PRIVACY POLICY

Your privacy is important to us, and we are committed to protecting your personal information. We will be clear and open about why we collect your personal information and how we use it. Where you have choices or rights, we will explain these to you.

This Privacy Policy explains how BetBull uses your personal information when you’re using one of our Application.

If you do not agree with any statements contained within this Privacy Policy, please do not proceed any further on our Application. Please be aware that registering an account on our application, placing bets and transferring funds will be deemed confirmation of your full agreement with our Terms and Conditions and our Privacy Policy. You have the right to cease using the application at any time; however, we may still be legally required to retain some of your personal information.

We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on our platforms. We recommend that you revisit this Privacy Policy regularly.

Who is in control of your information?

Throughout this Privacy Policy , "BetBull", "we", "our" and "us" relates to BetBull Limited, a limited liability company, registered in Malta with company number C68251, having its registered address at Tower Gate Place, Tal-Qroqq Street, Msida MSD 1703, MALTA operating by Vivaro Limited, a company duly incorporated and registered on 23rd December 2008 under the laws of Malta, with Company Registration No.C45929, and having its registered office and business address at Luxe pavilion 2nd level, Diamonds International Building, Portomaso, St. Julian’s, STJ 4010 Malta.

Our Data Protection Officer

If you have concerns or would like any further information about how BetBull handles your personal information, you can contact our Data Protection Officer privacy@betbull.com

Information we collect about you

Personally identifiable information

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

You provide this information to us in the process of setting up an account, placing bets and using the services of the application. This information is required to give you access to certain parts of our application and related services. This data is collected when you:

• Register an account with BetBull

• Voluntarily provide it when using the application

• Personally, disclose the information in public areas of the application

• Provide it when you contact our customer support team

The information includes your:

• Username

• First and surname

• Date of birth

• Email address

• Residential address

• Phone number

• Billing address

• Identification documents

• Proof of address documents

• Transaction history

• Website usage preferences

• Any other information you provide us when using our platforms

• Credit/debit card details, or other payment information

The information is also required for billing purposes and for the protection of minors. You can amend and update this information by contacting Customer Support. This data is for internal use only and is never passed to any third parties except those stated below.

Non-personally identifiable information and traffic analysis

BetBull strives to make our application as user friendly as possible and easy to find on the internet. BetBull collects data on how you use the site, which does not identify you personally. When you interact with the services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. This information is essential for the provision and quality of our services.

Cookies

Information placed on your device

When accessing our services, 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 that record your preferences. We also use Local Shared Objects or ‘flash cookies’. ‘Flash cookies’ are similar to browser cookies. They allow us to remember things about your visits across our sites. Neither cookies nor flash cookies can be used to access or use other information on your computer. We only use these methods to track your use of our services. Cookies help us monitor traffic to the site, 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 show you more relevant and desirable advertisements.

Strictly necessary cookies

Strictly necessary cookies are essential to allow a user 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.

During the registration process

These cookies will hold information collected during your registration and will allow us to recognize you as a customer and provide you with the services you require. We may also use this data to better understand your interests while online and to enhance your visits to our platforms.

On our website

For visitors to our website, we use cookies to collect information. Our servers use three different types of cookies:

A ‘session-based’ cookie: This type of cookie is only allocated to your computer 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 customer, it allows us to give you 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 computer for a period of time set for each cookie. Flash cookies are also persistent.

‘Analytical’ cookies: This type of cookie allows us to recognize and count the number of visitors to our site and see how visitors use our services. These helps us improve the way our sites work, for example, by ensuring you can find what you are looking for easily.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the 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 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 Settings Manager. Alternatively, you can also 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 older web browser, the Settings Manager may not be available to you. We recommend that you ensure that you refresh your Flash Player and browser to the latest available versions.

If you choose to decline cookies, you may not be able to experience all of the interactive features on our sites.

How and why we use your personal information

We use your personal information in a range of ways that fall into the following categories:

• To provide you with the products or services you have requested (contract)

• To meet our legal or regulatory obligations (legal obligation)

• To monitor our website or application performance; and (legitimate interest)

• To provide you with marketing information (legitimate interest)

Your rights over your personal information differ according to which category and lawful basis these fall into. This section provides more information about each category, the rights it gives you, and how to exercise these rights. These rights are in bold following each category.

Providing our products and services

We use your personal information to enable you to use our application, to set up your account, participate in the online casino and to provide you with customer service assistance.

To provide our products and services, we share your information with external organisations working on our behalf. Further information can be found in the Sharing Information section.

This category covers the essential activities required in order for us to provide you with the services you use or have signed up for. If you don’t want your information used in this way, your option is to not use our services and close your account.

Legal and Regulatory Requirements

In the UK, we are regulated by the UK Gambling Commission. To comply with their requirements, we carry out identity verification, fraud prevention and anti-money laundering checks when you create an account with us and throughout the life of the account.

UK customers can utilise ‘Gamstop’, a national self-exclusion scheme. Should this service be used, we will receive a notification and will then apply the chosen restriction across our application.

BetBull will use your identification document and/or proof of address to check your details in order for us to protect our users from fraudulent behaviour and to promote responsible gambling.

We may conduct a security review at any time to validate the registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms and Conditions and of applicable law. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third-party databases.

We are required to carry out these activities to provide our products and services legally, responsibly, and in line with the requirements stipulated by regulators. We cannot provide you with our services without carrying out these activities, if you don’t want your information used in this way, your option is to not use our services and close your account.

