1. GENERAL

1.1 TV Global Enterprises Limited (hereinafter ‘We’ and/or the ‘Company’) is committed to complying with General European Data Protection regulations, including, but not limited, national legislation related with data protection, for the purposes of this Policy.

1.2 This Privacy and Cookies Policy, hereinafter referred to as the ‘Policy’, provides information on how and why your personal information will be collected by us.

1.3 Personal data/information is defined as any information relating to an identified or identifiable natural person which includes data such as a name, surname, date of birth, residing address, IP address, an email address or a telephone number, ID documentation, financial documents as utility bill or bank statements and etc., hereinafter referred to as the ‘Personal Data’ or ‘Your Information’. Processing activities include, among others, the collection, use, retention and disclosure of such data.

1.4 Your personal data will be processed by us (including any of our agents and/or employees), and (where appropriate) any other company in our company Group and/or our partners and subcontractors, in accordance with this Policy.

1.5 When we are collecting, processing and retaining your personal information, us or our affiliates will be acting act as a data controller.

1.6 By continuing to use our services after publication of this Privacy Policy, You agree to the terms of this Privacy Policy and to the use of your personal information in accordance with these terms. This Policy applies to this website, mobile, tablet and any other of our platforms.

1.7 We are reserving the right to change this Policy including altering the purposes for which it processes your personal information. Any changes will be published on our website. We, therefore, recommend that you check the Privacy Policy frequently for updates. Moreover, by continuing to use the Website, You agree to be bound by this Policy as well as by the latest modifications to it. If you do not agree to be bound by the changes to this Policy, then you shall have no right to use or access our Services.

1.8 Protecting the Privacy of Children, TV Global Enterprises Limited does not market to children under the age of 18. Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else. If you are under 18, please do not visit Betcris.com.

2. THE COLLECTION, PROCESSING AND USE OF DATA

We may collect and process the following data about you:

2.1 Registration/Login

By registering as account holder and user of our services (or by completing the registration form), the information provided shall be used for the identification of the user and for account management by Us.; This information may include, but not limited to the following information: your name, surname, date of birth, email address, residing address, phone, details, occupation, business, profession, or trade, IP-address, device, utility bills, bank statements, and any other mandatory details as might be requested from you for the purpose of registration and/or continued use of the service. The said data is processed in order for the Company to perform its contractual obligation with its users and also pursuant to the legitimate interests of the Company.

2.2 Live Chat/Support/Contact Form

We monitor and/or record your conversations with us and retain the recordings for such periods as may be necessary to handle your inquiries, or as may be required by law and/or in the best interest of the Company.

2.3 Payment Processing

Any provided account, credit card or other information regarding payment transactions will be collected and may be transmitted to the payment service provider, in order to fulfill the payment, requested by the user. Additional terms and conditions of the payment providers may apply, which should be available in the transaction process.

2.4 Identification Documentation

We collect and store uploaded documents, in order to identify customers, to process your requests and/or to comply with effective laws and regulations. These documents are also used for the purpose of prevention and detection of fraud, prevention of money-laundering and terrorist funding and ensuring responsible gambling.

2.5 Newsletters

Should you have provided your contact details to the Company to receive marketing material, we shall process your data in order to send you any news which might be of interest to you. If you want to unsubscribe from receiving the said newsletter, you are kindly requested to change the setting at the personal settings of your account or use the unsubscribe functionality in any marketing material. The said contact details are lawfully processed by the Company on the basis of your consent.

2.6 Player Behavior

We also process information for the prevention of money laundering and/or funding of terrorism, the prevention of fraud, ensuring responsible gambling, improvement of quality of service and customer recommendations, if the Player’s behavior and information let us draw to this conclusion. We process such data on the basis of a legal obligation, legitimate interest, and consent.

2.7 Confidential

Your personal data will be treated as strictly confidential. We shall only retain your personal information for the length of time necessary for the intended purpose of data collection or for as long as we are legally required.

2.8 Use

As outlined above, We shall only collect and use the personal data if one of the following purposes exist.

You have given us consent for the processing of your personal data for one or more specific purposes:

• Processing is necessary for the performance of the agreement between the Company and yourself or in order to take steps at your request prior to entering into a contract.
• Processing is necessary for compliance with a legal obligation to which We are subject.
• Processing is necessary in order to protect your vital interests or of another natural person.
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• Processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by Your interests or fundamental rights and freedoms which require protection of personal data.

