Scope

This Privacy Policy outlines the manner in which the Company handles the information and personal data which you have provided to us and which enables us to be able to effectively manage the relationship which you have with us.

This policy applies to the collection and other processing of your personal data in connection with your use of the Betinia (the “Website). If you do not agree with the terms of this policy please do not use the Website or otherwise provide us with your personal data.

All processing of personal data performed by the Company as envisaged in this Privacy Policy shall be carried out in line with the following legal provisions (these shall hereafter be collectively referred to as the “Data Protection Laws”):

• Regulation (EU) 2016/679 of The European Parliament And of The Council of 27 April 2016 On The Protection of Natural Persons With Regard to The Processing of Personal Data And On The Free Movement of Such Data, And Repealing Directive 95/46/EC (General Data Protection Regulation)” (hereinafter referred to as “the Regulation” or “GDPR”);
• The Danish Act No. 502 of 23 May 2018 on supplementary provisions to the regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Data Protection Act) as well as any other subsidiary legislation issued under that DPA as may be amended from time to time; and
• The Maltese Data Protection Act (hereafter referred to as the “DPA” - Chapter 586 of the Laws of Malta) as well as any other subsidiary legislation issued under that DPA as may be amended from time to time.

Definitions

Any references in this policy to the “Company”, “us”, “we” or “our” relate to the company operating this Website, namely, Denix Limited (C95188) having its registered office at Level 2, Suite 2, The Phoenix Business Centre, Triq il-Ferrovija, c/w Triq Regjonali, c/w Triq Il-Blata L-Kahla, Santa Venera, SVR9022, Malta. The Company determines the means and purposes of the processing of personal data and therefore acts as the “data controller” in terms of the applicable Data Protection Laws. Any references to “you”, “your” and similar refer to you, the individual using the Website.

“data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

“data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“personal data” means any and all data that relates to you as an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us, via the Website or otherwise, or that we collect about you. This definition shall, where applicable, incorporate the definitions provided in the GDPR.

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

Security

The Company has adopted a secure communication protocol via the Internet TLS 1.2, used to implement the protected remittances. This protocol involves the encryption of your personal data during transmission over the Internet. Moreover, the Company stores your personal data digitally on encrypted hard drives which is an additional guarantee of security of personal data.

Our services are registered with site identification authorities so that your browser can confirm our identity before any personally identifiable information is sent. In addition, our secure servers protect this information using advanced firewall technology.

Personal Data Protection

Personal data held by us is protected using the highest industry standard security processes and systems. Our commitment to protect personal data is not merely through quality and high standards but also through the best and most efficient application of the law. We are bound to only process personal data if such processing is based of one of the appropriate legal grounds established by the GDPR.

Processing on the Basis of our Legitimate Interests

A legitimate interest exists when we have a business or commercial reason upon which personal data will be processed. In such a case we undertake to protect any and all of your personal data and the manner in which such data is processed and to ensure that such processing would not be unfair to you or to your interest.

If and when we decide to process your personal data on the basis of legitimate interest, we will inform you of such, what said legitimate interest are and provide a process whereby you will be able to raise any questions and/or objections which you may have in relation to such processing. It is important to note that the Company is not obliged to stop processing if the grounds for processing over-ride your right to object. An example of this can be in the case where we need to process your data to abide with the anti money laundering purposes.

Processing on the Basis of Your Consent

Consent is not the only ground we may be permitted or obliged to rely on to process your personal data. We will only process personal data on the basis of your consent where we cannot or otherwise choose not to rely on any ulterior legal ground (such as compliance with a legal obligation or legitimate interest). Where we process your personal data on the basis of your consent, you shall have the right to withdraw your consent at any time and in the same manner as it had been previously provided by yourself. In the case that you exercise your right to withdraw consent, we would then determine whether we are able (or obliged) to process your personal data on the basis of any other legal ground other than consent. If this is the case we will notify you accordingly. Any such withdrawal of your consent will not invalidate any processing operations carried out prior to you having withdrawn your consent.

Data Retention Policy

Any and all personal data the Company will keep will be protected in the best way possible and will only be used for purposes which are compatible with the applicable Data Protection Laws as well as any other applicable laws. The Company will retain your personal data only for as long as is necessary (taking into consideration the purpose for which it was originally obtained). The criteria we use to determine what is ‘necessary’ depends on the particular personal data in question and the specific relationship we have with you (including its duration).

Generally, our normal practice is to determine whether there is/are any specific EU and/or Maltese law(s) (for example tax or corporate laws) permitting or even obligating us to keep certain personal data for a certain period of time (in which case we will keep the personal data for the maximum period indicated by any such law). For example, any data that can be deemed to be ‘accounting records’ must be kept for ten (10) years.

