Last modified: 11/04/2022
YouGmedia B.V. shall handle and store personal data provided in the manner described in this Policy. This privacy policy provides an overview of how YouGmedia B.V. collects and processes your personal data and tells you about your rights under Curaçao Ordinance No. 84 of 4 September 2010: Laying Down Rules on the Protection of Personal Data.
Who we are?
Batery.win is operated by YouGmedia B.V., company number 153269, with registered address at Dr. H. Fergusonweg 1, Curaçao, that is authorized by the Government of Curaçao to conduct gaming operations under auspices of License #365/JAZ (Sub-License Number: GLH-OCCHKTW0707032021 issued on July 7th 2021).
Protection of Personal Data
We like to make things easier for our customers and that includes being clear and open about how and why we use your personal information. We hope you’ll find it helpful but if you have any concerns or questions please feel free to contact us. This Policy applies to web sites, applications, products or services associated with this policy or does not have a separate privacy policy (collectively, our "Services"). It describes how we collect, use and process your personal data, whether you’re just visiting our website or placing a bet and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights. The purpose of this privacy policy is to help you understand better:
Please read this policy thoroughly, before accepting it. It is important to check this update policy regularly. If we make any changes, we will notify you by submitting a notice to the respective service and / or we will contact you by other methods, such as e-mail.
We collect information about you during the account creation process for any of our Services. This information may include, but is not limited to, your name, date of birth, residential address, email address, telephone number, credit / debit card details and any other information that may be required to register and / or continue to use the Services us. We may also collect information from you if you ask us for information or customer support.
We collect information from the devices you use to receive Batery.win content, products and services. This includes but is not limited to the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), telephone hardware model, operating system and version, browser type, preferred language, device motion information, mobile network information and location data.
We also collect server logs, which include information such as dates and times of access, the app features or pages you view, app crashes and other system activity, and the third-party site or service you were using immediately before visiting our site.
YouGmedia B.V. will use cookies to deliver a better and personal service to users of their website.
Cookies are small text files stored in your web browser that enable us to recognize your computer when you visit one of our websites. Cookies are essential to keep certain parts of our websites functioning correctly and securely. We also use them to make things quicker, easier and more personal to you, and to help us understand how our websites are used. They can also be used to present you with more tailored advertising content.
To do all of these things, cookies collect some personal information about you whenever you use our websites. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings. We will make you aware of this by showing you our cookie banner when you visit our site. If you then continue to use our website without adjusting your browser settings, we will use cookies as set out in the sections below, so to help you make an informed choice it’s important to know why we use the different types of cookie and what that means for your online experience. This section provides you with a summary of the main points and tells you how switching off the different types of cookie will affect your experience on our websites.
Strictly Necessary cookies: Making our websites work:
These Cookies are essential so that you can move around the sites and log in to the secure areas. They also enable us to deliver content in a way that works for your device.
Without these cookies you would be unable to place bets or access your account so if you opt out of receiving these cookies, parts of our site will not work correctly and may not work at all.
A few examples of the ways in which we use strictly necessary cookies:
As a betting company we have certain legal obligations we need to abide by. One of those rules is that we must do everything we can to prevent fraud and money laundering. These Cookies help us to protect our customers and our business by ensuring that customers are genuine, haven’t registered more than once, and are not fraudulently trying to access accounts that don’t belong to them. They also help us to recognize behaviour that may indicate fraud, money laundering, other illegal activities or breaches of our terms and conditions.
Without these cookies you will be unable to use our websites. If you do not wish to accept this type of cookie, your option will be to close your account and not use our services.
These Cookies allow our websites to remember choices you have made, such as your account number, your region or the selections you have placed on your bet slip. They help us keep you logged into your account as you navigate around our websites, and enable you to use certain features such as resetting your PIN or email address. We also use them to personalise your experience by, for example, showing more relevant offers, giving you access to information provided by social media websites such as Twitter, or to show you ‘related article’ links relevant to information you’re looking at.
Without these cookies you will still be able to use the site but may experience difficulty using certain features and will need to keep logging in as you navigate around our sites. You will not see content (including price boosts) that is relevant to you.
