Version 1.1
Last updated: November 2023
At Superbet, we take the protection of your privacy and personal data very seriously. We want you to understand how we protect your privacy when we obtain personal data from you, how we use your data, what your rights are in this respect and how we safeguard it while you use our services and products or use their functionalities. For this reason, we are providing you with this Privacy Notice which we kindly ask you to read before you engage with our services and products.
By using our products and services, you acknowledge that you have read our Privacy Notice and understood that any personal data you provide to us is supplied at your own free will and shall be used in accordance with the purposes described in this Notice. If you do not understand this Privacy Notice, we recommend you do not use our services and products. Before submitting any information within Supersocial, please read this Privacy Notice carefully.
We reserve the right to change and/or update our Privacy Notice at our discretion and at any time. You will be notified accordingly and in advance about these changes and or updates.
SB Global Markets Limited ("us", "our", "we" or the "Company"), a company incorporated under the laws of Malta with registration number C 81168 and registered address at LEVEL 1 BURLINGTON COMPLEX DRAGONARA ROAD, ST. JULIANS, MALTA. SB Global Markets Limited is licensed and regulated by the Malta Gaming Authority (the "MGA") under licence number MGA/B2C/938/2022 issued on 26/04/2023
This Privacy Notice only applies to the processing of players' personal data for which Superbet is a data controller, as described in the General Data Protection Regulation 2016/679/EU and General Personal Data Protection Law ('LGPD') No. 13.709 of 14 August 2018.
As used in this Privacy Notice, "personal data" means any information about you that can be used to identify you, directly or indirectly, through your use of Supersocial, alone or along with other information; or contact you online or elsewhere.
The categories and volume of personal data that we collect vary depending on: i) the activities you choose to undertake in relation to the services we provide and ii) our purposes for processing.
Generally, we will collect your personal data in the following manner:
Directly from you when:
Indirectly from you when:
By law, we must have a lawful reason for processing your personal data. The data we collect about you will only be used for the purposes stated below in this Privacy Notice, to perform our contractual obligation towards you, to comply with our legal obligations and to protect our legitimate interests in specific circumstances.
| Purpose of processing | Personal data collected and processed | Legal basis for processing |
|---|---|---|
| Account registration, login | Personal identification details (such as username, userID, account profile, social display name, user tag, profile picture, personal description, age, gender) | Contractual obligation – T&C |
| Product and service functionality | Details about followers, tickets, reactions, comments, likes, analyses, bet swipes | Contractual obligation – T&C |
| Private chat functionality | Inbox functionality | Contractual obligation – T&C |
| Use of video feature | Video content | Contractual obligation – T&C |
| Content moderation | Content, videos, profile picture | Legal obligation; Contractual obligation – T&C |
| Customer support | Identification details, content you provide related to your request | Consent; Legitimate interest |
| Marketing | E-mail address | Consent |
| Security, functionality | Identification details | Legitimate interest |
| Campaigns | Personal identification details | Campaign Contractual obligation – T&C |
| Share functionality | Personal identification details (such as nickname, ticket details, profile picture) | Contractual obligation – T&C |
Information you share with other users that can identify you directly or indirectly. When registering in Supersocial, you have the option NOT to use personal information that could reveal your identity directly or indirectly. In this way, your identity can remain anonymous compared to other users of the platform.
As explicitly stated in the Terms of Use of the application, for which you are directly responsible, for the security of your personal data, it is important NOT to post/comment on Supersocial information with your personal data that may affect you!
* Where we rely on legitimate interest as a ground for processing your personal data, we always carry out an assessment to ensure that your fundamental rights, interests and freedoms are not outweighed by our legitimate interests. You have the right to object at any time and we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
** When you visit our website/app, we will process your data collected through cookies and other tracking technologies. The cookies used on our website do not collect directly identifiable personal data such as name, address, email address etc. However, certain cookies may collect information which relate to details about the device used, geographical location data, journal information like IP, searches, browser, browser’s language, hardware settings, date and time of the request, method used to send requests to the server, file capacity obtained in response, and other parameters regarding the user’s operating system, which, when combined with other information, it becomes personal data and can indirectly identify you. For more information on what are cookies are and how we use them, including on how you can consent to their use, please read our Cookie Policy available here: XXX
Once collected, we shall at all times ensure that any processing of personal data is carried out in compliance with applicable laws, with this Privacy Notice and for the purpose for which you submitted your data to us.
You can decide at any time not to provide us with the requested personal data. However, if you refuse to share your personal data with us when requested, we may not be able to provide full functionality of Supersocial. You may also not be eligible to participate in certain activities or events if you do not provide us with the minimum required information (for example, if you refuse to share your contact information, you may not participate in a promotional activity because we could not contact you to give you the winnings).
Your refusal to share your personal information with us in order to benefit from certain services may also limit the services and special offers we may offer you.
We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you of this and you have given us your explicit permission to do so. In certain circumstances described below, we will only transmit certain data:
1) Other companies of Superbet Group for the purpose of internal assistance, administrative matters and daily activities in line with this Privacy Notice.
