At Betbull, we value your privacy and are committed to protection any personal data that you may share with us.
We will always be clear and open about why we collect and how we use your personal data. Wherever you have choices or rights as to the use of your personal data, we will explain these to you in terms that are as clear as possible.
Who is in control of your personal data?
If you have concerns or would like any further information about how BetBull handles your personal information, please feel free to contact our Data Protection Officer at email@example.com
What personal data do we collect and how do we collect it?
You provide us with your personal data when you visit our mobile application and/or website to register for or make use of our Services. We may collect your personal data in a number of different circumstances during our interaction with you. These circumstances may include:
- The process of registering an account with Betbull.
- Voluntarily providing additional information when you make use of our Services.
- Interacting with any of the public areas of social features that we provide on our mobile application.
- Contacting our customer support team to help resolve any query or complaint you may have.
The personal data we collect from you may include the following categories of data:
- Identification and personal information you provide when registering for an account with Betbull; such as your first name and last name, date of birth.
- Contact and correspondence information you provide when registering for an account with Betbull; such as your email address, telephone number and residential address.
- Information and documents we request from you to verify your identity and/or comply with legislation and regulations that Betbull must adhere to; such as identification documents, proof of address documents and billing information.
- Information that you provide and generate through use of our Services; such as transaction information and Payment Solution Provider information.
- Technical and network information that you provide and generate through use of our Services; including technical information about your use of our mobile application such as IP address, time and date of access and device information, when such information is kept in a format that can be associated with you.
- Information and preferences that you provide to make use of our Services and personalise your experience; such as username, mobile application and/or website usage preferences.
- Information that is generated through the use of our Services that will help us detect possible fraudulent or criminal activity and that may also be used by us enhance your personal experience; such as betting history and patterns.
- Information that you voluntarily provide through surveys you complete or competitions you enter.
- Any other categories of information that you may provide when you are using our mobile application and/or website; particularly if you choose to use any of the social features and options that are provided by Betbull.
We would like to remind you that you are not required to provide us with any such personal data as listed above and do so on a voluntary basis. However, if you choose not to provide such data, we may not be able to provide you with our Services.
It is important for us that you keep your personal information that we store about you as accurate and up to date as possible. You can amend and update your personal information through the relevant sections of the mobile application or by contacting our Customer Support.
What purposes do we use your personal data for?
Under the applicable European Union data protection legislation, primarily the General Data Protection Regulation, Betbull as the data controller may process your personal data in the situations that one or more of the legal grounds of processing listed below exist:
- To fulfil any contract that Betbull has with you.
- Where Betbull has a legal obligation to process the personal data.
- Where you have consented to Betbull’s processing of your personal data.
- When such processing can be considered to fall under Betbull’s legitimate interest.
- When such processing is in the public interest
- When such processing is in your vital interest.
As Betbull, we process your personal data for the following purposes:
- To provide you with our Services Starting from when you register for an account, we process your personal data to be able to verify your identity, approve and register your account, provide you all of the features of our Services and provide you with customer service assistance.
We process your personal data for this purpose on the grounds of necessity for the performance of our contract with you. However, we may also retain and process certain personal data, such as your communication with our customer support services, on the grounds of legitimate interest to help improve our customer support services and provide you with better assistance.
To provide you with our Services, we may also share your personal data with third parties working on our behalf. Further information can be found below in the section that details who we share your personal data with.
- To comply with our legal and regulatory obligations As Betbull, our activities and our Services we provide are regulated by a number of different regulatory authorities. For example, in the United Kingdom, we are regulated by the Gambling Commission of Great Britain and are subject to legislation including the UK Gambling Act 2005 and the UK Gambling (Licensing and Advertising) Act 2014.