To monitor our website or application performance

As detailed above, we use cookies and traffic analysis in order to improve the performance of our application and services available. We have a legitimate interest in carrying out these activities and we ensure that we minimise any impact on your privacy. We may use your data for statistical analysis to help us understand how our customers use our service.

You have the ‘right to object’ to activities carried out for our legitimate interest if you believe your right to privacy outweighs our legitimate business interests. However, as the activities involved are central to our business, if you wish to object further than managing your cookies this may mean you need to close your account.

Marketing

As a social betting service, we provide you with information and notices of popular betting opportunities, betting fixtures and award you with the benefits and rewards you are entitled to receive:

• We communicate with you in order to ensure that we are giving you the best experience of our product.

• Our communication with you is in line with the normal practice and service that you would expect from other betting services.

• We ensure that our communications are not sent to you if you have chosen to exclude yourself from receiving such information. The Preferences section in Settings will allow you to choose how you wish to receive communication from us.

Communication may be via Push Notifications, email, SMS or online.

We may profile you to better to understand your preferences and which offers may be suitable to you.

From time-to-time, we may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age). By accepting any contest prize or winnings from us, you consent to use of your name for advertising and promotional purposes without additional compensation, except where prohibited by law.

When you share your bet, we may use your avatar, username and accumulators to share inside the app and to use for digital marketing assets, affiliate material, on social media, for offline marketing and in any other area for marketing purposes. Bet Sharing toggle in App Settings will allow you to stop sharing your bets with others. If you manually turn off Bet Sharing, we will remove associated profile from marketing banners within 5 days except for placements managed by third parties which could take up to 4 weeks.

You have the right to update your marketing preferences at any time and if you opt-out we will not send any messages to you.

Your rights

Your rights to rectification

If you believe the personal information we hold on you is incorrect, you have the right for this to be rectified. For any information that cannot be updated through My Account, please contact support@betbull.com

Your right to request a copy of your personal information

If you would like a copy of the personal information we hold about you, you should request it through live chat or by emailing privacy@betbull.com and we will provide you with a form to complete. The form is not compulsory but helps us to provide you with the information you are looking for in a timely manner. To ensure the security of your personal information, we will ask you for valid proof of identity and once we’ve received it we will provide our response within one month. If your request is unusually complex and likely to take longer than a month, we will let you know as soon as we can and tell you how long we think it will take, such request may also incur an administration cost.

Your right to complain to the regulator

Further information about your rights can also be obtained from your national data protection regulator – in the UK the Information Commissioner’s Office ( https://ico.org.uk/) or in Germany responsibility is split to regional authorities – the BFDI ( https://www.bfdi.bund.de) can provide you with relevant contact details. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection regulator.

Your right of erasure

You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.

The right to erasure does not apply if processing is necessary for one of the following reasons: to exercise the right of freedom of expression and information; to comply with a legal obligation; for the performance of a task carried out in the public interest or in the exercise of official authority; for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or *for the establishment, exercise or defence of legal claims.

Your right of to be informed

You can request information about our collection and use of your personal data. This Privacy Policy should tell

you everything you need to know, but you can always contact us to find out more or to ask any questions using the details at the end.

The right to access the personal data we hold about you

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in below.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

The right to restrict (i.e. prevent) the processing of your personal data.

The right to object to us using your personal data for a particular purpose or purposes.

The right to data portability

This means that, if you have provided personal data to us directly, we are using it with your consent or for the

performance of a contract, and that data is processed using automated means, you can ask us for a copy of that

personal data to re-use with another service or business in many cases.

Rights relating to automated decision-making and profiling

You have a right to request an explanation of the logic involved where we make decisions about

you solely through automated means. We do not undertake any automated decision-making.

Sharing your personal information

We may disclose your Personal Data to third parties:

• if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation;

• in order to enforce or apply the terms of this notice or any other agreements;

• to assist us in providing you with the products and services you request, including but not limited to third party software providers;

• if, in our sole determination, you are found to have cheated or attempted to defraud us, or other users of the service in any way including but not limited to game manipulation or payment fraud;

• for the purpose of research on the prevention of addiction (this data will be made anonymous)

• to protect the rights, property or safety of us, our customers or others; and

• where we have received your permission for us to do so.

Personal Information collected on the services may be stored and processed in any country in which we or our affiliates, suppliers or agents maintain facilities. By using our services, you expressly consent to any transfer of information outside of your country. When we transfer any part of your Personal Data outside the EEA or adequate jurisdictions we will take reasonable steps to ensure that it is treated as securely as it is within the EEA or adequate jurisdictions. These steps include but are not limited to the following:

• Binding corporate rules;

• Model contracts; or

• US/EU privacy shield

Security

We understand the importance of security and the techniques needed to secure information. We store all of the Personal Information we receive directly from 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). We also take measures to ensure our subsidiaries, agents, affiliates and suppliers employ adequate security measures.

Retention

We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, BetBull takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need your personal information, we securely delete or destroy it.

Third-Party Practices

We cannot ensure the protection of any information that you provide to a third-party online site that links to or from the services or any information collected by any third party administering our affiliate program (if applicable) or any other program, since these third-party online sites are owned and operated independently from us. Any information collected by these third parties is governed by the privacy policy, if any, of such third party.

Our application may contain links to other web sites, which are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours. We are not responsible solely the operators of these websites shall be responsible for their functionality or possible errors on the linked sites.

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of user behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of BetBull, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data

Place of processing: US-PrivacyPolicy-Opt out

Disclaimer

The Services operate ‘AS-IS’ and ‘AS-AVAILABLE’ without liability of any kind. We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technology and business, we cannot guarantee, nor do we claim that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said Personal Information.