PRIVACY POLICY

Last updated September 11, 2024

In this Privacy Policy we explain how we process personal data when we provide our services and when you navigate through our website, as well as when you communicate with us by phone, e-mail, social media and otherwise.

This Privacy Policy describes policies and practices regarding our collection and use of Your personal data, as well as sets forth Your privacy rights. We recognise that personal data protection is an ongoing responsibility, and we may from time to time update this Privacy Policy, as we undertake new personal data processing practices.

Please take your time to carefully read this Privacy Policy and, if you have any requests, questions, or suggestions regarding your personal data or any general questions regarding methods of processing and using the services that are provided to you, please contact us at support-en@20bets.com.

1. DEFINITIONS

The following terms are defined as follows in this Privacy Policy:

• We/ Controller - Edjowa -Gaming N.V., registration number: 148723, legal address: Abraham de Veerstraat 1, Curacao, e-mail support-en@20bets.com.
• You –visitors of our Website and the employees, contact persons, board members or authorized persons of our Partners.
• Partner – our Partners, contractors and affiliated parties that provides the Website and platform management services.
• Services- services you offer and provide to Us, in accordance with Terms and Conditions placed on this Website.
• Website – means https://20bets.partners

We may periodically make changes to this Privacy Policy and notify you of these changes by publishing the modified terms on our Website.

We recommend that you review this Privacy Policy regularly.

• ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

We process your data specified in this Privacy Policyon these legal grounds:

• for fulfilment of legal obligations and requirements of legal acts applicable to us (Article 6(1)(c) of the GDPR);
• for pursuing our legitimate interests and those of third parties (Article 6(1)(f) of the GDPR);
• for acting in accordance with your consent (Article 6(1)(a) of the GDPR).

In the scope and under the conditions set by applicable legislation, one or several of the abovementioned legal grounds may apply to processing of the same of your personal data.

Protection our property and legal interests

We process your personal data in order to protect our property and interests and those of our Partners and other persons, collect evidence of, as well as to administer, manage and recover damages inflicted on us and our property.

Website administration, support, improvement

When you visit and browse our Website, for the purpose of collecting statistical data and improving the quality of Services and visitor experience, we process the following data:

Providing customer service – inquiries, requests, complaints

If you contact us in writing (by e-mail or otherwise), we will store the fact of you contacting us and the information provided, including personal data, so that we can properly examine your request and/or respond to your question, request or complaint.

If you contact our customer service centre by phone, we will write down the information you provide, including personal data, so that we can properly examine your request and/or respond to your inquiry.

Registration on the Website and provision of Services by You

You may be asked to provide Personal Data when using our Website, registering an account or providing Services to us, as more detailed described in this Privacy policy.

In order for us to conclude agreements with our Partners and to manage platform we process personal data of our Partners’ employees, contact persons, board members or authorized persons.

When you interact with services, our servers store your unique activity log, which collects certain administrative and traffic information, including.

source IP address

access time

date of access

visited web pages

language used

software crash reports

type of browser used

This information is needed to ensure we provide services of the highest quality.

We never collect personal information about you without your knowledge.

3. MEANS OF GATHERING AND PROCESSING DATA

We may automatically collect certain data, as discussed above, and receive Personal Data about you where you provide such information voluntarily through the services or other communications and interactions on the 20bets site.

We may also receive personal information from online vendors and service providers, and from customer lists lawfully acquired from third-party suppliers.

In addition, we may use the services of third - party service suppliers for technical support of your online transactions and for maintaining your account.

We will have access to any information you provide to such suppliers, service providers, and third - party e - commerce services.We will use the Personal Information in accordance with the provisions of this Privacy Policy.

This information will be disclosed to third parties outside the company only in accordance with this Privacy Policy and the legislation of your state.

4. THE USE OF DATA

We use the personal information that you provide to us when deliver Services,to ensure the necessary security, for the identity verification and checks, to process any of payments, as well as to assist your participation in third - party promotions, that meet certain business conditions, and for any other purposes related to the operation of our affiliate platform.

Therefore, during the provision of Services we may share your personal information with our carefully selected partners (including any other parties that have arrangements with you about the sharing of your data).

Your personal information may also be used by us to provide you with:

• promotional offers and information about our products and services
• promotional offers and information about our partners’ products and services, in order to enlarge the range of products provided to end users.