2) Service providers authorized to process personal data who are acting as our contractors, for the purpose of managing our activities, such as:
3) Based on legal obligations. In this regard, please note that there may be legal obligations on our part to share your personal data with the authorities if required by applicable laws. We may also share your personal data in good faith in order to protect, secure or prevent the loss of our rights or in the legitimate interests of Superbet, its customers or the general public, or to respond to complaints from others.
4) In the event of our reorganization, merger or acquisition by another company or in the event of the transfer of our business on the basis of our legitimate interest in consolidating, expanding or streamlining our business. In any of the situations listed, the person receiving the data may have access to the data we store, including your personal data, always in accordance with applicable law.
5) Based on consent in cases where your personal data is transferred to any other third party where you have consented or requested that we do so.
6) We may transmit aggregate statistical data or survey results, but this data will be anonymized and will not contain personal data.
Your personal data will be kept, processed and stored by us and our service providers in the territory of the European Union, Serbia, UK.
Each of our service providers who process and store your personal data is required to keep it protected and secured in accordance with applicable industry standards and regardless of whether less stringent legal provisions apply in their jurisdiction.
If such data recipients are located in third countries for which the European Commission has not issued an adequacy decision, Superbet has contractual relations with each such recipient, which include standard contractual clauses approved by the European Commission or other authority of supervision, where necessary, designed to ensure an adequate level of protection and we will always carry out rigorous verification actions to ensure that there are no risks to such transfers. A copy of the standard contractual clauses used by Superbet can be found at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj.
We assure you that your personal data will be stored only for a strictly necessary period, in accordance with the purpose for which it is collected. For your information, we will retain your personal data:
For the time required to answer your questions, provide guidance and resolve issues related to the services provided;
Upon expiration of the applicable deadlines, your personal data will be securely deleted or anonymised. If, at any time, you wish us to discontinue the use of your personal data and stop providing you with our services, please contact us in the manner described in Section – Your rights.
Superbet has implemented all necessary state of the art and industry standard technical and organizational measures, whether physical, electronic or procedural, to protect the confidentiality and security of the personal data you share with us. These measures have been implemented to protect data against unauthorized access, destruction, loss, alteration, access, disclosure or use. Our security controls are designed to maintain an adequate level of confidentiality, integrity and data availability.
Despite the security measures mentioned above, we want you to know that IT and the internet are not perfectly secure mediums and there will always be the chance that your personal data could potentially be subject to unauthorized acts by third parties. Although we take reasonable steps and employ appropriate security measures to safeguard your personal data, no method of transmitting or storing data is completely secure.
At any given time, you will have the following rights regarding your personal data processed by us. Please note, other than your right to object to us using your information for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute in case of other applicable laws.
(A) The right to information: you have the right to be provided with information on the identity of the personal data controller, on the reasons for processing your personal data and other relevant information necessary to ensure the correct and transparent processing of your personal data.
(B) The right of access: you have the right to make a request for details of your personal data and a copy of that personal data.
(C) The right of rectification: you have the right to have inaccurate data about you corrected or removed without undue delay.
(D) The right of erasure ("right to be forgotten"): you have the right to have certain personal data about you deleted from our records. If your requests to delete your personal data violate our legal or regulatory obligations, or the data related to the request for deletion are necessary to exercise or defense our legal claims, we may not be able to act upon your request and we will notify you of this decision.
(E) The right to restriction of processing: you have the right to ask us to restrict the use of your personal data.
(F) The right to data portability: you have the right to ask us to transfer the personal data you have given us to you or to someone else in a format that can be read by computer.
(G) The right to object: you have the right to object to us processing (including profiling) your personal data in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your data for our or a third party’s legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing.
(H) The right in relation to automated decisions: you have the right to not be subject of a decision which produces legal effects which concern you or which has a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorised by law or you have given your permission for this.
To exercise any of the above rights, please contact us by email: support@superbet.com. Your request will be reviewed and answered within 15 days or one calendar month from receipt, in accordance with the Brazilian data protection act or GDPR . If we receive a large number of requests, or particularly complex requests, the deadline can be extended by a maximum of another two months. In certain circumstances as prescribed by data protection law (i.e. excessive requests), we might refuse to act upon your request.
As a rule, you can exercise your rights for free. However, we reserve the right to charge a reasonable fee if your requests are manifestly unfounded or excessive, in particular because of their repetitive nature.
We pay the utmost attention to the confidentiality of all personal data and reserve the right to verify your identity if you submit a request for personal data to avoid a potentially undesirable situation for another person to illegally exercise a right on your behalf.
In the event your personal data is processed based on your consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
You also have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing or any competent court to defend the rights guaranteed by the applicable legislation.
If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process information about you, please contact our Data Protection Officer by emailing data.privacy@superbet.com or by post.
For more information on how Superbet manages and uses your personal data, please see the Privacy Notice published on the Superbet website.