Privacy Policy – 4RaBet

DEFINITIONS

✔️ Company	Umbrella Development B.V. Address: Curaçao, Chuchubiweg 17, License No. 8048/JAZ
✔️ Mobile Platform	An application that is distributed by the Company through AppStore or Google Play – official application 4RaBet
✔️ Website Platform	A website that is operated by the Company and available at https://4rabet-game.com
✔️ Platform	Collective name that can refer to both the Mobile and Website Platform
✔️ Umbrella Development B.V.	Collective name that can refer to both the Platform and the Company
✔️ Privacy Policy	This document
✔️ Customer	An individual Customer from an age of 18+ or a legal entity that has read and agreed to the Customer Agreement of Umbrella Development B.V. and uses services of the company provided through the Mobile or Website Platforms
✔️ GDPR	The General Data Protection Regulation (EU) 2016/679
✔️ KYC or Due Diligence	Documents that are requested by Umbrella Development B.V. from the Customers in order to identify the Customer and comply with applicable laws

PURPOSE AND SCOPE

The Policy is meant for use by Customers of Umbrella Development B.V.

Umbrella Development B.V. is a company registered in Curacao that has developed and governs the Platform and the services, products, and content that are accessible and offered on the Platform.

The company is compliant with the applicable the laws of Government of Curacao and International laws for the Prevention of Money Laundering and Terrorist Financing, the General Data Processing Regulation as well as other legislation applicable in the Government of Curacao.

This policy aims to provide Company’s Customers with information on what type of information the Company collects, how it is used, and the circumstances where it could be shared with third parties.

Through this document, the Customer’s data may be called either “personal data” or “personal information”. Company may also sometimes collectively refer to handling, collecting, protecting, and storing Customer’s personal data or any such action as “processing” of such personal data. For the purposes of this policy, personal data shall mean any information relating to the Customer, which identifies or may identify a Customer and which includes, for example, the Customer’s name, address, and identification number.

The present Privacy Statement aims to help you better understand the most recent changes to the Privacy Policy and cookie policy and how they may affect Customers. To understand the changes in full, the Customer will need to read the full Privacy Policy and cookie policy.

COLLECTION OF PERSONAL DATA

The company collects the information it needs to fulfil its legal obligation to provide services and to improve our service to you.

 Umbrella Development B.V. will gather information and documentation to identify, contact or locate Customers and may gather information from third parties and or other sources, which will help us to offer our services effectively.

PURPOSE OF COLLECTING AND PROCESSING OF PERSONAL DATA

 According to the laws of the Government of Curacao and International laws for the Prevention of Money Laundering and Terrorist Financing, as well as in order to enhance Customer support, Customer’s personal data will be used for specific, explicit, and legitimate purposes.

The performance of contractual obligations

Personal data received from Clients is used to verify the Client’s identity for Due Diligence purposes, to manage the Client’s account on the Platform, to process Client transactions, to provide post-transaction information to Clients, to inform Clients about additional products and/or services appropriate to the Client’s profile, to obtain analysis and statistics to help the Company improve its products and services, and for the purpose of improving the Platform.

Identity Verification purposes

The Company needs to perform its Due Diligence measures and apply the principles of KYC (Know-Customer’s-Customer) before entering a business relationship with any Customer in order to prevent actions, such as money laundering or terrorist financing, and to perform other duties imposed by law.

The Company collects identity confirmation information from its Clients (e.g. copies, images, scans of the Client’s government-issued national identity card or international passport, or other government-issued identity document) or other information to verify authenticity. Umbrella Development B.V. also asks its Clients to provide the Company with a recent utility bill to verify the Client’s residential address. In addition, the Company may engage third parties to carry out identity checks on its behalf.

4rabet may request the following documents from its players to complete the entire KYC procedure:

1. A screenshot of the bank personal data page with the account number; 
2. A photo of the NATIONAL ID CARD and registration document on both sides; 
3. A selfie with a sheet of paper where login, date, and the inscription “4rabet” are written. And also identity documents; 
4. Take a video where you go to the bank app/website, open your profile, and show the outgoing transaction, where you can see: the time, the recipient of the payment, and the amount. If the video quality is low, the complaint may be rejected.

Compliance with a legal obligation

There are a number of legal obligations emanating from the relevant laws to which the Company is subject, as well as other statutory requirements.

Such obligations and requirements impose on Umbrella Development B.V. are necessary for personal data processing activities for credit checks, identity verification, compliance with court orders, tax law or other reporting obligations, and anti-money laundering controls.

Purposes of safeguarding legitimate interests

The company processes personal data to safeguard the legitimate interests pursued by Umbrella Development B.V. or by a third party. A legitimate interest is when Umbrella Development B.V. has a business or commercial reason to use the Customer’s information. Even then, it must not unfairly go against what is right and best for the Customer.

Examples of such processing activities include:

• Initiating court proceedings and preparing our defence in litigation procedures;
• Means and processes we undertake to provide for the Company’s IT and system security, preventing potential crime, asset security, admittance controls, and anti-trespassing measures;
• Measures to manage the business and for further developing products and services;
• The transfer, assignment (whether outright or as security for obligations), and/or sale to one or more persons and/or charge and/or encumbrance over, any or all of the Company’s benefits, rights, title, or interest under any agreement between the Customer and the Company.