From time to time, we may request information from you via surveys or competitions. Participation in these surveys or competitions is completely voluntary and you have the choice of whether or not to disclose your personal information.

You may ‘opt out’ of receiving any promotional communications either by choosing to opt out via your account settings available on our sites or through our services in response to a promotional email you receive from us at any time by sending an e-mail.

By taking part in any competition or accepting winnings(prizes) from us, you consent to the use of your name for promotional purposes without additional remuneration, except where prohibited by law.

If you have not unequivocally decided whether to receive promotional information from us, we may use your personal information(including your e - mail address and phone number) to provide you with information regarding our products, services, and promotions, including other gaming products (including online poker, casino, betting, backgammon etc.) and third - party products and services carefully selected by us.

5. CONSENT OF THE PERSONAL DATA SUBJECT

Your provision of the services is your voluntary agreement with our Privacy Policy and you thereby give us the right to collect, process, and store your personal data.

This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable Terms and Conditions published on our platforms and websites.

We may periodically make changes to this Privacy Policy and will notify you of these changes by publishing the modified terms on our platforms and websites.

Your continued provision of the services following any changes to this Privacy Policy constitutes your acceptance of the changes.

The processing of your personal data at 20bets.partners starts only after you have clearly expressed the approval that establishes and confirms freely given, explicit, informed, and unambiguous expression of your consent to the processing of your personal data (hereinafter «Consent»).

The Consent you give us freely, voluntarily and in your interest is explicit, informed, and conscious.

Your consent to the processing of personal data may be given to us by you in any form that allows to confirm that it was received.

In this event the Consent should contain the following information.

• surname, first name, patronymic (if applicable), address of the subject of personal data, number of the main identification document, document issue date and the issuing authority, or surname, first name, patronymic, address of the representative of the personal data subject, the number, issue date, and issuing authority of their main identification document, the requisites of the notarized power of attorney or other document confirming the authority of that representative (upon receipt of the consent from the representative of the personal data subject)
• the postal address of 20bets.partners receiving the consent of the personal data subject
• the purposes of processing the personal data
• a list of the personal data, for the processing of which the consent of the subject of personal data is given
• the name and address of the person (legal entity) that is processing the personal data on behalf of 20bets.partners, if the processing is delegated to such person (entity)
• a list of actions on personal data to which the consent is given; general overview of the personal data processing methods
• the period during which the consent of the subject of personal data is valid, as well as the method of its withdrawal
• the signature of the personal data subject

- BY WAY OF IMPLICATIVE ACTIONS OF a personal data subject which express their will to establish a legal relationship with 20bets.parners, not in the form of an oral or written expression of their will, but by their behavior, from which such intention can be concluded (for example, registration on the 20bets.partners website, execution of monetary transactions into their personal account obtained through registration on the 20bets.partners website, which is a condition for participating in affiliate program in accordance with the Terms and Conditions of 20bets.partners, compliance with the rules established by the advertising rules, etc.).

20bets.partners does not require your Consent to process your personal data in the following cases:

• where the processing of personal data is necessary to achieve the objectives provided for by international treaties or laws of local jurisdictions, for the performance and discharge of the functions, powers, and duties conferred by law;
• where processing of personal data is necessary for the administration of justice, the execution of a court decision or a decision by another legal body or an official subject to execution in accordance with local laws;
• where processing of personal data is necessary to protect the life, health, or other vital interests of the subject of personal data if obtaining their consent is not possible;
• where processing of personal data is necessary for the purposes of exercising the rights and legitimate interests of 20bets.partners or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of your personal data;
• where processing of personal data is carried out for statistical or other research purposes, subject to obligatory anonymization of your personal data, except when personal data is processed for marketing purposes;
• where access to the personal data that is being processed has been provided by you to an unlimited number of persons;
• where personal data that is being processed is subject to publication or mandatory disclosure in accordance with the laws of local jurisdictions.

6. HOW LONG DO WE STORE YOUR PERSONAL DATA?

Personal data specified in this Privacy Policy shall be stored and otherwise processed for no longer than the period specified in this Privacy Policy for each relevant data category and for no longer than necessary to achieve the purposes for which the data were collected.

In those cases when the data storage period is not indicated in this Privacy Policy, your data will be stored no longer than necessary for achievement of the purposes, for which the data were collected, or for a period set by legal acts.

