Privacy Policy

We want you to understand how we protect your privacy when we obtain personal data from you, how we use that information, what your rights are in this respect and how we safeguard that.

By reading this Privacy Notice, you hereby acknowledge and agree that the personal data you provide to us is supplied at your own free will and will be used in accordance with the purposes described in this Privacy Notice. If you do not understand this Privacy Notice, please do not register on our website and do not share your personal data with us.

We reserve the right to change and/or update our Privacy Notice at our discretion and at any time. You will be notified accordingly and in advance about these changes and or updates, which we kindly ask you to read carefully and make sure you understand and agree with.

1. General information

Raging Rhino N.V., Reg No. 148106, having its registered address at Abraham de Veerstraat 9, Willemstad, Curacao, licensed to conduct online gaming operations by the Kahnawake Gaming Commission, license number: #00858 (issued 27th May 2020). Monkey 9 LIMITED, Reg No. HE 391776, having its registered address at Avlonos, 1, Maria House, Nicosia, Cyprus, is a wholly owned subsidiary of Raging Rhino NV which provides management, payment and support services related to the operation of the website(hereinafter: “Operator”, “we” or “our”) and is part of the Superbet group of companies.

This Privacy Notice only applies to the processing of Personal Data of Clients/Players for which Raging Rhino N.V. entity is responsible and qualifies as Controller under GDPR 2016/679/EU and any applicable local data protection legislation, as further described in this Privacy Statement.

2. What personal information we collect?

As used in this Privacy Notice, personal data means any information that can be used to individually identify you, directly or indirectly, alone or along with other information, or contact you online or elsewhere.

The categories and volume of personal data that we collect vary depending on the activities in relation to which the data is collected and include, but are not limited to:

• your name and surname
• postal address
• email address and phone number
• age and gender
• personal identification number
• other personal data on your ID document, including scanned copy of your ID document
• information about your placed bets, betting tickets and winnings
• details of any contact we have had with you, such as any complaints or incidents
• recording of your voice and conversation when you get in contact with us
• financial details, such as details about bank account and bank statements
• results in the course of prevention of fraud, misuse of services and money laundering checks
• data on political exposure
• method of exposure
• type of public exposure/function
• source of funds/wealth in specific cases based on the result of the risk assessment
  

We also collect personal data that we are not receiving directly from you, such as:

• information about how you use our website, which we obtain through tracking technologies such as “cookies” (more information about cookies can be found in our Cookie Notice available on our page), IP address registration, Google Analytics, log files

3. How we collect your personal information?

We solely collect your personal data with your informed knowledge, i.e. when you voluntarily submit it to us or when it is generated during your relationship with us.

Collection of data occurs in various ways by forms filled in by you, or at your request by our employees or other dedicated personnel (such as hostesses), fiscal or electronical receipts. For example, personal data collection happens:

• when you register for a Superbet account
• during our checks due to possible frauds, money laundering or terrorism financing prevention
• when you participate to events we organize
• when you agree to participate to our marketing campaigns
• when you register for a bonus
• when you subscribe for notifications about our services and products (newsletters)
• when you register for our loyalty cards
• when you contact us for various purposes (feedback, questions, or comments through a ‘contact us’ form)
• through different tracking technologies such as cookies, IP address recording, log files, Google Analytics

Once collected, we shall at all time ensure that any processing of your personal data is carried out in compliance with applicable laws, with this Privacy Notice and for the purpose for which you submitted your data to us.

4. What we use your personal information for?

By law, we must have a lawful reason for processing your personal information. The data we collect about you will only be used for the purpose for which you submitted it to us, to perform our legal obligations and our legitimate interests in specific circumstances. Such purposes are made clear to you at the point of collection or in this Privacy Notice. Thus, we process your personal data for the following purposes:

• to perform our contractual obligations in order to provide you with our gambling services (e.g. during your registration on our internet page)
• to comply with various local laws and secondary legislation applicable to our business activity
• based on your prior consent for marketing communication purposes (e.g. to register to an event such as contests, bonuses, free bets, personalised offers and other promotional activities). You have the right to refuse or unsubscribe to such communications
• in our legitimate interests which we or a third party may have, except when such interests override by your interests or fundamental rights and freedom (e.g., our interests for improving our products and services, to strengthen, expand or make our business activity more efficient (reorganisation, merger or acquisition by another company), for protection of our rights when receiving your complaints, for security purposes and protection of our property)

