This privacy policy is composed of the several sections. Each of the sections is equally important, so we encourage you to carefully read all of them before you consent to the processing of your personal data.

What information can be found in this Policy?

1.Introduction

2.Data Controller and Data Subjects

3. Data we process
3.1 Identification data
3.2 Recordings
3.3 Private habits and interests

4. Why we process your data and how
4.1 Identification data
4.2 Recordings
4.3 Private habits and interests

5. Our use of cookies

6. How we protect your data

7. Your rights
7.1 Right to lodge a complaint
7.2 Right to withdraw consent
7.3 Right to data portability
7.4 Right to object to the processing of your data and rights related to automated decision making
7.5 Right to restrict processing
7.6 Right to erasure (right to be forgotten)
7.7 Right to rectification
7.8 Right to access

8. How long we keep your data

9. Who else may access your data

10. Transfer of your data to third countries

1.Introduction

A Smartbets user (‘you’) may share information and opinions on sport matches, search for tips, check the match statistics, get reviews of bookmakers and information about free bets (‘services’). You can also connect to your bookmaker account in order to place bets according to Smartbets statistics. More information about our services is available in our Terms and Conditions. When you use our services many of your information might be shared with us or third parties.

This Privacy Policy is important to you to understand how your personal data is collected, used, consulted or otherwise processed when you use www.smartbets.com (‘Smartbets’). Personal data is any information about you that might be used to identify you, or make possible to identify you. This Privacy Policy applies to your personal data processing on Smartbets, and not to data processing that may occur on other services or web pages regardless whether they are provided by the owner of Smartbets of someone else. The owner of Smartbets (‘we’, ‘us’, ‘our’) is:

Better Collective A/S,
Tolbodgade 12,
1253 Copenhagen K (Hovedstaden)
Denmark (DK)
CVR. 27652913

This Privacy Policy is effective from May 25th 2018. This Privacy Policy may be modified from time-to-time.

Essential modifications are those that affect your rights, obligations and state with regard to protection and processing of your personal data. The essential modifications might include (but not limited to) launch of new services, deployment of new technologies and processing your data for new purposes. Therefore, if we make essential modifications to the Privacy Policy, we will send you notice through our Services, or by other means, and give you the opportunity to review the changes before they become effective. You will be asked to consent to the processing of your personal data in accordance with updated Privacy Policy. If you do not consent to this, you will not be able to use your account, and services available for registered users.

In addition, from time to time we make minor modifications of the Privacy Policy. Minor modifications do not impact your rights, obligations and state with regard to protection of personal data. These types of modifications might include (but are not limited to) organizational and grammatical changes to this Privacy Policy in order to makes our policy easy to read. The fact that you continue to use our Services after we publish the updated Privacy Policy with only minor modifications means that the processing of your personal data is subject to the updated Privacy Policy with only minor modifications.

2.Data Controller and Data Subjects  

By using Smartbets services you may disclose various pieces of  information, including those that would be considered personal data. When your personal data is processed then you are considered a data subject and you are entitled to exercise your rights guaranteed by EU Data Protection Law, and explained in this Privacy Policy. Taking into account that we determine the purposes and means of processing personal data on Smartbets we are legally considered as data controller over your personal data on this Website. Being data controller provides us the opportunity to process your personal data, but also obliges us to protect them in the way regulated by EU Data Protection Law, particularly by the General Data Protection Regulation (‘GDPR’), and this Privacy Policy.

3.Data we process

We are processing various categories of your data. Below you may find information on which data we process, as well as their categorizations.   

3.1 Identification data

Personal Identifiable Information (PII) - If you decide to create account on Smartbets we process your email address, user name, first and last name (if you sign up using your social network profile), ID assigned by our system as well as ID from bookmaker you choose to connect. We may also process your address, city and country information if you choose to add them to your profile.  

Electronic identification data - When you log in to the Smartbets we process the IP address of the device you use, the type and version of browser and operating system you use as well as the time of logging in. If you are logging in via social networks, they will generate ‘social tokens’ - that is actually your authentication data that we process whenever you want to login on Smartbets via social networks. We may process access token from your bookmaker account that confirms that bookmaker authenticated you.    

3.2 Recordings

Images - You may choose to upload your photo (or any other photo) as a profile picture on Smartbets. If you sign up using your social network profile, Smartbets automatically pull your social network account profile picture and makes it your Smartbets profile picture, until you change it.

3.3 Private habits and interests

If you choose to, you may select your favorite teams, leagues, bookmakers and markets to be highlighted in odds comparison. You also choose to determine a default stake for your direct bets as well as odds format. We also know whether you are interested in receiving notifications from Smartbets and what do you add to your betslip.

If you place a bet through connected bookmaker account, we process information about your betting habits, such as sports, leagues, teams you bet on, currency you use, dates of placed bets and so on.

4. Why we process your data and how

We collect and  process data about you when you sign up, and use our service. We process your personal data in order to provide our services to you, to improve your experience about our services, to further develop our service, and to secure and maintain regular functioning of Smartbets. More about purposes for processing your data you may find below.  

4.1 Identification data

Personal Identifiable Information (PII) - Your PII that we process serve to distinguish you from other Smartbets users. Your email address is used so that we can communicate with you regarding any changes to your account or our services, as well as for commercial communication if you agree to receive it. It is up to you to decide whether to reveal your first name, last name, address, city and country where you live. This information might contribute to the personalization of your user account.

Electronic identification data - We process the IP address of the device you use in order to enable communication between your device and our server; to determine your approximate geolocation which may be further used for service customization (for instance to provide appropriate content for your language of choice and gambling-related content that is legal in your country) as well as for analytical purposes. More about how we process your data for analytical purposes you may find in our Cookie Policy.

