BetRebels is a brand of the Rebels Gaming Ltd. Group (the "Group"). At BetRebels, we respect your privacy and are committed to protecting your personal information. We have created this Privacy Policy to let you know what information we collect when you use services at the online site at BetRebels and the Group companies (collectively, the "Service"), why we collect this information and how we use the collected information. This Privacy Policy describes the way in which BetRebels processes personal data and informs players about their rights. Personal data means any information relating to an identified or identifiable individual. The processing of players' data complies with all applicable data protection regulations including the European General Data Protection Regulation. By accepting this Privacy Policy, the player (hereinafter referred to as a neutral term and applicable to both sexes) confirms his consent to the use of his personal data as set out in this Privacy Policy.

We may periodically make changes to this Privacy Policy of which we will notify you by posting the modified terms on the website and we advise you to revisit this Privacy Policy regularly.

The data controller of BetRebels is Rebels Gaming Ltd, 177A St. Moritz, Tower Road, Sliema SLM 1603, Malta, Registration Number C51793.

For any privacy issues or for further information on BetRebels data processing activities please contact the data protection officer of Rebels Gaming Ltd:

Rebels Gaming Ltd. 177A St. Moritz, Tower Road, Sliema SLM 1603, Malta, e-mail privacy@betrebels.com Fax +356 27040187

There are various ways you can contact us.

For general queries do not hesitate to get in touch with our Customer Service team via phone, email or live chat - please see our Contact us page.

If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at privacy@betrebels.com

We collect personal information when you interact with us and use our services. Sometimes, this information is provided to us by you – like when you register for the first time and when you make use of our products or get in touch with us. Sometimes third parties or publicly available sources provide us information about you.

Information you provide to us

At registration

• Your personal details, such as your name, email address, postal address, telephone or mobile number, gender or date of birth;
• Photographic identification and proof of address documents (to carry out due diligence)
• Banking and financial details (to establish the source of funds where a transaction is involved)
• Your account login details, such as your username and password

Through your use of BetRebels services

• Information about how you interact with our products
• Information about your online browsing behaviour on BetRebels websites, mobile apps, and other BetRebels content online;
• Information about any devices you have used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier)
• Recording phone calls – we may monitor or record phone calls with you. We might do this to check that we have carried out your instructions correctly; to resolve queries or issues; for regulatory purposes; to help improve our quality of service; to help us train our staff; or to help detect or prevent fraud or other crimes.

Other sources of personal data

• Where we provide personalised services, we may use third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation.
• Data received from our business partners and from other organisations, such as specialist companies providing verification services, credit reference agencies, and fraud prevention agencies.
• Publicly available sources, like postcode lookup.

Information about third parties

If you give us personal information about someone else (for example via a Refer a Friend scheme) then you should not do so without their permission. Where information is provided by you about someone else, or someone else discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this Privacy Policy. This list of personal data types collected by BetRebels is not exhaustive and further information may be requested from you when BetRebels considers it fair and necessary to do so.

Special categories of data

Personal data collected by BetRebels may include so called “special categories of data”, such as data revealing health (responsible gambling related).

We have in place additional measures to protect your sensitive personal data and its confidentiality.

Website Analytics

BetRebels uses website analytics tools for the purpose of understanding the player’s behaviour on the BetRebels websites and therefore optimise the services provided by BetRebels. Website analytics tools collect data by using cookies and IP address tracking for that purpose. For further information on the use of cookies on the BetRebels websites, please refer to section 10 of this page. The following website analytics tools are integrated to the websites of BetRebels:

Google Analytics (IP addresses collected by Google analytics will solely be transmitted anonymised)

Additional Data collected when using BetRebels Services

Profiles

BetRebels processes information that is collected by cookies, logfiles, clear gifs, and/or by third parties' support in order to create player profiles. A profile contains information on individual players including preferences concerning the activities of the player. This information is related to the players' personal and identifiable data and used to provide and improve our services to the benefit of the player. Profiles are also used to design each player's experience on the BetRebels website individually and to provide specific marketing information.

Logfiles

BetRebels uses logfiles. These include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyze trends for administration of the site, to track players' movements on the site, and to gather usable comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.