3. SHARING YOUR INFORMATION

3.1 Third-party services

We may share personal data with other third-party providers when you request a service, which we offer partly or fully through the third-party provider. Third-party providers have a contractual relationship with us. We took precautions to ensure that these third-party providers have the same privacy standards and we only transfer data to states outside the European Economic Area, provided the recipient guarantees a standard of data protection comparable to that in place in Europe.

One of said third party providers we use to perform due diligence checks on new and existing customers is TransUnion, and you can find information regarding their Privacy Notice at
https://www.transunion.co.uk/legal-information/bureau-privacy-notice.

3.2 Fraud

1. Identification
   We reserve the right to carry out security checks at any time to validate your identity. Security checks can include, but are not limited to, age, registration data, financial transactions, credit information and/or other forms of confirmation of your data from third-party databases. To facilitate such security checks, you also agree to provide us with any and all additional information and documents that we may request. This is necessary specially to control a possible breach of our General Terms and Conditions and/or applicable legislation.
   By agreeing to our General Terms and Conditions and our Privacy Policy, you authorize us and our employees, representatives and suppliers to use your personal information. We may obtain information about you from third parties for the purposes of our compliance with anti-money laundering, anti-fraud and customer due diligence checks, such as credit reference agencies and fraud prevention agencies.
2. Regulatory and Enforcement Authorities
   In fulfillment of the Company’s compliance with its legal obligations, we may be required to transfer your registration details, identification documentation, financial transactions, gaming transactions, general information about your account held with the Company to regulatory and enforcement authorities within the European Union/EEA, and other countries we operate in. The said disclosure shall also include any disclosure to the Financial Intelligence Authorities in accordance with our legal obligation in terms of Directive 2015/849 of the European Parliament and of the Council, as this may be amended from time to time.
3. Gaming and Data Platform Providers
   In order for the Company to provide its services, it makes use of a Gaming Platform Providers and a Data Platform Providers.
4. Match-fixing
   We are engaged into the integrity of sports, thereof your Personal Data may be disclosed to any regulatory or sporting body in connection with policing the integrity or enforcing the rules of a sport or game and/or prevention and detection of crime and with whom the Group has agreements from time to time for the sharing of such data, and where the Group considers that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant sport or game. Those bodies may then use your Personal Data to investigate and act on any such breaches in accordance with their procedures. The information we receive from them will serve as a basis for our decision.
   The Provider that the Company uses in this respect is the following: 1. Sportradar AG, Feldliststrasse 2, 9000 St. Gallen, Switzerland.
5. Customer Care
   In order for the Company to provide support services to You, we use a third party provider as a tool for customer care. This said tool allows us to have in place live chat support for you.
6. Marketing
   In order for the Company to provide information that is of interest to you, we use third party providers to assist us with the provision of our marketing practices. This would only apply if you are subscribed to receiving the Company’s newsletter, as per clause 2.5 above.

4. EXTERNAL CONTENT & COOKIES

4.1 External Content & JavaScript

While our services may contain links to websites and applications operated by parties other than us (for example the MGA’s website, responsible gaming etc.), We (and/or any other company in our company Group) are not responsible for the privacy practices or content of any such websites or applications.

In addition, we use active JavaScript contents from external providers on our websites. When you access our site, these external providers may receive personal information relating to your visit to our websites.

By installing a JavaScript blocker such as the browser plugin ‘NoScript’ (www.noscript.net) or by disabling JavaScript in your browser, you can prevent it. Please note that if you do so, you may not be able to use the full functionality of the websites you visit. Also, note that we cannot accept any responsibility for external content.

4.2 Plug-ins

For the functionality of our websites or services, we may use plugins and active script contents (including JavaScript) from third-party providers. We reserve the right to use additional plugins and active script contents at any time.