In order to comply with these legal and regulatory requirements, we carry out identity verification, fraud prevention and anti-money laundering checks when you create an account with us and throughout the time that you hold an account with Betbull to protect our users from fraudulent behaviour and to promote responsible gambling. This will include disclosing necessary information to third parties such as identity verification institutions, credit reference and verification agencies and fraud prevention and detection agencies. When permitted by the applicable data protection legislation, such third-party agencies may retain a record of the search and utilize this record for further verification purposes.
From time-to-time we may also receive legitimate requests from regulatory authorities to provide information within the scope of an investigation. In such situations, we will be under the obligation to comply with any such legitimate requests and share the requested information, which may include your personal data.
We may conduct a security review at any time to validate personal data provided by you and to verify your use of our Services and your financial transactions for potential breach of the Betbull Games Limited Terms and Conditions and applicable legislation. Such security reviews may include, but are not limited to, ordering a credit report and/or otherwise verifying the personal data you provide against third-party databases.
As Betbull we are also under the obligation to adhere to responsible gambling and social responsibility obligations. To achieve this, we will monitor your patterns of use of our Services to identify any concern in terms of responsible gambling. Furthermore, as a user you may make use of self-exclusion schemes such as “Gamstop” that operates within the United Kingdom. Should you utilize such services, we will also receive a notification and apply the chosen restrictions across our mobile application and/or website.
We process your personal data for this purpose on the grounds of necessity to comply with a legal obligation. We will be unable to provide you with our Services without carrying out such processing activities. Therefore, if you do not want your personal data to be processed for these purposes, please close your account and refrain from further use of our services.
- To monitor the performance and functioning of our mobile application and/or website
We use such methods as cookies, traffic analysis and performance monitoring tools in order to analyse our players’ use of our Services and improve the performance and reliability of our mobile application, website and our Services.
We may use your personal data for such analysis to help us understand how our customers use our Services. This is to ensure that the mobile application and website functions correctly, that we are able to enhance user experience, minimise user inconvenience due to systems performance issues and so that we are able to provide you with a better and more personalised gaming experience.
We process your personal data for this purpose on the grounds of our legitimate interest. When carrying out processing for such purposes, we ensure that any impact on your privacy is minimized, and we take into account how long we retain such information, ensure that we only collect and process the minimum personal data that is necessary for this purpose and ensure that all appropriate security measures are implemented. We make sure that we consider and balance any potential impact such processing may have on you and your rights before processing your personal data for our legitimate interests. We do not engage in processing on grounds of legitimate interest for cases where our legitimate interests are overridden by any potential impact on you. You have the right to object to any processing that we carry out on the grounds of our legitimate interest if you believe that your right to privacy outweighs our legitimate interests.
- To provide you with marketing and promotion information through marketing activities
When we have obtained your consent to do so, we will provide you with information and notices of opportunities and promotions that we think may interest you. We make sure to ensure that any such communication is in line with the normal practice and service that you would expect from similar companies that operate online betting services.
We will send you such marketing communication only in the situation that we have obtained your consent to do so. Such communication may be via Push Notifications, email, SMS or online marketing. We will ensure that such marketing communication is not sent to you if you have not provided consent or if you have subsequently opted out of receiving such information. The Preferences section in the Settings menu will allow you to choose how you wish to receive communication from us.
Your personal data may also be used to profile what preferences and offers are most suitable to your needs and interests, so as to prevent us from sending you marketing communication that would not be of interest to you.
From time-to-time, we may also request information from you via surveys or contests. Participation in these surveys or contests is on a completely voluntary basis and you will always have the choice of whether you disclose such information. The types of information that will be collected through such surveys or contents will be clearly specified for each case and may include information such as contract information and demographic information.
When you engage with any of the social features of the mobile application, such as when you share you bet, we may use your avatar, username and accumulators to share inside the mobile application with other users and for use in digital marketing assets, affiliate material, social media content, offline marketing and any other related area for marketing purposes. If you do not want this information used by us for such marketing purposes, you can manually turn off Bet Sharing using the Bet Sharing toggle in the Setting menu. If you disable Bet Sharing in this way, we will remove your associated profile and information from marketing banners within 5 days. However, please note that it may take up to 4 weeks to remove such information from placements managed on our behalf by third parties.