The collection of such data is required for us to provide our services to the player. It is also necessary to protect our customers and ourselves from crime and to comply with legal obligations. It is also in our legitimate interest to improve and promote our services.

Communication with Players

BetRebels stores communication with players including requests for information or customer support. This applies to communication via email, the website or other means of communication including telephone. Telephone calls are recorded for training and security purposes.

The collection of the player’s personal data is required for us to provide our services to the player and to comply with legal obligations. It may also be necessary for enforcing our contractual agreements and therefore in our legitimate interest.

We recognise the trust and confidence our customers place in us as a service provider. In return, BetRebels is open about why we collect your data. First and foremost, collecting your information is essential for providing you the services and products you want. In addition, your data is used to personalise and improve your experience using our services, and to contact you from time to time with important information. In some cases, we need to collect and use your information to comply with the law. Under data protection laws, we also need to identify a specified lawful basis upon which we are processing your personal information. We rely on different bases for different processing activities.

a) Under the contract - when it is necessary for the performance of a contract to which you are a party. Our T&Cs, which you have accepted at registration, set out the terms of the contract and the services we will provide:

to make our services available to you as part of our contract

• To provide gaming and betting services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
• For "service administration purposes", such as password reminders, service messages, such as site maintenance, updates to our Privacy and Cookies Policy or Terms of Use, to let you know if your BetRebels account has become dormant and to ask if you would like to use it again before we close it;
• To assess betting risk - when you make a bet, an automated system may be used to assess the risk connected to your bet, in accordance with our Betting Rules. It is a system widely used by the betting operators to help make fair and informed decisions on betting.
• To process your transactions;

b) Under legitimate interests - It is necessary to process your data for the purposes set out below, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine if we can process your data on this basis, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.

To personalise your experience

• To offer a more relevant, tailored service; for instance, we could use your playing history to provide personalised recommendations and products;
• If you are signed-in or subscribed to our marketing offers, you will receive a personalised service. If you don’t want to receive these services you can unsubscribe from marketing offers from your BetRebels account, or by sending an email to privacy@betrebels.com

To improve our services and products

• To provide you with the most user-friendly online navigation experience;
• For analysis and research purposes so that we may improve the services offered by BetRebels;
• Testing new systems and checking upgrades to existing systems;
• Evaluating the effectiveness of marketing and for market research and training;
• Customer modelling, statistical and trend analysis, with the aim of developing and improving products and services.

To contact and interact with you

• Contact you about our services, for example by phone, email or post or social media;
• Manage promotions and competitions you choose to enter;
• Invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by BetRebels and by other organisations on our behalf (We carry out market research to improve our services, however, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice and this will not affect your ability to use our services);
• Respond to your queries and complaints.

To make your game safer and more enjoyable

• To deter, prevent or detect the use of third party software in peer-to-peer gambling;
• To deter, prevent, or detect any activities conducted in breach of the BetRebels T&Cs.

c) Under the legal obligation - when it is necessary in order to comply with mandatory legal obligations to which we are subject under EU or local laws:

• To determine where you are accessing the services from to redirect you to the correct country site, in accordance with our license conditions;
• To make sure we offer our services to eligible persons;
• Crime detection, prevention, and prosecution;
• To verify your identity and establish the source of funding in any transaction;
• To carry out appropriate anti-fraud checks (by conducting online searches using a third party identity provider). Please note that this will not affect your credit rating;
• To assess and manage any potential risks and prevent problem gambling.

d) Marketing Activities and Market research

We will send you relevant offers and news about our products and services in a number of ways including by email, sms, phone call, post, social media targeted advertising, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices online from your BetRebels account or by sending an email at privacy@betrebels.com.

Whenever a player has not consented to the use of his personal data for marketing purposes we process personal data for marketing purposes only as necessary for the purpose of our legitimate interests in promoting our services.

We also like to hear your views to help us to improve our services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

e) Special categories of data

We will only process such data if:

• You have given us your explicit consent;
• It is necessary for the purposes of carrying out the obligations and exercising specific rights of BetRebels or of the data subject in the field of employment and social security and social protection law;
• It relates to personal data which you have made public;
• It is necessary for the establishment, exercise or defence of legal claims;
• Is necessary for reasons of substantial public interest, on the basis of European Union or Member State law.

