Introduction

1. Welcome to BetWarrior’s privacy and cookies policy (Policy).

2. BetWarrior respects individuals’ privacy and is committed to protecting their personal data. This Policy will inform BetWarrior customers (Players) how we look after their personal data when they visit the BetWarrior.bet website (Website) or access the BetWarrior.bet mobile application (App) (regardless of where they visit them from) or if they provide personal data by any other means (for example, over the phone). It will tell Players about their privacy rights and how the law protects them.

3. We use cookies and similar technologies to distinguish between each Player that accesses our Website and App. This Policy provides information on the cookies that we deploy and how Players can block cookies.

4. This Policy forms an integral part of the Player Terms and Conditions, and by accepting the Player terms and conditions, Players also accept the terms of this Policy. By accepting this Policy, Players agree that they understand and accept the use of their personal data as set out in this Policy. If Players do not agree with the terms of this Policy, they should not use the Website or the App or otherwise provide us with their personal data.

Purpose of this Policy

1. This Policy aims to give Players information on how BetWarrior collects and processes Players’ personal data when they use the Website and the App. For example, when Players provide personal data when they create a BetWarrior account.

2. The Website and the App are not intended for children, and we do not knowingly collect personal data relating to children.

3. It is important that Players read this Policy together with any other privacy policy or fair processing policy that we may provide on specific occasions when we are collecting or processing personal data about Players, so that they are fully aware of how and why we are using their data. This Policy supplements other notices and privacy policies and is not intended to override them.

Who we are and how to contact us

1. The BetWarrior.bet Website and App are operated by GoforLA B.V., a company registered in Curaçao with registration number 146039 and registered office at E-Commerce Park Vredenberg, Hoek Dr. M.J. Hugenholtzweg/Heelsumstraat, Curaçao.

2. GoforLA B.V. (referred to as "BetWarrior", "we", "us" or "our" in this Policy) is a controller in respect of Players’ personal data because we determine the purposes for which, and the way in which, Players’ personal data is processed. We take our duties as data controller seriously and take full responsibility for Players’ personal data as well as for the Website and the App.

3. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If Players have any questions about this Policy, including any requests to exercise their rights in relation to personal data, they should contact the data privacy manager using the details set out below:

4. If Players have any questions about this Policy or our privacy practices, they should contact our data privacy manager in the following ways:

   1. Email: [email protected]; or

   2. Postal address: Data privacy manager, GoforLA B.V. (T/A BetWarrior), E-Commerce Park Vredenberg, Hoek Dr. M.J. Hugenholtzweg/Heelsumstraat, Curaçao.

5. Players have the right to make complaints at any time to the relevant data protection and privacy regulator. We would, however, appreciate the chance to deal with Players’ concerns before they approach the regulator, so we kindly request that Players contact us in the first instance.

Changes to the Policy and Players’ duty to inform us of changes

1. We keep this Policy under regular review.

2. It is important that the personal data that we hold about Players is accurate and current. We kindly request that Players keep us informed if their personal data changes during their relationship with us.

Third-party links

1. This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about Players. We do not control these third-party websites and are not responsible for their privacy statements. When Players leave our Website or App, we encourage them to read the privacy policy of every website that they visit.

The data we collect about Players

1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2. We may collect, use, store and transfer different kinds of personal data about Players which we have grouped together as follows:

   1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

   2. Photographs includes passports and other photographic identification that are collected to verify Players’ identities.

   3. Contact Data includes a billing address, home address (if difference to billing address), email address and telephone numbers.

   4. Financial Data includes bank account and payment card details.

   5. Transaction Data includes details about deposits and withdrawals from Players’ BetWarrior accounts and other details of services (e.g. casino games) that Players have used on the Website or on the App.

   6. Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices Players use to access the Website or the App.

   7. Profile Data includes Players’ usernames and passwords, BetWarrior services that Players have used, their interests, preferences, feedback and survey responses.

   8. Usage Data includes information about how Players use the Website, the App and BetWarrior products and services.

   9. Marketing and Communications Data includes Players’ preferences in relation to receiving marketing from us and third parties and Players’ communication preferences.

3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Players’ personal data but is not considered personal data in law as this data will not directly or indirectly reveal a Player’s identity. For example, we may aggregate Players’ Usage Data to calculate the percentage of Players accessing a specific Website or App feature. However, if we combine or connect Aggregated Data with Players’ personal data so that it can directly or indirectly identify a Player, we treat the combined data as personal data which will be used in accordance with this Policy.