You have the right to update your marketing preferences and withdraw your consent at any time. Should you opt-out, you will not be sent any further marketing communication.
How long do we retain your personal data?
We retain your personal data for as long as is reasonably required for legal and business purposes. In determining data retention period, Betbull takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When the purposes that require the processing and retention of your personal data no longer exist, we securely delete or destroy your personal data.
In practice, this will mean that we retain most of your personal data for the period that you are a registered customer of Betbull. However, there may be situations where we are legally required to retain some of your personal data for an additional period to satisfy our legal and regulatory obligations.
Who do we share your personal data with?
As Betbull, we may share your personal data with our subsidiaries and affiliates within our company group.
In addition to sharing your personal data within the Betbull company group, we may share your personal data with additional third parties. Such additional third parties may include the following:
- Law enforcement agencies, regulators and other authorities.
- Identity verification agencies.
- Credit reference and verification agencies.
- Fraud prevention and investigation agencies.
- Commercial and business partners.
- Third parties that we work with to provide our Services, such as service providers, suppliers and customer support agencies.
- Third parties that we work with for the purposes of marketing and advertising, such as digital advertising agencies and marketing agencies and consultants.
We may share your personal data with such aforementioned third parties for the following reasons:
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation.
- To assist us in providing you with the products and services you request, particularly games and services that we provide through third-party software providers.
- To investigate or verify suspicions of cheating, fraud or other uses of our Services in any way that is contrary to the Betbull Games Limited Terms & Conditions.
- To investigate and defend ourselves, our partners and our users against any third-party claims or allegations.
- To protect the rights, property, security and wellbeing of Betbull, our partners or our users.
- Situations where Betbull’s assets are being reviewed or used for the purposes of a business transaction, such as a merger, change of control, sale of assets or bankruptcy.
- Situations where we have received your consent to do so.
From time-to-time, we may also share anonymous data regarding our users use of our Services with third parties. We may share such data for public interest purposes such as research on understanding and preventing addiction or for our own legitimate interest such as understanding general patterns and trends regarding the use of our Services. Any information shared in this way and for these purposes will be anonymous and will not contain any personal data.
Do we transfer your personal data outside of the EEA?
In the course of providing you with our Services, we may need to transfer personal data that we have collected from you our affiliates, subsidiaries, partners, service providers and subcontractors who may be based outside the European Economic Area (“EEA”). Such countries may include the United States of America, Turkey and Ukraine.
- Binding corporate rules,
- Standard Contractual Clauses,
- US/EU Privacy Shield registration and proof of compliance.
How do we keep your personal data secure?
We understand the importance of security and utilizing the correct techniques needed to secure your Personal Data. We store all Personal Data we receive for you in an encrypted and password protected database residing within our secure network behind active state-of-the-art firewall software. Our Services support SSL Version 3 with 128-bit encryption and we are committed to reviewing and updating our security and systems to ensure we remain up to date.
We also take measures to ensure that our subsidiaries, affiliates, agents, service providers and suppliers also employ adequate security measures.
Due to the complex and ever-changing nature of technology and business, to the extent possible under the applicable data protection legislation, we cannot guarantee or claim an error-free performance regarding the privacy of your personal data. Thus, to the extent possible under the applicable data protection legislation, for events that our beyond our direct control we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or disclosure of such information.
What happens if you access third-party provided links?
When accessing our Services and/or website, we may store information on your device. This information is referred to as cookies, which are small text files that are stored on your device when you visit online pages and serve the function of recording your preferences.
