Privacy Policy

Version 1.8

February 2019

Best Gambling Ltd, . Cody Technology Park, Building A8, Old Ively Road, Farnborough, Hants, GU14 0LX

Contents

1. GET TO KNOW US
2. OUR DATA PROTECTION OFFICER
3. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
4. HOW WE USE YOUR PERSONAL DATA
5. MARKETING
6. HOW WE SHARE YOUR PERSONAL DATA
7. KEEPING YOUR PERSONAL DATA SAFE
8. WHERE WE TRANSFER your PERSONAL DATA
9. DATA RETENTION
10. YOUR RIGHTS
11. WHAT HAPPENS WHEN YOU VISIT OTHER WEBSITES?
12. CONTACTING US ABOUT THIS PRIVACY POLICY
13. CHANGES TO THIS PRIVACY POLICY
14. GLOSSARY

INTRODUCTION

Welcome to our privacy policy!

This privacy policy is dated July 2019. To navigate through our privacy policy just click on the links below.

The website metabet.gg is operated by Best Gambling Limited of Cody Technology Park, Building A8, Old Ively Road, Farnborough, Hants, GU14 0LX (“Best Gambling”), who owns this branded website and/or related mobile application (“Website”). Best Gambling is the data controller in relation to your Personal Information. If you want to learn more information about how and why Best Gambling handles your Personal Information, please read the Best Gambling Privacy Notice below.

Best Gambling respects your privacy and is committed to protecting your Personal Data when you use our website (www.metabet.gg) including any mobile or device specific version of the website and any related applications (or “apps”) (together the “Website”).

This privacy policy sets out how we collect, use and look after your Personal Data when you access our Website and tells you about your privacy rights.

We know no one likes to read a lengthy document, so we have tried to make your life easier by structuring our privacy policy with different sections, which give you an overview of the entire policy and let you choose the sections you want to read in more detail. We have also added a Glossary at the end of this document to give you more information about the specific terms we use in it.

We have tried our best to make this Privacy Policy as clear as possible but if you have any questions, please feel free to contact our data protection officer.

1.                GET TO KNOW US

Information about our Website

Our Website is operated by Best Gambling Ltd (“BG”) which is a Data Controller in respect of your Personal Data as it relates to your use of the Website.

This Privacy Policy explains how BG handles your Personal Data and references in this document to “we”, “us” or “our” are references to Metabet.gg.

Data Controller contact details:

Best Gambling Limited:

Best Gambling Limited
Cody Technology Park,

Building A8,

Old Ively Road,

Farnborough,

Hants,

GU4 0LX

2.                OUR DATA PROTECTION OFFICER

The Best Gambling Group has appointed a data protection officer (“DPO”). If you have any questions about this privacy policy and want to know more about how we handle your Personal Data when you use our Website, please contact the Best gambling DPO:

By mail to:

The Data Protection Officer

Best Gambling Ltd,

Cody Technology Park,

Building A8,

Old Ively Road,

Farnborough,

Hants,

GU14 0LX

By email to: dpo@bestgambling.co.uk

If you want to know how to contact us to exercise your legal rights in respect of the information we hold about you, please see section 11 “Your Rights” below.

3.                WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

When you use our Website, we may collect Personal Data about you. We have set out below what data we collect and how we collect it.

You are under no obligation to provide Personal Data to us. However, certain Personal Data is essential for the provision of and the quality of the products and services we offer (for example, enabling you to set up your Player Account or to play the games on our Website) and you might not be able to obtain certain services if you do not provide the information required for those services. In addition, we need certain Personal Data to fulfil our legal and regulatory. If you refuse to provide your Personal Data where law or regulation requires us to collect it from you, we cannot allow you to access our Website.

Information you directly provide to us

When you use our Website, we collect the following kinds of information from you:

We use these terms throughout this document where we describe how these types of data are used.

Information we collect from your device (“Device Data”)

We collect the following information from your device when you connect to our Website: information about your device’s hardware and software, use of the Website, traffic information, IP address, time of access, date of access, web page(s) visited, language(s) used, software crash reports, device information including the unique device identifier.

Information we collect through cookies

We collect information using cookies to protect our Website, offer you a personalised experience with us, tailor our marketing services and improve our Website. For more information about the cookies we use and how to manage your cookie preferences please see our Cookie Policy.

Information we collect from third parties

In order to operate our Website, we collect information about you from third party service providers for various reasons such as making sure our Website is safe, to offer a good level of service and also to comply with our legal and regulatory obligations as per the requirements of the Gambling Commission. We collect information about you from the following categories of third party service providers:

We will use Personal Data obtained from these third parties in accordance with this Privacy Policy.

Information we collect from publicly available resources

In order to comply with our legal and regulatory obligations (including in respect of anti-money laundering and responsible gaming) and to protect our Website from abuse and fraud, we may look at other information from publicly available resources. Our searches may include collecting information about you from the following sources: social media platforms (e.g. Facebook, LinkedIn), the electoral roll, public databases (e.g. telephone directories), internet search engines (e.g. Zoopla, Google, PayScale) the insolvency registry, companies house register and the UK land registry.