These Cookies collect information about how people use our website and how the sites are performing, e.g. how many people visit, which pages are most popular and whether and where people see error messages. They also ensure we fulfill our contractual agreement with our marketing partners correctly for users they refer to us. A few examples of the ways in which we use Analytical cookies:
These cookies are used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. The Cookies remember that you have visited a website, and we share this information with other organisations for advertising purposes. We also use them to test and improve our products and services by, for example, testing out different product experiences with different groups of customers to see which is most popular
Without these cookies: You will be able to use and enjoy all the features of our websites but the adverts you see will not be tailored to your interests
All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:
To help us comply with our legal and regulatory obligations, when you open your account we request a check up on information from Thomson Reuters. This portal keeps records of any positive or negative information on individuals (if those are official). This helps the Company to minimize any potential risks and keep crime out of betting industry.
We may also collect information from third parties such as our affiliates, service providers and publicly available sites (ie, social platforms), to comply with our legal and regulatory obligations, to offer Services that we consider to be of interest, to maintain accuracy of the data, and to provide and improve the Services.
Sometimes we need to undertake additional checks to verify information or, once an account is active, to investigate activity that could indicate a risk. To do this we use organizations and databases which collate information and make it commercially available for use in crime prevention and detection, the promotion of safer gambling and ensuring the fair use of services. We also look at publicly available information to verify things like occupation status or property ownership, and at social media.
If you would like to know more about gambling regulation and the obligations it places on companies like Batery.win, you can find out more content on Safer Gambling websites.
We look at information on your Facebook or other public social media pages when carrying out checks to comply with our legal and regulatory obligations. This helps us to verify information you have given us and ensure our products are being used legally and responsibly.
We use the information we hold about you in a range of different ways, which fall into these broad categories:
We may also collect the following information:
Legal and Regulatory Requirements
We need to comply with a range of legal and regulatory requirements, some of which involve the use of personal information and/or set out timescales for which we need to keep that information. As a provider of betting services, we are regulated by the Gaming Curaçao.
We take our social responsibility and our commitment to safer gambling very seriously and we actively look for behaviour that may indicate that someone is at risk of problem gambling so that we can intervene at an early stage to provide them with support and direct them to sources of help. To help us understand the factors that can indicate the early stages of problem gambling, we look at information about customers who have self-excluded, such as age, location and past betting behaviour, to identify common factors. This helps us intervene earlier in cases where customers may be at risk of problem gambling and provide them with better support. We are also subject to laws and regulations relating to other aspects of our business, such as payment processing or complaint handling and some of these too involve the use of, or set timescales for holding, your personal information.
When you set up an account with us, place bets we carry out identity verification, fraud prevention and anti-money laundering checks, validating the information you give against third party crime prevention databases and, where necessary, information from publicly-available sources. We share your personal data with organisations that verify details and transactions and identify potential indicators of illegal activity, which they make available to other organisations using their services. Where necessary, we share your data with Risk Intelligence agencies or fraud prevention agencies, which keep a record of that information and make it available to other organisations for use in identification checks and fraud detection and prevention. Where appropriate, we pass information to the police and other law enforcement agencies, debt recovery companies and other similar bodies.
As well as fraud and money laundering, we carry out ongoing monitoring to ensure that our products and services are not used for other Illegal purposes such as event manipulation, “match-rigging” or other forms of cheating. We do this in a variety of ways, including the use of cookies, and where we find transactions, data or behaviour that could indicate illegal activity we share information with third parties, including the police.
This category covers activities we are obliged to do in order to provide our products and services legally, responsibly, and in line with the requirements of our regulators, and ultimately to protect our customers and our business. We cannot provide you with our products and services without carrying out these activities, and if you don’t want your data used in this way your option is to not use our services and close your account.
Running our business effectively and efficiently
There are some things we do to help us operate as a commercial organisation. We have a legitimate interest in carrying out these activities, and where they involve using your personal information we are careful to carry them out in a way that minimizes any impact on your privacy. Data protection law gives you the ‘right of objection’ to the activities in this category if your right to privacy outweighs our legitimate business interest in doing them. You always have the option to exercise this right but, as we explain in more detail below, the activities involved are central to our business, so if you wish to do so it will usually mean you need to close your account. Please read this section carefully and ensure you are happy with it before providing us with your personal information.
