General statement

Bet Angel and its associated companies value your business and have always aimed to be completely compliant with all revelant laws related to your personal data. We do not share, unless required to do so by law or contractual arrangement, your information with any third party. UK based, we are fully ICO registered and adhere to their guidelines. Thank you for trusting us.

Introduction

This Policy applies to our websites, application, products or services that link to this policy or do not have a separate privacy policy (collectively our “Services”). This includes the Bet Angel software and related services such as server provision and training. If you are in any doubt as to whether this policy applies to you, please contact the data controller for clarification.

This purpose of this privacy policy is to give you a better understanding of:

• what information we collect;
• how we use that information;
• how this information is shared;
• your rights; and
• other useful privacy and security related matters.

Who is the Data Controller?

The data controller for this agreement is Bet Angel Limited

They can be reached at www.betangel.com/support/ our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the ‘Your Rights’ section below.

Information we collect

When you use our Services, we collect the following types of information:

Information you provide us:

We collect information about you during the purchase process for any of our Services. This information may include, but is not limited to your name, postal address, e-mail address, phone number, and any other details as might be requested from you for the purpose of registration and/or continued use of our Services.

We may also collect information from you if you request information or customer support.

Additional Information collected:

We may also collect the following information:

1. name, contact information and message if you contact us or participate in a survey, contest or promotion;
2. details such as traffic information, location data and other communication data (including IP address and browser type) collected by your availing of the Services;
3. device information including unique device identified;
4. pages visited and content viewed, links and buttons clicked, URLs visited before and after you use our Service. For more information about cookies and how to manage them please see our Cookie Policy;
5. information and communications on forums on the websites, including chat rooms and message boards, profile comments, and chat messaging with other users;
6. your response to marketing campaigns from us or through our third parties i.e. open/click on such emails;
7. your social media profile details (name, profile photo and other information you make available to us) when you connect with or contact us through a social media account;
8. information derived based on profiling activity (see below); and
9. information from third party databases to comply with our legal and regulatory obligations.

Third Party and Publicly Available Sources

Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as our partners, service providers and publicly available websites (i.e. social media platforms). We may also do this to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and provide and enhance our Services.

Please note that we do NOT collect or store your password or access information to your exchange accounts nor any specific activity you undertake on the exchange. Our service simply logs you into the exchange to transact and that process is strictly controlled and monitored by Betfair. For information relating to your account, security and privacy related to that exchange you will need to contact that specific exchange where you hold an account.

Cookie Collection

We collect browser and cookie information when you first navigate to our websites. We use cookies to give you a better customer experience and for use of access. Certain cookies will allow you to leave and re-enter our Websites without re-entering your password. This will be monitored by a web server. For more information on the use of cookies, how you can control their use, and information relating to our internet-based and mobile advertising, see our cookies policy here.

How do we use this information?

We process personal information for these Services – and business -related purposes:

• Account setup, verification and management: We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, process payment information and send important account and Service information. Each time to you into your account we monitor usage for planning purposes.

We may also use personal information to enforce our terms and conditions.

• Marketing and events: Subject to any preferences you have expressed (where applicable), we use personal information to deliver marketing and event communications to you across various platforms. We will do this during the period of your relationship with us and, unless specifically instructed otherwise by you, for a reasonable period of time after the relationship has ended in order to inform you about products, services, promotions and special offers which we think may be of interest to you.

If we send you a marketing message, it will include instructions on how to opt out of receiving these marketing communications in the future. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

Except where we use your personal data for marketing purposes on the basis of your prior written consent and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.

• Diagnostics, research and development: We use personal information for internal research and development purposes, to help diagnose system problems, to administer our websites, to improve and test the features and functions of our Services, to develop new content, products and services. To carry out testing and analysis. This processing is necessary for the purpose of our legitimate interests.
• Chat rooms, messaging, and community forums: A number of our Services provide features including chat rooms, messaging services, and community forums for collaboration, peer connection,  and information exchange purposes. Depending upon the Service, the personal information you choose to post, share, upload, or make available is public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. These services may have their own Terms of Use and, where appropriate, their own privacy statements.
• Legal and regulatory obligations: We may be required to use and retain personal information for legal and compliance reasons. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate under applicable law.

How is the information shared?

Your personal information may be transferred or disclosed to any company within the Group or, subject to appropriate agreement, to third parties. If you join any mailing or marketing list within our group we only use that for our own purposes and will not pass your details to a third party without your appropriate permission, or where we are required to do so to comply with applicable laws.

Within the Group:

Any reference to the “Group” within this Policy includes Bet Angel Limited and all or any of its direct or indirect subsidiary undertakings, joint venture partners, and their related companies wherever located in the world as may exist from time to time. Any member may use and share, within the group and with its advisors, the information you provide and other information it holds about you for the following purposes:

• Account set up, verification and management;
• Marketing and events
• Risk management; and
• Legal and regulatory obligations.

Our third-party service providers & partners:

The Group may, from time to time, retain trusted third parties to process your information to provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys. As part our agreements with our partners, we may be required to share your information for the purposes these functions.

Third parties for legal reasons:

We will share personal information when we believe it is required, such as:

• To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
• In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
• To protect our rights, users, systems, and Services.

International Transfers

Bet Angel may operate businesses in multiple jurisdictions some of which are not located in the European Economic Area (“EEA”). Countries outside the EEA do not always have strong data protection laws. Where we transfer personal information from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it. We take steps to ensure that the information we collect is processed according to this privacy policy and the requirements of the applicable law wherever the data is located. Please contact us below if you require further information.

Your rights

Under the General Data Protection Regulation, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.

• Access to personal data: You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please see the Contact Us section for information on how to contact us.
• You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible.
• Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect.
• Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.

To opt out of marketing, you can use the unsubscribe link found in the marketing communication you receive from us. For other marketing preferences or if you are unable to locate an opt out link, use the “Contact Us” option within the relevant Service.

• Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right especially where you have anonymised information such as on a forum or community.
• Right to data portability: This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible or applicable.
• Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
• Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
• Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.

How to contact us

For any requests related to your personal information or any of your rights referenced above, please feel free to contact us at: –

Filing a complaint

If you are not satisfied with how we manage your personal data, you have a right to make a complaint to your local Data Protection Authority.