Privacy Notice
Version: 1.2
Date of last revision: 6.12.2022
Introduction
This Privacy Notice outlines what you can expect from us regarding the handling of your personal information when you interact with our website (https://mr.bet/), including any mobile or device-specific versions, and any related applications (collectively referred to as the “Website”), as well as any other products or services we offer (collectively, the “Services”).
We understand that you are aware of and care about your privacy interests, and we take that seriously. This Privacy Notice describes our policies and practices regarding collection and use of your personal data, and sets forth your privacy rights.
We will tell you:
- Our contact details
- Data Protection Officer
- How we collect your personal information
- What happens if you do not give us your data?
- How we use your personal information
- When and how we share information with others
- Transferring personal data from the European Economic Area
- Data subject rights
- Security of your information
- Data storage and retention
- Changes and updates to the Privacy Notice
Our contact details
References in this Privacy Notice to “we”, “us” or “our” relate to Faro Entertainment N.V., a company incorporated in Curaçao, and having its registered address at Kaya Richard J. Beaujon Z/N, Curacao, P.O. Box 6248, and Faro Entertainment Europe Limited, its wholly-owned subsidiary, and having its registered address at 12 Demostheni Severi Ave., office 601, 6th floor, Nicosia, 1080, Cyprus.
We control the ways your personal information is collected and the purposes for which it is used, acting as the data controller.
More details are below.
Our postal address:
Faro Entertainment N.V.
Kaya Richard J. Beaujon Z/N,
Curacao, P.O. Box 6248
EU Representative:
Faro Entertainment Europe Limited
12 Demostheni Severi Ave.,
office 601, 6th floor,
Nicosia, 1080,
Cyprus.
Office address
Diogenous 1, Block A, 2nd Floor,
Engomi, 2404 Nicosia,
Cyprus
Our email address:
References to “you” and “your” shall refer to the person using our Website and providing personal information to us.
Data Protection Officer (DPO)
We have appointed a data protection officer for you to contact if you have any questions or concerns about our personal data practices. The data protection officer’s contact information is as follows:
Email address:
How We Collect Your Personal Information
1. Personal Information You Provide to Us
- Identity Information: When creating an account, we collect details like your name, username, date of birth, password, email, mailing address, and mobile number.
- ID Documents: For identity verification and to comply with anti-money laundering regulations, you may need to provide government-issued IDs, bank statements, tax invoices, or utility bills.
- Communication Information: We keep records of communications via email, postal service, chat, or phone, including recorded phone calls, for quality improvement, security, legal defense, and regulatory compliance.
2. Additional Information Collected
- Payment Information: We use SSL encryption for secure data transmission. While we don't store full payment details, we keep records of your transactions and limited payment data (e.g., last four digits of your credit card).
- Gaming Information: Details like your account balances, bets, bonuses, and winnings are recorded.
- Device and Connection Information: We gather data like IP addresses, location, browser type, and other usage details.
- Activity Information: Interaction with our website, such as email responses, clicked links, and browsing history, is tracked.
- Profile Information: We note your interests, preferences, and favorite games based on your website activity and communication.
3. Personal Information from Third Parties
We occasionally receive information from third-party sources, like AML service providers or marketing firms, to maintain data accuracy and enhance our services.
4. Special Categories of Personal Data
For fraud prevention and legal compliance, we might process sensitive data, including health information (if voluntarily provided).
In exceptional cases, when legally allowed, we may process data on criminal convictions and alleged offences for purposes like conducting checks, crime prevention, and complying with anti-money laundering, fraud, and terrorist financing laws.
5. Personal Information from Public Sources
We may obtain data from public databases, social networks, and other public platforms to fulfill legal requirements.
6. Cookies
We use cookies for security and to tailor your browsing experience. They record your preferences to facilitate easier access to Services.
Consequences of Not Providing Data
Without your personal data, access to many services is restricted. Certain information is essential for contractual and legal compliance, service provision, and authentication.
How We Use Your Personal Information
1. We process your personal information for several purposes to enhance our Services.
Below are the key areas where your data plays a crucial role:
- Account Management: We use personal information to create and manage user accounts.
- Service Access and Gameplay: This involves providing access to our Services and processing gaming activities.
- Competition Participation: We enable users to participate in various competitions.
- Payments: Your data helps in offering, processing, and facilitating payments related to our Services.