The processing of details about the browser and operating system you use is necessary to ensure the regular provision of our services to you. Also, sometimes we will need this data to solve some technical problems if they emerge.  

If you decide to login via your social network account, social network tokens (random string of characters) will be generated and then used solely for authentication purposes.    

When you connect to bookmaker account, we may process your access token. Processing  access token is necessary to process your actions on SmartBets that affect your bookmaker account.

4.2 Recordings

Images - we might be storing your profile photo, in order to enable you to personalise your profile on our website.

4.3 Private habits and interests

Favorites - We process information about your favorite teams, leagues, sports and markets in order to offer you personalised feed with all the matches you might be interested in.

We process information about how do you place bets, in order to enable you to place a bet at your bookmaker account as well as to measure what kind of betting markets and leagues you prefer. This information help us in offering more relevant content on our website.

Moreover, we process different information about your personal interests in order to recognize your personal preferences, and create your profile that might be used for commercial communication purposes. For this purpose we use the Eloqua marketing platform. More about this toll and related process you may find in our Cookie Policy. If you do not want to be a subject to automated decision making including profiling please check subsection ‘Right to object to the processing of your data and rights related to automated decision making’ under the section ‘Your rights’ in this policy.       

5. Our use of cookies

Any browser visiting our Website will receive cookies from us. We use cookies because we wish to provide the best possible on-site experience to everyone who visits our website.

By the use of cookies we process standard internet log information and details of Website visitors behaviour patterns. The use of cookies enable us to improve site navigation, analyse on-site behaviour of everyone who visits the website, promote our products and provide content from third parties. To find out more about our use of cookies, read our Cookie Policy.

6. How we protect your data

We do not collect personal data in excessive manner. We only process data that we really need and only for agreed purposes. We are tending to keep your data up to date and to store them securely. We do not process your data for period longer than it is necessary for the purposes for which data is processed.  

We use technical and organisational measures in accordance with good industry practice to safeguard your information. Thus, we take appropriate technical and organizational measures to ensure protection of your personal data against accidental or unlawful loss, alteration, steal, unauthorized disclosure or access, unauthorized use and against all other unlawful forms of processing.

We apply different levels of access control to your data. Restriction of access control is based on business needs and security requirements. We ensure you that only appropriately authorized persons have access to your data, whose knowledge and skills about data is necessary to fulfill their obligations arising out of or in connection with the performance of their job.

7. Your rights

7.1 Right to access

You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. If you would like to get the confirmation as well as the access to your personal data please send contact us via [email protected].

7.2 Right to rectification

You have the right to ask us to delete inaccurate personal data concerning you. Taking into account the purposes of the data processing, you have the right to have incomplete personal data completed.

7.3 Right to erasure (right to be forgotten)

In limited circumstances, you will have the right to request that we erase the information we hold about you:

7.4 Right to restrict processing

You have the right to seek the restriction of processing of your personal data in the following circumstances:

7.5 Right to object to the processing of your data and rights related to automated decision making

You have the right to object our processing of your data on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling. Upon your objection, we will stop processing your data unless we can demonstrate compelling legitimate grounds for continuing the processing which override interests of your fundamental freedoms and rights, or if further processing is necessary for the establishment, exercise or defence of legal claims.

At any time you have the right to object processing your data, including profiling, for direct marketing purposes. We use Eloqua for automated decision making including profiling, for marketing purposes, and you may opt-out from further data processing for this purpose at the following link. Upon your opt-out your personal data will not be longer processed for direct marketing purpose. In regard with automated decision making about you, you may have right to request human intervention.

7.6 Right to data portability

Under certain circumstances you have right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format (i.e. in digital form) and you have the right to request the transmission of those data to another entity without hindrance from us, if such transmission is technically feasible.

7.7 Right to withdraw consent

If the ground for processing your personal data is your consent, you can withdraw your consent at any time without giving any reason to us, and free of charge. In order withdraw the consent you should delete your account on Smartbets.

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Please be aware that after withdrawal of the consent we will not be able to process your data and consequently we will not be able to offer our services to you.

7.8 Right to lodge a complaint

If you feel that your personal data rights have been breached, you can can contact us on [email protected]. Also you have the right to lodge a complaint with your local data protection authority. The relevant data protection authority in EU Member States might be determined either by your place of habitual residence, or the place where the alleged infringement emerged.

As we are established in Denmark you may choose to contact Danish Data Protection Agency - Address: Datatilsynet, Borgergade 28, 5, DK-1300 Copenhagen K; email: [email protected]

8. How long we keep your data

We keep your data until you delete your account on Smartbets. When you delete your account we will erase your personal data.

9. Who else may access your data

We may share your data with third parties. The third parties are categorized as follows:

10. Transfer of your data to third countries

We may transfer your personal data outside the European Economic Area in order to provide our services on regular base and/or to further develop our services. We take all measures in relation to the recipients of your personal data, to ensure an adequate level of protection and appropriate safeguards as defined by the applicable data protection law and particularly GDPR are implemented.

Your personal data might be transferred to the recipient based in country the European Commission considers to have an adequate level of data protection. You may find out more about countries with adequate level of protection here.

If your data is transferred to a recipient based in US, then we aim to transfer your data in the way laid down by Privacy Shield mechanism. More about Privacy Shield mechanism is available here.

We will conclude Data Protection Agreements as necessary  with recipients of your data that will include Standard Contractual Clauses issued by the European Commission and that would oblige the data recipient to provide an adequate level of protection and implement appropriate safeguards as defined by the applicable data protection law, and particularly GDPR, with regard to processing your personal data.

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