Privacy Policy

Last Updated: 09/05/2024

At, Betty, our aim is to provide you with a fun and entertaining gambling experience, but we take the security and privacy of you and your personal information just as seriously. For your peace of mind, you can find our complete Privacy Policy below. The aim of this policy is to give you better understanding of:    
• What personal information we collect    
• Why we collect it and how we use it    
• How this information is shared    
• The rights you have to your personal data    
• Other privacy and security information    
• Please note, you should read this notice in conjunction with our Terms and Conditions.

 References to “we” “our” and “Betty” all refer to the Excelsior Works and the relevant Data Controller. Applicable Law The applicable Privacy Laws is the General Data Protection Regulation (Regulation (EU) 2016/679), abbreviated GDPR.


Helpful Definitions

“Data Controller” – the entity (Betty in this case) that determines the purpose and means of processing of personal information “Data Processor” – the entities or institutions who process personal information under the agency or instruction of the Data Controller “Personal Information” – any information which is related to an identified or identifiable natural person, including:    
- Relating to race, national or ethnic origin, colour, religion, age, sex, sexual orientation, marital status    
- Relating to the education, medical, psychiatric, psychological, criminal or employment history    
- Any identifying number, symbol or other particular assigned to the individual    
- The personal opinions or views of the individual    
- Correspondence between a person and an institution that is private or confidential in nature (i.e. not already public)    - The individual’s name, where it appears with other personal information relating to the individual, where the disclosure of the name would reveal other personal information about the individual 

“Personal Information Bank” – means a collection of personal information that is organised and capable of being retrieved using an individual’s name or particular assigned to the individual

Data Controller

The data controller for Betty’s services is the licence holder, Excelsior Works Ltd: for any queries about your personal information or privacy, please email the Data Protection Officer at dpo@betty.com or write to Data Protection Officer, Excelsior Works Ltd, 8 Mykinon Street 1065 Nicosia, Cyprus

The personal information we are going to collect

Your personal information will be collected and processed in line with the applicable privacy laws and regulations. All collected data is only used for the purposes outlined in this Security and Privacy Policy. Data that does not serve the respective purposes will not be collected. 1. In accordance with general practice, certain information will be automatically logged in even prior to an individual registering as a player. This personal information will comprise of:    
• Name or network address of the computer.    
• The date and time of connection. 
Technical information, including device type, the Internet protocol (IP) address and Internet service provider (ISP) used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, screen resolution, location, font encoding. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time); products you viewed or searched for; referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, date/time stamp, and/or clickstream data, and any phone number used to call our customer service number. 
2. Personal information that we collect during the registration process and the course of our relationship    • Full legal name.    
• Date of birth.    
• Nationality.    
• Identity reference number (where applicable).    
• Permanent residential address.    
• E-mail address and telephone number.    
• Other identification data, such as passport, identity card, residence permit, driving license, as well as other personal identification data you provide us with.    
• Your password.    
• Customer service records. 

Information regarding any responsible gambling obligations, such as your self-exclusion choices, any limits placed, etc. Financial information necessary for maintaining the gaming account, including, but not limited to number of bank accounts, bank account IBANs, the date and time of the transactions, the amount of the deposits and/or withdrawals, the nature and number of the other payment methods used, monthly income and expenses, financial and credit card information, bank account number, transactions in bank accounts. Any other supporting information and/or documentation requested regarding our legal obligations, including, but not limited to our obligations to combat money laundering and financing of terrorism, and to prevent fraud. 
3. Additional details of your visits to our website, including, but not limited to, the ID, type and location of the devices used, registration and log-in dates, referral source, language settings, geographical location, or information regarding the timing, frequency and pattern of your visits, traffic data, games sessions, weblogs, and other communication data and the resources that you access. This information may be aggregated and may help us gather useful information regarding the use of the website. If such usage information is anonymized (and therefore not identifiable to you as a natural person), then such information is not covered by this Security and Privacy Policy. This information is collected automatically through your use of the website. 
4. Information you submit when responding to our surveys or customer research that we carry out. 
5. We may request information about you from third parties or verify information about you with the assistance of third parties, including but not limited to social media websites and/or platforms that you use to access our services and third-party vendors we use to perform our legal obligations. We do that in accordance with the current data protection regulation, and where it is necessary, we will obtain your prior consent. We may receive information about you:  
  