- Updates Notification: We keep you informed about changes to our Website, Services, and Terms and Conditions.
Our legal basis for these activities stems from the fulfillment of our contract with you and our legitimate interests, such as ensuring account functionality and processing payments.
2. User Support
Inquiry Response: We process personal data to respond to your inquiries and questions.
Support Improvement: This includes efforts to enhance our support processes.
For these purposes, we rely on legitimate interests, such as resolving issues and addressing any concerns you might have.
3. Safety and Security
We utilize personal information to enhance the safety, security, and integrity of our Services and users. Our measures include:
- Ensuring network and information security;
- Preventing unauthorized access to electronic communication networks and mitigating damage to computer and electronic communication systems.
Our legitimate interest lies in maintaining personal information for these safety and security purposes. Additionally, we use your data to comply with legal obligations.
4. Responsible Gaming
As a committed gambling operator, we process personal information to fulfill our legal obligations. These responsibilities include:
- Conducting age verification;
- Facilitating self-exclusion from gambling activitie;
- Safeguarding you against irresponsible gambling;
- Reducing gambling-related harm.
We handle the above data in compliance with legal requirements and for legitimate interests, including our social responsibility commitment.
5. Legal and Regulatory Obligations
We utilize personal data as mandated by license conditions and relevant legislation, including:
- Verifying user identity for Know Your Customer (KYC) compliance;
- Preventing and detecting money laundering, terrorist financing, and other illegal activities;
- Minimizing fraud risk;
- We process this personal information to comply with our legal obligations. Additionally, when processing information to protect our business from illegal activities, we rely on our legitimate interest.
6. Research and Development
We may use the data we collect for testing, research, analysis, development, and improving user experience. This assists in enhancing our Services and marketing campaigns, developing new features and products, and facilitating finance solutions related to our Services.
Understanding how you use the Website is in our legitimate interest. This knowledge helps us provide more relevant Services and ensure appropriate staffing to meet user needs.
7. Marketing
We may use collected data to market our Services, specifically to:
- Personalize our offers;
- Suggest and recommend options based on your preferences;
- Assess the effectiveness of our marketing campaigns;
- Implement promotions (including bonuses, loyalty programs, and VIP management).
We process personal information for marketing purposes based on legitimate interest. However, we will send you marketing communications only with your explicit consent. You can manage your marketing preferences at any time.
Should you request not to receive marketing communications, we will retain your contact details on our “do not send” list to honor your request.
8. Automated Decision Making and Profiling
As a licensed and responsible gambling operator, we adhere to stringent legal requirements. To prevent fraud, money laundering, and other illegal activities, we monitor user activities on our Website through an automated system. This system flags suspicious behavior, with final decisions regarding users made by an authorized specialist.
For our loyalty program and to provide tailored services and games, we categorize users into different clusters. This clustering is automated and does not have any legal effect on you. However, if segmentation results significantly impact you, they are reviewed by a human before any action is taken.
Sharing Information with Others
The personal information we collect is stored in databases hosted by third parties within the European Union (EU). These parties are restricted to using your information solely for cloud storage and retrieval, without access for other purposes.
We only disclose your personal data to third parties in the following cases:
1. Service providers
We provide your personal data to the following categories of service providers:
- Hosting;
- Games and sportsbook;
- Identity verification and AML;
- Payment processing;
- User support;
- Safety and information security;
- Marketing;
- Data analytics;
- Legal, auditing, accounting and other professional services.
2. Fraud Prevention and Anti-Money Laundering
To fulfill regulatory and legal obligations, we share your personal data with third parties (including anti-fraud and AML service providers, payment service providers, banks, and financial institutions) for identity checks, monitoring gaming behavior, and safeguarding our Website from illegal activities.
These providers act as independent data controllers and may possess certain information about you. We have established data processing agreements with them to ensure that the protection level for your data, as mandated by applicable data protection laws, is maintained.
3. Other Disclosures
In addition to the disclosures for the purposes identified above, we may disclose your personal information to third parties:
- To comply with the law (for example, to comply with a search warrant, subpoena, or court order);
- To comply with a request for information from a governmental body such as law enforcement (police) or other public authorities;
- To enforce our Terms and Conditions;
- To address disputes, claims, or to establish, exercise, or protect our rights, property, or safety, or the rights, property, or safety of others;
- To comply with a regulatory investigation from a relevant gambling authority (e.g., Curaçao eGaming) or a relevant data protection authority (e.g., the Office of the Commissioner for Personal Data Protection in Cyprus); and/or
- While negotiating or in relation to a business transaction, such as a merger, change of control, sale of assets, or bankruptcy.