We would also have to determine whether there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are (this is usually five (5) years). In the latter case, we will keep any relevant personal data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as is necessary.

Where your personal data is no longer required by you, we will either securely delete or anonymise the personal data in question.

Failure to provide your personal data may prevent the Company from meeting its legal and regulatory obligations, fulfilling its contractual obligations and rendering and/or performing the necessary services needed to satisfactorily manage and maintain your account. Therefore, failure to provide the necessary personal data may lead to the Company being unable to provide you with certain products and/or services.

Personal Data Which We Collect, Purpose of the Processing & Legal Basis of the Processing

The following table outlines the categories of personal data which we process, the purpose for which we process such data as well as the corresponding legal basis used for such processing. It is pertinent to know that the same categories of personal data may be processed for different purposes and therefore on the basis of a various legal grounds simultaneously depending on the purpose of processing.

The Company may also collect personal data from publicly available sources such as web searches, company registers and broadcast media provided it is reasonable to do so and such conduct is not detrimental to your rights and freedoms.

Some of your data will also be used to carry out checks which will help complete the Profiling of your account. Profiling is a procedure that includes any form of automated processing of personal data required to abide with AML directives and prevent any other Fraudulent activity from happening using your personal details. These could be Tax Evasion or Suspicious betting patterns to name a few.

No automated decision will be made for Marketing purposes. Example of details which are verified automatically by the system are IP address or PEP checks required. Email address is also verified however you will receive an email to confirm your own email address.

Processing on the Basis of Consent

For the avoidance of all doubt, we would like to point out that in those limited cases where we cannot or choose not to rely on another legal ground (for example, our legitimate interests), we will process your personal data on the basis of your consent.

In those cases where we process on the basis of your consent (which we will never presume but which we shall have obtained in a clear and manifest manner from you), YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME and this, in the same manner as you shall have provided it to us.

Should you exercise your right to withdraw your consent at any time (by writing to us at the physical or email address below), we will determine whether at that stage an alternative legal basis exists for processing your personal data (for example, on the basis of a legal obligation to which we are subject) where we would be legally authorised (or even obliged) to process your personal data without needing your consent and if so, notify you accordingly.

When we ask for such personal data, you may always decline, however should you decline to provide us with necessary data that we require to provide requested services, we may not necessarily be able to provide you with such services (especially if consent is the only legal ground that is available to us).

Just to clarify, consent is not the only ground that permits us to process your personal data. In the last preceding section above we pointed out the various grounds that we rely on when processing your personal data for specific purposes.

Other Purposes

We may be required to use and retain personal information for; loss prevention; and to protect Our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.

Disclosure to Authorities

Personal data relating to you may be shared with authorised third parties or any of the relevant competent authorities located in or outside of the EU/EEA where such disclosures are required pursuant to Data Protection Laws and/or any other applicable legislation.

These authorised may include, but are not limited to law enforcement agencies, gambling regulators, criminal investigation agencies, courts, and anti-money laundering agencies. We may also share your personal data with third parties when you have asked us to do so. The personal data shared will depend on the product/s and or service/s you choose to use.

When any such personal data has to be transferred outside of the EEA – European Economic Area, we ensure that all the necessary and appropriate safeguards are in place.

Marketing

We will use your Personal Information, such as your name, home address, email address, telephone number etc., collected by ourselves and/or through our third party subcontractors for the purpose of providing you with promotional materials via different marketing techniques such as direct email, telephone marketing, SMS and post concerning the Service as well as products, services, websites and applications which relate to: (i) other companies within the Company's group; or (ii) the Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.

We may 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 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 business partners and marketing affiliates by either: following the links inserted in the promotional emails (e.g., selecting the opt-out link), by contacting our customer support at support@betinia.dk. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

Sharing Your Personal Data

We may share your personal data with select third parties, who act as our personal data (sub)processors. This is done to enable us to provide our services to you, to improve our services, to provide information to you, and/or to meet our legal obligations.

The categories of our (sub)processors include: game and content providers - to provide you with games, odds and other content; banks and payment service providers – to enable financial transactions with you; verification, KYC, anti-money laundering, security and anti-fraud agencies and consultants – to verify, compile, obtain and combine personal data about you in order for us to meet our legal obligations and protect us against fraud; hosting providers and IT service providers – to provide our services to you and to meet our legal obligations; data analytics providers – to analyze and improve our services; our legal and professional advisors (lawyers, auditors, insurance firms) – to enable us to meet our legal obligations and protect us against legal claims; our affiliates and other members of the Soft2Bet Group – to provide our services to you, to improve our services and for those parties to perform other activities on our behalf; marketing agencies, marketing affiliates and marketing consultants – to inform you about our services and for other marketing purposes.

