Online Privacy Notice

Last updated in April 2023

1. General information
2. What personal data we collect about you and why?
3. What happens if you do not provide or allow us to use your personal data?
4. Who do we share your personal data with?
5. Where is your personal data stored?
6. How long we keep your personal information for?
7. How we keep your personal data secure?
8. Automated decision making and profiling
9. Your rights
10. Protection of children
11. How to contact us


At Superbet, we take the protection of your privacy and personal data very seriously. We want you to understand how we protect your privacy when we obtain personal data from you, how we use your data, what your rights are in this respect and how we safeguard it while you use our services and products, visit our websites or use their functionalities. For this reason, we are providing you with this Privacy Notice which we kindly ask you to read before you engage with our services and products.  

By using our products and services, you acknowledge that you have read our Privacy Notice and understood that any personal data you provide to us is supplied at your own free will and shall be used in accordance with the purposes described in this Notice. If you do not understand this Privacy Notice, we recommend you do not use our services and products. 

  • Give you additional information about specific processing activities (for example, particular services and products may explain in more detail how or why it processes your data); or
  • Tell you that a different Privacy Notice applies in relation to specific processing activities (for example, some marketing activities have their own separate Privacy Notice in addition to or instead of this Privacy Notice).

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 the changes. 

1. General information

Superbet.com is operated by SB GLOBAL MARKETS LIMITED, with registered address at Level 1 Burlington Complex, Dragonara Road, St. Julians, STJ 3143, Malta, registered under Company Registration Number C 81168 and is a gambling organizer, trading under the brand name Superbet (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 customers for which SUPERBET is a Controller as described under the General Data Protection Regulation 2016/679/EU and any applicable local data protection legislation, as further described in this Privacy Notice. 

2. What personal data we collect about you and why?

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: i) the activities you choose to undertake in relation to the services we provide you and ii) our purposes for processing. Generally, we will collect your personal data in the following manner: 

Directly from you when:

  • you register for a Superbet account and provide requested identification documents;
  • you participate to events, campaigns and quizzes we organize and claim your winnings or prizes;
  • you provide us with your feedback during our customer research interviews or surveys ;
  • you contact us for various purposes (customer support, feedback, questions, or comments through a ‘contact us’ form);

Indirectly from you when:

  • It is generated from your usage of our products and services and your betting patterns;
  • It is generated through different tracking technologies such as cookies, IP address recording, geographical location data.

By law, we must have a lawful reason for processing your personal data. The data we collect about you will only be used for the purposes stated below in this Privacy Notice, to perform our contractual obligation towards you, to comply with our legal obligations and to protect our legitimate interests in specific circumstances.  

Purpose of processing  

Personal data collected and processed  

Legal basis for processing  

Account registration, login and age verification  

Personal identification details such as full name, email address, username, password, CNP, phone number, home address, DOB and PlayerID which is automatically generated upon account creation 

Contractual obligation - T&Cs 

‘Know Your Customer’ checks  

  

  

Personal identification details such as Full name, citizenship, tax residency, postal address, Birth date and place, CNP, ID number, copy of ID, selfies, source of funds & wealth such as bank statements, payslips, purchasing contracts, public information about political affiliations or ties, public information about criminal sanctions, history of financial transaction with Superbet (withdrawals, deposits, etc.). 

Legal Obligation - Anti-Money laundering Legislation   

Data is manifestly made public - Article 9(2)(e) GDPR 

Processing of personal data relating to criminal convictions and offences - Article 10 GDPR 

Responsible Gaming and addiction checks 

Details about account identifiers, browsing time, deposits, withdrawals, use of bonuses, betting pattern, losses, limits on deposits and bets, interactions with Customer support that could imply financial difficulties, addictions, requests for Time-out and/or Self-exclusion 

Legal Obligation – Gambling legislation that are related to prevention of pathological gambling  

Legitimate interest* – prevention of gambling addictions 

Further conditions imposed by Local Laws, including limitations, with regard to the processing of data concerning health – Art 9(4) GDPR 

Self exclusion, time-out 

Details about account identifiers 

Legal obligation - Gambling legislation  

Monitoring of fraudulent activities 

Details about account identifiers, account behavior and device used (such as IP address, geographical location data, device identifiers, device type, screen resolution, operating system and browser type), details of any linked accounts - to the extent such data constitutes Personal Data  

Legitimate interest* - business protection against fraudulent activities 

Monitoring of bonus abusing activities 

Details about account identifiers, usage and interactions with bonuses, free spins, free bets, deposits, withdrawals, placed bets, details of any linked accounts - to the extent such data constitutes Personal Data 

Legitimate interest* - business protection against service abuses 

VIP Scheme 

Details about account identifiers, betting pattern, interaction with Superbet products and services, VIP status, conversations with Account managers 

Legitimate interest* - customer retention and loyalty rewarding 

Anti-match fixing 

Details about account such as name, address (only shared when absolutely necessary), telephone numbers (only shared when absolutely necessary), email addresses (only shared when absolutely necessary), IP data, details of any linked accounts (only shared when absolutely necessary), amount wagered, stake odds, selections, and winning amount, precise time at which the bets in question were made, details regarding how the bets differ from the account behaviour seen to date. 