After the end of your data processing and storage period set in this Privacy Policy, we destroy your data or anonymise them irreversibly and reliably as soon as possible, within a period reasonably necessary for performance of such an action.

If different processing or storage periods can be applied to the same data category for different purposes in accordance with this Privacy Policy, the longest of the applicable periods shall apply.

Your personal data can be stored for a period longer than indicated in this Privacy Policy only when:

• your data is necessary for the proper administration of damages (for example, you have caused damage to us or other persons), examination and settlement of a dispute, complaint, the protection of our legitimate interests or those of third parties;
• that is necessary in order that we could defend ourselves from existing or threatening demands, claims or legal actions and exercise our rights;
• there are reasonable suspicions of violations, illegal activities, which are or may be a subject to investigation;
• this is necessary for ensuring the functioning, resilience, integrity of backup copies, information systems, traceability of operations, statistical and other similar purposes;
• there are other grounds provided for in legal acts.

7. INFORMATION DISCLOSURE

We do not disclose your Personal Information to companies, organizations or individuals not associated with 20bets.partners.

Service providers

In order to provide our services, we rely on various service providers (e.g. providers of server hosting, data centres, cloud computing, audit, accounting, legal, tax advisory services, administration of damages, and other services).

Our data processors we use are usually located in the Member States of the European Union or store data entrusted to them by us in the European Union. However, when we manage our social media Accounts, we receive and provide data to social network platform operators (e.g. LinkedIn, Facebook, Instagram), which also operate outside the European Union, e.g. in the USA. We closely follow practices of data protection supervisory authorities and the guidelines on the transfer of data outside the European Union, and we diligently consider conditions, under which data are transferred and may be subsequently processed and stored after the transfer outside the European Union.

Third parties

If necessary and legally justified, we also provide your data to separate data controllers, namely to the competent authorities, institutions, organisations, also other data controllers who are entitled to receive information in line with the applicable legislation and/or our legitimate interests, or based on your consent. Please see below a non-exhaustive list of examples of such situations:

• we have the right and the obligation to transfer information to the competent authorities (pre-trial investigation bodies, etc.) for the purposes of prevention of fraud, offence and crime prevention and investigation;
• we provide data to service providers that are separate controllers of your data (partners whose offers you have agreed to receive, etc.).

We may disclose your Personal Information if required to do so by applicable law, or if we believe in good faith that such actions are necessary to comply with any legal issue or process that concerns us, any of our websites or services or in circumstances where we are essentially bound by legal obligation protect our rights or property protect the personal safety of our service users or the public.

If, in our opinion and sole determination, you are found to have deceived us or attempted to deceive us, or any other service user in any way including but not limited to game tampering

and payment fraud.

If we have grounds to suspect you of payment fraud, including the use of stolen credit cards, or any other fraudulent activity, including any payment reversal or other, payment cancellation, or prohibited transactions, including money laundering, we reserve the right to share this information together with your identity information with other online gaming sites, banks, credit card companies, appropriate regulatory agencies, and relevant law enforcement authorities.

For the purpose of public research on the prevention of addiction, your data can be passed on to the relevant institutions.

8. COOKIES

The registration process cookies will hold information collected during your registration and will allow us to recognize you as a customer and provide you with the services you require. We may also use this data to better understand your online interests and preferences and to constantly enhance your visits to our platforms and use of our services.

Our servers use three different types of cookies.

«Session-based» cookies: This type of cookie is only allocated to your computer for the duration of your visit to our website. A session-based cookie helps you navigate our website faster and, if you are a registered customer, allows us to give you information that is more relevant to you. This cookie automatically expires when you close your browser.

«Persistent» cookies: This type of cookie will remain on your computer for a set period of time for each cookie. Flash cookies are also persistent.

«Analytical» cookies: This type of cookie allows us to recognize and count the number of visitors to our site and see how visitors use our services. This helps us improve the way our sites work, for example, by ensuring you can log in and find what you are looking for easily.

You make a decision and you always have a choice of whether to accept or decline cookies.

Most web browsers automatically accept cookies, but, if you prefer, you can modify your browser settings to keep control over your cookies.

You can use your web browser to.

delete all cookies;

block all cookies;

allow all cookies;

block third-party cookies;

clear all cookies when the browser is closed;

open a "private browsing"/"incognito" session that allows you to browse the Internet without storing data locally;

install add-ons and plug-ins to extend browser options.

