PRIVACY NOTICE

Table of contents

• Who we are
• Data Protection Officer (DPO)
• How we collect your personal data
• How we use your personal data
• How we share your personal data
• International transfers of personal data
• Your rights
• Security of personal data
• Data retention
• Changes to this Privacy Notice

Who we are

References in this Privacy Notice to “we”, “us” or “our” relate to Inextro B.V., a company incorporated in Curaçao under registration number 146616, and having its registered address at Fransche Bloemweg 4, Willemstad, Curaçao, and Beriston Limited, its wholly-owned subsidiary incorporated in Cyprus under registration number HE385830, having its registered address at Prodromou ave 75, ONEWORLD PARKVIEW HOUSE, 3rd floor, Flat/Office 304, 2063, Nicosia, Cyprus.

We control the ways your personal data is collected and the purposes for which it is used, acting as the data controller.

Our contact details:

Inextro B.V.

Fransche Bloemweg 4, Willemstad, Curaçao

Representative in the European Union:

Beriston Limited

Prodromou ave 75, ONEWORLD PARKVIEW HOUSE, 3rd floor, Flat/Office 304, 2063, Nicosia, Cyprus

Our email address: [email protected]

Data Protection Officer (DPO)

If you require further information regarding this Privacy Notice and the processing of your personal data when using our Website, please do not hesitate to reach out to our Data Protection Officer (DPO):

By mail to: Beriston Limited, Prodromou ave 75, ONEWORLD PARKVIEW HOUSE, 3rd floor, Flat/Office 304, 2063, Nicosia, Cyprus

By email to: [email protected]

How we collect your personal data

We have outlined below the types of data we collect and the methods by which we collect them. It is important to note that providing personal data is not mandatory. However, certain data is vital for providing and ensuring the quality of our services. For instance, setting up your account on the Website. Failure to provide the necessary personal data may result in the inability to access services.

Additionally, we are obliged to collect certain personal data to fulfill legal and regulatory requirements, including anti-money laundering measures, responsible gambling guidelines, and compliance with the license conditions as a gambling operator. If you decline to provide personal data that is required by law or regulation, we cannot grant you access to our Website.

1. Personal data you directly provide to us

2. Personal data we collect during the use of the Website

3. Personal data from third parties

https://bruce.bet/ uses SSL encryption that ensures the confidentiality of your information in the transmission of data. In no case, we do collect, store, or transfer data from your card. The payment operations are carried out entirely through the secure server of the payment gateway(s) and/or payment processor(s). Beriston Ltd will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone, except, it’s Acquirer, Card networks/associations or in response to valid government demands.

4. Special Categories of personal data and information about criminal convictions and offences

We may process specific categories of personal data for limited purposes, such as fraud detection, prevention of money laundering, legal compliance, and ensuring accessibility to our services. This may involve health information that you voluntarily share during communication with us.

In accordance with applicable laws, we may handle data related to criminal convictions, offenses, and alleged offenses for specific activities, including checks, crime prevention and detection, and compliance with laws regarding money laundering, fraud, and terrorist financing. It is important to note that this information is collected only in exceptional circumstances, not as part of our regular business operations.

5. Personal data from publicly available sources

In order to meet licensing conditions and legal obligations, we may obtain personal data about you from publicly accessible sources, including but not limited to public databases, social media platforms, search engines, and similar sources.

6. Personal data we collect through cookies

We and our service providers have the capability to collect browser and cookie information. “Cookies” refer to small text files that are transmitted to your device by the website.

How we use your personal data

1. We process your personal data for the following purposes

• Ensuring the security of network and data;
• Preventing unauthorized access to electronic communication networks and preventing harm to computer and electronic communication systems.

2. Automated decision-making and profiling

We adhere to stringent license conditions and legal requirements. As a responsible gambling operator, it is crucial for us to monitor user activities on the Website to prevent fraud, money laundering, and other illegal actions. To accomplish this, our automated system identifies and highlights suspicious behavior and activity on the Website. However, the final decision regarding a user is made by an authorized specialist.

We categorize our users into different groups to facilitate our loyalty program and provide personalized services and games. This categorization is conducted without human intervention and does not have legal implications for you. If the outcomes of this segmentation significantly impact you, a human review is conducted before any action is taken.

How we share your personal data

1. Sharing personal data with group companies

In accordance with applicable data protection laws and the terms of this Privacy Notice, your personal data may be shared with companies within our group. This sharing is carried out for the purposes outlined in section ‘How we use your Personal Data’ above, which include activities such as setting up your account, providing customer support services, managing risks to our Website and business, complying with legal and regulatory obligations, sending marketing communications, and preventing irresponsible gambling.

2. Sharing personal data with service providers

In order to provide the best possible services, we engage the services of third-party providers to assist with the operation of our Website. We establish contractual agreements with these service providers to ensure that they handle your personal data responsibly and securely.

