Privacy Policy

1.0 BACKGROUND

Bahamas -based entity AE Limited (AE), registered in the Commonwealth of Bahamas under Company No. 200850 B, with its registered headquarters at 1st Floor, Building A, Caves Corporate Center, Blake Road & West Bay Street, Nassau, Bahamas. (“we” “us” or “our”), is an online entertainment company that provides interactive gaming experiences. AE collects specific types of customer data to enable these services and to create an optimal Customer Experience (CX) across our platforms. AE is the Data Controller for the personal data it processes under this policy. A “Data Controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. The Controller’s Data Protection Officer (DPO) can be reached at DPO@bet5games.com.

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. If you wish to update your personal data, please do so via your account or by contacting DPO@bet5games.com.

2.0 SCOPE

This policy explains what personal data AE collects, how the personal data is used (processed, stored, and shared), how the personal data is protected, and your rights relating to your personal data. This policy describes the basis for collecting, processing, and sharing your personal data and provides relevant contact details.

This policy is applicable to our use of personal data, and it is designed to meet the company’s legal obligations. We recognize that the use and disclosure of data has important implications for us and for the individuals whose data we process. We operate in countries which regulate the use and impose restrictions on overseas transfers of personal data. To ensure that we handle personal data properly, we have adopted a global approach to our privacy compliance.

Personal data includes any information about an individual from which that person can be identified. It does not include personal data where the identity has been removed (anonymous data). This includes information that can or could be used to identify an individual or an individual’s online activity either directly (e.g. name, e-mail-address) or indirectly (e.g. payment-data). Personal data can also be your use of a website (e.g. Information about website visits, browser info and information regarding your device(s)).

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3.0 WHY AND HOW AE COLLECTS AND USES PERSONAL DATA

AE’s goal is to be a premier entertainment provider and to deliver a world-class CX to each user every time they use one of our products or services. Achieving this level of service requires an in-depth understanding of our users’ preferences, what they like about the products and services, and what can be improved upon.

We will only process (i.e. use) your personal data when the law allows us to, that is, when we have a legal basis for processing. Section 4.0 (PERSONAL AND SENSITIVE DATA WE COLLECT AND PROCESSING PURPOSES) below sets out further information about the legal basis that we rely on to process your personal data. We use your personal data in the following circumstances:

• “performance of a contract”: where we need to perform a contract which we are about to enter into or have entered into with you as a party or to take steps at your request before entering into such a contract;
• “legal or regulatory obligation”: where we need to comply with a legal or regulatory obligation that we are subject to;
• “legitimate interests”: where necessary for our interests (or those of a third party), provided that your fundamental rights do not override such interests. This can mean, for instance, that it is in our interest to understand how you interact with our games to ensure that the security of games is maintained. 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; and
• “consent and explicit consent”: where you have provided your consent or explicit consent to process your personal data.

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 at DPO@bet5games.commailto:.

It is our intention to only collect the data required to provide our products and services and/or meet legal and regulatory requirements.

4.0 PERSONAL AND SPECIAL CATEGORY/SENSITIVE DATA WE COLLECT AND PROCESSING PURPOSES

AE and where applicable its partners will securely collect, process, use, store, and transfer the following categories of personal data to enable us to provide our services, optimal operations, meet regulatory requirements, and continuously improve our products, services, and CX. We may process your personal data under more than one legal basis depending on the specific purpose(s) for which we are using the data. Please contact us at DPO@bet5games.com if you need details about the specific legal basis, we follow to process your personal data where more than one ground has been set out.

• Providing our services this data includes all of those listed below to be able to actually provide our services, but will also include, in some instances, your Personal Data being made publicly available e.g. when you are participating in a tournament, your ranking and league position may be made public.

• User Data, Background Checks, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and Problem Gambling Prevention – this includes proof of a user’s identity, name, age, data of birth, residency, location, likeness (i.e. images, photos, voice, and/or identification (ID) uploaded by the customer ), ticket ID (i.e. this is associated with your activity with us) account information (i.e. User ID and Password), occupation, preferences and trends, and associated account data (i.e. social media accounts the customer chooses to link to their profile) to help ensure the customer’s eligibility to legally use and participate in AE’s products and services. This may include submitting your personal data (which may include your financial data for example, sources of income/wealth from bank statements), your name and address and for the prevention of problem gambling, transaction ID and the volume, types, information you provide to customer services and the amount of each of your transactions, for a credit or background check to a third-party service provider, and to conduct affordability assessments, source of wealth/income checks, KYC, CDD, and/or EDD processing in compliance with our obligation to regulators to prevent problem gambling, fraud, money laundering, and terrorism funding activities. Our lawful basis for processing this activity is legitimate interest and legal or regulatory obligation.