Information we collect from social media platforms

We collect information about you when you contact us through your account on a social media platform such as Facebook, Twitter, etc for various purposes (such as to enter a competition, contact us for information).

We also collect information about you if you chose to interact with our content and pages available on a social media platform. When you do this, the provider of the social media platform may provide us with your details such as your account information. You should read the relevant social media platform’s privacy policy and terms and conditions to understand how you share your information when using their services.

4.                HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data as permitted by law. Most commonly, we will use your Personal Data in the following circumstances:

• To perform the contract we are about to enter into or have entered into with you.
• For our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those legitimate interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you have consented to our use of your Personal Data.

Purposes for which we use your Personal Data

We have set out below, a description of all the ways we may use your Personal Data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact our DPO (see Section 2) if you need details about the specific legal ground we are relying on to process your Personal Information.

5.                MARKETING

This section of our privacy policy explains how you will be contacted for marketing purposes.

How to manage the marketing messages you receive:

You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you.

Marketing communications may contain details about:

• new games, promotions, competitions and offers available to you on the Website;
• other promotional information about the Website.

You can choose to opt-in to receive marketing communications from us about the Website via the following channels:

• email marketing: when you opt-in to receive marketing communications by email;
• SMS marketing: when you opt-in to receive marketing communications by SMS;
• Call Marketing: when you opt-in to receive marketing communications by telephone; and
• Push notifications: when you have installed the app on your device and enable push notifications in your device settings.

Additionally, you may receive marketing communications by post from us about the Website when you provide your contact details and have not opted-out from receiving marketing communications by post.

You can opt-out from receiving marketing communications from us at any time by following the instructions below:

• Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences in My Account;
• SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences in My Account;
• Call Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences in My Account;
• Post Marketing: to opt-out from receiving marketing by post, you can manage your preferences in My Account; and
• Push notifications: to opt-out from receiving push notifications, you can disable push notifications in your device settings.

If you choose to opt-out from email, SMS or phone marketing, you will stop receiving marketing communications within 96 hours.

When you choose to opt-out from receiving post marketing, please be aware it may take up to 28 days for your request to take effect.

Social Media Marketing. We may also use information you provide to us to show you relevant advertising and personalised content about us on certain third party social media platforms made available to us through those services (e.g. Facebook, Twitter). We do not control the way these platforms operate and collect your information and you should read their respective privacy policies online to understand how they use your personal information.

About Facebook Ads. If you are a Facebook user, we may periodically use the Facebook Ads services (including Custom Audiences and Facebook Pixels, click here for more information) to provide you with personalised content about us. When you are logged into your Facebook account, we may provide you with personalised content. To provide this personalised content, Facebook may be sharing information with us that you have chosen to make available pursuant to your Facebook settings, such as your profile information and information collected through the “like button”). You can read more information about how Facebook uses your information in their privacy policy. We may also show you personalised and targeted advertisements on the news feed of your Facebook account. If you no longer want to receive personalised and targeted advertisements from us on Facebook, you can manage your advertising preferences and decide what you want or do not want to see by using the settings in your Facebook account. You can read more details about how to manage your ad preferences on Facebook here: https://www.facebook.com/help/769828729705201/.

Alternatively, you can also opt-out from receiving personalised advertisements on social media platforms in My Account.

Marketing communications from Third Parties. You will only receive marketing communications from Third Parties if you have agreed to this and if you have opted-in. On our Website, you may be invited to opt-in to receive marketing communications about products, competitions, prizes and offers from our selected partners and third-party services (“Third Parties”). If you decide to opt-in, your information will be passed to these Third Parties and treated in accordance with their own privacy policies as available on their sites from time to time. We do not control the use of your personal information by these Third Parties and you should contact them directly if you want to opt-out from receiving their marketing communications.

6.                HOW WE SHARE YOUR PERSONAL DATA

Sharing your Personal Data within the Best Gambling Group

Your Personal Data will be disclosed to companies within the Best Gambling Group in accordance with applicable data protection laws and the terms of this privacy policy, for the purposes set out in section 5 above (e.g. to set up your Player Account, to provide you with customer support services, to manage any risks to our Website and to our business, to comply with any applicable legal and regulatory obligations, to send you marketing communications, etc.).

Sharing your Personal Data with our services providers

We use service providers in connection with the operation of our Website to ensure we deliver the best possible services. We enter into contracts with our service providers and ensure they take good care of your Personal Data we share with them for that purpose. We are committed to protecting your Personal Data and we oblige our service providers to handle your Personal Data in accordance with applicable data protection laws and the terms of this Privacy Policy.

We engage service providers for the following services:

• Hosting our Website: we use hosting providers such as Amazon AWS services;
• Marketing services such as segmentation, analytics, email messaging services and SMS marketing service providers;
• IT services and security services: we use services such as Neustar;
• Customer support software service providers;
• Data storage services: we use providers such as Google Cloud Platform;
• Data analytics services to measure and understand our audience, tailor our marketing services, improve your website experience and data cleansing services to suppress our marketing lists; and
• Audit, legal and compliance services.