1. Tracking by cookies
   This website uses tracking tools, such as Google Analytics, Hotjar, Google Optimize, Google Tag Manager, Facebook pixel, among others. These tracking tools use various techniques, including so-called ‘cookies’, which are text files placed on your computer to help the website analyze how users use the site. The information obtained by the tracking tools about your use of the website will be transmitted to and stored by the mentioned companies’ servers, which may be operated outside of member states of the European Union, as well as outside of states party to the Agreement on the European Economic Area. In case of activation of IP anonymization within the tracking tools for this website, they will anonymize your IP address before transmission. This website uses a tracking code for each tool, to which an anonymization is added to enable anonymized collection of IP addresses (so-called IP masking). These companies will use this information on behalf of the website operator for evaluating your use of the website, compiling reports on website activity and for providing other services relating to website activity and internet usage to the website operator. The tracking tools will not associate your IP address with any other data held by them. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do so, you may not be able to use the full functionality of this website. You can prevent your data collection and use of data relating to your use of the website (incl. your IP address) by downloading and installing the relevant browser plug-ins available through the internet.
2. Social Media
   Social plug-ins of social networks are integrated on the Website. You can recognize the plug-ins through the company signs. If you visit one of our websites and services that uses such social plug-ins (e.g. ‘like’- button by Facebook), your browser will directly connect to the server of the social network. Regarding information about purposes and the amount of data collection through the social networks, as well as your rights and alternative adjustments regarding the protection of your privacy, please have a look at the private policy declaration of the particular social network.
   Social Media Providers:
   Facebook (Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA or, as may apply, its subsidiary Facebook Ireland Ltd., Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland).
   https://www.facebook.com/policy.php
   Twitter.com (Twitter, Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA)
   http://twitter.com/privacy
   Pinterest (Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA)
   https://policy.pinterest.com/en/privacy-policy
   instagram.com (Instagram Inc, 181 South Park Street Suite 2, San Francisco, CA 94107, USA)
   https://help.instagram.com/155833707900388
   LinkedIn (LinkedIn Inc. 2029 Stierlin, Court Mountain View, CA 94043 USA)
   http://www.linkedin.com/legal/privacy-policy
   vk.com (VK.com Ltd, 8-B Tverskaya Street, St. Petersburg, Saint Petersburg, Russia)
   https://vk.com/privacy
3. YouTube
   The video platform YouTube is operated by YouTube LLC, based in 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is owned by Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We may use YouTube plugins for the purpose of showing information, tutorial or advertisements videos on the Website. To start the video, you have to click on the start button. YouTube may assign this information to the individual user account, if you are logged in your YouTube account. By logging out from your YouTube account and other accounts of YouTube LLC and Google Inc. and deleting their cookies you can prevent assignment.
   For further information on the purpose and scope of data collection and data usage by Google as well as all rights and options for adjustments designed for the protection of YouTube customers please refer to the YouTube data protection policy (http://www.youtube.com/t/privacy).

4.3 Cookies

While you visit the Website, your web browser may automatically download a copy of the site you are visiting in addition to a text file called ‘Cookies’. This file is then stored on the hard drive of your personal computer. Cookies help us improve our Websites. Cookies may be declined by changing the settings to the web browser. Should you decide to decline cookies, you may not be able to access certain sections of our Websites. To ensure that our mailing tools are working properly, we may also use cookies and web beacons. By using our website/services you agree to the use of these cookies.

Some cookies provide us with anonymous information about how many visitors access our Websites, the date and time of their visit, the length of their stay, and which pages they view. We also use these cookies to determine which web browsers our visitors use and the address from which they accessed our sites (for example, if they connected to a website by clicking on one of our banner ads). We may share this information with third parties to improve the content and functionality of our Websites, to better understand our customers and markets, and to improve our products and services.

Some cookies may enable us to compile statistics about our visitors and their use of our sites (e.g. IP address, your operating system, website from which a file was accessed, name of file, date and time of retrieval, volume of data transmitted, web-logs etc.).

4.3.1 We use these types of cookies:

1. Session-based cookie
   A session-based cookie is a cookie that is erased when the user closes the web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed. Session cookies do not collect information from the user’s computer. A session-based cookie helps you move around our website faster and, if you are a registered customer, it allows us to give you information that is more relevant to you.
2. Persistent cookie
   A persistent cookie type is a cookie that is stored on a user’s hard drive until it expires (persistent cookies are set with expiration dates) or until the user deletes the cookie. Persistent cookies are used to collect identifying information about the user, such as web surfing behavior, or user preferences for a specific web site (e.g. language setting).
3. Analytical cookie
   Cookies in this category are used to collect information about the site. Analytical cookies allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it. These cookies collect anonymous data on the activity of users and as it came on the site.

Cookies allow us to:

• Improve the use of the website/services and to make the content more interesting and relevant to the wishes of users, like offering you more relevant promotional offers.
• Distinguish you from other users of our sites to grant a good user experience.
• Identify your settings and preferences regarding customized content or functionality.
• Your log-in details for the confirmation as a registered user for our website/services.
• Collect statistical analysis on the use of our website/services.