We may also use your personal data for the following purposes:

• when you communicate with us for any questions, complaints, requests or to provide guidance, clarification, assistance and support
• when we send you administrative communication (e.g. email confirmations when you sign up for, or unsubscribe from, a specific registration or activity and/or send you certain service-related announcements, such as updates to our Privacy Notice or other policies)
• when we place certain cookies on your computer, called essential cookies, which are necessary to display our website to you. More information about cookies can be found in our Cookie Notice
• in order to improve your experience on our website and to provide you with a customised content, (e.g. your IP address and, if you have registered, your registration details, and are collected using cookies or other tracking technologies)

5. What happens if you do not provide or allow us to use your personal data?

You can decide at any time not to provide us with the requested personal data. However, if you refuse to share your personal data with us when requested, we may not be able to fulfill our contractual obligations if the collection and processing of such data is lawful. You may also not be eligible to participate in certain activities or events (for example promotional activities) if you do not provide us with the minimum required information.

Your refusal to share your personal information with us in order to benefit from certain services may also limit the services and special offers we may offer you. For example, if you do not give us your consent to receive the newsletter, you will not be able to receive any of our newsletters. We will not process your personal data if you just want to visit our site and find out more details about our services and products.

6. Who do we share your personal data with?

Each of our processors who process and store your personal data has an obligation to keep it protected and secure, in accordance with applicable business activity standards and the country's legislation applicable to them. In the event that such processors are located in third countries for which the European Commission has not decided on an adequate level of protection, Raging Rhino N.V. has concluded contracts with such processors, which include standard contractual clauses approved by the European Commission or another supervisory authority, which ensure an adequate level of protection of personal data. The standard contractual clause form is available on the official EU website and can be found via the following link https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010D0087

We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you and you have given us explicit permission to do so. We may share your personal data within the Superbet Group, as well as with third parties acting as processors, to the following extent and for the following purposes:

(A) To data processors authorized to process personal data who are acting as our contractors, for the purposes listed in the “What we use your personal information for” section above. For example, we use:

• companies that provide us with technical and administrative support in our day-to-day activities (trading services, marketing services, archiving and other secondary activities related to gambling)
• companies that provide us with support for communication with clients (chat services, e-mail services and for communication by other means)
• providers of software tools necessary for our business (these processors must ensure an equal level of technical and organisational protection measures when processing your personal data)
• legal entities that are part of the Superbet Group who can process your personal data for internal administrative processes and for analytical purposes
• sports organisations (Superbet takes reasonable steps to ensure accurate and fair coverage of sporting competitions and other events. As a result of this obligation, we enter into agreements to maintain the integrity and/or enforce the rules of sport or play and/or prevent or investigate criminal offences, in cases where we have reasonable grounds to suspect that you may be involved in a breach of such rules or laws, you have knowledge of a breach of such rules or laws or otherwise pose a threat to the integrity of the relevant sport or game based on our assessment of your betting conduct or on the basis of information provided to us by a regulatory or sports authority. These authorities may then use your personal data to investigate and comply with their procedures
• payment institutions for the transfer or withdrawal of your winning

(B) Based on legal obligations. In this regard, please note that there may be legal obligations on our part to share your personal data with State authorities (such as Tax authorities, courts, Financial Agency) all for the purpose of applying regulations governing the prevention of money laundering and terrorist financing to which the Superbet Group is obliged

(C) In the event of our reorganization, merger or acquisition by another company or in the event of the transfer of our business on the basis of our legitimate interest in consolidating, expanding or streamlining our business. In any of the situations listed, the person receiving the data may have access to the data we store, including your personal data, always in accordance with applicable law.

(D) Based on consent in which cases your Personal Data is transferred to any other third party where you have consented or requested that we do so.

(E) We may transmit aggregate statistical data or survey results, but this data will be anonymized and will not contain personal data.

Please note that access to and processing of your personal data by above-mentioned entities is regulated by appropriate data protection agreements, i.e. additional data protection clauses that serve as an Addendum to existing master agreements.

