10bet, which includes all of the entities specified below under “The Group” section, including its affiliates (collectively, the " Company"), offers online gambling services, such as casino, and sports gambling (collectively, the “Services”) via its own in-house brands (each, an "In-House Brand"; together with the Company: “Group”, " we", " our" or " us").
1. The Group and the Data Controllers
The Group and the Data Controllers includes and ares the following companies: Supabets Limited.
The Group provides the Services through the following applications and platforms (collectively the “Platforms”):
· This internet website, including any subdomains and any affiliated websites;
· Downloadable applications and software ("Software"), such as native applications which are distributed through mobile application stores, as well as PC and Mac desktop software which can be downloaded to your computer;
· Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.); and
· Facebook applications.
2. Privacy Principles
The Group follows the rules of ZDPR. This means that whenever we handle your personal data, we always follow ZDPR with regards to:
· Lawfulness, fairness and transparency
· Purpose limitation
· Data minimization
· Storage limitation
· Integrity and confidentiality
3. Why we Collect Personal Information
We need to process your personal information in order to provide you with our services. We will only ever ask you for the smallest amount of information that we need and we only ever use it for lawful purposes. We never sell your information to anyone else.
4. What information we collect?
We collect two types of information from our Users:
· Personal Information
The first type of information is information that identifies or may reasonably identify an individual with reasonable effort (“ Personal Information”). Personal Information that is being gathered may consist of the following:
· Registration details: When you open an account and register to use the Services, we may collect certain information as required under various Know Your Client("KYC") and Anti-Money Laundering ("AML") regulatory requirements, such as first and last name, email address, gender, birth data, physical address, ID number, phone number, occupation, your source of funds and source of wealth. Some of the information we process about you is necessary for us to meet the legal and regulatory obligations that we have as a gambling company. This includes licensing requirements, responsible gaming obligations and Anti Money Laundering (AML) Regulations.
· Governmental - issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
· Gaming information: in order for us to provide the Services, we automatically record different information related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings, as well as participation in promotions, draws or contests.
We also collect information regarding potential gambling problems or addictions, based on your patterns of gambling across our Service, in order to ensure a responsible gaming environment and as required by law.
· Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases etc.), payment information will be collected from you, such as your mobile money wallet details.
· Voluntary information: We also collect information that you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games. This includes information you are willing to share with us for the purpose of improving and developing our relationship with you, as well as for maintaining your satisfaction from our Services. Please note that communications with our Users (including VIP customers) can take place via a variety of channels, including through third party messaging apps.
· Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI and, MAC address), browser fingerprinting, IP address and geo-location data.
· Telephone calls: We record or monitor telephone calls the following purposes:
· Dispute resolution, exercise and establishment of legal claims;
· Customer service (such as ensuring quality monitoring and assurance, operational efficiency, ensuring that quality standards are met in terms of support performance and Users' satisfaction, etc.);
· Compliance monitoring;
· Training purposes;
· Detecting and preventing crime or fraudulent activities.
· Events: during our events, we conduct interview and take photos and videos, which may feature attendees, speakers, sponsors or exhibitors. Where photos and videos are taken that feature you as an attendee, speaker, sponsor or exhibitor, we may use those photos and videos for promotional purposes. We may also use your interview for promotional purposes (such as by quoting you).
· Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information that is relevant to the provision of the Services, as well as information that is gathered in order to verify your identity and prevent fraudulent or illegal activity.
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-personal Information we collect from or about you including the following:
· Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
· Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms.
· Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
· Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
5. Conditions for Processing Personal Information
We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws, based on the following lawful grounds:
· Fulfillment of a contract, compliance with a legal obligation
It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for the User Agreement) or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licenses and complying with any AML and KYC legislation.
· Legitimate interests
We also process your Personal Information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights, and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to anyone or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) detection and retention of information pertaining to those with responsible gambling issues; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iv) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (v) adhering to regulatory and statutory requirements; (vi) devising a tailored reward scheme for players; and (vii) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. However, on certain occasions, we may ask for your consent to processing Personal Information. In these instances, your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
· Special Categories of Personal
Our processing of your Personal Information may also involve special categories of personal data, such as your racial or ethnic origin. We will process such information, as well as disclose it to competent authorities (such as licensing bodies or law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act, (i) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes. In addition, we may process and disclose such information where it is necessary for the purposes of safeguarding your (or others’) economic well-being (such as detection and retention of information pertaining to those with responsible gambling issues).
· Vital Interest
We may process your Personal Information if it is necessary in order to protect your vital interests or the vital interests of another natural person, such as to prevent physical harm or threats that pose a risk of injury or other damage to the health of an individual.
· Public Task
On certain occasions, we may process or disclose your Personal Information if it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority; for example, if we are requested by an officer of a public body competent for investigating crime to cooperate in an on-going investigation, or where we decide to proactively disclose data to a third party having such an official authority (such as competent law enforcement).