• In the course of any registration.    
• By seeking information about you, employment position, relevant registers (including registers containing information on income, credit history, debts against third persons, addresses, ID documents, fraud, money-laundering and terrorism financing, and politically exposed persons), agencies, financial institutions, other our group companies, and other third persons, and publicly available sources.    
• By receiving information, you have provided to our business partners when you apply for service.    
• By receiving information from banks, financial and payment institutions regarding your payments to us.    
• From other group companies and business partners with whom we cooperate regarding competitions, promotions, or surveys you participate in.    
• From business partners in technical, payment and delivery services, advertising networks, analytics providers, search information providers when they provide services to us.    
• In any other case when you consented to data disclosure to us.

IP Addresses and Cookies

1. We will collect information about your use of the website, including your IP address, operating system, and browser type, for system administration and reporting purposes. 
2. We may obtain information by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our website and to deliver a better and more personalized service. They enable us to identify you, monitor your usage of the website and to recognize you when you return to it. 
3. Upon accessing our website, we will request your consent to use cookies where you will be able to manage the extent of information we collect via cookies. Alternatively, you may restrict or deactivate cookies in the settings on your browser. However, if you select this setting, you may be unable to access certain parts of our site. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you log on to our website. 
4. Betty’s use of cookies on the Website is required for:    
• Session Management – to enable you to use and navigate properly through the site.    
• Functionality – to remember your preferences and improve your experience.    
• Fraud prevention - the cookies store information which assists us with identifying fraudulent activity.    
• Tracking - to record the way you reached our site and identify the source of this traffic.    
• Statistical analysis - to identify and count the number of users visiting our site, the pages they visit and their actions. Such analysis can help us with improving our site. We will therefore make use of tools which will help us to profile you better. Profiling entails the analysis of information gathered about players and the process of making predictions about players and what is most likely of interest to a subset of players falling within the same profile, based on the mentioned information gathered. This allows us to find the marketing material best suited for our players (if you have consented to this). This is the only form of automated decision making which Betty will resort to.

Purposes for collecting your personal information

The "Purposes" for which we may collect personal data are   
 - Identification (this may also include use of face recognition, voice, fingerprint, or other biometric technologies, as well as online identification systems) and verification of your identity and the provided personal documents and information.    
- Carrying out legally prescribed checks on an ongoing basis.    
- Administrative operation of your account.    
- Providing you adequate service when you have a request or complaint.    
- Personalizing our service.    
- Carry out customer research, surveys, and analyses.    
- Notifying you about any updates to our software and/or services.    
- Notifying you about new promotions or dedicated offers.    
- Fulfilling our legal obligations and regulatory duties.    
- Identifying irregular activity and/or cheating.    
- Identifying and preventing any fraud, money laundering, terrorism financing and other criminal activities.    
- System administration, bug tracking and producing user statistics.    
- Updating and implementing new technologies regarding identification, risk assessments, fraud prevention, anti-money laundering and counter-terrorism financing.    
- Any other lawful use that is relevant to our relationship with you.    
- Legal basis for processing your personal information In accordance with GDPR, Betty shall collect customer personal information based on the following legal basis:    
• To fulfil a contract or for pre-contractual measures – the processing is necessary for the performance of the arrangements made in the agreement (the terms and conditions) of registering on our website.    
• Legal obligation – the processing is necessary in order to comply with a legal obligation incumbent on us.    
• Consent – processing is permitted due to obtaining your unambiguous and explicit consent.    
• Legitimate interest – the processing is necessary for the protection of Betty’s legitimate interests and/or for business or company strategic reasons.

