Scope

This Privacy Notice (hereafter referred to as the “notice”) explains how NaoBet and its direct and indirect subsidiaries (collectively, “NaoBet”, “us”, “we”, “our”) handles your personal data.

This Privacy Notice applies to the personal data collected from registered users (“Player(s)”) who have an account on our website and visitors to our website.

Who We Are

The operator of this website is the Data Controller of your personal data. We are the data controller of your personal data because in the context of our business relationship with you, we decide how and why it is processed in the ways explained in this notice. Together with our joint controller, we maintain the ownership and security of the personal data you provide to us.

If you have any questions about this notice including any requests about exercising your privacy and data protection rights, you can contact our Data Protection Officer by sending an email to [email protected].

What Personal Data Do We Collect?

Data you provide to us directly

We may collect the following personal data from you depending on how you interact with our services:

Registration Data:
To create an account on our website, you need to provide us with your personal data, including your email address, date of birth, country, phone number, gender, full name, social security number, zip code, username. Upon registering, we will automatically receive your IP address and location data.

Due Diligence Data:
We collect your identity card number/driving license/passport number, proof of address, social security number, source of wealth/funds, bank ID, and financial statement/details to comply with our due diligence and Know Your Customer (KYC) obligations, for age and identity verification purposes for Anti-Money Laundering purposes and/or to comply with our license or other legal requirements.

Financial Information:
We may collect your financial information, including Bank ID, CPR number, CPF number, IBAN, and payment system details, to facilitate withdrawals and deposits to your account. Additionally, this information may be used for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance purposes.

Personal Data We Collect Automatically

Device Information:
We receive information about the device and software you use to access our services, including Internet protocol (IP) address, operating system version, and device identifiers.

Logs and Usage Information:
To help us understand how you use our services, and to help us improve them, we automatically receive information about your interactions with our services. Our servers automatically log usage data when you interact with our website. This information includes records of your activities like viewing content, clicking ads, performing searches, and sharing our services on social media on our website, date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. We gather some of the data through cookies and similar technologies.

Location Information:
We may collect or infer your general location information when you use our Services.

Personal Data That We Receive From Others

We may collect your personal data from other sources to provide and personalize our services to you and/or to comply with legal obligations. We may gather data from:

• Publicly available sources such as public and government databases, internet, social media platforms, online and printed media, and so on.
• Commercially available databases and third-party entities, including financial and credit institutions, fraud prevention agencies, and public authorities. These sources help us in verifying your information and investigating suspicious activities, especially for fraud prevention and anti-money laundering purposes.
• Inferences. We may infer additional personal data based on the personal data described above. For example, we may infer your interests and game preferences based on the web pages you view and the games you play.

Personal data you have made public, such as information available on social media platforms, linked accounts (e.g., Facebook or Google), and other publicly accessible digital platforms.

Why Do We Collect Your Data?

We use the personal data we collect to:

• Provide you with our services.
• Respond to your questions or requests.
• Test, research, troubleshoot and analyze data to develop and improve our products and services.
• Prevent, detect, and manage risk against harmful behavior, fraud and illegal activities.
• Send you marketing content, newsletters and personalize our marketing to you.
• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies.
• Fulfill regulatory and legal obligations.

Maintain the security and functionality of the service, including ensuring technical availability of the website, protecting our systems and intellectual property from security threats and unauthorized access.

What Are Our Lawful Basis for Processing Your Personal Data?

In compliance with the GDPR and other applicable data protection laws, we process your personal data when we have a legal basis to do so. For some processing, more than one lawful basis may be relevant. Here are some lawful bases that we rely on:

Conclusion and Performance of a Contract

We process personal data in order to fulfill or enter into a contract with you. For example, to create and support your account with us, to communicate with you to fulfill our obligations under the Terms and Conditions, and so on.

Legal Obligation

Processing your personal data may be necessary to comply with legal obligations. This may include:

• Verifying your age and identity as part of our KYC and AML obligations.
• Determining your location and applicable legal requirements using your IP data.
• Managing risks, including preventing problem gambling and promoting responsible gambling.
• Ensuring network and information security.
• Complying with legal processes like search warrants, subpoenas, or court orders.
• Preventing crimes related to money laundering, terrorist financing, fraud, or computer crimes.
• Regular reporting activities to meet economic, financial, technical, and legal requirements.
• Dealing with requests from you to exercise your rights under data protection laws.

