Help Centre

Introduction

Here at NetBet, our approach to our customers and their privacy is that of complete clarity which starts with a Privacy Policy that uses plain English. We want our customers to have full knowledge of the way their information is collected, used and stored, without getting bogged down in confusing jargon and lengthy small print.

If you are new to NetBet, or have been with us for a while but haven’t checked back with the T&Cs in ages, it’s important to give this policy a read, making sure you understand everything. As long as you have a NetBet account with us, keep coming back every so often for updates and to keep the information fresh in your mind. If we ever make any big changes to the policy, we will get in touch with you and let you know.

NetBet does its utmost to respect your privacy and to ensure that your data is protected. In particular we ensure that we are compliant with the following applicable data protection laws:

i) The Maltese Data Protection Act (Chapter 586 of the Laws of Malta) and any relevant subsidiary legislation;

ii) The General Data Protection Regulation (Regulation (EU) 2016/679) of the EU Parliament and of the EU Council (hereafter the ‘GDPR’); and

iii) Any specific data protection legislation or instrument in the territory or market of operation, as may be applicable by virtue of territorial or extra-territorial scope of application.

By accepting this Privacy Policy, you are confirming that you have fully read and understood how your personal information is used by NetBet, as set out in this policy. Furthermore, it is your responsibility to ensure that the information provided to us by yourself is kept accurate and up-to-date.

1.     Who we are

References in this Privacy Policy to “NetBet”, “we”, “us” or “our” relate to NetBet Enterprises Ltd C 39044, Ewropa Business Centre, Level 3, Suite 704, Office A, Dun Karm Street, Birkirkara, BKR 9034, Malta.

NetBet, as the data controller, determines the purposes and means of processing your information.

2.     Contact details

For general queries, please get in touch with our Customer Support team via phone, e-mail or live chat.

For more specific questions regarding your personal information or how we use it, our Data Protection Officer (DPO) can be reached at [email protected].

You can find useful information about how to exercise your rights in the section “Your rights concerning your Personal Data” below.

3.     Information we collect

The personal information (“Personal Data”) about you that we collect includes:

● Registration and Contact Data that is information that you provide us during the account registration process for any of our products and services (‘Services’) and/or when you open your Member Account with us (as per the NetBet T&Cs) including first name, last name, username or similar identifier, date of birth, gender, opt-in for marketing, jurisdiction, and any additional information you submit through your use of our Services, for example on any forums, chat rooms, comment sections or in response to quizzes and questionnaires. Contact Data includes permanent address, email address and telephone numbers.

● Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) that include your permanent address and proof (e.g. utility bill or other documentation showing your address), nationality, employment information (i.e. descriptive occupation, business phone number, employer name and address), politically exposed person information and head of international organisation information, open source information, financial status information (e.g. bank statement, source of income and source of wealth, tax information), government-issued identification number, KYC documentation (e.g. ID card, Power of attorney), country of residence, place of birth, and citizenship,

● Responsible Gambling Data (RG) including name, surname, postal code, email, phone number, country, date of birth, territory applicable social insurance number where permitted or required by law, approved transactions (deposits and withdrawals), denied transactions (deposits and withdrawals), Identification and Verification Data, Self-exclusion Data, player session lengths, reason for denied transactions, customer use of on-site tools (session reminders, cool-off, self-exclusion, deposit/bet/loss limits and account closures), completion of on-site "fair gaming" questionnaire, session limit, loss limit, wager limit, deposit limit, reality check

● Self-exclusion Data includes data pertaining to you and your self-exclusion such as your Registration and Contact Data and your self-exclusion info such as reason, start and date, utilisation of self-exclusion tools.

● Transaction Data which pertains to dDetails of any transactions you carry out with us, such as payments, withdrawals and wagers.

● Communication and Correspondence Data which pertains to details of your participation in our surveys or promotions and your communications through our Services, Your interactions with our customer support team (e.g. chat, phone calls, e-mails). including our social media channels y.our response to marketing campaigns, from us or through our third parties i.e. when you open/click on such e-mails.

