How we use your data

This Privacy Policy describes the way in which Cloudbet (otherwise referred to herein as "we" or "us") deal with the information and data you provide to us to enable us to manage your relationship with Cloudbet.

This Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other Privacy Policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Important information and who we are

Controller

The Cloudbet.com data controller is Halcyon Super Holdings BV who is responsible for your personal data.

We have appointed a Data Privacy Manager (DPM) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

Contact details

Full name of data controller: Halcyon Super Holdings BV

Name or title of DPM: Privacy Manager

Email address: privacy@cloudbet.com

Postal address: Halcyon Super Holdings BV, Pareraweg 45, Curaçao

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. This version was last updated on 5 June 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.

The data we collect about you

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). Information about a business is not normally personal data, although we may collect the personal data of individuals in the course of our dealings with businesses.

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

• Identity Data which includes first name, maiden name, last name, username or similar identifier, title and job title.
• Contact Data which includes address, email address and telephone numbers.
• Financial Data which may include any personal bank account, bitcoin, and payment card details that are provided to us and the results of credit checks where these are carried out on individuals.
• Transaction Data which includes details about payments to and from you and other details of products and services you have purchased using the Website.
• Technical Data which includes internet protocol (IP) address, your 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 you use to access the Website.
• Profile Data which includes your username and password, purchases and orders made by you or your feedback.
• Usage Data which includes information about how you use the Website
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences
• Cookies We use cookies to improve the user experience, and to gather general statistics about users of the Website. Among other things, cookies allow you to log on to the Website. We use both First Party Cookies – these are set by us and can only be read by our systems; as well as Third Party Cookies – these are by one of our approved third parties to monitor the Website and improve the user experience.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your 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 ). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you 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 you (for example, to provide you access to the Website or provide you with a service or information via the Website). In this case, we may not be able to provide the information or service in question.

How is your personal data collected?

We use different methods to collect personal data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial and other data through using the Website. This includes personal data collected through:

• - information that you provide to us by filling in forms on the Website or any other information you submit to us via the Website or email;
• records of correspondence, whether via the Website, email, phone or any other means;
• your responses to surveys or customer research that we may carry out;
• details of the transactions you carry out with us, whether via the Website or other means

• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  • Information provided by credit checking agencies.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data although in limited circumstances we may get your consent before sending some direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

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

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Data security

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

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

Phone Calls

Phone calls to and from our Customer Support Team are recorded for training and security purposes, along with the resolution of any queries arising from the service you receive.

Use of Cookies

We may use cookies as a means of collecting information from a web server for the above purposes following a customer's use of the Website.

What are cookies

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer if you agree. They help us to improve the Website and deliver a more personalised service. Cookies contain information that is transferred to your computer’s hard drive. Some of the cookies we use are essential for the Website to operate.

Cookies we use and their purpose

We use 7 types of cookies on our website - : ‘Strictly necessary cookies’, ‘Analytical or performance cookies’, ‘Targeting cookies’, ‘Functionality cookies’, ‘Session cookies’, ‘Fraud cookies’ and ‘Social media cookies’. Each type of Cookie and the purposes for which we use them are described below:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. For example, if you log into the website, we use a cookie to keep you logged in and allow you to access restricted areas, without you having to repeatedly enter your login details.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Session cookies: These cookies assist in managing your session and the navigation throughout the Website.
• Fraud cookies: These cookies help us prevent fraudulent activities on our website.
• Social media cookies: These cookies allow you to share what you have been doing on a website on social media, such as Facebook or Twitter which may be linked to targeting or advertising activities.

Internet-Based Transfers

Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Some of the data processors engaged to process personal data may be based outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Disclosure of Information

We may share your personal data with , the parties set out below for the purposes set out in the table above.

• The regulator, sporting bodies and other bodies, including the police.

• With corporate affiliates such as associated or subsidiary companies and to business partners and suppliers that are engaged to process such information on our behalf.
• 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 your personal data in the same way as set out in this privacy policy.

• Credit checking/ reference agencies.

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

Data retention

In order to comply with Cloudbet's legal and regulatory requirements and Cloudbet's own internal risk management procedures, we will retain your personal data for a period of time (generally not more than 6 years) after closure of your account. All such information will be held in accordance with this Privacy Policy.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your 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 you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to Our Privacy Statement

Any changes we may make to our Privacy Policy in the future will be posted on this page and any such changes will become effective upon posting of the revised Privacy Policy. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email, notice on the Website or other agreed communications channels.

Glossary

LAWFUL BASIS

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Last updated 5 June 2020.