General Information

Player’s personal data is treated as strictly confidential.

Personal player data may be disclosed to third parties

• if the player has given consent with such disclosure,
• the disclosure is necessary for compliance with legal obligations to which BetRebels is subject, or
• when the disclosure is necessary for the purposes of the legitimate interests pursued by BetRebels or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the player.

BetRebels only transfers data to states outside of the EU/EEA provided the recipient guaranties a standard of data protection comparable to European standards (e.g. by agreeing to approved contractual clauses, intragroup agreements or other measures designed to ensure that the recipients of personal data protect them).

In the following it is described how BetRebels shares personal data.

Sharing of personal data within the Rebels Gaming Group

Personal data may be transferred or disclosed to any company within the Rebels Gaming Group and their related companies.

Sharing of personal data with Service Providers

On a case-by-case basis, BetRebels makes use of trusted third parties to process players’ personal data including but not limited to payment services, information technology, customer support, sales, marketing. Pursuant to applicable data protection regulations including the General Data Protection Regulation these third parties are contractually obliged to treat players' data securely and confidentially. Their use of the said data is restricted to the extent required to fulfil the respective task.

Sharing of personal data for KYC, the Prevention of Fraud and Money Laundering

In order to complete players' identity verification, to carry out security checks, to assess players’ compliance with our Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and the protection of minors, player data may be matched against third party databases.

Upon any indication of transactions and/or activities that may raise suspicions of criminal activities, BetRebels will report to the relevant parties in charge (e.g. police, sporting associations, private associations aiming at the prevention of criminal and fraudulent activities in sports betting and/or games of chance).

In this context, data on players’ activities and personal data may also be transferred in the framework of an early warning system to the European Sports Security Association (ESSA) and the respective sports federations.

Furthermore, BetRebels reserves the right to record telephone calls with players and forward recordings to law enforcement agencies if there is precise evidence of criminal offences.

With the acceptance of the General Terms and Conditions and this Data Protection Policy, the player grants his explicit consent to these procedures including requests for credit information and the matching of data provided against databases of third parties.

The sharing of players’ data also is necessary to protect players and ourselves from crime and to comply with legal obligations.

Sharing of anonymized Data

BetRebels commitment to the protection of personal data notwithstanding, the company reserves the right to publish gaming data (e.g. achieved results), the player's first name, the initial of the surname as well as the player's country of residence on the BetRebels website as long as the player remains, directly and indirectly, unidentifiable.

Sharing of personal data for other purposes

It may be necessary to share personal data for additional purposes. However, BetRebels will only disclose personal data if and to the extent that one or more conditions set out in Sec. 7 a. are met.

Certain Excluded Disclosures

We may disclose your Personal Information if required to do so by law, or if we believe in good faith that such action is necessary to: (1) comply with any legal process served on us, the BetRebels website or the Service; (2) protect and defend our rights or property; or (3) act to protect the personal safety of users of the Service or the public. If, in our sole determination, you are found to have cheated or attempted to defraud BetRebels or any other user of the Service in any way including but not limited to game manipulation or payment fraud, or if we suspect you of fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), we reserve the right to share this information (together with your identity) with other online gaming sites, banks, credit card companies, and appropriate agencies.

You may "opt out" of receiving any promotional communications either by choosing to opt out where such option is made available on the BetRebels website or the Service or in an email you receive from us, or at any time by sending an email to privacy@betrebels.com. In addition you may contact us at the just mentioned addresses if you: 1). want to confirm the accuracy of the Personal Information we have collected about you; 2). would like to update your Personal Information or delete your Personal Information; and/or 3) have any complaint regarding our use of your Personal Information. If requested, we will change any information you have provided to us or mark any information to prohibit future use, provided that you provide evidence as we may reasonably require for such changes.

We will only retain your information for as long as is reasonably necessary to carry out the purposes outlined above and to satisfy our legal obligations. While you are a customer, we will usually need to retain your information to meet our legal and contractual requirements. However, when you cease using BetRebels services, we will normally still retain your personal information for a period of time.

Typically, we will store your personal information for a period of ten years after you cease being a customer of BetRebels, beginning at the date your account is closed. There are several reasons which we retain your information, these include:

• To comply with legal obligations under EU/local laws (for example, anti-money laundering regulations, or licensing regulations);
• To establish or defend legal claims (for example negligence claims) which could be made against us.