Any such sharing and processing will be done in accordance with the Data Protection laws (for example, all our processors are contractually bound by the requirements in the said Data Protection Laws, including a strict obligation to keep any information they receive confidential and to ensure that their employees/personnel are also bound by similar obligations).

Your personal data will never be shared with third parties for their marketing purposes (unless you give your consent thereto).

Internet Communications

You will be aware that data sent via the Internet may be transmitted across international borders even where sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done by you or any third party in connection with any personal data prior to our receiving it including but not limited to any transfers of personal data from you to us via a country having a lower level of data protection than that in place in the European Union, and this, by any technological means whatsoever (for example, WhatsApp, Skype, Dropbox etc.).

Moreover, we shall accept no responsibility or liability whatsoever for the security of your data while in transit through the internet unless our responsibility results explicitly from a law having effect in Malta.

Accuracy of Personal Data

All reasonable efforts are made to keep any personal data we may hold about you up-to-date and as accurate as possible. You can check the information that we hold about you at any time by contacting us in the manner explained below. If you find any inaccuracies, we will correct them and where required, delete them as necessary. Please see below for a detailed list of your legal rights in terms of any applicable data protection law.

Links to Third Party Sites

Links that we provide to third-party websites are clearly marked and we are not in any way whatsoever responsible for (nor can we be deemed to endorse in any way) the content of such websites (including any applicable privacy policies or data processing operations of any kind). We suggest that you should read the privacy policies of any such third-party websites.

Transfer of Data Outside of the Eea

Your personal data will only be transferred outside of the EEA or any other non-EEA country which has been deemed by the European Commission to offer an adequate level of protection (also referred to as “white-listed countries” – listed here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en) in the following circumstances: When you have expressly consented to us doing so; when it is necessary to constitute or execute a contract entered between you and the Company; or to be compliant and in line with any and all legal obligations or duties.

In the event that personal data is transferred outside of the EEA, within the Company or to any of the Company’s business partners, we ensure to implement all appropriate safeguards to ensure that the same protection is afforded and the same standards are applied as would be within the EEA. You are entitled to receive a copy of such safeguards by contacting us.

Contracts containing the EU Standard Contractual clauses (EU Model Clauses) will be used which require the entity receiving the personal data to use the same standards as they would be subject to within the EEA. Should any data be transferred to the USA and the entity receiving the data is registered with Privacy Shield (a framework that ensures personal data protection) it will be taken that the same level of protection as approved by the European Commission.

Data Subject Rights

The Company undertakes to assist you in the best way possible should you choose to exercise any of your rights with respect to your personal data. In certain cases we might need to verify your identity prior to acceding to your request to exercise any relevant right.

Right of Access

You have a right to ask us whether we are processing any personal data which concerns you and if this is the case, you shall have the right to access that personal data as well as the following information:

• What personal data we have,
• Why we process them,
• Who we disclose them to,
• How long we intend on keeping them for (where possible),
• Whether we transfer them abroad and the safeguards we take to protect them,
• What your rights are,
• How you can make a complaint,
• Where we got your personal data from and - Whether we have carried out any automated decision-making (including profiling) as well as related information.

Right to Rectification

You have a right to ask us to have any inaccurate or incomplete personal data relating to you rectified and/or completed.

Right of Erasure (the “right to be forgotten”)

You have the right to ask us to delete your personal data and we shall comply without undue delay where:

• The personal data are no longer necessary for the purposes for which they were collected; or
• You have withdrawn your consent (in those instances where we process on the basis of your consent) and we have no other legal ground to process your personal data; or
• You shall have successfully exercised your right to object (as explained below); or
• Your personal data shall have been processed unlawfully; or
• There exists a legal obligation to which we are subject; or
• Special circumstances exist in connection with certain children’s rights.

In any case, we shall not be legally bound to comply with your erasure request if the processing of your personal data is necessary to comply with a legal obligation imposed on you.

Right to Restriction of Processing

You have the right to ask us to restrict the processing of your personal data. However, you are only able to exercise this right where:

• The accuracy of your personal data is contested (see the right to data rectification above), for a period enabling you to verify the accuracy of the personal data; or
• The processing is unlawful and you oppose the erasure of your personal data; or
• We no longer need the personal data for the purposes for which they were collected but you need the personal data for the establishment, exercise or defence of legal claims; or
• You exercised your right to object and verification of our legitimate grounds to override your objection is pending.
• Should you successfully exercise this right, we would only be in a position to process your personal data:
• Where we have your consent; or
• For the establishment, exercise or defence of legal claims; or
• For the protection of the rights of another natural or legal person; or
• For reasons of important public interest.

