BETBULL PRIVACY POLICY
At Betbull, we understand and respect our customers, guests, and users’ privacy. This Privacy Policy describes how we collect, use, store, share and protect personal data collected from or about you in connection with your use of the Betbull Application and websites, and when you contact us (collectively the “Services”). This Privacy Policy does not cover information about Betbull’s practices relating to information pertaining to employees, applicants, and candidates for employment.
We strive to be clear and open about what personal data we collect, why we collect it and how we use your personal data. Wherever you have choices or rights as to the use of your personal data, we will explain these to you in terms that are as clear as possible.
Please read this Privacy Policy carefully to understand how we collect, use and process personal data in connection with our Services. By visiting, accessing, or using, or providing information to us in connection with the Services, you understand and acknowledge our collection, storage, use and sharing of your personal data as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with the Services. You can contact us with questions about our information practices or policies at privacy@betbull.com.
Unless the context otherwise requires, capitalised terms not defined in this Privacy Policy shall be as defined in the Betbull Games Limited General Terms & Conditions, which for the avoidance of any doubt, also apply to you if you are making use of our Services.
We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on our Application and revising the “last updated” date at the end of the Privacy Policy. In order to remain informed about the most up-to-date terms, we recommend that you revisit this Privacy Policy regularly.
Who is in control of your personal data?
Throughout this Privacy Policy, references to “Betbull”, “we”, “our” and “us” relates to Betbull Games Limited, a limited liability company, registered in Malta with company number C87520, having its registered address at Elite Business Centre, Trejqa ta’ Box Box, Msida MSD 1840, Malta, its subsidiaries and holding companies.
For the processing activities and processes listed under this Privacy Policy, we act as the “data controller” for the purposes of the applicable data protection legislation, control the ways in which your personal data is collected and the purposes for which your personal data is used by us.
What personal data do we collect and how do we collect it?
You provide us with your personal data when you use our Services, including without limitation, when you visit our mobile application and/or website to register for an account or contact our customer support team. We may collect your personal data in a number of different circumstances during our interaction with you. These circumstances may include:
Online Enrolment Process – We offer the option to register for a Betbull account (“Account”), by submitting a request through the Betbull Application or website, collecting certain information necessary to establish the Account. We will ask you to create a password to manage your account.
Voluntary Information – We collect information which you provide to us voluntarily when you communicate with us directly, including through our account representatives, customer service team members and through use of the social features available on the Application. This includes information you share with us through your use of the Services, such as your preference of casino games or other services and amenities offered on the Application and website. Where you choose to self-exclude or self-limit, we will collect your personal information in relation to this request.
Casino Gaming Activity – We collect information about your gaming activity (such as your wagers, payouts, winnings, and game session duration) when you use the Services.
Financial Transactions and Privileges – We collect or use your name, email address, phone number, username and related information in connection with financial dealings with us or to administer and service your Account. We also collect, where applicable, banking information that is necessary to process payments or other transactions, such as withdrawals and deposits or personal check cashing.
The personal data we collect from you may include the following categories of data:
Identification and personal information you provide when registering for an Account with Betbull; such as your first name and last name, and date of birth.
Contact and correspondence information you provide when registering for an Account with Betbull; such as your email address, telephone number and residential address.
Information and documents we request from you to verify your identity and/or comply with legislation and regulations that Betbull must adhere to; such as identification documents, proof of address documents and billing information.
Information that you provide and generate through use of our Services; such as transaction information and payment solution provider information.
Technical and network information that you provide and generate through use of our Services; including technical information about your login information, domain server, type of Web browser as well as the pages you visit on our websites, browser type and version, time zone setting, browser plug-in types and versions, mobile device identification, operating system and platform, IP address, and time and date of access , when such information is kept in a format that can be associated with you.
Information and preferences that you provide to make use of our Services and personalise your experience; such as username, mobile application and/or website usage preferences.
Information that is generated through the use of our Services that will help us detect possible fraudulent or criminal activity and that may also be used by us enhance your personal experience; such as betting history and patterns.