Legitimate Interest

When necessary, we may process your personal data to safeguard our legitimate interest, a third party, or a commercial reason provided your rights, freedoms, or interests do not outweigh those interests. Examples include:

• Initiating legal claims and preparing our defense in litigation/administrative procedures.
• Undertaking IT and system security procedures.
• Managing our business relationship and enhancing our products and services.
• Engaging in analytics, data aggregation, and research for development or marketing.
• Customer segmentation to manage risks and ensure responsible gaming.
• Analyzing your gaming behavior using ML to recommend games and features.
• Detecting and preventing activities that compromise service integrity, such as fraud or cheating.

Consent

With your consent, we may:

• Send direct marketing messages via email, SMS, phone calls, website or app notifications.
• Customize offers and promotions based on your gaming history and preferences.
• Use data about your online behavior to display targeted advertisements.
• Personalize and assess the effectiveness of our marketing.
• Administer your participation in competitions, tournaments, rewards, loyalty schemes, and promotions.

How We Share Your Personal Data

We may share your personal data with the following categories of recipients:

• Internally with authorized employees, brands, contractors, agents, joint controllers, affiliates, and subsidiaries within our group or parent company.
• Payment providers and financial institutions. Shared data may include personal and KYC information to comply with legal and AML obligations.
• Third-party service providers (e.g., customer support, email/SMS/voice call, hosting).
• Marketing partners.
• Fraud prevention agencies.
• Third parties in corporate transactions (merger, acquisition, bankruptcy, etc.).
• Game providers.
• Data aggregators or analytics providers for market research and service improvement.
• Law enforcement agencies, regulatory and licensing authorities.

If you submit a complaint or query to a third-party platform (casino review, gambling forum, etc.), we may need to respond and share strictly limited data to identify your account and respond appropriately. We do not initiate such disclosures unless your submission or a public allegation requires a response, and any shared data is proportionate and necessary for factual clarity.

How Long We Keep Your Data

We will retain your personal data only for the duration that you maintain an account with us and to fulfill the purposes outlined in this privacy notice.

Additionally, we may keep your data for a longer period as required by applicable legal obligations, such as anti-money laundering (AML) regulations or other regulatory requirements.

Once your account is closed and there is no longer a legal or business need to retain your data, your personal data will be either deleted or anonymized so that it can no longer be associated with you.

Your Rights

You have certain rights regarding the personal data we hold about you. They include:

• Right to request access to the personal data we hold about you and obtain information about how we process it.
• Right to rectify or correct any inaccurate or incomplete personal data about you.
• Right to erase, delete, or remove your personal data when there is no compelling legal or business reason for its continued processing.
• Right to restrict the processing of your personal data in certain circumstances.
• Right to request the transfer of your personal data to another party in a structured, commonly-used, and machine-readable format.
• Right to object to the processing of your personal data, particularly if we are processing it on grounds of legitimate interests or for direct marketing purposes.
• Right to withdraw your consent at any time, without affecting the lawfulness of previous processing based on your consent.
• Right to lodge a complaint with a supervisory authority.

To exercise your rights, contact:
Customer Support: [email protected]
Data Protection Officer: [email protected]

Cookies and other Tracking Technologies

We use cookies, tags, pixels, web beacons and other similar technologies to enhance your experience on our website and applications.

Upon your first visit, we will ask for your consent to use non-essential cookies. Strictly necessary cookies do not require consent.

More information: Cookie Notice

Data Security

We prioritize the security of your personal data and implement robust measures to protect it from unauthorized access, loss, theft, and misuse. This includes:

• Administrative, technical, and physical safeguards.
• Defense against unauthorized disclosure, alteration, and destruction.
• Continuous assessment and improvement of security practices.

However, no system is completely safe, and we cannot guarantee absolute security.

Transfer of Data Outside EU/EEA

We may process your personal data in countries outside of the EU/EEA. In such cases, we ensure:

• Appropriate safeguards are in place.
• Transfer only to countries approved by the European Commission or protected under Standard Contractual Clauses or equivalent safeguards.

Change in Ownership or Control

In the event of a sale, merger, or change in ownership/control of our company, your personal data may be disclosed. The new entity may use your data only in accordance with this Privacy Notice, unless you provide explicit consent otherwise.

How To Contact Us

If you have questions about this privacy notice or our data collection practices:

• Email: [email protected]
• Data Protection Officer: [email protected]

Updates To This Notice

We may update, modify, or amend this Privacy Notice as our technology or the law evolves.
It is your responsibility to review the Privacy Notice periodically. The effective date will be posted on our website.