Rev.: 04 – 15/07/2019 – Sogno di Tolosa Ltd
The Privacy Notice describes how www.betn1.com and its subdomains, operated by Sogno Di Tolosa Limited (or otherwise referred to herein as “betn1” “us” or “we”) treats your personal information and the data provided to us in order to be able to manage our relationship. We manage any personal information you provide to us (either through the website of www.betn1.com or through any other similar means) and are kept by us in relation to you in the manner specified in this Privacy Notice. This privacy notice applies to the betn1 website and also to official presence on any social media (e.g. Facebook, Instagram). Where we refer to the “Website”, we also refer to data collection via these third-party platforms. You can contact us via email at [email protected]
WHO ARE WE?
www.betn1.com is operated by Sogno di Tolosa Limited which is a Maltese Company whose registered address is at 114/3, The Strand, Gzira, GZR1027, Malta.
We may be contacted at [email protected]
Our Data Protection Officer may be contacted on [email protected]
WHY DO WE COLLECT PERSONAL DATA?
We need to collect data from you to be able to provide you with the service of remote gaming. This may include the need to share this data with our partner companies and service providers, with whom we would have established safeguards to protect your data, for the purpose of providing you with our services as requested when you signed up and accepted the terms and conditions.
When we provide remote gaming services to our customers, we must collect personal data from you so that we can comply with our legal obligations related to our remote gaming licence obligations to the Malta Gaming Authority, for company tax reporting obligations to the tax authorities, and to meet our obligation to assist authorities, when requested, in the investigation of potential criminal activity.
We also have a legitimate interest to protect our services from promotion abuse, fraudulent activities and internet security risks. This also allows us to ensure the security, integrity, accessibility and availability of our data and services.
We will also ask you if you wish to receive marketing communications from us so that you are constantly kept updated with news about new products, bonuses, special offers and other similar promotions. You have the right at all times to withdraw your consent through your account profile privacy settings or by contacting our customer support.
WHAT PERSONAL DATA DO WE COLLECT?
Your personal information, which we collect and use, relates to the following:
- Personal identification and communication details provided to us by completing the registration form on the website or any other information you submit to us through the website or by email.
- Verification documents provided for Identity, Age and Address, Payment Method verification and other documentation we may request due to our obligations at law.
- Contact information collected through the website, email, telephone or other media.
- Your answers to questionnaires or surveys we may conduct directly or through third parties.
- Elements of transactions, including financial accounts information that you may provide us, made through the website, telephone or other media.
- Details of your visits to the site, including but not limited to traffic data, site information, weblogs and other contact information.
- Telephone calls or chat sessions to and from our Customer Service Department are recorded for security and educational purposes along with the resolution of questions arising from the service provided to you.
We do not collect special categories of data on a regular basis; however, we may receive such data from you if you tell us that you have a problem controlling your betting activity. We would treat such data as equivalent to health data and protect it accordingly.
We also receive your personal data indirectly, when you use our services via a Sportello Virtuale based in the Italian territory, and use it to provide you with the service of online gaming, as well as to comply with our legal obligations such as AML requirements and obligations.
COOKIES AND WIDGETS
Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the website and provide better and more personalized services. Some of the cookies we use are necessary for the operation of the site.
If you want to delete any cookies already stored on your computer or stop cookies that record your browsing habits on the webpage, you can do so by deleting your existing cookies and / or by changing your browser’s privacy settings to block cookies (the procedure you follow will vary depending on the browser). Please note that by deleting our cookies or by deactivating our future cookies, you may not be able to access certain sites or services on the site.
Our website also features social media widgets, such as the Facebook “like” button, Twitter “follow” button. These social media features are either hosted by a third party or directly on our website. When using these widgets, or our respective pages on these provider’s platforms, we encourage you to read and refer to their respective privacy notices.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services:
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 this Application, 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.
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, for contacting and being contacted by this Application support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Tawk.to Widget (tawk.to ltd.)
The Tawk.to Widget is a service for interacting with the Tawk.to live chat platform provided by tawk.to ltd.
Personal Data collected: Cookies, Data communicated while using the service and Usage Data.
When available on our website, by registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this website. Your email address might also be added to this list as a result of signing up to this website or after making a purchase.
Personal Data collected: email address.
HOW DO WE USE YOUR PERSONAL DATA?
We use your personal data to:
- Create, operate, and manage your account.
- Allow you to participate in games and perform relevant functions to participate in them.
- Carry out identification procedures for your participation in the game.
- To place your bets and processing online payments.
- Comply with the legal and regulatory frameworks governing our operations, including transmission of personal details, personal data about transactions and traffic data to authorities.
- Create personal profiles for Fraud and Anti-Money Laundering Risk Assessment purposes.
- Track transactions for the purpose of preventing fraud, abnormal betting, money laundering and fraud, including exchanging personal data with our suppliers of Payment Processing services.
- Conduct research, questionnaires and analysis.
When you explicitly consent to marketing, we use your data to provide you with information about site changes, new services, offers and promotions. In case you do not wish to receive marketing information, you have the right to leave or opt-out of this service. You can re-consent to be provided with marketing information by emailing our support department or by using your Privacy Dashboard.
Personal data that is provided to us will be shared amongst group companies which will handle relevant aspects of processing in order to provide you with requested services.
To provide our services, and for the purpose of preventing illegitimate use of our services, we carry out profiling of our customers and their activities using automated processes. However, any decisions taken based on these profiles and information are taken by natural persons.
WHERE DO WE KEEP YOUR DATA?