For more information please read Cookie policy, placed here https://20bets.partners/cookiepolicy

9. CONSENT TO USE OF ELECTRONIC SERVICE PROVIDERS

In order to make a comission payment to you, you will be required to receive money from us.To facilitate such services we may use third - party electronic payment systems to process the required financial transactions.

By agreeing to and accepting this Privacy Policy, you expressly and voluntarily consent to the transfer to third parties of your personal information which is necessary for the processing and completion of monetary transactions including, when necessary, to the transfer of your personal information outside of your country.

We take steps to ensure that your privacy is protected when using third party payment systems.

10. CONSENT TO SECURITY REVIEWS

We reserve the right to conduct a security review at any time to validate the registration details provided by you and to verify our financial transactions, in order to prevent potential breaches of our Terms and Conditions and of any applicable law.

By participating in our affiliate program and thereby agreeing to our Terms and Conditions, you authorize us to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide during registration of account, including, where necessary, the transfer of your personal information outside your country.

Security reviews may include but are not limited to ordering a credit report and otherwise verifying the information you provide against third - party databases.

11. SECURITY

We understand the importance of providing security and the methods needed to secure the confidentiality, integrity, and accessibility of information.We store all personal information we receive directly from you in an encrypted and password -protected database stored within our secure network behind active up-to-date firewall software.

Our Services support SSL Version 3 with 128-bit encryption.

We also take measures to ensure our subsidiaries, agents, partners, affiliates, and suppliers employ adequate security measures.

However, sending information via the internet is usually not completely secure, and we cannot guarantee the security of your data while it is being sent.

ANY DATA, WHICH YOU SEND, IS SENT AT YOUR OWN RISK.

20bets.partners has all security procedures and features in place to protect your data after it is received.

12. PROTECTION OF MINORS

Our affiliate program are not intended for persons under the age of eighteen (18) or the lawful age in their respective jurisdiction.

Any person who provides their information to us through any part of the registration process confirms to us that they are eighteen (18) years of age (or the lawful age in their respective jurisdiction) or older.

It is our policy to uncover attempts by minors to access our services which may require an additional security review.

If we become aware that a minor has attempted to or has submitted personal information via our platform, we will not accept their information and will take all steps to purge the information from our records.

13. INTERNATIONAL TRANSFERS

Personal Information collected by us may be stored and processed in any country in which we or our affiliates, suppliers, partners or agents provide marketing services and services of our affiliate platform.

By using our affiliate platform, you expressly consent to any transfer of information outside your country (including to countries that may not be considered as having adequate privacy laws).

Nevertheless, we take steps to ensure that our agents, partners, affiliates, and suppliers comply with our standards of privacy and this Privacy Policy regardless of their location.

14. THIRD-PARTY RELATIONSHIPS

We cannot ensure the protection of any information that you provide to a third-party website that links to our services or of any other information collected by any third party managing it in compliance with our affiliate program (if applicable) or otherwise, since these third-party online services and websites are not owned by us and are operated independently from us.

Be careful.

Any information collected by these third parties is governed by the privacy policy, if any, of such third party.

15. LEGAL DISCLAIMER

We are not responsible for events beyond our direct control.

Due to the complex and ever-changing nature of our technologies and business, we provide comprehensive, but we do not guarantee an error-free, operation regarding the confidentiality of your personal information when you visit other websites using links located on our website. Websites that are beyond our control, and especially not covered by this Privacy Policy, should provide you with an opportunity to familiarize yourself with their security policies. If you visit other websites, you should be aware that the operators of these websites can collect your personal information, which they will use in accordance with their privacy policy, which will differ from ours.

We do not guarantee the security of your data, while it is being transmitted through channels of communication.

ANY DATA, WHICH YOU SEND, IS SENT AT YOUR OWN RISK.

We are also not responsible for any direct or indirect damage arising from the unlawful use or theft of your Personal Information.

17. YOUR RIGHTS

You, as a data subject, have certain rights under the GDPR, including the right:

• to request access to your personal data and get a copy thereof;
• to request rectification or restriction of inaccurate or incomplete personal data;
• to request deletion or restriction of personal data which are excessive or unlawfully processed;
• to object to the processing of your personal data;
• to request transfer of your personal data provided in a structured, machine-readable format;
• to withdraw your consent at any time if data processing is based on the data subject’s consent (withdrawal of the data subject’s consent shall not affect lawfulness of data processing before the withdrawal of the consent);

• to file a complaint with the Data State Inspectorate of your country, we would recommend contacting us first and we will try to resolve all your concerns together with you.