We engage the following service providers:

• Hosting providers: To store and transfer our content and data;

• Marketing providers: To conduct marketing activities;

• IT and security service providers: To protect our Website and infrastructure;

• Customer support providers: To answer your questions and resolve any other problems;

• Payment service providers: To process payments on the Website;

• KYC and anti-fraud providers: To verify your identity, mitigate risks related to anti-money laundering (AML), as well as to prevent fraud and other illicit activities on the Website. These service providers may operate as independent controllers of Personal Data, as their databases may contain specific information about you. We have established appropriate data processing agreements with them, which include obligations to ensure that the level of protection for personal data, as mandated by the applicable data protection legislation, remains uncompromised;

• Games and sportsbook providers: To provide games and sportsbook content;

• Analytics providers: To evaluate and assess the performance and effectiveness of the Website and marketing campaigns;

• Audit, legal, and compliance services providers: To receive professional advice.

3. Sharing personal data in other cases

We will disclose your personal data when required by applicable law in the following situations:

• To fulfill a request for information from governmental bodies such as law enforcement agencies or other public authorities;

• To comply with a court order mandating the disclosure of your personal data;

• To adhere to a regulatory investigation conducted by a relevant gambling authority or a relevant data protection authority;

• For the establishment, exercise, or defense of a legal claim, including investigations or inquiries by competent regulatory authorities;

• If we contemplate selling or acquiring any business or assets, we may disclose your personal data to potential sellers or buyers involved in such transactions. Furthermore, in the event that a third party acquires us or a substantial portion of our assets, personal data may be among the transferred assets.

International transfers of personal data

Our service providers may be located outside the European Economic Area (EEA) in countries with varying standards of personal data protection compared to the EEA countries. Nevertheless, we will make every reasonable effort to implement adequate safeguards to protect your personal data. We will also ensure that our service providers enter into data processing agreements that comply with relevant data protection legislation to ensure the proper handling of your personal data.

We use the following mechanisms:

• We will only transfer your personal data to countries where such transfers are allowed based on an adequacy decision issued by the appropriate regulators. For more information about adequacy decisions, click here;

• We may also establish contractual clauses that have been approved by the relevant regulators, ensuring that your personal data receives comparable protection to that offered in the EEA. For more information about standard contractual clauses, click here.

Your rights

You have the following rights regarding your personal data:

• Right of access: You have the right to request access to your personal data held by us;

• Right to rectification: You can request the correction of inaccurate or incomplete personal data;

• Right to erasure: You can request the deletion of your personal data under certain circumstances;

• Right to restriction of processing: You have the right to limit the processing of your personal data under certain circumstances;

• Right to data portability: You can request a copy of your personal data in a commonly used, machine-readable format;

• Right to object: You have the right to object to the processing of your personal data, including for direct marketing.

You also have a right to withdraw your consent for processing of personal data. If you wish to withdraw your consent or object to the processing of your personal data for direct marketing purposes, you can use the marketing preferences tool within your account or follow the opt-out instructions provided in our messages. Please note that it may take up to 48 hours for your request to be fully processed. In order to manage push notifications, please adjust the settings on your device accordingly.

If you have concerns about how we process your personal data, you have a right to lodge a complaint with the appropriate data protection authority, in particular in the country of your habitual residence, place of work or of an alleged infringement.

We kindly ask that you please attempt to resolve any issues you may have with us first (even though, as stated above, you have a right to contact the competent regulator at any time).

How to exercise your rights

To exercise any of your rights, you can reach out to us directly at [email protected]. Alternatively, you can get in touch with our customer support team via email, chat, or phone.

There are no charges associated with exercising your rights.

We will strive to respond to your request within one month. If, for any reason, we are unable to fulfill your request within one month, we will provide you with a specific timeline for processing the request. In the event that your request is denied, we will provide an explanation for the denial.

Security of personal data

We prioritize adherence to security regulations, standards, guidelines, and privacy laws, placing great emphasis on implementing security measures to ensure the confidentiality, integrity, and availability of personal data. We employ appropriate organizational, technical, and administrative measures to safeguard your personal data against unauthorized access, alteration, disclosure, or destruction.

Data retention

We adhere to the principle of retaining your personal data only for as long as necessary. The specific duration for which we retain your personal data, both during your active membership and after you cease to be a member, may vary and is influenced by various factors.

To determine the appropriate retention period, we take into account the scope, nature, and sensitivity of the personal data, the potential risks associated with unauthorized use or disclosure, the purposes of processing the personal data, the feasibility of achieving those purposes through alternative means, and our legal obligations.

As an example, we retain certain elements of personal data for a period of up to 6 years after the closure of your account to meet anti-money laundering regulations and for the purposes of the establishment, exercise and defense of legal claims.

Changes to this Privacy Notice

Any future modifications to this Privacy Notice will be published on this page and, when necessary, communicated to you via email. We recommend checking this page regularly to stay informed about any updates or revisions to this Privacy Notice.