● Device Data from the device that you use to access and use Services. For example, mobile network information, location data, IP address, browser type, hardware model, operating system and version, software and unique device identifieridentified., pages visited, content viewed, links and buttons clicked, URLs visited before and after you use our Services. You can find the section “Cookie Policy” below for further information.

NetBet ensures that no special categories of personal data is collected or processed on you. Special categories of data include race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. However, please note that in certain cases, such as for Responsible Gambling purposes, there may be situations where you may willingly choose to provide us data that would pertain to a health nature. Although provided by yourself, we will ensure that sensitive data is only utilised by us to specifically comply with obligations that are established by law.

4.     Information obtained from third parties

We may also collect information about you from third parties, such as our partners, service providers and publicly available websites, in order to comply with our legal and regulatory obligations.

We may use services offered by trusted third parties to process your information. These services include, but may not be limited to customer support, information technology, payments, sales, marketing, data analysis, research and surveys. We may share information about you with such third parties as is necessary for the performance of their services to us. This includes sharing your personal data with payment services providers, depending on the payment method chosen by you, for the purpose of facilitating deposits and withdrawals.

For our AML/CFT/KYC compliance legal obligations, we may obtain data from 3rd party providers. Moreover, we may carry out investigations in your background information which is processed from publicly available or open sources, such as but not limited to, through Google searches, all social media services like Facebook, Twitter, Pinterest, Instagram, LinkedIn as well as other services/sites.

5.     How we use your data

We use the information we collect from you to provide, maintain, protect and improve our Services, to develop new ones and to protect NetBet and yourself. We also use this information to offer you tailored content, like sending you more relevant promotional offers.

We will process your data in the following ways:use your data to:

● To set up, validate and manage your account

● To improve customer support and training

● To verify your identity

● To process payment information

● To communicate account and services information

● To ensure you are using the version of NetBet that corresponds to your location

● To verify your age and the accuracy of your registration details

● To iimprove your experience with the website, offering products and services relevant to your interests. This is necessary for the purpose of our legitimate interests in delivering or presenting relevant content to our customers.

● To promote marketing and events (unless you decide to withdraw your consent to it, which you can do through your account. Please allow up to 24 hours for any changes you make to your marketing preferences to be fully processed.)

● To evaluate and manage any risks you may pose to our business

● To research and diagnose our internal system issues, develop and improve our websites and their features.

● To personalise your experience through chat rooms, messaging and community forums. A number of our Services provide these for collaboration, peer connection, games, and NetBet information exchange purposes. We may use information you provide in the community, event profiles and forums to enhance our service. These services may have their own Terms of Use and, where appropriate, their own privacy statements.

● To uphold licensing and legal obligations, such as Responsible Gambling, Anti Money Laundering, Age Verification, Prevention of Fraud and to ensure the integrity of sporting events

● To subscribe players to our loyalty program

● To segment customers for marketing purposes and for responsible gambling purpose

● We may be required to use and retain personal information for loss prevention and to protect our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.

Please note that, unless you give us your prior written consent and/or you do not opt out to marketing communications, we will process personal data for marketing purposes as we see necessary for the purpose of our legitimate interests in promoting our products and services. We may publish players’ aliases and/or chat names, along with any winnings and prizes received, in accordance with our legitimate interests. Please note that we will provide you with the opportunity to opt-out before we publish such information.

6.     Legal basis of processing

Data Protection laws oblige NetBet to have a legal reason, referred to as a ‘lawful basis’, to justify the carrying out of a processing activity. NetBet determines the appropriate lawful basis before carrying out any processing activity.

For NetBet’s marketing activities, we will rely on your explicit consent which is obtained during our sign-up process. You can choose to opt-out from receiving marketing at any time and revoke your consent, whereby we will cease sending promotional material to you. Please note that even though you may have opted out from marketing we may still send you service messages which are necessary for providing our service to you.

Furthermore, during the course of our marketing campaigns we may analyse and establish various segments of our customers. NetBet ensures that these segments are processed and created manually with the intention of offering the most relevant and appropriate offers, bonuses, and messages. This segmentation is not taken automatically and will always involve human intervention.

