Privacy Policy

What Information Can Be Found In This Policy?

Introduction

Types of Data and Reasons for Processing
Identification Data
Recordings
Private Habits and Interests

Our Use Of Cookies

How We Protect Your Data

Your Rights
Right to Information
Right to Access
Right to Rectification
Right to Erasure (Right to Be Forgotten)
Right to Restrict Processing
Right to Object to the Processing of Your Data
Right Not to Be the Subject of Automated Decision Making
Right to Data Portability
Right to Withdraw Consent (Opting-out)
Right to Lodge a Complaint
How to Exercise Your Rights

Data Retention

Who Your Personal Data Can Be Shared With

Transfer of your data to third countries

Endnotes

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 get 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 some of your personal data is disclosed. This Privacy Policy is important for you to understand how your personal data is collected, used, consulted or otherwise processed when you use www.smartbets.com (‘SmartBets’).

This Privacy Policy applies to personal data processing on SmartBets and not data processing that may occur on other services or websites.

The owner of SmartBets and a data controller over your personal data (‘we’, ‘us’, ‘our’) is:

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

This Privacy Policy is effective from December 2018.

Types of Data and Reasons for Processing

We may process various categories of your personal data in order to provide and further develop our services, improve your user experience, as well as to secure and maintain regular functionality of SmartBets.

More information about the purposes and reasons for processing your data can be found below.

Identification Data

Personally Identifiable Information (PII) - If you create an account on SmartBets we process your email, user name, forename and surname (if you sign up using your social network profile), the ID assigned by our system, as well as the ID from the bookmaker that you choose to connect to your account. We may also process your residential information if you choose to add this to your profile.

Your PII is processed so that we are able 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 to send you newsletters and push notifications upon your consent. It is your choice whether you decide to reveal your real forename, surname, address, phone and mobile phone number. This information may contribute to the personalisation of your user account and development of your communication channels with us.

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

We process the IP address of the device you use in order to enable communication between your device and our server and to determine your approximate geolocation, which may be further used for service customisation (for example, to provide appropriate content for your language of choice and gambling-related content that is legal in your country). Your approximate location may also be used for analytical purposes. More information about how we process your data for analytical purposes can be found 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. We may also need this data to solve technical problems should they emerge.

If you log in via social networks, social network tokens (random string of characters) will be generated and then used for the authentication purposes. When you connect your bookmaker account with SmartBets we may process your access token, since your actions on SmartBets may affect your bookmaker account.

Recordings

Images - You can choose to upload a profile picture on to your account. I It can be a photo of you or any other picture that you wish to be linked to your account. If you sign up using a social network profile, SmartBets will automatically use your profile picture from your social network profile as your SmartBets profile picture. We may store your profile picture to allow personalisation of your profile on our website.

Private Habits and Interests

Favourites - You may select your favorite teams, leagues, bookmakers and markets to be highlighted in odds comparison. You can also choose to determine a default stake for your direct bets, as well as odds format.

We are aware of what you add to your SmartBets betslip. If you place a bet through a connected bookmaker account, we will process the information about your betting habits such as sports, leagues and teams you bet on, currency you use, and dates of bets placed.

If you opt-in to receive the newsletter or push notifications from SmartBets we will store the information relating to this.

We process information about your favourite teams, leagues, sports and markets in order to offer you a personalised feed with matches you may be interested in.

We process information about how 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 to offer more relevant content on our website.

Information about your personal interests is processed in order to recognise your personal preferences and create your profile that may be used for commercial communication purposes. For this purpose we may use marketing platforms that are explained in more detail in our Cookie Policy. If you do not want to be subject to automated decision making, including profiling, please check the subsections ‘Right to Object to the Processing of Your Data’ and ‘Right Not to Be the Subject of Automated Decision Making’ under the section ‘Your Rights’ in this policy for more information.

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. Through the use of cookies we process standard internet log information and details of the behavioural pattern of our website visitors. The use of cookies enables us to improve site navigation, analyse the 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, and how you can disable them, please read our Cookie Policy.