Legitimate interest* - anti-corruption work designed to detect and report suspicious betting activity 

Personalization through tailored content and games  

Details about account identifiers, customer clicks, betting and winning patterns, behavioral patterns 

Legitimate interest* – improvement of customer engagement with our products and services 

Customer segmentation for awarding of bonuses, free spins, free bets  

Details about account identifiers, DOB, amount of deposits, KYC status, other specific conditions you need to meet for such activities depending on each campaign 

Legitimate interest*- customer incentivization 

Payment of winnings, prizes and benefits and tax deductions   

Personal identification details such as your full name, your bank account and card details, information about placed bets such us the amount bet and amount won  

Contractual obligation  - T&Cs 

Legal obligation – compliance with Gambling Legislation and Tax, Fiscal and Accounting Laws  

Marketing communications (e.g. campaigns, promotions, bonuses, tombolas, prizes etc.) via email, SMS and automated phone calls 

Contact details such as your name, gender, email address, postal address, phone number and geographical location data 

Consent – your agreement to receive marketing communications  

  

Feedback and research interviews  

Information you provide us about your interaction with our products and services when you agree to participate in feedback sessions and opinion surveys; 

Legitimate interest*- product and service improvements  

Customer support through phone, email or online chat and chatbot 

Information you decide to provide in your communications to us  

Contractual obligation – T&Cs 

Legitimate interest* - offer support in relation to the use of our services and products  

Administrative communications (e.g. when you sign up for, or unsubscribe from a specific registration or activity; when we send you service-related announcements, such as updates to our Privacy Notice or other policies)  

Contact details such as name, e-mail address, postal address, phone number  

Contractual obligation - T&Cs 

  

Website security, functionality, personalization and analytics  

Information about your device and cookies** when you visit our website  

Legitimate interest* - website functionality  

Consent   

Business administration activities  

Personal identification details such as your name, date of birth, social security number, home and postal address  

Legitimate interest* - Business administration activities  

  

  

*Where we rely on legitimate interest as a ground for processing your personal data, we always carry out an assessment to ensure that your fundamental rights, interests and freedoms are not outweighed by our legitimate interests. You have the right to object at any time and we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.  

** When you visit our website, we will process your data collected through cookies. 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 details about the device used, geographical location data, journal information like IP, searches, browser, browser’s language, hardware settings, date and time of the request, method used to send requests to the server, file capacity obtained in response, and other parameters regarding the user’s operating system, which, when combined with other information, it becomes personal data and can indirectly identify you. For more information on what are cookies are and how we use them, including on how you can consent to their use, please read our Cookie Policy available here:  https://superbet.com/wiki/cookie-policy.  

Once collected, we shall at all times ensure that any processing of 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. 

3. 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 a legal obligation for us (for example, if refuse to provide us with your personal numerical code, we cannot grant you winnings, after accepting our services / products). You may also not be eligible to participate in certain activities or events if you do not provide us with the minimum required information (for example, if you refuse to share your contact information, you may not participate in a promotional activity because we could not contact you to give you the winnings). 

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. 

4. Who do we share your personal data with?

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. In certain circumstances described below, we will share a minimum amount of personal data as follows: 

Other companies of Superbet Group for the purpose of internal assistance, administrative matters and daily activities in line with this Privacy Notice. In situations where we share your data for other purposes than those mentioned above, we will always ask for your consent.  

Service providers authorized to process personal data who are acting as our contractors, for the purpose of managing our activities, such as:  

Service providers that offer technical support to our IT infrastructure, analytics, hosting providers, etc.; 

Gaming providers that offer gaming services; 

Companies who provide services such as SMS mass delivery, mass transmission of e-mails and automated phone calls for the purposes of marketing communications; 

Companies that support us in our marketing activities on the Internet and on social media platforms. 

Third party data controllers who assist us in secure payment processing, prevention of fraud, misuse of services and money laundering.  

Sports organizations (Superbet takes reasonable steps to ensure accurate and fair coverage of sports 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.) 

Based on legal obligations. In this regard, please note that there may be legal obligations on our part to share your personal data with local authorities (such as tax authorities, the National Gambling Office, the police, the courts) if required by applicable laws. We may also share your personal data in good faith in order to protect, secure or prevent the loss of our rights or in the legitimate interests of Superbet, its customers or the general public, or to respond to complaints from others. 

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. 

Based on consent in cases where your personal data is transferred to any other third party where you have consented or requested that we do so. 