Geo-location information when you access the Application.
Information that you voluntarily provide through surveys you complete or competitions you enter.
Any other categories of information that you may provide when you are using our mobile application and/or website; particularly if you choose to use any of the social features and options that are provided by Betbull.
We strive to make our mobile application as user friendly as possible. In order to achieve this, Betbull may occasionally collect information on how players use the mobile application and/or website. Generally, such information will not identify you personally and will be in the form of an activity log that collects certain administrative and traffic information. This information is essential for the provision and quality of our Services. However, if at any time, such information is of a nature that will render you identifiable, it will be treated accordingly as your personal data and will fall under the scope of this Privacy Policy.
We would like to remind you that you are not required to provide us with any such personal data as listed above and do so on a voluntary basis. However, if you choose not to provide such data, we may not be able to provide you with our Services.
It is important for us that you keep your personal data that we store about you as accurate and up to date as possible. You can amend and update your personal data through the relevant sections of the Application or by contacting our Customer Support at support@betbull.com.
What purposes do we use your personal data for?
Under the applicable UK data protection legislation and any applicable European Union legislation relating to personal data, primarily the General Data Protection Regulation, Betbull, as the data controller, may process your personal data in the situations that one or more of the legal grounds of processing listed below exist:
To fulfil any contractual obligation that Betbull has with you.
Where Betbull has a legal and regulatory obligation to process the personal data.
Where you have consented to Betbull’s processing of your personal data.
When such processing can be considered to fall under Betbull’s legitimate interest.
When such processing is in the public interest.
When such processing is in your vital interest.
We process your personal data for the following purposes:
To provide you with our Services
Starting from when you register for an account, we process your personal data to be able to verify your identity, approve and register your account, provide you all of the features of our Services and provide you with customer service assistance.
We process your personal data for this purpose on the grounds of necessity for the performance of our contract with you. However, we may also retain and process certain personal data, such as your communication with our customer support services, on the grounds of legitimate interest to help improve our customer support services and provide you with better assistance.
To provide you with our Services, we may also share your personal data with third parties working on our behalf. Further information can be found below in the section that details who we share your personal data with.
To comply with our legal and regulatory obligations
The Services we provide are regulated by a number of different regulatory authorities. For example, in the United Kingdom, we are regulated by the Gambling Commission of Great Britain and are subject to legislation including the UK Gambling Act 2005 and the UK Gambling (Licensing and Advertising) Act 2014.
In order to comply with these legal and regulatory requirements, we carry out identity verification, fraud prevention and anti-money laundering checks when you create an account with us and throughout the time that you hold an account with Betbull to protect our users from fraudulent behaviour and to promote responsible gambling. This will include disclosing necessary information to third parties such as identity verification institutions, credit reference and verification agencies and fraud prevention and detection agencies. When permitted by the applicable data protection legislation, such third-party agencies may retain a record of the search and utilize this record for further verification purposes.
From time-to-time we may also receive legitimate requests from regulatory authorities to provide information within the scope of an investigation. In such situations, we will be under the obligation to comply with any such legitimate requests and share the requested information, which may include your personal data.
We may conduct a security review at any time to validate personal data provided by you and to verify your use of our Services and your financial transactions for potential breach of the Betbull Games Limited Terms and Conditions and applicable legislation. Such security reviews may include, but are not limited to, ordering a credit report and/or otherwise verifying the personal data you provide against third-party databases.
We are also under the obligation to adhere to responsible gambling and social responsibility obligations. To achieve this, we will monitor your patterns of use of our Services to identify any concern in terms of responsible gambling. Furthermore, as a user you may make use of self-exclusion schemes such as “Gamstop” that operates within the United Kingdom. Should you utilize such services, we will also receive a notification and apply the chosen restrictions across our mobile application and/or website.
We process your personal data for this purpose on the grounds of necessity to comply with a legal obligation. We will be unable to provide you with our Services without carrying out such processing activities. Therefore, if you do not want your personal data to be processed for these purposes, please close your account and refrain from further use of our services.