The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected]
7. How we use the collected information?
We use your Personal Information for the purposes listed below:
· To set up, manage and update your account;
· To provide and operate the Services (such as for betting and payment processing);
· To communicate with you and to keep you informed of our latest updates to our Services and special offers;
· To market our Services (see more below under “Marketing”), as well as to serve you advertisements, personalised content including behavioral advertising;
· To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services). This enables us to understand the Users' preferences in order to better customize and personalize our offers and ultimately offer products and services that better meet the needs and desires of the Users, as well as to improve core product features. For this purpose, we collect the following information:
· Users' betting activity, capturing recording of betting sessions, as well as browsing and scrolling activity on our Services (including pages and links clicked, patterns of navigation, time at a page, devices used, where users are coming from etc.);
· Users' device data (including the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information).
· In certain cases, we may reach out directly to the Users and ask them to participate in an interview, survey or usability testing, or otherwise provide feedback on our products and Services. Such participation is voluntary and relies on the User's consent.
· For customer relationship management purposes, and to support and troubleshoot the Services and to respond to your queries;
· To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
· To provide you with a responsible gaming environment;
· To communicate with your and to process any of your requests to exercise your User Rights;
· To identify and authenticate your access to certain features of the Services;
· To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
· To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
· To investigate and resolve disputes in connection with your use of the Services;
· To assist us with meeting our regulatory obligations or as required by law or regulation (such as gambling regulations, KYC and AML regulatory requirements), including for the purpose of ascertaining your source of fund or income, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request:
· At times we need to ask you for your assistance to be able to confirm your identity and age, and show that you have sufficient funds to support your gambling activity. Where such information is required, your account may be subject to certain restrictions until you have provided the requested information and documentation in order to satisfy these checks.
· In order to verify your identity, we may ask you to provide a copy of photographic ID such as a copy of your passport, ID card, driving license or a document confirming your residential address such as a utility bill.
· In order to verify the source of wealth and the funds you use to bet with, we may ask you to provide additional information and documentation that shows you have sufficient funds to support your gambling activity. This might include information such as your occupation and salary, supported by documentation such as a copy of your bank statement or payslip.
· In addition, we use your Personal Information upon your specific and informed consent, such as for certain marketing and promotional activities.
The Group will use your Personal Information, such as your telephone number, ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; or (ii) the Group's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
We will use your Personal Information for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.
You may at any time decline receiving further marketing offers from us or from our Marketing Affiliates by contacting us at [email protected] or by unsubscribing from receiving marketing materials by following the guidelines available on the marketing communications (such as clicking on an “unsubscribe” button). Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you personaliszed content, service-related updates and notifications.
Please note: you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third party platforms (e.g. Facebook).
In addition, if you download any of our mobile application to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the setting on the device itself.
9. With whom we share information?
We share Personal Information with any of the following recipients:
· Any replacement service provider that we engage with to operate the Platforms;
· Companies within the Group and other affiliated companies;
· Gaming providers;
· Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
· Payment service providers, payment processors and banks;
· Any third parties who provides services in relation to the operation or promotion of the applicable Group’s brands;
· Any third party who provides you with tangible prize;
· Any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within the Group;
· Hotels and flight companies (such as in the context of offline events and promotions);
· Auditors, contractors or legal/financial/other advisers of any of the Group’s business processes;
· Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies, including in order to ascertain your source of income or funds (e.g. governmental authorities, police, banks and other investigatory organizations);
· Gambling addictions bodies;
· Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
· Storing such information on our behalf, for example by using cloud computing service providers;
· Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
· Performing research, technical diagnostics or analytics;
· Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, in the section titled "Marketing"); and
· When it is necessary for the protection of your vital interest or the vital interest of another natural person.
10. Third Party Tracking Technologies
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
11. Third Party Services
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
12. Retention Of Personal Information
If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, as strictly necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations, as well as to meet the Group's contractual obligations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where the Group is guided to do so by the applicable supervisory authority.
13. Your rights
You may contact us at any time by email (at: [email protected]), and request:
· To access or delete any Personal Information relating to you;
· To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
· That we will restrict or cease any further use of your Personal Information;
· That we will provide the Personal Information you volunteered to us in a machine-readable format.
· To object to the processing of your Personal Information (such as for marketing purposes);
· To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
· To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
14. How We Keep Your Information Secured
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
· Secure network topology, which includes intrusion prevention and Firewall systems;
· Encrypted communication;
· Authentication and Access Control;
· External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
16. How To Contact Us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at [email protected]
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. The Data protection officer (DPO) will then look into your questions and whether your information has been handled appropriately and in line with this privacy notice, our legal obligations and our internal policies and procedures. The DPO will then contact you regarding the outcome of the assessment and any steps that have been taken as a result.
If after raising your issues with the DPO you are unhappy with the resolution you can file a complaint online to the lead data protection supervisory authority - the Zambia Information and Communication Technology Authority.