4.3.2 List of the main cookies

4.3.3 Third Party Cookies

These are cookies set on your device by third party services. The setting of these cookies is regulated by the cookie policies of the respective third parties. The following are the third parties storing cookies on your terminal device:

4.3.3 Managing Your Cookies

Most browsers accept cookies automatically. However, one can configure the browser in a way that no cookies are stored on its computer or a hint appears before a new cookie is created. Please see the particular operator’s advice for the deactivation of cookies.

Disabling cookies completely may lead to decreased functionality regarding certain features of the Company’s website.

For further information on cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org

5. DATA SECURITY

We employ security measures to protect your information from access by unauthorized persons and to prevent unlawful processing, accidental loss, destruction, and damage. We use state of the art technological security solutions, including encryption when transmitting sensitive information across the Internet. This means that all personal and financial information sent to and from the Website are encrypted in accordance with good industry practice.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In order to protect both, ourselves and our customers from identity theft, we may verify the information you have provided with our banking institutions over secure lines. This will be carried out in accordance with our data protection obligations.

Where you have chosen a password which enables you to access certain parts of our websites, you are responsible for keeping the password, as well as any means to manage the password such as a registered email address, secure and confidential at all times.

As the security of some communications via the Internet is not completely secure, we cannot guarantee the security of any information that you disclose using your Internet connection. You accept the inherent security implications of using the Internet and TV Global Enterprises Limited will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.

While we are following best practice, including but not limited to implementing administrative, technical and physical measures to safeguard your Personal Data against loss, theft and misuse, you should also take personal steps to protect the security of your data both, physically and electronically, by following common best practice procedures such as:

1. Running Anti-Virus software and keeping it up to date.
2. Applying operating system, web browser and other security updates.
3. Ensuring your PC or other device is not left unattended whilst logged into our Websites.
4. Using strong passwords for all Services and logins.

When users submit sensitive information via the Website, their information is protected both, online and offline. When our registration form asks users to enter sensitive information (such as a credit card number), that information is encrypted and is protected using Secure Socket Layer– (SSL) technology. While on a secure page, such as our deposit page, the lock icon at the bottom, or in the URL, of your web browser becomes locked. The lock icon is unlocked, or open, when users are simply ‘surfing’ and are not inputting sensitive information. All payments made on our Site and Mobile Offer are secured, in compliance with the relevant EU rules and regulations.

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information offline. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only authorized employees/contractors are granted access to personally identifiable information. We perform checks on all of our potential employees/contractors to ensure that none of them has a criminal record. Our employees/contractors are regularly made aware of security best practices within the industry and security audits are carried out on a regular basis. Finally, the servers that store personally identifiable information are in a secure environment.

6. INTERNATIONAL TRANSFERS

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union ? in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.

7. DISCLAIMER OF LIABILITY

We endeavor to protect in the best possible manners and methods using up-to-date security measures. However, we do not accept any liability for events that:

1. Lie beyond our control, especially force majeure or natural disasters including power cuts and industrial action.
2. For damages caused by inaccurate, delayed, manipulated/falsified or inappropriate transmission of data which does not occur as a result of any negligence or willful misconduct by the Company.

8. WHAT ARE YOUR RIGHTS?

1. Rights of access and data portability – The Player may obtain a copy of the personal data held by the Company about them at any time and also, the right to request that said data is transferred to a third party.
2. Right of rectification – In the event that the data held about a Player by the Company is inaccurate, incomplete or outdated, you may request the rectification of said data.
3. Right of erasure – The Player may at any time request that the Company erases data held about them by sending an email to the Company as outlined in this policy. Players are, however, advised that with the deletion of their personal data, the customer might not be able to use the website/service anymore or the account might be totally closed.
4. Right to restriction of processing, objection to processing and withdrawal of consent – The Player may at any time request that the Company restricts or ceases to conduct certain data processes provided that there exists no other lawful basis on which the Company is authorized to process said data.
5. Right to lodge a complaint – All requests, complaints or queries may be addressed to the Company to the following email address; dataprotection@betcris.com with the subject ‘Privacy’. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. You can also file a complaint with the Data Protection Authority should you not be satisfied with the way in which we handle your personal information.

9. CONTACT FOR MATTERS OF DATA PROTECTION

TV Global Enterprises Limited is a company incorporated in Malta, bearing registration number C-44378 and having its registered address at 61, Msida Court, First Floor, Msida Seafront, Msida MSD 9043, Malta. For any privacy or data protection queries, the company’s Data Protection Officer can be reached via email on dataprotection@betcris.com with the Subject ‘Privacy’.

Version: 3.9

Last updated: March, 2023