To monitor the performance and functioning of our Application and/or website
We use such methods as cookies, traffic analysis and performance monitoring tools in order to analyse our players’ use of our Services and improve the performance and reliability of our mobile application, website and our Services. Please see our cookie information below or visit the cookie preference centre for more information.
We may use your personal data for such analysis to help us understand how our customers use our Services. This is to ensure that the Application and website functions correctly, that we are able to enhance user experience, minimise user inconvenience due to systems performance issues and so that we are able to provide you with a better and more personalised gaming experience.
We process your personal data for this purpose on the grounds of our legitimate interest. When carrying out processing for such purposes, we ensure that any impact on your privacy is minimized, and we take into account how long we retain such information, ensure that we only collect and process the minimum personal data that is necessary for this purpose and ensure that all appropriate security measures are implemented. We make sure that we consider and balance any potential impact such processing may have on you and your rights before processing your personal data for our legitimate interests. We do not engage in processing on grounds of legitimate interest for cases where our legitimate interests are overridden by any potential impact on you. You have the right to object to any processing that we carry out on the grounds of our legitimate interest if you believe that your right to privacy outweighs our legitimate interests.
To provide you with marketing and promotion information through marketing activities
When we have obtained your consent to do so, we will provide you with marketing information, notices of opportunities and promotions that we think may interest you. We make sure to ensure that any such communication is in line with the normal practice and service that you would expect from similar companies that operate online betting services. Such communication may be via Push Notifications, email, SMS or online marketing. We will ensure that such marketing communication is not sent to you if you have not provided consent or if you have subsequently opted out of receiving such information. The Preferences section in the Settings menu will allow you to choose how you wish to receive communication from us.
Your personal data may also be used to profile what preferences and offers are most suitable to your needs and interests, so as to prevent us from sending you marketing communication that would not be of interest to you.
From time-to-time, we may also request information from you via surveys or contests. Participation in these surveys or contests is on a completely voluntary basis and you will always have the choice of whether you disclose such information. The types of information that will be collected through such surveys or contents will be clearly specified for each case and may include information such as contact and demographic information.
When you engage with any of the social features of the mobile application, such as when you share your bets, we may, with your consent, use your avatar, username and accumulators to share inside the mobile application with other users and for use in digital marketing assets, affiliate material, social media content, offline marketing and any other related areas for marketing purposes. If you do not want this information used by us for such marketing purposes, you are not required to give consent. If you previously gave consent for such marketing purposes, you may withdraw that consent at any time by manually turning off Bet Sharing using the Bet Sharing toggle in the Setting menu. If you disable Bet Sharing in this way, we will remove your associated profile and information from marketing banners within 5 days. However, please note that it may take up to 4 weeks to remove such information from placements managed on our behalf by third parties.
You have the right to update your marketing preferences and withdraw your consent at any time. Should you opt-out, you will not be sent any further marketing communication.
How long do we retain your personal data?
We retain your personal data for as long as is reasonably required for legal and business purposes. In determining data retention period, Betbull takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When the purposes that require the processing and retention of your personal data no longer exist, we securely delete or destroy your personal data.
In practice, this will mean that we retain most of your personal data for the period that you are a registered customer of Betbull. However, there may be situations where we are legally required to retain some of your personal data for an additional period to satisfy our legal and regulatory obligations.
Who do we share your personal data with?
We may share your personal data with our subsidiaries and affiliates within our company group, including without limitation, Wynn Resorts, Limited and our U.S. affiliates such as WSI US, LLC, Wynn Las Vegas, LLC and Wynn MA, LLC (collectively the “Betbull Group”).
In addition to sharing your personal data within the Betbull Group, we may share your personal data with additional third parties. Such additional third parties may include the following:
Law enforcement agencies, regulators and other authorities.
Identity verification agencies.
Credit reference and verification agencies.
Fraud prevention and investigation agencies.