• Contact, Marketing, and Communication (CMC) Data – this data includes customer’s telephone number, communications preferences, email address, and records of consent to marketing communications from AE (e.g. special offers, promotions, and newsletter). With Personal Data, we use CMC data to ensure that only age-appropriate and legal marketing strategies are used. Our lawful basis of processing for this processing activity is consent and legitimate interest. You have the right to withdraw consent to electronic marketing at any time by following the unsubscribe instructions in such marketing materials or by contacting us.

• Technical and Behavioral Data – customer location, login data, browser info, time zone, device ID, operating system/platform, voice data, other technologies on the device, and IP address will all be collected when accessing AE products and services. This information will help build the customer’s profile, be used to expedite user authentication and to train, evaluate, and improve the speech recognition and natural language understanding models in our voice user interface. for this processing activity is legitimate interest.

• Contact (Non-marketing) – AE may need to contact you regarding your activity on its platforms, products, or services via phone, email text message or instant message for the following reasons: in relation to participation in tournaments and leagues and other online services, to conduct KYC and/or CDD, to investigate suspicious or potentially problematic activity, and for any other account related functions or operations. Our lawful basis for processing this activity is performance of a contract, legitimate interest and legal or regulatory obligation.

• Special Category/Sensitive Personal Data – Special categories of personal data include 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. In limited circumstances, we collect special categories of personal data about you to conduct KYC and/or CDD.

We will only use your personal data for the purposes for which we collected it as detailed in Section 3.0 (WHY AND HOW AE COLLECTS AND USES PERSONAL DATA) and Section 4.0 (PERSONAL AND SENSITIVE DATA WE COLLECT AND PROCESSING PURPOSES), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at DPO@bet5games.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.0 DATA COLLECTION METHODS

AE uses three basic methods to collect different types of personal data: direct customer-provided collection, indirect system-to-system collection, and third-party collection.

• Direct Collection – a customer uses AE’s website/platform to manually enter data, upload data (e.g. images), or send AE artifacts (e.g. copies of driving license or passport) and content during activities such as:

  • creating an account or updating a profile,
  • signing up for a newsletter, service, or membership program
  • Using your voice to help assist you when you are playing one of our games
  • communicating with AE via the website, or platform or via phone. This may include AE recording phone calls between you and AE personnel to confirm business transactions and/or to ensure compliance with regulatory requirements.

• Indirect Technical Collection – when a customer uses AE’s website/platform or associated third-party communications tools (e.g. Facebook Messenger), the system will automatically collect technical data from the customer’s device (i.e. hardware and software), usage data about the customer’s browsing, playing preferences, and session patterns. AE also uses cookies, session replay (a.k.a. session recording), and other analytics to automate technical data collection.

• Third-Party Collection – when a customer uses a social media profile (e.g. Facebook, Google, or Apple) to expedite the account creation or login process, AE partners will use the data from the associated profile to improve age verification, KYC/CDD efforts, location verification, build profiles, and customize marketing. If a customer chooses to participate in customer research efforts managed by third-party collection and analysis agencies, AE will gain access to the feedback and data customers voluntarily consent to provide.

6.0 AE PRIVACY AND SENSITIVE DATA PROCESSING SAFEGUARDS

In accordance with best practice and International Organization of Standards (ISO) 2700-based IT and security processes and procedures outlined in AE’s Information Security Policy (ISP), AE proactively enables and continuously monitors a robust system of layered security controls specifically designed to limit and protect the collection, processing, storage and use of personal data. The following safeguards are designed to educate AE staff and users about our personal data collection, use, sharing, and protection.

• Prior to our first collection and at any point when data use changes, AE informs users what data types are being collected, for what purpose(s), how long it will be stored, and where applicable, requests the data subject’s consent.
• Through direct and indirect collection, AE will verify data accuracy and encrypt stored data to promote the integrity of the data.
• AE’s Data Protection Officer (DPO) oversees staff training on data protection standards.
• AE’s DPO oversees data protection efforts and can be reached via email: DPO@bet5games.com.

7.0 COMPLAINTS

You may raise your concerns with your local data protection authority directly, without going through our Customer Complaint Policy and Procedures. However, we encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to our processing of your personal data.

8.0 DATA COLLECTION AND SHARING

It is our policy to only share personal data when informed consent has been given by the data subject, sharing has been requested by the data subject, or it is permitted/required by law. Personal data will be protected from access by persons within the company unless expressly required for job-related functions as outlined in the user consent.

We may share your personal data with the parties set out below for the purposes set out in Section 4.0 (PERSONAL AND SENSITIVE DATA WE COLLECT AND PROCESSING PURPOSES) with the following parties:

• External Third Parties: means service providers acting as processors who provide hosting and email management services in respect of our services, professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and regulators and others who require reporting of processing activities in certain circumstances.
• Internal Third Parties: means other companies in our group of companies who may provide support in respect of the operation of our services.