7. How long we keep your personal information for?

Your personal data will only be stored for a necessary and strict period of time in accordance with the purpose for which it is collected and applicable legal requirements. For your information, we will retain your personal data:

• deadlines prescribed by the applicable legislation regulating our business activity (Law on Games of chance, AML Laws etc.). Such data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity
• the existence of our legitimate interests in preserving our rights, security and protection of property, as well as responding to any complaints, requests or other questions regarding our services
• your explicit consent to the processing of personal data, for the duration of your consent
• until you request the application of your "right to erasure" or "right to portability" of data in accordance with the "Your rights" section, unless there is another legal basis for the continuation of the retention of personal data

Upon expiration of the above-mentioned deadlines, your personal data will be deleted or anonymised. If, at any time, you wish us to discontinue the use of your personal data and stop providing you with our services, please contact us in the manner described in “How to access, modify, delete or object to the use of your personal data” section. In the event, when we may not be able to act upon your request, we will notify you in written.

8. How we keep your personal data secure?

Superbet has implemented all necessary technical and organizational measures, whether physical, electronic or procedural, to protect the confidentiality and security of the personal data you share with us. These measures have been implemented to protect data against unauthorized access, destruction, loss, alteration, access, disclosure or use. Our security controls are designed to maintain an adequate level of confidentiality, integrity and data availability. Information transmitted and received through the Superbet site and in our applications is encrypted using Secure Socket Layer (SSL) technology. Superbet has a 24/7 network traffic monitoring system to detect signs of attacks or intrusions.

9. Your rights

At any given time, you will have the following rights regarding your personal data processed by us. Please note that your rights are not absolute in case of other applicable laws and lawful basis for data processing.

(A) The right to information: you have the right to be provided with information on the identity of the personal data controller, on the reasons for processing your personal data and other relevant information necessary to ensure the correct and transparent processing of your personal data.

(B) The right of access: you have the right to make a request for details of your personal information and a copy of that personal information. In emergency situations where the operation of the system is compromised, the Processor may be entitled to remote access, via an encrypted connection and with the security protocols of appropriate security previously exchanged.

(C) The right of rectification: you have the right to have inaccurate information about you corrected or removed without undue delay.

(D) The right of erasure ("right to be forgotten") in the following circumstances:

• if your personal data is no longer necessary for the purpose for which it was originally collected
• if you have withdrawn your consent to the processing of your personal data and there is no other legal basis for the continuation of processing
• if you oppose processing for which there are no overriding legitimate interests of the Controller
• if the processing of personal data is illegal
• if your personal data must be deleted in order to comply with our legal obligations

(E) The right to restriction of processing: you have the right to ask us to use your personal information for restricted purposes only.

(F) The right to data portability: you have the right to ask us to transfer the personal information you have given us to you or to someone else in a format that can be read by computer.

(G) The right to object: you have the right to object to us processing (including profiling) your personal information in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your information for our or a third party’s legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing.

(H) The right in relation to automated decisions: you have the right not to have a decision which produces legal effects which concern you or which has a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorised by law or you have given your permission for this.

The data subject has the opportunity to file a complaint with the relevant supervisory authority for the protection of personal data at any time.

We will respond to your request within 1 month of receiving it. If we receive a large number of requests, or particularly complex requests, the deadline can be extended by a maximum of another two months. In certain circumstances as prescribed by data protection law (i.e. excessive requests), we might refuse to act upon your request.

10. How you can access, modify, delete or object the use of your personal data

To apply for the purpose of exercising the above rights, please fill in the Webform available by clicking here

or contact us at: data.privacy@superbet.com In the event that your personal data is processed on the basis of your consent, you may withdraw your consent at any time by sending an email to the local Superbet Group entity that collects your data or at the email address: data.privacy@superbet.com specifying your request, and which withdrawal will be without affecting the lawfulness of processing on the basis of consent given prior to its withdrawal.

You may withdraw your prior consent to the processing of personal data at any time for the purpose of sending our promotional messages.

11. Treatment of children's personal data

Superbet services and products are not intended for children (that is persons under 18 years). Superbet does not knowingly collect personal data from minors.