Commercial and business partners; such as our gaming platform and technical services provider, third-party software and game providers, developers, and other system partners.
Third parties that we work with to provide our Services, such as service providers, suppliers and customer support agencies.
Third parties that we work with for the purposes of marketing and advertising, such as digital advertising agencies and marketing agencies and consultants.
The third party that provides the social features within the mobile application, including without limitation, your personal data and the contents of your communications.
Any personal data that is shared with third parties that we designate and transfer personal data to of our own accord will be carefully selected by Betbull and such third parties will only process data in accordance with our clear instructions and in a way that will remain compliant with this Privacy Policy.
We may share your personal data with such aforementioned third parties for the following reasons:
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation.
To enforce or apply the terms of the Betbull Games Limited Terms & Conditions, this Privacy Policy or any other agreement with you.
To assist us in providing you with the products and services you request, particularly games and services that we provide through third-party software providers.
To investigate or verify suspicions of cheating, fraud or other uses of our Services in any way that is contrary to the Betbull Games Limited Terms & Conditions.
To investigate and defend ourselves, the Betbull Group, our partners and our users against any third-party claims or allegations.
To protect the rights, property, security and wellbeing of Betbull, the Betbull Group, our partners or our users.
Situations where Betbull’s assets are being reviewed or used for the purposes of a business transaction, such as a merger, change of control, sale of assets or bankruptcy.
Situations where we have received your consent to do so.
From time-to-time, we may also share anonymous data regarding our users use of our Services with third parties. We may share such data for public interest purposes such as research on understanding and preventing addiction or for our own legitimate interest such as understanding general patterns and trends regarding the use of our Services. Any information shared in this way and for these purposes will be anonymous and will not contain any personal data.
Do we transfer your personal data outside of the EEA?
In the course of providing you with our Services, we may need to transfer personal data that we have collected from you our affiliates, subsidiaries, partners, service providers and subcontractors who may be based outside the United Kingdom and the European Economic Area (“EEA”). Such countries may include the United States of America, Turkey and Ukraine.
When we transfer any of your personal data outside of the United Kingdome and the EEA or any jurisdiction that is deemed as providing adequate safeguards at the level guaranteed under applicable data protection legislation, we will take all reasonable measures to ensure that your personal data remains as secure as it is within the United Kingdome and the EEA and is processed in accordance with the Privacy Policy. These measures include, but are not limited to, the following:
Binding corporate rules, and
Standard Contractual Clauses.
How do we keep your personal data secure?
We understand the importance of security and utilizing the correct techniques needed to secure your Personal Data. We store all Personal Data we receive for you in an encrypted and password protected database residing within our secure network behind active firewall software. Our Services support SSL Version 3 with 128-bit encryption and we are committed to reviewing and updating our security and systems to ensure we remain up to date.
We also take measures to ensure that our subsidiaries, affiliates, agents, service providers and suppliers also employ adequate security measures.
Due to the complex and ever-changing nature of technology and business, to the extent possible under the applicable data protection legislation, we cannot guarantee or claim an error-free performance regarding the privacy of your personal data. Thus, to the extent possible under the applicable data protection legislation, for events that our beyond our direct control we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or disclosure of such information.
What happens if you access third-party provided links?
Our Application and website may occasionally contain links to other websites that are outside our control and thus not covered by this Privacy Policy. If you access other websites using these provided links, the operators of these websites may collect information from you which will be used by them in accordance with their own privacy policies, which may differ from ours.
We cannot ensure or guarantee the privacy of any information that you provide to any such third-party websites that link to or from our Application and/or website, as these third-party websites are owned and operated independently from Betbull. Any information collected by these third-party websites will be governed by their privacy policy, if any, of such third parties and the operators of these websites shall be solely responsible for the functionality and security of the linked websites.
How do we use cookies?
When accessing our Services, we may use cookies and other similar technologies to collect information about your browsing activities over time and across different websites. This information is referred to as cookies, which are small text files that are stored on your device when you visit online pages and serve the function of recording your preferences.