Transferring Personal Data from the European Economic Area
Personal information we collect from you may be processed outside the European Economic Area (EEA). We rely on the following methods for transfers of personal data outside the EEA:
- Adequacy: We may transfer personal data to a third country when the European Commission has decided that such third country ensures an adequate level of protection. For more details, please see the European Commission official website;
- Appropriate Safeguards: Several possible mechanisms may be suitable for our purposes, namely model data protection clauses, binding corporate rules, approved codes of conduct. We enter into standard model clauses with our vendors whenever feasible and appropriate. For more information, please see the European Commission official website;
- Derogations: When none of the other transfer mechanisms are available, we may rely upon certain derogations to the prohibition on transfers outside the EEA, such as explicit consent of the data subject, performance of a contract involving the data subject, important public interest reasons based on European Union law, establishment, exercise, or defense of legal claims.
Data Subject Rights
The EU General Data Protection Regulation (GDPR) and other countries' privacy laws provide certain rights for data subjects. To process your request, we must confirm your identity before taking any action. For security reasons, we may need to request additional details regarding your identity. Once we receive the necessary information, we will handle your request within the legally specified timeframe.
You may request:
- Confirmation that we are processing your personal data, and, where applicable, access to the personal data, including information about: the purpose of the processing; the categories of personal data concerned; who else might have received the data; the source of the information (if not provided directly by you); the anticipated duration of storage.
- Rectification of your personal data in our records if it is inaccurate;
- Erasure of your data, subject to certain exceptions. We may decline your request to the extent that processing is necessary: for compliance with a legal obligation requiring processing under EU or member state law; for the establishment, exercise, or defense of legal claims;
- Objection to the processing of your personal data: this applies particularly where processing is based on our legitimate interests or the performance of a task carried out in the public interest; you may object to the use of your data for direct marketing purposes without any limitations.
- Restriction of processing under certain circumstances prescribed by law;
- Transfer of the information you provided to another organization or directly to you, when technically feasible. This right applies only if the processing is based on your consent or for the performance of a contract, and the processing is automated.
In many countries, you have the right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data.
If you wish to exercise any of these rights, please contact our customer support team by email, chat, or phone. The contact information is listed at the bottom of this page. Alternatively, you can exercise your rights by contacting us at [email protected].
Additionally, to exercise your right to withdraw consent or to object to the processing of your personal data for direct marketing purposes, you may use the marketing preferences tool in your account or follow the opt-out instructions in our messages. Please note that it can take up to 48 hours for your opt-out request to be fully processed.
To enable or disable push notifications, please adjust your device settings.
There is no charge for exercising your rights. We aim to respond to your requests within one month. If your request is complex or there are numerous requests, it may take us longer. We will notify you and keep you updated.
We have one month to respond to you.
If we are unable to fulfill your request within one month, we will provide a specific date when your request will be processed. In cases where your request is denied, an explanation will be provided.
Security of Your Information
To protect the privacy of your data, we maintain physical, technical, and administrative safeguards. Our security technology is continuously updated and tested. Access to your personal data is restricted to employees and vendors who need this information to provide services to you. We also train our employees in confidentiality, privacy, and security.
Data Storage and Retention
Your personal data is stored on our servers and on the servers of the third-party providers we engage, located within the EU.
We retain data for the duration of your business relationship with us and for a period thereafter if necessary for legal obligations, such as fraud prevention, record keeping, responsible gaming, resolving disputes, and as required by supervisory authorities.
Retention periods vary due to our regulatory and legal responsibilities. For instance, we retain certain personal data elements for up to 6 years after your account closure to comply with anti-money laundering regulations and for legal claim purposes.
Once we are no longer required to retain your information, we ensure its deletion.
Changes and Updates to the Privacy Notice
This Privacy Notice may change as our Website and Services evolve. We reserve the right to amend the Privacy Notice at any time, for any reason, without direct notice to you, except through the posting of the amended Privacy Notice on our Website. We may also inform users of significant changes via email. We recommend you check our Website regularly to view the current Privacy Notice and any updates.