We take all industry standard precautions to keep your personal data secure within our European Union physically located servers. These servers may in turn be accessed through encrypted connections over the internet. For this purpose, we do our utmost to follow best security practices and standards such as the ISO27001:2013 ISMS standard.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Betn1 may disclose or transfer data you provide to us, or inferred data based on your data for multiple purposes as described in the following sections:
Disclosures to third parties to provide you with services
Your personal data is transferred to some companies to carry out the following processes:
- Payment processing;
- Marketing (where consent has been provided – further information below);
- Casino platform services (e.g. Playngo, Casinolive,); and,
- Anti-Fraud and Anti-Money Laundering checks.
We ensure that data transfers with service providers are covered with appropriate controller-processor contracts and safeguards as specified by the General Data Protection Regulation (EU2016/679). Such contracts include confidentiality, strict processing rules, security safeguards, breach notification requirements and provision of assistance to Betn1 so that any exercise of your rights is satisfied.
In the event of a sale or purchase of any business, asset or share, we will attempt to inform you of it, as well as of the identity of the new Data Controller either by directly contacting you, by placing public notices on our website and potentially by using other appropriate media.
Disclosures to third parties to satisfy regulatory obligations and legitimate interests
When processing your betting account and its associated transactions, Betn1 and its contracted processors may need to appeal to credit rating agencies, fraud detection agencies and money laundering agencies to be able to comply with its regulatory and statutory obligations.
The purpose of such communications would be to:
- Assess whether you may be a Politically Exposed Person or an individual subject to Financial Sanctions;
- Assess whether your personal details are similar to those of people suspected of having committed fraud or money laundering;
- Verify your personal details through electronic means by matching against third party databases.
Where such information is requested by payment providers in relation to enquiries regarding fraud, we shall also provide such personal data as long as the request for information is aimed to protect your rights and/or, the legitimate interest of the company to protect itself from fraud.
We ensure that data transfers outside of group companies are covered by appropriate controller-processor contracts and safeguards as specified by the General Data Protection Regulation (EU2016/679).
DISCLOSURES TO REGULATORY AUTHORITIES
To satisfy our legal obligations, we may be requested to disclose your data to the:
- Malta Gaming Authority;
- Financial Investigations and Analysis Unit;
- Sanctions Monitoring Board;
- Other applicable Law enforcement bodies where so requested.
This can include transferring of all personal details, verification documents, payment and betting transaction history, communications history and any other information we have about you. The methods of transfer of such data may be prescribed by the relevant authority, over which we do not have control.
Disclosures for marketing Purposes
Betn1 will share personal data with marketing partners (network providers, affiliates, etc.) only based on a freely given, specific, informed and unambiguous consent from you. Such partners would be limited to receive contact information such as e-mail address and sports preferences for marketing reasons.
Your consent may be withdrawn at all times through your account profile or by contacting us on [email protected] .
Should you withdraw your consent, the company will inform marketing partners to stop their marketing communications to you as soon as your wish is communicated to them.
DO WE DO TRANSFERS TO THIRD COUNTRY?
The company does not regularly share any of the personal data you provide us to third parties (outside of group companies) located outside of the European Economic Area or countries considered by the EU to provide an equivalent standard of data protection.
If in the future the company will need to carry out transfers of personal data to such third parties (outside of group companies) to be able to provide you with your requested services, we will let you know about it. In such a case, we would ensure that we follow applicable data protection legislation and seek approval from our Lead Data Protection Authority to ensure that at all times, your personal data rights are respected and guaranteed.
FOR HOW LONG DO WE KEEP YOUR DATA?
After the closure of any account, Betn1 retains certain elements of personal data for a period of up to 10 years to meet our legal obligations towards Anti-Money Laundering and Countering Finance of Terrorism, Company and Taxation record-keeping obligations.
- For up to one (1) year: Details of your visits to the site, including but not limited to traffic data, site information, weblogs and other contact information; Telephone calls to and from our Customer Service Department;
- For up to 5 years from last activity: Personal identification and communication details provided, contact information through the website, email, telephone or other media;
- For up to 10 years from last activity: Elements of transactions, including financial accounts information that you may provide us, made through the website, telephone or other media.
We will also keep personal data for the purpose of presenting and processing in case of a litigation or a legal process which you, the relevant authorities or us may be party to, due to our provision of services to you.
If your account, in any of the above cases is not active, then we will not process the data further except for complying with the above legal obligations.
All this information is stored in accordance with this Privacy Notice.
YOUR PERSONAL DATA RIGHTS
You have the right to:
- access to the personal information provided by you;
- request rectification of personal data that you consider incorrect;
- request for restriction of processing of data;
- request erasure of data;
- file an objection about processing of your data;
- request to export and/or to transfer your data;
- be informed about automated individual decision-making, including profiling; and
- Your rights may be exercised in accordance with the Law, which might include restrictions on when you can exercise these rights.
You can exercise these rights by accessing your Privacy Dashboard or by contacting us on [email protected]
You have also the right to lodge a complaint with our Data Protection Authority, which is the Information and Data Protection Commissioner whose website may be found at http://www.idpc.org.mt/
You may also decide to lodge a complaint with your local Data Protection Authority. You may find a list with your local Data Protection Authority contact details at
CHANGES TO THE PRIVACY NOTICE
Any changes we may make to our Privacy Notice in the future will be published from this page on the site and will be effective from the time of their posting. Where the changes are substantial, we will offer you the chance to preview these changes and decide whether you wish to remain our customer prior to these changes coming into effect.