If you choose to decline cookies, you may not be able to experience all of the interactive features on our websites.
Strictly necessary cookies
“Strictly necessary cookies” are essential to allow a user to move around a website and use its features, such as accessing secure areas of the website or making financial transactions. Without these cookies we would not be able to make our websites work efficiently.
Use of cookies during the registration process
During your registration and use of our Services, we will use these cookies to hold information collected during the registration process and will allow us to recognize you as a customer and provide you with our Services, including your username, session expiration information, and a session token (which session token may be shared with third parties processing your information as stated above). We may also use the collected information to better understand your interests while online and to enhance your visits to our mobile application and/or websites.
For visitors to our websites, we use cookies to collect information. Our servers use three different types of cookies:
A “session-based” cookie: This type of cookie is only allocated to your device for the duration of your visit to our website. A session-based cookie helps you move around our website faster and, if you’re a registered user, it allows us to provide you with information that is more relevant to you. This cookie automatically expires when you close your browser.
A “persistent” cookie: This type of cookie will remain on your device for a set period of time that has been determined for each cookie and will help enhance future visits. Flash cookies are also categorized as persistent cookies.
An “analytical” cookie: This type of cookie allows us to recognize and count the number of visitors to our website and analyse how visitors use our website. This helps us improve the way our websites work. For example; ensuring that the page layout is optimized to help you find what you are looking for easily.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies. However, if you prefer you can modify your browser settings to decline cookies. The Help menu on the menu bar of most browsers will instruct you on how to prevent your chosen browser from accepting new cookies, how to have your browser notify you when you receive a new cookie and how to disable cookies altogether.
What are your rights as to your personal data?
As per the applicable data protection legislation, you have certain rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances as set out below. We also set out how to exercise those rights. Please note that we require you to verify your identity before we respond to any of your requests. The GDPR provides the following rights:
Right of Access
You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.
Right to Rectification
You have the right to ask us to correct your personal data where it is inaccurate or incomplete and we endeavour to do so without undue delay.
Right to Data Portability
In certain circumstances, you have the right to ask us for a copy of your data in a structured, machine readable format and to ask us to share (port) this information to another entity.
Right to Erasure
In certain circumstances, you have the right to ask us to delete the personal data we hold about you:
Where you believe that it is no longer necessary for us to hold your personal data;
Where we are processing your personal data on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
Where you have provided your personal data to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; or
Where you believe the personal data we hold about you is being unlawfully processed by us.
Right to Restriction of Processing
In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data:
Where you believe the personal data we hold about you is inaccurate and while we verify accuracy;
Where we want to erase your personal data as the processing is unlawful, but you want us to continue to store it;
Where we no longer need your personal data for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defence of legal claims; or
Where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.
Right to Object
You can object to our processing of your personal data based on our legitimate interests. We will no longer process your personal data unless we can demonstrate an overriding legitimate ground (such as where we are processing your personal data to prevent fraud).
Withdrawal of Consent
Where you have provided your consent for us to process your personal data, you can withdraw your consent at any time by visiting the preference centre in the Application or by emailing privacy@betbull.com.
Objection to Marketing and Profiling
At any time you have the right to object to our processing of personal data about you in order to send you promotions and special offers and other marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
Exercising your Rights
To exercise any of these rights above, please visit the preference centre on the Application or contact us at privacy@wynnresorts.com.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal information.
Normally we will not issue any charge for a request made with regard to any of your rights listed above. However, if your request is deemed to be “manifestly unfounded or excessive” (for example, if you make repeated requests on the same issue), to the extent allowed by the application data protection legislation, a fee may be charged to cover the costs required to respond.
How can you contact us for further information or to register a complain?
If you have any questions or concerns about our Privacy Policy and data processing activities or if you wish to contact us about your rights over your personal data, you can contact our Data Protection Officer at privacy@betbull.com. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to address grievances directly to the relevant Supervisory Authority.
This Privacy Policy was last updated on 01.04.2022