Business Insights
We carry out basic analytics to help us understand, how, when, where and why our customers use our services, and how our business is performing. This helps us monitor and plan everything from the effectiveness of our advertising through to ensuring we have enough staff available to handle queries at peak times. It also gives us a much clearer picture of our customers generally, the broad demographic groups they fit into (e.g. age group, gender, location, etc.) and the products and services they use, which in turn helps us to develop better and more relevant features, products and services.
Privacy Rights: Can I object to having my personal information used in this way?
Like any business, we need to keep a close eye on how our business is performing and whether we’re meeting the needs of our customers. As we do this in a way that does not identify you as an individual, there is no impact on your privacy. If you don’t want your data used in this way your option is to not use our services and close your account.
Protecting our commercial interests
Most people use our products and services fairly, but we carry out monitoring of how our customers bet, play and interact with our products and services, to identify behaviour that is not in line with our Terms and Conditions or that could be prejudicial to our commercial interests.
At our discretion, we have the right to use this information in making decisions about whether to place restrictions on people’s accounts or, on very rare occasions, to close their accounts. We take this very seriously, and consider a wide variety of factors in making such a decision, taking into the information we hold about you as well as any information obtained from industry databases. Please note that we do not use cookies to obtain information for this purpose.
Privacy Rights: Can I object to having my personal information used in this way?
As a business, we have a legitimate interest in protecting our commercial interests against deliberate misuse, and we are confident that we do it in a way that is proportionate to the risks we face and has minimal impact on your privacy. If you don’t want your data used in this way your option is to not use our services and to close your account.
Things we do with your consent: Marketing
We will send you offers and information only if you have given your consent for us to do so, in which case we will contact you via email, post, SMS or online about any of our group products and services. We never share your data with companies outside our group for them to use for their own marketing. From time to time, we may team up with a third party to bring you details of a product or service we think might interest you, but where we do this the contact will come from us - we will never pass your details to the third party without your prior consent. Please be assured that we do not use any sensitive information we hold about you (for example, information about self-exclusion, health or ethnicity) for marketing-related purposes.
Keeping it Relevant
At Batery.win we want to make betting better for you, so we want to be able to tell you about products, services and features that you will find exciting and relevant, and we tailor the offers and information we send to suit you. To do this, we look at what we know about you - such as your age, location and gender, your betting interests, your social media usage and how you interact with us - and we use it to build up a picture of you that helps us decide what you’re most likely to want to hear about. (This is sometimes known as ‘Profiling’). We also combine this with information we’ve obtained from publicly or commercially available sources about the things people with similar characteristics to you (in terms of age, gender, location etc.) tend to be interested in so we can fine-tune the offers we present to you.
Putting you in Control
We firmly believe our customers prefer offers and information that are relevant to them and their interests over general adverts, so we tailor all our marketing using this picture we’ve built up of you. We think this makes our marketing better both for you and for us. However, data protection law gives you the right to opt out of having your personal data used to build up this type of picture and predict what you might be interested in, so you can opt out at any time. As we explain above, all our marketing is tailored to you in this way, so to opt out of this type of personalisation you will need to opt out of receiving all direct marketing from us. You can do this when you sign up, by not ticking the box to opt in to marketing, or at any later point via your online account. We won’t then send you offers and information by post, email or SMS but we will continue to personalise your online experience based on the picture we’ve built up of you. This means you’ll continue to benefit from a more personalised look and feel on our websites and apps, and will still see the following:
We think this strikes the best balance: it lets you opt out of receiving marketing through offline channels (post, email and SMS) while still enjoying the best online and in-game experience and without having to miss out on bonuses, promotions and other benefits. However, if you prefer not to receive any personalised messages or offers online you can opt out by out by editing your account details via your online account. If you do opt out you will experience a less personal look and feel on our sites and apps and won’t get to hear about bespoke offers and bonuses. Please also note the following:
All our marketing is tailored to be more relevant and interesting to you, so if you’re:
Remember, you can change your mind at any time by updating your preferences in your account.
