- Privacy Notice
Last updated [March 23, 2022]
- 1. Who We are:
- 2. What personal data do We collect from you and for which purposes
- Contact information: your name, surname, address, age, birth date, social security number, gender, email address, phone number, zip code.
- Financial information: in order to operate online payments also based on the Agreement with Us. We collect your bank account/payment card details, such as card number 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 payment 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 for the purpose of fulfilling Our AML obligations, your personal data is shared between affiliate companies within Our group structure;
- 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 information about self-excluded customers and customers with gambling issues among affiliate companies within Our group structure and local authorities in order to enable cross-network exclusion and similar measures where necessary.
- 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 personal 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. If a call will be recorded, you will be verbally notified before the conversation begins;
- 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. 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 use of 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 information 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-automated processes to help Us to execute certain actions. For example, Our systems will automatically prevent you from depositing funds beyond limits set by Us; 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);
- Also, all the above processing operations that include an analysis of betting patterns/behaviour and other customer related data 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. Please note that if We use profiling in furtherance of decisions that can produce legal or significant effects, We will provide you with the option to opt-out in line with applicable laws.
- 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. Please note that most of Our surveys as well as our market analysis will use de-identified data (i.e. this will not involve any processing of personal data), hence such will be out of scope of this Notice;
- We will use details of the products you have previously used, as well as 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;
- We collect information from the devices you use for Our products and services in line with our duty of care 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. Any precautionary measures taken are set to be appropriate to the volume, scope and nature of personal data processed;
- We also collect server logs, which include information such as your logins (first log in, last login, last failed login), duration of logins, the app features or pages you view, app crashes and other system activity;
- All your information will be may be used for potential legal claims, in order to defend Our company business based on Our legitimate interest.
- 3. With whom might We share your personal data?
- 4. How long do We retain your personal data
- 5. Your rights
- Right to obtain confirmation that We are processing your personal data and request access the same;
- Right to request correction of your incorrect personal data to the extent allowed by law;
- Right to erasure. 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 personal data that We need to keep based on these retention periods for their duration);
- Right to data portability i.e. right to transmit personal data you have provided Us in a structured, commonly used and machine-readable format. Note that in line with Colorado Privacy Act you may only exercise this right up to two times per year;
- Right to opt-out of the processing of personal data for the purposes of targeted advertising, sale of personal data, and/or profiling in furtherance of decisions that produce legal or similarly significant effects, where We carry out such processing operations.
- 6. How to lodge a complaint with Us
- 7. How to contact Us
- 8. Changes to the terms of this Privacy Notice
Betsson U.S. Corp (“Betsson U.S.”, "We", "Us" or “Our”) respects your right to privacy. We have in place appropriate procedures and security measures to protect and manage your personal data in accordance with the Colorado Consumer Protection Act, the Colorado Privacy Act and any other applicable laws as may be in force from time to time (“applicable laws”)
This Privacy Notice sets out how We manage your personal data in the course of interacting with [Betsafe] and Our iGaming products and related services (“Services”).
The principles set out in this Privacy Notice apply to all instances in which Betsson U.S. processes your personal data for the purposes described in this Notice.
In the first place, We need to collect and process personal data that you provided to Us during the registration process or when deposit funds. This is necessary in order to open/set up your account and enable you to use the requested Services. This personal data is collected and processed based on your acceptance of Our Terms and Conditions (based on the Agreement with Us). The type of personal data that you provide is based on the specific function of the Services that you use, but you are not able to register your account without providing the following information:
Apart from the sabove, in order to open your account and to provide you with the requested Services, We need the following categories of personal data:
Moreover, to provide you with the Services We also collect and process personal data that We produce based on your activity while you are using Our Services. Such information is processed for the following purposes:
Regarding our direct marketing activities, please note that We will use your contact details for marketing purposes to communicate offers and other promotional materials to your registered email address, phone number or other direct contact only based on your consent to send marketing messages. Kindly note that, at any time and free of charge, you can change your direct marketing communication settings either from your account, by sending Us an email, via the unsubscribe button in order to opt out from receiving any direct marketing communication addressed to your email address, or by following the opt-out instructions within marketing texts / calls to opt out from phone marketing. In addition, We may send you push notifications related to our marketing activities 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 any time;
In addition, We might cooperate with companies such as social media platforms for prospective marketing to create 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.). Where this activity it constitutes targeted marketing, we will offer you the option to opt-out as per applicable laws.