The below table summarises the processing activities carried out by NetBet and the corresponding legal basis that we are relying on:

Purposes	Data Utilised	Legal Basis
To register you as a new player with NetBet and to provide you with access to our Games	● Registration and Contact Data	Performance of a Contract
Processing and management of Transactions through our payment service partners (‘PSPs’)	● Transaction Data	Performance of a Contract
‘Know Your Customer’ procedures	● Identification and Verification Data ● Device Data ● Registration and Contact Data	Compliance with our Legal Obligations
To ensure that we comply with our Responsible Gambling obligations	● Responsible Gambling Data; ● Transaction Data; ● Identification and Verification Data ● Device Data	Compliance with our legal obligations
Managing our relationship with you and ensure an adequate customer experience	● Registration and Contact Data ● Transaction Data ● Correspondence Data	Performance of a Contract
Ensuring that our players have the ability to self-exclude themselves from gaming on our site.	● Self-exclusion Data ● Device Data	Compliance with our Legal Obligations
Direct Marketing (E-mail, Push Notifications, mobile, postal)	● Registration and Contact Data ● Device Data	Consent (opt-in)
To investigate any suspicious behaviour in order to protect ourselves from any risks, such as fraud.	● Registration and Contact Data ● Transaction Data ● Device Data	Legitimate Interest
VIP experience; offering a tailored and personalised experience. Profiling for purposes of offering this tailored service	● Registration and Contact Data ● Transaction Data	Legitimate Interest
Anti-Money Laundering and Counter Terrorism purposes	● Registration and Contact Data ● Transaction Data ● Identification and Verification Data	Compliance with our Legal Obligations
Customer segmentation for marketing purposes	● Registration and Contact Data ● Transaction Data ● Device Data	Legitimate Interest
Commercial business analytics, including improving of our customer experience and business offerings	● Registration and Contact Data ● Transaction Data ● Device Data	Legitimate Interest Performance of a Contract

7.     Data Transfer Outside the EEA (European Economic Area)

We will only transfer your Personal Data outside of the EEA where:

• You have given your explicit consent, or

• it is necessary for us to set up or fulfil a contract you have entered into with us, or

• to comply with a legal duty or obligation.

If we do transfer your Personal Data outside of the EEA, we will carry out a risk assessment and ensure that the necessary measures and safeguards are in place in order to ensure that your data is offered the same level of protection as it would be within the EEA by relying on one of the following:

• The country that is receiving your Personal Data has been found by the European Commission to offer an adequate level of protection for personal data as the EEA. More information can be found on the European Commission website here (*insert link* https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).

• We will use the standard contractual clauses approved by the EU Commission in our contracts that obliges the recipient to protect your Personal Data to the same standards as it would be within the EEA.

8.     Your rights under the Data Protection Laws

We will advise you if you choose to exercise any of your rights under the General Data Protection Regulation, including:

• Withdrawing your previously granted consent, however, this will not invalidate any previously consented processes

• Lodging a complaint with any relevant Supervisory Authority

• Access to your Personal Data that we hold or process

• The correction of any Personal Data that is incorrect or out of date

• The erasure of any Personal Data that we process, when there is no compelling reason to continue processing it

• Restricting the processing of your Personal Data in certain circumstances

• Right to data portability, that enables you to ask us to provide you or another company you nominate with some of your Personal Data

• The right to object to any processing data where we are doing it for our own legitimate interests, although we may continue to process your data when there are compelling legitimate grounds or in connection with any legal claims

• The right not to be subject to a decision made entirely by an automated process. This means you can request that we involve a person in the decision-making process.

9.     Who we share your information with

We may use services offered by trusted third parties to process your information. These services include customer support, information technology, payment service providers (‘PSPs’)s, sales, game providers, marketing, data analysis, cloud service providers, research and surveys. Please note that we will share data with our partners and processors however when doing so we will ensure that the necessary contractual arrangements are in place with our providers and/or that an appropriate legal basis is in place before sharing any data. We may also be obliged to assist our PSPs by sharing KYC documentation and/or information in order for them to comply with their own legal obligations. Before sharing any data with PSs, we will ensure that all appropriate safeguards are in place.