We also use Local Shared Object, otherwise known as “flash cookies”. Flash cookies are similar to browser cookies and they allow us to remember things about your earlier visits across our websites. Neither cookies nor flash cookies can be used to access or use other information on your computer, mobile device or other devices. We only use these methods to track your use of our Services. Cookies help us monitor traffic to our website, improve our Services and make it easier and/or more relevant for your use. We use flash cookies and third-party cookies to help us display more relevant and desirable advertisements.
If you choose to decline cookies, you may not be able to experience all of the interactive features on our websites.
Strictly necessary cookies “Strictly necessary cookies” are essential to allow a user to move around a website and use its features, such as accessing secure areas of the website or making financial transactions. Without these cookies we would not be able to make our websites work efficiently.
A “session-based” cookie: This type of cookie is only allocated to your device for the duration of your visit to our website. A session-based cookie helps you move around our website faster and, if you’re a registered user, it allows us to provide you with information that is more relevant to you. This cookie automatically expires when you close your browser.
A “persistent” cookie: This type of cookie will remain on your device for a set period of time that has been determined for each cookie and will help enhance future visits. Flash cookies are also categorized as persistent cookies.
“Analytical” cookies: This type of cookie allows us to recognize and count the number of visitors to our website and analyse how visitors use our website. This helps us improve the way our websites work. For example; ensuring that the page layout is optimized to help you find what you are looking for easily.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies. However, if you prefer you can modify your browser settings to decline cookies. The Help menu on the menu bar of most browsers will instruct you on how to prevent your chosen browser from accepting new cookies, how to have your browser notify you when you receive a new cookie and how to disable cookies altogether.
- Flash cookies
You can modify your Flash Player settings to prevent the use of flash cookies. The Settings Manager of your Flash Player allows you to manage your preferences. To disallow flash cookies from all third-party content, go to the “Global Storage Settings” panel of the Settings Manager and de-select the check box labelled “Allow third party flash content to store information on your computer” and close the Setting Manager. Alternatively, you can adjust your settings for specific websites you visit through the “Website Storage Settings” panel which is also found in the Settings Manager.
If you are using an old version of Flash Player or an older web browser, the Settings Manager may not be available to you. We recommend that you ensure that you update your Flash Player and browser to the latest available versions.
What are your rights as to your personal data?
As per the applicable data protection legislation, you have the following rights in relation to your personal data:
- Right to be informed about our collection and processing of your personal data.
- Right to submit a request to access your personal data that is processed or stored by us.
- Right to rectify personal data that we hold on you if you believe such personal data is incorrect or out of date.
- Right to request erasure of personal data where there is no longer a compelling reason or legal grounds to continue processing.
- Right to restrict the processing of your personal data.
- Right to withdraw your consent for processing activities where we have asked for, obtained and rely upon your consent as our only legal ground of processing.
- Right to object to any data processing that Betbull carries out for its own legitimate interest.
- Right to data portability to ask for personal data we are processing using automated means to be transmitted to you or, where technically feasible for us to do so, to another data controller.
- Right to be informed about the logic behind any automated decision-making processes we may use, or contest decisions made by solely automated processing.
- Right to lodge a complaint with any relevant Data Protection Authority.
For more information on these rights or to exercise any of your rights, please contact our Data Protection Officer at firstname.lastname@example.org.
As Betbull we value your privacy and will try to accommodate any request you make in respect of your aforementioned rights. However, we would like to remind you that these rights are not absolute rights and we may have to refuse your request or only partially comply with it. Should we be in a position where we cannot fully comply with your request, we will provide you with an explanation as to why we are unable to do so.
If you submit a request to exercise any of your rights listed above, we may ask you for proof of identification for verification purposes. We may also have to request that you clarify your request as to the exercise of your rights.
Normally we will not issue any charge for a request made with regard to any of your rights listed above. However, if your request is deemed to be “manifestly unfounded or excessive” (for example, if you make repeated requests on the same issue), to the extent allowed by the application data protection legislation, a fee may be charged to cover the costs required to respond.
How can you contact us for further information?