We collect certain information about Our customers and visitors of Our websites via cookies. All information about cookies that We use can be read in Our Cookies Policy and Our cookie consent banner.
Lastly, We will also use your contact details to pass on Service communications regarding your account and the Services through different communications channels. Please be aware that these are not marketing messages, but Service information that you need to be aware of as Our customer. 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 carrying out Our processing operations we abide by the duty to avoid unlawful discrimination, which prohibits Us from processing personal data in violation of state or federal laws that prohibit discrimination.
Your personal data will be transferred or disclosed (for the purposes described in this Notice) to affiliate companies (within our group structure) for business and operational purposes based on our affiliate data processing agreements.
Apart from that, We share your personal data with Our business partners (such as, platform providers, gaming providers, marketing tools providers, etc.) 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 personal data with them in accordance with the applicable laws and subject to appropriate agreements.
While using the Services you may find links to third-party websites/applications (for example identity masking tools or social media platforms). Please note that this Privacy Notice does not apply to such third-party websites/applications. In order to find out more about processing of your personal data by these third-party websites/applications, We instruct you to carefully read their privacy notices and the terms of use before starting to use their services.
We may disclose your personal data if We believe, in good faith, that such disclosure is necessary to comply with state and federal regulations. For example, any governmental, regulatory or enforcement authority for the purpose of prevention and detection of different offences or in response to any court subpoena, order or similar official request. In certain cases, relevant laws may oblige Us to disclose your personal data to financial institutions such as competent tax authorities, IRS, banks, and insolvency services or to regulatory authorities within the regular reporting activities. Your personal data may also be disclosed to any regulatory or sporting body in connection with policing sport 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 data to investigate and act on any such breaches in accordance with their procedures. Categories of data that We will share will depend on each request, but most commonly will include your personal identifiers (such as full name, address, email, phone, etc.) information about your account activity (such as transaction history including bets placed, withdrawals etc.).
In line with applicable laws, We may share some or all of your personal data with any subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, acquisition, bankruptcy, or other transaction in which a third party assumes control of all or part of Our assets. Alternatively, We may seek to acquire other businesses or merge with them.
We will retain your personal data only for as long as is necessary for the purposes set out in this Policy. Where Your personal data is no longer required by Us, We will either securely delete or de-identify the personal data in question.
The criteria we follow in determining what is ‘necessary’ depends on 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.
You as the consumer have certain rights with respect to the personal data We hold on you. These include the following:
Please note that certain personal data is readily available from your account. Nevertheless, you may also exercise your rights by sending us an email at [email protected] via your registered email address, specifying the nature and scope of your request. Please note that We will respond to any of your requests about your rights without undue delay, and in any event within forty-five days from receipt of your request. Provided that this period may be extended as permitted under applicable data privacy law. In any case, we will notify you of such extension within the initial forty-five days. We may deny or fulfil a request only in part, based on our legal rights and obligations under applicable data privacy laws.
If you are unsatisfied with Our response, you have the right to appeal within thirty days from receipt of Our reply to your request by sending an email to our Data Protection Officer at [email protected] via your registered email address. We will review your request and provide you with a response without undue delay, and in any event within forty-five days from its receipt. Provided that We may extend this period as reasonably necessary and as provided under applicable laws. In any case, we shall notify you of such extension within the initial forty-five days. In our response we shall provide you with a written explanation of any actions taken and the reasons supporting those actions. We’re happy to clarify any concerns which you may still have, however, if We are unable to satisfactorily address such concerns, please be informed that you may lodge a complaint with the state’s Attorney General.
Betsson U.S. Corp has appointed a Data Protection Officer (DPO) to oversee the safety of your personal information.
If you have any questions about this Privacy Notice or Our information collection practices, please contact Us at [email protected] and specify your state of residence and the nature of your question. Our registered address is 1975 South State Street, Suite B, Dover, DE 19901.
We will occasionally make changes and corrections to this Privacy Notice and We will inform you by implementing the updated version on this site and in the event of substantial changes, also by sending you an email or a website notification about the changes. Any change will be effective immediately.