We may also share your personal information with the following organisations to comply with our legal and regulatory obligations:

● Law enforcement agencies, regulators and other authorities

● Credit reference agencies

● Fraud prevention agencies

● Identity verification agencies

● Sports governing bodies

● Organisations that introduce you to us

● Third parties you ask us (or permit us) to share your data with

10.     Retention Period

We will ensure that your Personal Data is protected and only used for reasonable or justifiable purposes.

Please note that we will store your data for as long as you remain a customer with us.

If you stop being a customer with us, we will keep your data for the minimum length of time necessary in order to fulfil any purpose set out in this policy and any relevant legal or regulatory obligations. We determine whether data is still necessary or not by identifying whether there is any specific EU or national law, such as, but not limited to, licensing requirements, tax requirements, statute of limitations, or other such legislation.

We will generally retain your data for no longer than 10 years from the moment that you close your account. However, please note that we may retain your data for longer in the case where the statute of limitations of a particular territory is longer than the 10 year timeframe. In certain cases, we may also be required to retain data for longer in the scenario where you are under an investigation by an authority or where there is a legal dispute including cases where we need to defend ourselves.

Please note that we may be required in certain circumstances to retain your information indefinitely (for example under our procedures on responsible gambling and self- exclusion). We will take all necessary steps to ensure that the privacy of information is maintained for the complete period of retention.

11.     Security

We understand that online security and data protection is an area of vital importance for all of our customers, so it is important to us that you have confidence in the security of your personal details before you register an account. We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. Our technological security solutions are robust and are governed by a mature framework.

Our approach is focused on preventing risks. In order to help us in this regard, we adopt robust procedures and technologies to reduce the impact of any potential incidents. As the security of some communications via the internet are not completely secure, we cannot guarantee the complete security of any information that you disclose using your internet connection. You accept the internet security implications of using the internet and the NetBet Group will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.

12.     Changes to our Privacy Policy

We may update this policy from time to time, so please review it frequently. If any material changes are made to this Privacy Policy we will use reasonable endeavours to inform you in advance by e-mail or notices on our website or other agreed communications channels. We will communicate the changes to you in advance, giving an appropriate amount of time for you to consider and understand the changes before they become effective.

We will not enforce material changes to the Privacy Policy without your express consent. If you do not accept the changes to the Privacy Policy, or fail to accept the changes in time, we may not be able to continue providing you with some or all products and services.

13.     Cookie Policy

Cookies are text files composed of letters and numbers that are stored on your computer or device when you visit our site/s. Cookies collect some of your personal data when you use our site in order to improve your online experience. Cookies also allow us to identify you in order to be able to tailor our content relevant to you. NetBet utilises both first party and third party cookies, and therefore both types of cookies are stored when you access our products and services.

We use different kinds of cookies:

Strictly necessary: these cookies are essential for the functioning of our website. They allow you to login, navigate and view our products and services, and are crucial for providing our services to you. Moreover, they can be used for security and integrity purposes. Please note that such types of cookies are placed on your device regardless of your settings.

Functionality: these cookies storer the choices that you make and primarily function in order for us to improve and personalise your experience.

Performance/Analytics: these types of cookies collect information about the way you use the of the website and interact with our services and help us improve the performance of our website. Please note that, in most cases these cookies collect the information in an aggregated manner and without specifically identifying you.

Third party Marketing/Targeting: These cookies allows us to deliver advertisements and content that is relevant and tailored to you. They might also limit the number of times you see a specific advertisement, measuring the effectiveness of an advertising campaign. We use cookies placed by third parties (including, for example, advertising networks and providers of external services like web traffic analysis services). If you disable these cookies, you will still be able to use our website, but the advertisements will not be tailored according to your interests.

Examples of these type of cookies are:

- Collecting information about your browser’s usage in order to target website content and adverts

- Delivering content and marketing communication tailored to your interests

- Performing search retargeting, which on the basis of your browsing activities allows our adverts to be displayed on third party websites

You can change your cookie settings at any moment, clicking on ‘options’ or ‘preferences’ menu of your browser or otherwise use the 'Help' option in your browser for more details. Please note that when you block or delete cookies, some of the services and functions of the website may not work as intended.