How We Protect Your Data

We do not collect or retain your personal data longer than is necessary for the purposes explained above.

We use technical and organisational measures in accordance with good industry practice to ensure appropriate security of your personal data against accidental or unlawful loss, alteration, theft, unauthorised disclosure or access, unauthorised use and all other unlawful forms of processing.

Access to your personal data is restricted to only authorised employees, whose knowledge about data is necessary in order to provide a required service to you. They process your data in a confidential manner which prevents them from disclosing any data to third parties without the appropriate grounds to do so.

Your Rights

As defined under the EU General Data Protection Regulation (‘GDPR’), being a data subject means that you are entitled to the following rights:

Right to Information

You have the right to be provided with certain pieces of information about the processing of your data and your relation with us. This includes our identity and contact details, the reasons or purposes for processing your personal data, the legal basis for doing so, recipients of that data (especially if they reside in third countries) and other relevant information that is necessary to ensure the fair and transparent processing of your personal data.

Right to Access

You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, information about the processing of your data and your rights and where applicable, to request access to the data.

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 and inaccurate data to be corrected.

Right to Erasure (Right to Be Forgotten)

In limited circumstances you have the right to request that we erase the information we hold about you. These are as follows:

We will be exempt from this obligation if it is impossible to comply with or would require disproportionate effort to prove.

Right to Restrict Processing

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

Right to Object to the Processing of Your Data

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

Right Not to Be the Subject of Automated Decision Making

You have the right to object to our processing of your data for automated decision making, including profiling, where such processing produces legal effects concerning you or similarly significantly affects you. Upon your legitimate objection, your personal data will no longer be processed for automated decision making. You also have the right to request human intervention in relation to automated decision making about you.

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). You also have the right to request the transmission of the data to another entity without hindrance from us, if such transmission is technically feasible.

Right to Withdraw Consent (Opting-out)

We rely on your consent to send you email newsletter and push notifications that contain news and stats on forthcoming matches as well as the latest freebets offers from bookmakers we are partnered with. You can withdraw your consent at any time without giving any reason to us and without any charge to you.

To opt-out from receiving newsletter emails from us, you should click on the unsubscribe link available at the bottom of any email that have you received.

You can turn off push notifications through your browser settings. Please visit this website for more detailed instructions on how to opt-out of Web Push.

The withdrawal of consent does not affect the lawfulness of processing based on consent before its’ withdrawal. After the consent is withdrawn we will not be able to share the latest news and offers with you.

Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority. The relevant data protection authority in EU Member States may 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.

How to Exercise Your Rights

If you have any questions or doubts regarding the processing of your personal data on SmartBets, or wish to exercise any of your rights as listed above, please send us an email at [email protected]

Data Retention

We will store your data in the database even if you delete your account. In this case your profile data will not be publicly displayed. If you would like your personal data deleted from our systems, you can send an erasure request by using the process described in the section above.

Who Your Personal Data Can Be Shared With

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

Transfer of your data to third countries

We may transfer your personal data outside of the European Economic Area in order to provide our services on a regular basis and/or to develop our services further. 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 may be transferred to a recipient based in a country that the European Commission considers to have an adequate level of data protection. You may find out more about countries with an adequate level of protection here.

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

We will conclude Data Protection Agreements with recipients of your data where necessary. These will include Standard Contractual Clauses issued by the European Commission that would obligate 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 the processing of your personal data.

Endnotes

This Privacy Policy may be modified from time to time.

Essential modifications are those that affect your rights, obligations and state with regards to the protection and processing of your personal data. The essential modifications may include, but are not limited to, the launch of new services, deployment of new technologies and processing your data for new purposes.

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.

Minor modifications are those that do not impact your rights, obligations and state with regards to the protection of your personal data. These types of modifications may include, but are not limited to, structure, organisational and grammatical changes to this Privacy Policy in order to make it easier to read and understand.

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