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

5. Where is your personal data stored?

Your personal data will be kept, processed and stored by us and our service providers in the following territories: the EEA (European Economic Area) and the USA. 

Each of our service providers who process and store your personal data have an obligation to keep it protected and secured, in accordance with applicable industry standards and whether less stringent legal provisions apply in their jurisdiction. 

Where such recipients of data are located in third countries for which the European Commission has not issued an adequacy decision, Superbet has in place contractual relationships with each such recipient that include standard contractual clauses as approved by the European Commission or other supervisory authority where required, intended to ensure an adequate level of protection and will always conduct rigorous due diligence to ensure there are no risks to such transfers. A copy of the standard contractual clauses used by Superbet can be found at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj

6. How long we keep your personal information for?

Your personal data will only be stored for a necessary and strict period of time of maximum 5 years in accordance with the purpose for which it is collected and applicable laws or regulatory requirements (e.g. National Gambling Legislation, Anti Money Laundering Legislation, etc.). Generally, this means we will keep your personal data until the end of the interaction with you, after we have paid your winnings and fulfilled our obligations to you, plus a reasonable period of time after that where necessary to deal with legal, tax, accounting or administrative matters and to respond to any inquiries, complaints or legal claims.  

Upon expiration of the applicable deadlines, your personal data will be securely 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 Section 9 – Your rights.  

7. How we keep your personal data secure?

Superbet has implemented all necessary state of the art and industry standard 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. 

Despite the security measures mentioned above, we want you to know that IT and the internet are not perfectly secure mediums and there will always be the chance that your personal data could potentially be subject to unauthorized acts by third parties. Although we take reasonable steps and employ appropriate security measures to safeguard your personal data, no method of transmitting or storing data is completely secure.  

8. Automated decision making and profiling

In certain situations, we may perform certain automated profiling activities such as to analyse, predict or evaluate aspects concerning the characteristics of your behaviour and betting pattern on our platform, using special automated programs, in order to better understand the way you interact with our products and services in accordance with our legitimate interests and legal obligations applicable to us.  

The reason we do this, is because we want to: 

enhance and personalize your interaction with us and to award you with bonuses, free spins, free bets or other benefits based on predefined criteria; 

detect players that are struggling or have issues with gambling as part of our Responsible Gaming activities; 

protect our business against fraudulent activities and service abuse. 

In any case, we want you to understand that we do not make decisions about you through solely automated means that could produce legal or similarly significant effects on you. We ensure our staff are always involved in such profiling through automated means to protect your privacy and your rights in accordance with the law.   

You have the right to object to such profiling in situations where we rely on legitimate interest as a ground for processing your personal data. If you choose to exercise this right, we will assess the situation and, unless, we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, we will no longer process your personal data for this reason.  

9. Your rights

At any given time, you will have the following rights regarding your personal data processed by us. Please note, other than your right to object to us using your information for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute in case of other applicable laws.  

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. 

The right of access: you have the right to make a request for details of your personal data and a copy of that personal data. 

The right of rectification: you have the right to have inaccurate data about you corrected or removed without undue delay.  

The right of erasure ("right to be forgotten"): you have the right to have certain personal data about you deleted from our records. If your requests to delete your personal data violate our legal or regulatory obligations, or the data related to the request for deletion are necessary to exercise or defense our legal claims, we may not be able to act upon your request and we will notify you of this decision. 

The right to restriction of processing: you have the right to ask us to restrict the use of your personal data. 

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

The right to object: you have the right to object to us processing (including profiling) your personal data 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 data 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. 

The right in relation to automated decisions: you have the right to not be subject of 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. 

In order to exercise any of the above rights, you can send us an email to support@superbet.com. Your request will be reviewed and answered within one calendar month from receipt, in accordance with the GDPR. 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. 

As a rule, you can exercise your rights for free. However, we reserve the right to charge a reasonable fee if your requests are manifestly unfounded or excessive, in particular because of their repetitive nature.  

We pay the utmost attention to the confidentiality of all personal data and reserve the right to verify your identity if you submit a request for personal data to avoid a potentially undesirable situation for another person to illegally exercise a right on your behalf.  

In the event your personal data is processed based on your consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent before its withdrawal. 

You also have the opportunity to lodge a complaint with the relevant Data Protection Authorities for the protection of personal data or any competent court to defend the rights guaranteed by the applicable legislation at any time in particular in the Member State of your habitual residence, place of work or place of an alleged infringement. You can find a list of data protection authorities in each respective EU state here: https://edpb.europa.eu/about-edpb/board/members_en.  

10. Protection of children

Superbet services and products are not intended for children (that is persons under 18 years).  Superbet does not knowingly collect personal data from minors. You must be over 18 years old to benefit from the services and products of and engage in communications with Superbet.  

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 terms and conditions made available to you and this Privacy Statement. 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 their personal data. 

11. 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 our Data Protection Officer by emailing data.privacy@superbet.com.