How can you contact us to exercise of your rights?

You can submit your request for the exercise of your rights to us in the following ways:

• submitting a request by e-mail at support-en@20bets.com or
• sending a request by post to the address Abraham de Veerstraat 1, Curacao.

17.1. The right to access data processed and the right to obtain a copy of personal data

Should you wish to obtain a copy of your personal data, contact us at support-en@20bets.com.

17.2. Right to rectification of personal data

In case of changes in data presented by you to us in your Application (surname, e-mail address, telephone number, etc), or in case you think that the information processed by us about you is inaccurate or incorrect, you have the right to demand to modify, amend or correct such information.

17.3. Right to withdraw the consent

When we process your data on the basis of your consent, you have the right to withdraw your consent at any time and data processing based on your consent will stop.

You have the right to withdraw consent at any time by e-mail:support-en@20bets.com.

17.4. Right to object to data processing, when processing is based on legitimate interests

You have the right to object to personal data processing, when personal data is processed based on our legitimate interests by e-mail:support-en@20bets.com.

17.5. Right to erasure (right to be forgotten)

When there are certain circumstances indicated in the legislation on personal data protection (e.g. when the basis for data processing has disappeared, etc.), you have the right to request that we erase your personal data. In order to exercise this right, please contact us.

If you provide us with the request to erase all or some of your data and express your wish “to be forgotten”, we will no longer process those data of yours which will no longer be necessary for the purposes for which they were collected or otherwise processed. After you have exercised the right “to be forgotten”, your personal data will be further processed for the following main purposes and on the following main grounds (the list is non-exhaustive):

• for the purposes of meeting accounting, tax requirements, personal data will be further processed according to Article 6(1)(c) of the GDPR (data processing is necessary to fulfil the legal obligation imposed on the data controller);
• in order to manage clients’ complaints and other requests and inquiries, personal data will be processed according to Article 6(1)(b) of the GDPR (it is necessary to process data in order to fulfil the contract, a party to which the data subject is);
• in case of disputes, administration of damages, in order to pursue our other legal claims and protect our rights, data will be further processed according to Article 6(1)(f) of the GDPR (data processing is necessary in pursuance of legitimate interests of the data controller or a third party).

17.6. Right to restriction of data processing

When there are certain circumstances indicated in personal data protection legislation (when personal data is processed unlawfully, when you challenge data accuracy, you stated an objection to data processing on the basis of our legitimate interest, etc.), you also have the right to restrict your data processing.

However, we must point out that, because of the restriction of data processing and during the period of such restriction, we may be unable to guarantee you all the Services.

In order to exercise this right, please contact us.

17.7. Right to data portability

In order to exercise this right, please contact.

17.8. Right to lodge a complaint

If you think that we process your data in breach of requirements of personal data protection legal acts, we always ask that you contact us directly at first. We believe that our good will efforts will be enough to disperse any doubts you may have, to answer your questions, to satisfy requests and correct any errors we made, if any.

If you are not satisfied with a solution we suggest or if, in your opinion, we are not taking actions that must be taken in order to satisfy your request, you will have the right to lodge a complaint with the Data State Inspectorate of your country.

18. HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?

We use appropriate organisational and technical personal data security measures, including protection against unauthorized or unlawful processing of data and against accidental loss, destruction or damage. Such measures have been selected taking into account the risks that may arise for your rights and freedoms as those of a data subject.

We regularly monitor our systems for possible breaches or attacks, but it is not possible to guarantee full security of information transmitted online. With this in mind, you provide us with information by use of the internet connection at your sole discretion and assuming any associated risks.

19. YOU CAN CONTACT US AS FOLLOWS:

• Edjowa -Gaming N.V., Abraham de Veerstraat 1, Curacao
• email: support-en@20bets.com.

You may contact us at any time if you want to find out what of your personal information we collect, process, and store, and also from which sources we have obtained it want to confirm the accuracy of the personal information we have collected about you would like to update your personal information; and/or have any complaint regarding our use of your Personal Information

If required, we will update any information you have provided to us, given that you prove the necessity for such changes and verify your identity.

For the avoidance of doubt, nothing in this Privacy Policy shall allow us to retain your Personal Data if we are required to provide it by the law of your country.