8.1 INTERNATIONAL TRANSFERS

AE is a global company and therefore uses global vendors and subcontractors as well as global IT systems and applications. As a result, the Personal Data we collect about you may be transferred to, and stored at, a destination outside of your country which may have less strict, or no data protection laws, when compared to those in your country. We will comply with the requirements for data transfers as required by your country.

When we share your personal data within the AE group of companies, this involves transferring your personal data outside of the jurisdiction you are located in. The personal data is shared in accordance with your country’s international transfer requirements with regard to personal data, which require all AE entities to follow the same rules when processing your personal data. You can request a copy of our international transfer agreements at any time by contacting us at DPO@bet5games.com.

In some cases, the parties we use to process personal data on our behalf are based outside your jurisdiction, therefore their processing of your personal data will involve a transfer of such data outside of your jurisdiction. Similarly, we may be requested by a government regulator or authority based outside of your jurisdiction for your personal data. Where this is the case, we will only share the minimal amount of personal data necessary for the purpose of processing and, where possible, we will inform you of the transfer and share the personal data in an anonymized form.

Whenever we transfer your personal data out of your jurisdiction, 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 by your government; and/or
• where we use certain service providers, we may use specific contracts approved by your data protection regulator, which gives personal data the same protection it has within your jurisdiction

Please contact us at DPO@bet5games.com if you would like further information about the specific mechanism used by us when transferring your personal data out of your jurisdiction.

9.0 USE OF COOKIES

AE uses cookies to enable website features and customer experience (CX) by customizing each user’s interaction with site services and capabilities. Cookies are small files stored on the user’s computer designed to hold a modest amount of data specific to a client and website, which can be accessed either by the web server or the client computer. Tables on each website outline the names and types of cookies used (including those used by third parties) and how each is used.

In general, AE websites use the following types of cookies, the scope and function of which are explained below:

• Session cookies
• Persistent cookies.

Session cookies are automatically deleted when you close the browser. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This enables your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

Persistent cookies are automatically deleted after a specified period of time which may vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. Please note that you may not be able to use all the features of this website.

The cookies we use are categorized into the following functions:

• Necessary: These cookies are required to ensure the website functions as designed and meets your device parameters.
• Preferences: These cookies enable the website to remember your preferences and optimize your personal CX by enabling the site to remember data that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Statistics: These cookies enable AE to understand how visitors interact with websites by collecting and reporting information anonymously.
• Marketing: These cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. These cookies will only ever be enabled with your consent.

10.0 CONSENT FOR MARKETING PURPOSES

Prior to receiving direct marketing material from AE, users shall provide active consent. Consent will be requested during account registration, and users may update their marketing preferences at any time through their profile settings.

12.0 DATA RETENTION

AE will only retain personal data for as long as necessary to fulfill the purposes it was collected for, including compliance with any applicable legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, AE will take into account its legal and regulatory obligations, the amount, nature and sensitivity of the data and potential risk from unauthorized use or disclosure of personal data.

User data will be retained for as long as the player’s account is active and for at least five years afterward for RMG accounts. Electronically stored data will be backed up and protected in accordance with processes and procedures outlined in AE’s ISP.

AE will continually assess the purposes for which the data is collected and processed to determine whether those aims might be achieved through other means. Customer data may be anonymized, such that it can no longer be associated with a specific user, for research or statistical purposes. In these cases, we may use this information indefinitely without further notice to customers or data subjects.

In response to a data subject request to “be forgotten” or have data deleted, where applicable, AE will delete and/or obfuscate the data such that it cannot be associated with the individual. We will maintain a record of the date of your request, how it was made, and when it was completed.

13.0 CUSTOMER RIGHTS AND RESPONSIBILITIES

AE has a legal obligation to protect customer data as a controller of personal data. For the customers’ part, data should be kept up-to-date, accurate, and secure from public disclosure or easy unauthorized access. Customers will have access to and the ability to update their personal data via the website and/or platform. Customers should never share accounts, user IDs, or passwords, and passwords should be complex.

You have the right to:

• Know and have access to what personal data AE collects and uses,
• Request correction of any incomplete or inaccurate data,
• Request erasure of personal data (subject to legal obligations that AE has in relation to data retention, of which the customer will be notified, if applicable, at the time of the request), this includes closing your account,
• Object to processing of personal data (e.g. marketing; automated decision making or profiling),
• Request to suspend the processing of personal data,
• Request to transfer (data portability) personal data to a third party,
• Withdraw consent to the processing of your personal data (where a customer withdraws consent, AE may not be able to provide products or services to that customer), and
• Right not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect – you have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.

Data subject access requests should be sent to DPO@bet5games.com. We try to respond to a request within one calendar month, unless a request is particularly complex, or a significant number of requests have been made. AE may refuse to comply with a customer request in certain circumstances such as clearly unfounded, repetitive or excessive requests. As part of its handling of the requests, AE may need to contact you to confirm your identity to process the request.