (EEA), we put the necessary and appropriate safeguards in place. Further details appear in the section concerning international transfers.

We do not provide your Personal Data to third parties for their own marketing unless you consent.

Sharing with Staff, Affiliates, and Service Providers

Where appropriate and consistent with the Data Protection Laws, relevant information may be disclosed to:

• Company members and employees.
• Other entities within the Company, including where required to meet legal obligations.
• Affiliated entities.
• Subcontractors and service providers that support the Website or provide services you require.

Such sharing must relate to a purpose described in this Policy. We disclose Personal Information only to supply requested services or for another lawful reason, including authorised disclosures that do not require consent.

Our processors are contractually required to comply with the Data Protection Laws. Their obligations include keeping received information confidential and placing equivalent confidentiality duties on their employees and personnel.

Service providers acting as processors must also meet other applicable requirements, particularly those established by Article 28 of the GDPR.

Your Personal Data will not be shared for a third party’s own marketing purposes without your consent.

Internet Communications

Information transmitted over the internet may cross international borders even when both sender and recipient are in the same country.

We are not responsible for actions or omissions by you or a third party concerning Personal Data before we receive it. This includes transfers through countries offering lower protection than the European Union, regardless of the technology used, such as WhatsApp, Skype, or Dropbox.

We also accept no responsibility or liability for the security of information while it travels over the internet unless a law effective in Curaçao expressly places that responsibility on us.

Keeping Personal Data Accurate

We take all reasonable steps to keep the Personal Data we hold accurate and current.

You may contact us using the methods described below to check your information at any time. If you identify an error, we will correct it upon request.

Your applicable data protection rights are explained in the sections below.

Links to External Websites

Links to third-party websites are clearly identified. We are not responsible for their content, privacy policies, or data processing activities, and linking to them does not constitute endorsement.

We recommend reviewing the privacy policy of any external website you visit.

Transfers Outside the EEA

Protecting your information is a priority. We use appropriate technical and organisational safeguards, and all Personal Data is stored on secure servers operated by reputable, certified service providers.

Your information is primarily stored and processed within the EEA. However, third parties described in this Policy may receive, access, or store it. Some may act as sub-processors outside the EEA. Our employees or agents working outside the EEA may also access and process your information.

For such transfers, we ensure that appropriate safeguards, enforceable data subject rights, and effective legal remedies are available. We rely on standard contractual clauses, other appropriate legal grounds, or both.

You may request a copy of the safeguards by contacting us through LiveChat.

All processors are contractually required to follow strict security standards that maintain a level of Personal Data protection equivalent to that within the EEA.

By accepting this Policy, you expressly agree and opt in to the transfers outside the EEA described here.

Exercising Your Data Protection Rights

The Company will assist you as effectively as possible when you exercise rights concerning your Personal Data.

We may need to confirm your identity before handling a request.

Right of Access

Upon request, we will confirm whether we process Personal Data concerning you. Where we do, you may access that information and receive details about:

• The Personal Data we hold.
• The purposes of processing.
• The recipients of disclosures.
• The intended retention period, where this can be specified.
• Any international transfers and the safeguards applied.
• Your rights.
• How to submit a complaint.
• The source of your Personal Data.
• Any automated decision-making, including profiling, and related information.

Right to Rectification

You may ask us to correct inaccurate Personal Data or complete information about you that is incomplete.

Right to Erasure

You may request deletion of your Personal Data, also known as the “right to be forgotten”. We will act without undue delay where:

• The information is no longer needed for its original purposes.
• You withdraw consent and no alternative legal ground permits processing.
• You successfully exercise your right to object.
• The information has been processed unlawfully.
• A legal obligation requires us to erase it.
• Special circumstances relating to certain children’s rights apply.

We are not legally required to fulfil an erasure request where continued processing is necessary to meet a legal obligation imposed on us.

Right to Restrict Processing

You may request a restriction on processing in the following circumstances:

• You dispute the accuracy of your information, while we take the time needed to verify it.
• Processing is unlawful, but you oppose deletion.
• We no longer need the information for its original purposes, but you require it to establish, exercise, or defend legal claims.
• You have objected to processing, and a decision is pending on whether our legitimate grounds outweigh your objection.

Following a successful restriction request, we may process your Personal Data only:

• With your consent.
• To establish, exercise, or defend legal claims.
• Where we no longer require the information for the purposes for which it was collected.
• To protect another natural or legal person’s rights.
• For reasons of significant public interest.

Right to Data Portability

You may request a copy of the Personal Data you previously supplied to us in a structured, commonly used, machine-readable format.

Where technically possible, we may instead transmit it directly to another Data Controller, provided that doing so does not adversely affect other people’s rights and freedoms.

This right applies only where both of the following conditions are met:

• Processing relies on your consent or the performance of a contract with you.
• Processing takes place through automated means.

Right to Withdraw Consent

You may withdraw consent at any time. The sections on consent above explain how to exercise this right and when another legal basis may permit continued processing.

Right to Object

In certain circumstances, you may object to the processing of your Personal Data. This right applies where processing is necessary:

• To perform a task in the public interest.
• For legitimate interests pursued by us or a third party.

Where processing relies on legitimate interests, it will stop only if the Data Controller has not demonstrated compelling, legitimate grounds that outweigh your objection and require continued processing.

You may object at any time to the use of your information for direct marketing.

Outside the circumstances described above, this general right to object does not apply.

Right to Submit a Complaint

If you believe the Company has infringed your rights, you may submit a complaint to a relevant Data Protection Supervisory Authority at any time.

Although this right remains available to you, we ask that you first try to resolve the issue directly with us.

The Company may refuse a request where it can reasonably justify doing so, despite the rights described above. Such a refusal does not prevent you from complaining to the relevant data protection authority.

Contact Information

Please contact us if you have privacy-related questions or comments, or wish to exercise your individual rights.

Our Customer Service team can also provide assistance.

The Company’s Data Protection Officer can be reached directly through LiveChat.