Sharing your Personal Data with statutory authorities

We will share your Personal Data when it is required by applicable law in the following cases:

• To comply with a request for information from a governmental body such as law enforcement (police) or other public authorities (e.g., Insolvency Service);
• To comply with a court order to disclose your Personal Data; and/or
• To comply with a regulatory investigation from a relevant gambling authority (e.g. the Information Commissioner’s Office in the UK).

Sharing your Personal Data in other circumstances

We may transfer all your Personal Information to a third party if the operator of the Website changes, or if there is a sale of all or any part of its business or its assets. In the event of any of these transfers occurring, the party who acquires the data will assume the rights and obligations described in this Privacy Policy.

7.                KEEPING YOUR PERSONAL DATA SAFE

What we do to keep your Personal Data safe:

We have appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where appropriate, we employ encryption, pseudonymisation (for example, by using your Player ID rather than full name where appropriate) and anonymisation solutions to reduce the impact of any security incident to Personal Data. Although, the nature of the internet means that transmission of information may not be totally secured, we have deployed end to end encryption security measures to protect the transmission of your Personal Data when you use our Website.

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Managing security incidents relating to Personal Data:

We have procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If you have any reason to believe that your Player Account information may no longer be safe, please contact our customer support staff.

Keeping your player account safe:

When you create an account with us, we ask you to choose a password to retrieve access to your player account. We use password protection to ensure your player account is safe at all times and can only be accessed by you. You must keep your username, password details private and confidential at all times. Please choose a password that is strong and not easy to guess. Please do not share your password with anyone and please change it on a regular basis. If you suspect your password has been disclosed to anyone, please change it immediately to ensure your Player Account remains safe.

8.                WHERE WE TRANSFER your PERSONAL DATA

We primarily store and process our Player Account data within UK (“EEA”).

However, in the following cases we can transfer your Personal Data outside the EEA:

• If we have a legal or regulatory reason to do so;
• If we use third parties service providers located outside of the EEA; or
• If you have consented to this transfer.

Third parties service providers.

To operate our Website, we may use third party service providers which are based outside the EEA, so their processing of your Personal Data will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Data to a service provider outside of the EEA, 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 where the European Commission considers they provide an adequate level of protection for Personal Data. For further details on this safeguard, see European Commission: Adequacy of the protection of Personal Information in non-EU countries.

• We may contract with the service provider on terms that are approved by the European Commission to aim to give Personal Data the same protection it has in Europe. For further details on this safeguard, see European Commission: Model contracts for the transfer of Personal Information to third countries.

• Where we may use service providers based in the United States of America, we may transfer data to them if they are part of what is known as the “Privacy Shield”. This Privacy Shield requires them to provide similar levels of protection to Personal Data shared between the Europe and the US. For further details on this safeguard, see European Commission: EU-US Privacy Shield.

If you want further information on the specific mechanism used by us when transferring your Personal Data outside of the EEA, please contact our DPO (see section 2 of this Privacy Policy).

9.                DATA RETENTION

We will not keep your Personal Data for longer than required. The precise duration for which we keep your Personal Data when you have a live Player account with us or for a period after your cease to be a Player with us, can vary and depends on various reasons. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and what the law requires us to do. For example, we retain a copy of your Player Account’s records of all financial and wagering transactions together with any identification provided for as long as is necessary for the relevant service and for no longer than 7 years after you have closed your Player Account.

When we no longer need to keep your Personal Data, we anonymise it securely and this process cannot be reversed. In certain cases, we need to securely retain certain Personal Data to fulfil our legal and regulatory obligations.

Additionally, where we decide to retain your information for analytics purposes, we will fully anonymise it in accordance with applicable security standards, so it can never be linked back to an individual.

Please note that if you decide to opt-out from receiving marketing communications from us (see section 6 above), we will need to retain a copy of your contact details, so we can add them to our suppression list and make sure you do not receive any information about our future marketing activities.

Please contact the DPO (see section 2 above) if you need any further information.

10.           YOUR RIGHTS

The law gives you legal rights in respect of the Personal Data we hold about you. You can exercise your legal rights for free except where this Privacy Policy states otherwise. We may need to request specific Personal Data from you from time to time to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month of receipt. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Below is a summary of the legal rights you have, what we do to protect them and how you can exercise them:

11.           WHAT HAPPENS WHEN YOU VISIT OTHER WEBSITES?

Our Website may contain links to websites where information practices may be different to ours. You should read the other websites’ privacy notices, as we are not responsible for and have no control over information that is submitted to, or collected by, these websites when you visit them.

12.           CONTACTING US ABOUT THIS PRIVACY POLICY

If you have any questions or comments about this privacy policy or want to know more about how we use your Personal Data, please contact our DPO (see section 2).

If you want to exercise your right to access your Personal Data, please email us at dpo@bestgambling.co.uk as set out in section 11 above.

13.           CHANGES TO THIS PRIVACY POLICY

We may, from time to time, change or update this privacy policy. All changes to this privacy policy will be published on this page of the Website. Each change will become effective on publication. We recommend that you revisit and read this privacy policy regularly to ensure that you are up-to-date with the current terms.

14.           GLOSSARY