4. We do not collect any Special Categories of Personal Data about Players (this includes details about Players’ race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Players’ health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If Players fail to provide personal data

1. Where we need to collect personal data by law, or under the terms of a contract we have with Players (for example, where it is required under the Player Terms and Conditions), and they fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with Players (for example, to provide Players with the ability to place bets or wagers). In this case, we may have to cancel a product or service that a Player may be attempting to access, but we will notify Players if this is the case at the time.

How is Players’ personal data collected

1. We use different methods to collect data from and about Players including through:

   1. Direct interactions. Players may give us their Identity, Contact and Financial Data by filling in forms on the Website or App or by corresponding with us by post, phone, email or otherwise.

   2. Automated technologies or interactions. As Players interact with our Website and App, we will automatically collect Technical Data about Players’ equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below in this Policy for further information on cookies.

   3. Third parties or publicly available sources. We may also receive personal data about Players from various third parties as set out below:

      1. Technical Data from the following parties:

         1. analytics providers;

         2. advertising networks; and

         3. search information providers.

      2. Contact, Financial and Transaction Data from providers of technical and payment services, such as payments solutions providers (PSPs) that facilitate deposits and withdrawals from BetWarrior accounts.

      3. Identity and Contact Data from data brokers or aggregators.

How we use Players’ personal data

Purposes for which we use Players’ personal data

1. We collect Players’ personal information so that we can provide an excellent level of service and so that Players can use the Website and App in an agile and secure way. Collecting personal data also allows us to offer Players more customisation on the Website and App.

2. More specifically, we collect Players’ personal data for the following reasons:

   1. So that Players can register a BetWarrior account and use BetWarrior services through the Website and App.

   2. So that the customer services team can provide the best, customised service to Players and so that they can efficiently deal with any queries or complaints.

   3. To develop internal studies on the interests, behaviours and demographics of Players to understand their needs and interests better and to offer better services or provide related information through the Website and the App.

   4. To improve our commercial and promotional initiatives and to analyse Players’ interactions with the Website and App in order to improve the content and services that we offer and to provide better Player customisation.

   5. To send information or messages to Players by SMS, email or through the Website or App about new services. To display advertising and promotions, banners and news about BetWarrior that we think will be of interest to Players. For further information, see the Marketing section below.

   6. To send operational messages to Players which are required for the Website and App to function properly. These may be sent by SMS, email or through the Website or App. For example, we may send operational emails to notify Players if there are technical issues with the Website or the App or to confirm successful withdrawals and deposits.

   7. To carry out identity checks to prevent anti-money laundering and fraud and so that we can carry out any other checks that we are required to carry out under applicable laws and regulations.

      Marketing

3. We may use Players Identity, Contact, Technical, Usage and Profile Data to form a view on what we think they may want or need, or what may be of interest to them. This is how we decide which products, services and offers may be relevant for Players (we call this marketing).

4. Players will receive marketing communications from us if they have requested information from us or used BetWarrior services through the Website or App and they have opted in to receiving that marketing.

5. Players can ask us or third parties to stop sending them marketing messages at any time by contacting us or adjusting the marketing settings on the Website or App.

6. Where Players opt out of receiving these marketing messages, this will not apply to personal data provided to us for reasons other than marketing.

Cookies and similar technologies

1. Our Website and App use cookies and similar technologies to distinguish between each Player that accesses the Website and the App. This helps us to provide Players with the best experience when they browse the Website and App, and it also allows us to improve the Website and App. We also use this for fraud prevention and generally to safeguard privacy. By continuing to browse the Website and the App, Players agree to our use of cookies and similar technologies.

2. A cookie is a small file of letters and numbers that we store on a Player’s browser or the hard drive of a Player’s computer if they agree to this. Cookies contain information that is transferred to a Player’s computer's hard drive.

3. We use the following cookies and similar technologies:

   1. Strictly necessary. These are cookies that are required for the operation of our Website and App. They include, for example, cookies that enable Players to log into secure areas of our Website and to process transactions (for example, deposits and withdrawals).

   2. Analytical/performance. These cookies allow us to recognise and count the number of Players and to see how Players move around our Website and the App when they are using it. This helps us to improve the way our Website and App works, for example, by ensuring that Players are finding what they are looking for easily.

   3. Functionality. These cookies are used to recognise Players when they return to our Website or the App. This enables us to personalise our content for Players, greet them by name and remember their preferences (for example, Players’ choice of language or currency).

   4. Targeting. These cookies or similar technologies record Players’ visits to our Website and App, the pages Players have visited and the links they have followed. We will use this information to make our Website and the App and the advertising displayed on them (if any advertising is displayed) more relevant to Players’ interests. We may also share this information with third parties for this purpose.