Right to Data Portability

You have the right to ask us to provide you with your personal data which we process. We will provide you such data in a structured, commonly used, machine readable format, or (where technically feasible) we may have the data sent directly to another Data Controller, provided this does not adversely affect the rights and freedoms of others.

Right to Withdraw Consent

You have the right to withdraw your consent at any time. For detailed information on this right, please refer to “PROCESSING ON THE BASIS OF CONSENT” section 9 which can be found above.

Right to Object to Processing

You have the right to object to the processing of your personal data. Where we are only processing your personal data on the basis of one of the following purposes:

• The processing is necessary for the performance of a task carried out in the public interest; or
• When processing is necessary for the purposes of the legitimate interests pursued by us or by a third party,

the processing shall only cease where the Data Controller has not provided compelling and legitimate grounds which outweigh the objections raised by you in such a request and which require the processing to continue.

Where your data is being processed for direct marketing purposes, you have the right to object to the processing of your personal data at any time.

In all other instances apart from those listed above, this general right to object shall not subsist.

Right to Lodge a Complaint

As a Data subject you may at any time lodge a complaint with any relevant Data Protection Supervisory Authority should you feel that any of your rights have been impinged by the Company. The Competent Supervisory Authority in Malta is the Office of the Information and Data Protection Commissioner (IDPC) and the Competent Supervisory Authority in Denmark is the Danish Data Protection Agency (Datatilsynet).

Notwithstanding this right, we kindly ask you to please attempt to resolve any issues you may have with us prior lodging a complaint with a data protection authority.

It is important to note that notwithstanding such rights, the Company may still refuse such request if it can reasonably justify such decision. Such refusal does not prohibit you from lodging a complaint with the relevant data protection authority.

Company Contact Information

If you have any questions or comments about privacy or should you wish to exercise any of your individual rights, please contact us directly at support@betinia.dk or by calling us at our contact number (+356) 27369050 (during office hours 09.00 to 18.00) or by contacting our Data Protection Officer.

The Company’s Data Protection Officer is Oksana Tsyhankova who can be contacted directly at dpo@soft2bet.com.

Cookie Policy

When you visit or access our websites or applications operated by us, or when you interact or engage with our content ("Services"), we use (and authorize third parties to use) cookies, pixel tags, beacons, local storage and similar technologies ("Tracking Technologies").

These allow us to automatically collect information about you, your device, and your online behavior (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services' performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.

We also allow third parties to collect information about you though Tracking Technologies.

What are cookies?

Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.

Storing Tracking Technologies

We store Tracking Technologies when you visit or access our Services (for example when you are visiting our Website or using our mobile applications) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies".

Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

What types of Tracking Technologies do we use?

When you use or access our Services, we use the following categories of Tracking Technologies:

• Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed on your computer or device when you access our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
• Functionality Tracking Technologies – these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
• Performance Tracking Technologies – these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
• Marketing or Advertising Tracking Technologies – these Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.
• Social media Tracking Technologies – Our website includes social media features, such as the Facebook "Like" or "Share" buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.

The following Tracking Technologies are used in connection with our Services. For additional information about any of the Third Party Tracking Technologies, please visit the links of those companies provided.

Cookies allow us to:

• Improve the use of the Service and to make the content more interesting and relevant to the wishes of users, like offering you more relevant promotional offers.
• Distinguish you from other users of our sites to grant a good user experience.
• Identify your settings and preferences regarding customized content or functionality.
• Your log-in details for the confirmation as a registered user for our Service.
• Collect statistical analysis on the use of our Service.

Managing Your Cookies

Most browsers accept cookies automatically. However, one can configure the browser in a way that no cookies are stored on its computer or a hint appears before a new cookie is created. Please see the particular operator’s advice for the deactivation of cookies. Other methods of managing your Tracking Technology preferences includes: changing your browser settings to send a "Do-Not-Track" signal. In such case, your browser will send us a special signal to stop tracking your activity

Disabling cookies completely may lead to decreased functionality regarding certain features of the Company’s website.

To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser

Turning off third party advertising cookies: you can turn off certain third party cookies for advertising purposes by visiting the Network Advertising Initiative, located here: Network Advertising Initiative or the DAA opt-out program, which are located here: https://www.aboutads.info/choices/,here (for EU/EEA citizens): https://www.youronlinechoices.eu/ and here (for mobile devices): https://www.aboutads.info/appchoices.