By registering to our events and contacting us, you confirm that you are at least 18 years old and are fully able to enter into, comply with and be legally bound by any of our rules. If we are notified or learn that a minor person has submitted personal data to us by any means of communication, we will immediately delete his/her personal data.

12. How to contact us

If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process information about you, please contact us by emailing on data.privacy@superbet.com.

Cookie Policy

1. Introduction

When you use our website, we and third-party companies collect information by using cookies and other technologies such as pixel tags (for simplicity we refer to all such technologies as 'cookies').

Our Cookies Policy explains what cookies are, how we use them, how third-parties we partner with may use cookies, your choices regarding cookies and any other further information you should know about.

2. What are cookies

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser, it allows the Service or a third-party to recognize you, make your next visit easier and the Service more useful to you.

A pixel tag (sometimes called a web beacon) is an invisible image with a line of code which is placed within an email message or on a web page.

3. Information collected via cookies and other technology

The cookies used on our website do not collect directly identifiable personal data such as name, address, email address etc. However, certain cookies may collect information which relate to a unique ID or another identifier which, when combined with other information, allow a profile to be created.

4. Types of cookies

There are different types of cookies which are used to do different things such as letting you navigate between different pages on the website efficiently, remembering preferences you have given, helping us to identify ways to improve your overall site experience, provide you with advertising, etc.

To help you understand the different types of cookies we use on this website and what they do, we have grouped cookies into two categories as described below.

“First party” cookies are cookies stored on your device by us using our website. In this case, that means cookies that our website “published” and stored on your computer the moment you visited this website / accepted or declined cookies on this website.

“Third party” cookies are cookies designed and “published” by our third parties. Our website only uses credible third-party cookies, and we do not allow any third party to use these cookies other than for the purposes listed in this policy.

Please note that we cannot influence or control third-party cookies that are already on your computer at the time of visiting our website, nor do we have the ability to know what information such cookies collect.

To find out more about cookies visit aboutcookies.org, allaboutcookies.org or Network Advertising Initiative: https://thenai.org/

5. How we use cookies?

We use cookies for the following purposes:

• to enable certain functions of the Service
• to provide analytics
• to store your preferences
• to enable advertisements delivery, including behavioral advertising

We have grouped the cookies used on our sites into five categories as set out below:

(A) Necessary/essential cookies

These cookies help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. These cookies don't gather any information about you that could be used for marketing or remembering where you've been on the internet.

As these cookies are necessary for the correct functioning of our website, you are unable to control them.

(B) Preferences/performance cookies

Preference cookies enable our website to remember information that changes the way our website behaves or looks, like your preferred language or the region that you are in.

(C) Statistics/Analytical cookies

Statistic cookies helps us to understand how our visitors interact with our websites by collecting and reporting information anonymously.

(D) Marketing/Advertisement cookies

Marketing cookies are used to track visitors across our website. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

(E) Unclassified cookies

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

6. Third-party cookies

As well the cookies we use, we work with third-party companies who place cookies on your device. Please note that the data they collect may be subject to their own privacy policies.

When working with third-party companies we take steps to protect your data. For example, we place contractual limits on how data collected about people using our services is used and we regularly audit our sites to make sure only cookies we have authorised are being used.

For a list of third parties we use, please see our Cookies List below.

7. How to manage cookies?

Once you have given us your cookie consent, we will store the cookie on your device to be used for your future visits to our website.

Once you have given us your consent to cookies, we will store the cookie on your device, which will be used for your future visits to our website.

On your first visit, you will be able to choose for what types of cookies you give us permission to use, however, if you change your mind later, we will give you the option to opt out or turn on any type of cookie.

Alternatively, you can use your browser settings to manage cookies including deleting cookies previously stored and blocking cookies from being set.

If you'd like to delete or block cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser as you will have to manually erase out cookies through the settings in your internet browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly or you may significantly reduce functionality of individual websites.

The following links may be useful if you are interested in more details regarding cookies management for certain browsers:

• Google Chrome
• Mozilla Firefox
  
• Microsoft Edge
• Android browser
• Opera & Opera Mobile
• Safari & Safari Desktop

8. Cookies List