4. Should Players require more information about the individual cookies and similar technologies that we use and the purposes for which we use them, they should contact us.

5. Players can block cookies by activating the settings on their browser that allow them to refuse the setting of all or some cookies. However, if Players use their browser settings to block all cookies (including essential cookies), they may not be able to access all or parts of the Website or App. Should a Player require more information on how to disable cookies or change their privacy settings, they should visit www.allaboutcookies.org. The internet browser's 'help' function should also tell Players how to do this.

6. Except for essential cookies, all cookies will expire after thirty days.

Disclosures of Players’ personal data

1. We may share Players’ personal data with the parties set out below for the purposes set out above.

2. Internal third parties:

   1. Other companies in the BetWarrior group acting as joint controllers or processors who may provide services such as IT, HR, customer services and system administration services and who undertake leadership reporting.

3. External third parties:

   1. IT service and system administration providers.

   2. Third parties that licence key software to BetWarrior without which BetWarrior would not be able to provide services to Players, for example, providers of casino games.

   3. Payment solutions providers to facilitate deposits and withdrawals from BetWarrior accounts.

   4. Identity verification providers, to prevent fraud.

   5. Third parties that facilitate the sending, or that themselves send, BetWarrior marketing communications to Players.

   6. Professional advisers including lawyers, bankers, auditors and insurers that provide consultancy, banking, legal, insurance and accounting services to BetWarrior.

   7. Tax authorities, regulators and other authorities that require reporting of processing activities in certain circumstances.

   8. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use Players’ personal data in the same way as set out in this privacy policy.

4. We require all third parties to respect the security of Players’ personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use Players’ personal data for their own purposes and only permit them to process Players’ personal data for specified purposes and in accordance with our instructions.

Data security

1. We have put in place appropriate security measures to prevent Players’ personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Players’ personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Players personal data on our instructions, and they are subject to a duty of confidentiality.

2. We have put in place procedures to deal with any suspected personal data breach and will notify Players and any applicable regulator of a breach where we are legally required to do so.

How long will BetWarrior use Players’ personal data for?

1. We will only retain Players’ personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Players’ personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with Players.

2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Players’ personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

3. In some circumstances, Players can ask us to delete their data, see the Players’ rights section below for further information.

4. Sometimes we will anonymise Players’ personal data (so that it can no longer be associated with an individual Player) for research or statistical purposes, in which case we may use this information indefinitely without further notice to Players.

Players’ rights

1. Under certain circumstances, Players may (this is not an absolute right) have the following rights under data protection laws in relation to their personal data:

   1. Request access to their personal data (commonly known as a "data subject access request"). This enables Players to receive a copy of the personal data we hold about them.

   2. Request correction of the personal data that we hold about them. This enables Players to have any incomplete or inaccurate data we hold about them corrected, though we may need to verify the accuracy of the new data the Players provide to us.

   3. Request erasure of Player personal data. This enables Players to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Players also have the right to ask us to delete or remove their personal data where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal data to comply with local law. Note, however, that we may not always be able to comply with a Player’s request of erasure for specific legal reasons which will be notified to the Player, if applicable, at the time of the request.

   4. Object to the processing of their personal data where there is something about a Player’s particular situation which makes them want to object to our processing as they feel it impacts on their fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process Players’ information which override their rights and freedoms.

   5. Request restriction of processing of their personal data. This enables Players to ask us to suspend the processing of their personal data in the following scenarios:

      1. If they want us to establish the data's accuracy.

      2. Where our use of the data is unlawful but Players do not want us to erase it.

      3. Where Players need us to hold the data even if we no longer require it as they need it to establish, exercise or defend legal claims.

      4. Players have objected to our use of their data, but we need to verify whether we have overriding legitimate grounds to use it.

   6. Request the transfer of their personal data to them or to a third party. We will provide to a Player, or a third party they have chosen, the Player’s personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which the Player initially provided consent for us to use or where we used the information to perform a contract with the Player.

1. If Players wish to exercise any of the rights set out above, they should contact us, and we will confirm whether they are able to do so.

2. Players will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if a Player’s request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with a Player’s request in these circumstances.

3. We may need to request specific information from Players to help us confirm their identity and ensure their right to access their personal data (or to exercise any of their other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact Players to ask them for further information in relation to their request to speed up our response.

4. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than one month if a Player’s request is particularly complex or they have made a number of requests. In this case, we will notify Players and keep them updated.