Online banner adverts: cookies
If you have enabled cookies in your browser you may receive banner adverts on our homepage, as these are cookie-based and not tailored using other information we hold about you. As they are cookie-based you will receive them even after you have opted out of personalised marketing, but you can control them easily via your browser settings
Advertising on Social Media
If you have given your consent to marketing, we will work with social media companies such as Facebook and Twitter to provide you with information about our products and services via their platforms. If you do not wish to see these adverts, you can control this easily by disabling preference-based marketing in the privacy and ad settings on each individual platform.
Even if you have withdrawn your consent to personalised marketing by Batery.win, you might still see general adverts for Batery.win products and services on your social media feeds. These will not be specifically targeted to you, and again, you can control this via the privacy and ad settings on each platform.
Marketing on our apps: Push Messages
When using our apps, you will receive push messages. These can be easily disabled through your phone or device’s settings.
Privacy Rights: Can I opt out of marketing?
Yes, you have the right to opt out of having your information used for direct marketing and the right to opt out of having it used to build up a picture of you so we can personalise our marketing to suit you. Please read the sections headed ‘Keeping it relevant and keeping you in control’, which explain how we use your personal data in our marketing, and how to control the marketing you see, and remember you can change your mind about receiving marketing material at any time via your Batery.win account.
As our marketing campaigns are prepared well in advance, you are likely to continue to receive material for a short period of time after updating your preferences.
Remember, even if you choose not to receive marketing email, we may continue to send you important service information related to your accounts and subscriptions.
More sensitive matters: how we use sensitive data
As a responsible provider of betting services, we do our best to ensure that our customers bet responsibly, and encourage you to make use of the range of tools available to help you with this. This means that on occasion you may provide us, directly or indirectly with information about your physical, psychological or emotional health or situation and talk to us about problems with gambling. We appreciate the sensitivity of this information and use it only to provide you with the support you have asked for and to signpost you to the appropriate sources of help.
To help us in our commitment to safer gambling, it’s important that we understand the factors that can lead people to self-exclude or may indicate the early stages of problem gambling. Where a customer self-excludes, we look at demographic information about them (such as age group and location) and their past betting behaviour and transactions to help us identify common factors. This in turn helps us to provide earlier and better support to customers who may be at risk of problem gambling. As well as ensuring we do all we can to fulfil our regulatory obligations, it helps us to help our customers gamble responsibly.
On occasion, you may provide us, usually indirectly, with other sensitive information about yourself, such as your ethnicity or nationality (for example, identity verification documentation or checks can reveal this information). It is rare for us to ask you for this type of information directly, and we will only do so if we have a specific and valid legal reason, which we will explain clearly at the time. Where we do need to hold this type of sensitive information because it is shown in an identification document for example, we will do so only to comply with our legal or regulatory requirements and will not use or make it available for any other purpose.
Where you provide us with details of, or a copy of, your passport, driving licence, national identity card, or other national identification documentation, we use it only for identification and verification purposes required to fulfil our legal and regulatory requirements.
Other circumstances in which we share your personal data
Apart from the functions set out above, we do not share your personal information with third parties except where we are compelled or permitted by law to do so. These circumstances are rare, but may require us to share information with the police or other law enforcement agencies, the courts, statutory authorities (e.g. in connection with tax matters).
Where necessary to protect or defend our rights and interests, resolve disputes or enforce our agreements, we will share personal data with our regulators, external legal advisors and debt recovery and tracing agencies, although again these circumstances are rare.
If ownership of all or part of our business changes or we undergo a reorganisation or restructure, we will transfer your personal information to the new owner or successor company so we or they can continue to provide the services you have requested. The following measures can be performed only with your explicit consent.
Whenever we share personal information, and whatever the reason or circumstances, we will always do so legally and with due regard to your privacy. If we receive a request from law enforcement or other statutory bodies, we do not disclose personal information without a warrant, court order or other legally valid proof of authority.
How long do we keep your information?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. Your personal data will be maintained for the period of at least 5 years since the date of the last transaction made on your account. Your personal data may be destroyed after the period of 5 years, since a last transaction will pass and the approval by the Authority will be granted.