Cookies are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. We use cookies to track use of the BetRebels site. We also may use cookies to monitor traffic to the site, improve the Service and make it easier and/or more relevant for your use. You have the ability to accept or decline cookies. Most online browsers automatically accept cookies, but if you prefer you can usually modify your browser setting to decline cookies. If you choose to decline cookies, you may not be able to fully experience the interactive features of the BetRebels online sites. Further information about cookies, including instructions on how to disable them, is contained in our Cookie Policy.

In order to play Real Money games on the Service, you will be required to send money to and receive money from us. We may use third party electronic payment processors and/or financial institutions ("ESPs") to process such financial transactions. By accepting this Privacy Policy, you consent to Personal Information necessary for the processing of transactions being shared with ESPs, including where necessary the transfer of information outside of your country. We take steps to ensure that our arrangements with ESPs protect your privacy.

We reserve the right to conduct a security review at any time to validate your identity, age, and registration data provided by you and to verify your use of the Service and your financial transactions for potential breach of our Terms and Conditions and of applicable law. By accepting this Privacy Policy, you authorise us, our staff, affiliates, subsidiaries, agents and suppliers to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide to us in the course of using the Services, including where necessary the transfer of information outside of your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third party databases. In addition, to facilitate these security reviews, you agree to provide such information or documentation as we may request.!

We understand the importance of information security and the techniques needed to secure information. We store all of the Personal Information we receive directly from you in a password-protected database residing within our secure network behind active state-of-the-art firewall software. We take steps to ensure our subsidiaries, agents affiliates and suppliers also employ adequate levels of security.

The Service is not intended for or directed to persons under the age of 18. Any person who provides their information to us through any part of the Service represents to us that they are 18 years of age or older. It is our policy to endorse the Children's Online Privacy Protection Act of 1998 and to use our best efforts to comply with that Act. This may involve us having to access and verify your Personal Information. If we become aware that a minor has attempted to or has submitted personal information via the online site, we will not accept this information and will take steps to remove such information from our records.

Personal Information collected on the Service may be stored and processed in any country in which we or our affiliates, suppliers, subsidiaries or agents maintain facilities, and by using the Service, you consent to any transfer of information outside of your country (including to third countries which may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our affiliates, agents, subsidiaries and suppliers comply with our standards of privacy regardless of their location.

We cannot ensure the protection of any information or images that you provide to a third-party online site that links to or from the BetRebels website or any information collected by any third party administering our affiliate program or any other program, since these third-party online sites are owned and operated independently of us. Any information collected by these third parties is not governed by this Privacy Policy but by the privacy policy, if any, of such third party. If you have questions about a third party's information practices, please read its privacy policy. We assume no responsibility or liability whatsoever for the practices, actions or policies of such third parties, and are not responsible for the content or privacy practices of such online sites.

The Service operates "as is" and "as available," without liability of any kind. We are not responsible for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee nor do we represent that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of Personal Information.

If we should ever file for bankruptcy or be acquired by a third party, merge with a third party, sell all or part of our assets, or otherwise transfer substantially all of our relevant assets to a third party, we are entitled to share the Personal Information and all other information you have provided through the Service to potential and subsequent business and merger partners.

The player has the right to:

• request access to personal data
• request correction of personal data
• withdraw the consent to the processing of data (e.g. for marketing activities)
• request erasure of personal data
• receive data in a structured, commonly used and machine-readable format (data portability)
• request the restriction of processing personal data
• to object to the processing of personal data.

Some of these rights may only apply under certain circumstances as set forth in data protection legislation including the General Data Protection Regulation.

All requests related to personal data or any rights mentioned above may be addressed to the contact details mentioned in Sec. 3 above.

If the player is not satisfied with how we handle your personal data, the player is entitled to file a complaint to the competent data protection authority.

By clicking "Yes" during the registration process or by your continued use of the Service following the posting of this Privacy policy (as applicable) you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable terms posted on our online sites. We may periodically make changes to this Privacy Policy that we will notify to you by way of posting the modified terms on the online sites and we advise you to revisit the Privacy Policy regularly.

Version 1.2 – last update on 17/05/2018