How long do we keep your Personal Data

Your personal information will be kept as long as you have an active player account on our website and/or as long as is required by the applicable privacy regulations.Once you stop being our customer, we will retain your personal information for at least a period of five years post account-closure in compliance with the regulatory requirements and guidelines. We engage in periodic deletion of our players’ records in the cases where the account has been closed for more than five years. Should an existing customer request a right to erasure, the deletion of his data will be possible five years after his request has been received. Additionally, there are different factors, as well as legal obligations, which would need to be taken into consideration prior to determining the specific length of time for which some types of personal information are to be retained. In this regard even after the five-year period elapses, we would need to retain certain information, that include for instance, information related to safer gambling and self-exclusion, and/or other personal information related to regulatory, anti-money laundering obligations, and taxation regulations. We will take all necessary steps to ensure that the privacy of your personal information is maintained for the periods of retention.

Transfer of personal information outside of the EEA

It is sometimes necessary to have your personal information transmitted on an international basis to some of the data processors we work with, which may be based outside of the European Economic Area (EEA). Therefore, by accepting our Terms and Conditions, as well as this Security and Privacy Policy, you acknowledge and agree that your data might be transmitted to authorized processors based outside of the EEA, while we require and ensure that appropriate safeguards are in place. We will only divulge the information if strictly necessary and only to service providers who are bound by rigorous terms and conditions and by the applicable law in the relevant non-EEA jurisdiction. Betty will in any case ensure that appropriate safeguards are applied to transfers of data to such jurisdictions.

Your Privacy Rights Right to access to your information

You have a right to access the personal data we hold in our records. Depending on the Subject Access Request (SAR) you send to us, we will:    
• Confirm that data about you is being processed, and/or   
• Provide you with a copy of your personal data undergoing processing, and/or    
• Provide you with supplementary information, such as information on appropriate safeguards in place when transferring data. We may decide not to comply with your request for information which reveals trade secrets, intellectual property and, in particular, copyright protecting software or if we feel that your request goes beyond your right to request access to information.

Right to be forgotten or Right of Erasure

You may at any time request us to erase all your data. This will, however, obstruct the provision of the promised services. Furthermore, we will only be able to comply with your request following the requirements specified in Section “How long do we keep your Personal Data”. Any such requests should be submitted to support@betty.com

Rectification and erasure

Though we strive to ensure that your data is up to date all the time, there may be situations wherein we fail to do so – for instance, if such information is not provided to us. In that respect, Betty takes no responsibility or liability for the accuracy or correctness of the data provided. Nevertheless, you may, at any time, request us to correct any inaccuracies.

Restriction of processing

You may, at any time, submit a request to restrict the processing of your data.

Right to Data Portability

Upon your request, we shall:    
- Forward to you the personal data which we have received from you, in a structured, commonly used and machine-readable format; and    
-Transmit those to a data controller which you specify, where it is technically feasible for us to do so.

Right to opt out of having your information used for marketing

You have the right to withdraw your consent to have your information used for direct marketing at any time. This may be done by sending an email to our Customer Support Team or by clicking on the ‘unsubscribe’ option provided in each marketing email you receive. If you wish to exercise any of your rights, please send us a written request in accordance with this Security and Privacy Policy. We will endeavor to respond to your request without unreasonable delay and in any event within a period of one month following receipt. If we are unable to respond within the aforementioned period of one month and wish to extend the period, we will notify you accordingly. If we decide that we have a valid reason not to comply with any of your requests which are based on any of the above rights, we will inform you that we will not accede to your request. In such circumstances, as per Article 77 of the General Data Protection (GDPR) (Regulation (EU) 2016/679) you will always be able to lodge a complaint with the The Commissioner for personal data protection in Cyprus, the latter being the supervisory authority to which Betty is subjected to.

Changes to The Security and Privacy Policy

Privacy Policy requirements may need to be changed due to the addition of an existing product or service, or due to changes in law, or change in technology. For material amendments we will notify you in advance by email to the email address specified in your account or through a notice on the Betty home page. When we make material amendments to how we collect, use, or disclose your personal information, we will require you to accept and consent to the amended Security and Privacy Policy prior to accessing Betty.

Liability

Once you agree to the Terms and Conditions, you will therefore be deemed to have read, understood and agreed to the terms of our Security and Privacy Policy. In that way, you agree to waive all rights to holding Betty liable for any claim arising out of or in connection with the processing of your data, unless such data has been fraudulently or negligently processed.