When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to gambling, anti-money laundering, taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuse of our services, and audit requirements. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we delete it securely. Please note that if you opt out of receiving marketing from us, we will still need to keep your contact details in order to suppress them from future marketing activity.
Staying in control of your Personal information: Your Privacy rights
We respect the fact that your personal information is your information so we want to be clear about what those rights mean in practice and how you can exercise them. Please see ‘how and why we use your data’ for more information about the purposes for which we process your information and the rights this gives you.
The right to opt out of having your information used for marketing
You can opt out of receiving marketing at any time. You also have the right to opt out of having your information used to create a ‘profile’ of you for marketing purposes. We firmly believe that our customers prefer to receive offers and information that are relevant to them so we tailor all of our marketing to make it more interesting to our customers. Please read the section ‘Keeping it relevant and putting you in control’ for more details.
The right to have any inaccuracies in your personal information corrected
You can update your personal details at any time via your online Batery.win account.
Please help us to help you by keeping your contact details up to date and letting us know if you spot any errors in the information we hold about you. If it is something you cannot correct yourself online, you should contact us at [email protected]. We’ll update inaccuracies promptly, and within a month if you are requesting a more complex change. If we take the decision not to make a change you have requested, we will explain why and make a note on your account to show that you requested the change. If you disagree with our decision, you have the right to complain to the Office of the Commissioner for Personal Data Protection.
Your ‘right of objection’ to certain activities Data protection law gives you the right to express an objection to activities detailed in the section entitled Running our business effectively and efficiently if you believe your privacy rights outweigh the legitimate interest we have as a business in doing those things. Please read that section carefully before getting in touch with us and note that exercising your right of objection will usually mean you need to close your account and stop using our services. If you disagree with our decision on this, you have the right to complain to the to the Office of the Commissioner for Personal Data Protection.
Your Right to Erasure
People sometimes refer to this as the ‘right to be forgotten’. Under data protection law, you have the right to request erasure of your personal data in the following circumstances:
How do I exercise this right?
Please read the sections entitled ‘How long do we keep information’ and ‘your right to erasure carefully before contacting us. If you still wish to exercise your right, you should contact us at [email protected] and we will respond to your request within a month and without undue delay. If we uphold your request and erase your data we will also notify any third parties to which the data has been passed, where we are able to do so, and tell you who they are. If we do not uphold your request, we will tell you why. If you disagree, you have the right to complain to the to the Office of the Commissioner for Personal Data Protection.
The right to access the data we hold about you
If you would like a copy of the personal information we hold about you, you should request it here. We will ask you to complete and return a form, which is not compulsory but helps us to help you by providing the information you are looking for. Before we respond to your request, we will ask you for valid proof of identity and once we’ve received it we will provide our response within one month. If your request is unusually complex and likely to take longer than a month, we will let you know as soon as we can and tell you how long we think it will take.
We will fulfil requests wherever possible, but there are occasional situations in which local or general data protection regulation (GDPR) 2016/679 requires or permits us to withhold some information (such as where it would involve disclosing information about another person or information which is commercially sensitive) or permits us to make a small charge. If either of these applies, we will explain this to you.
Your Right to ‘Data Portability’
The right to ‘data portability’ aims to enable consumers to re-use some of their personal information online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. This is a new initiative and it is not yet possible to ‘port’ data directly between providers in the betting and gaming industry. However, if you wish to exercise this right, you should submit your request here, and we will provide you with the following information as a CSV file:
Before responding to your request, we will ask you to provide valid proof of identity, and we will provide our response within one month of receiving it.
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the privacy regulator. As we are based in Cyprus, our principal data protection regulator is the Office of the Commissioner for Personal Data Protection.
Your privacy and shared computers
If you log in to one of our websites from a shared computer, cookies may cause your e-mail address or user name to display in the login field to anyone who uses the site on that computer after you. You can avoid this by clearing the Cookies stored by the web browser. The option to do this is normally in the ‘Tools’ dropdown menu at the top of the browser window. If you have opted to stay logged in, remember that another person using the same device could access your account unless you log out.
Passwords and PINs
Remember to keep your passwords and PINS secret, choose complex passwords, change them periodically and never use the same password or PIN on multiple websites.