Marketing Purposes

The Company may use Customer Data, such as location or transaction history to deliver any news, analysis, research, reports, campaigns, and training opportunities that may interest the Customer, to their registered email address.

The customer always has the right to change the option if he no longer wishes to receive such information.

CONTROLLING AND PROCESSING CUSTOMER’S PERSONAL DATA

Umbrella Development B.V. and any agents that it engages for the purpose of collecting, storing, and processing personal data and any third parties acting on the Company’s behalf, may collect, process, and store personal data provided by the Customer.

For the purpose of processing and storage of personal data provided by the Customer in any jurisdiction within the European Union or outside of the European Union, the company can confirm this will be done in accordance with applicable laws.

Authorized Processor

The GDPR sets out what needs to be included in the contract to which the company has adhered to, the below is not an exhaustive list of the obligations of all relevant parties:

1. Such third parties must only act on the written instructions of our company (unless required by law to act without such instructions).
2. Ensure that people processing the data are subject to a duty of confidence.
3. Take appropriate measures to ensure the security of processing.
4. The rights of Customers will not be impaired in meeting GDPR requirements.
5. The security of processing, the notification of personal data breaches, and data protection impact assessments will not be impaired.
6. Deletion or return of all personal data as requested at the end of the contract.
7. Such providers will provide various services as agreed with the Company.

Umbrella Development B.V. has a regulatory obligation to supervise and effectively oversee the outsourced functions and to act appropriately when it determines that the service provider is not performing the said functions effectively and in accordance with the applicable legislation.

It’s may use or disclose personal information without the Customer’s consent only in certain circumstances:

• if required by law or by order of a court, administrative agency, or other government entities;
• if there are reasonable grounds showing disclosure is necessary to protect the rights, privacy, property, or safety of Customers or others;
• if we believe the information is related to a breach of an agreement or violation of the law, that has been, is being, or is about to be committed;
• if it is necessary for fraud protection, risk reduction, or the establishment or collection of funds owed to us;
• if it is necessary to enforce or apply the Terms and Conditions and other agreements, to pursue remedies, or to limit damages to our company;
• for other reasons allowed or required by law;
• if the information is public.

Where the Company is required or permitted to disclose information without consent, the Company will not disclose more information than is necessary to achieve the disclosure objective.

Umbrella Development B.V. informs all Customers to maintain confidentially and not to share with others its Customer names and private passwords or as provided by the Company. The Company bears no responsibility for any unlawful or unauthorized use of Customers’ personal information due to the misuse or misplacement of Customers’ access codes (i.e. passwords/credentials), negligent or malicious, however, conducted.

HOW THE COMPANY TREATS CUSTOMER’S PERSONAL DATA FOR

MARKETING ACTIVITIES

The Company may process Customers’ personal data to inform Customers about products, services and offers that may be of interest to them. The personal data that Umbrella Development B.V. processes for this purpose consists of information that Customers provide to the Company and data that Umbrella Development B.V. collects and/or receives when the Customer uses the services of the Platform, such as information about Customer transactions. The company studies all such information to form a view on what is needed or what may be of interest to Customers.

In some cases, profiling may be used. Profiling is a process whereby customer data is automatically processed in order to evaluate certain personal aspects and further provide customers with targeted marketing information about products.

The Company’s website uses third-party technology to help the Company recognize the Customer’s device and understand how the Customer uses the Company’s website so that Umbrella Development B.V. can improve its services with the Customer in mind and advertise for services that may be of more interest to the Customer.

Specifically, these partners collect information about the Customer’s activity on Company’s site to enable Company to:

• measure and analyze traffic and browsing activity on Company’s site;
• show advertisements for Company’s services to Customers on third-party sites;
• measure and analyze the performance of the Company’s advertising campaigns.

The company may share data, such as hashed emails derived from emails or other online identifiers collected on Company’s site with Company’s advertising partners. This allows Company’s partners to recognize and deliver ads to Customers across devices and browsers.

Umbrella Development B.V. can only use Customer’s personal data to promote its products and services to Customers if Umbrella Development B.V. has the Customer’s explicit consent to do so – by clicking on the tick box during the account opening form – or in certain cases if the Company considers that it is in their legitimate interest to do so.

Further, Customers have the option to choose whether they wish to receive marketing related emails (company news, information about campaigns, the company’s newsletter, the company’s strategic report, etc.) to the Customer’s provided email address by clicking the relevant tick box during the account opening form.

The company’s partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. The customer’s browser may not permit blocking such technologies. For this reason, Customers can use the following third-party tools to decline the collection and use of information for the purpose of serving Customer interest-based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform: http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Customers have the right at any time to object to the processing of Customer personal data for marketing purposes or to unsubscribe from marketing-related emails provided by the Company by contacting the Company’s customer service department at any time by the following means:

1. By Email: support@4rabet.com
2. Customer support via the platform

Period of keeping Customer’s personal information

The Company will keep Customer’s personal data for:

1. As long as a business relationship exists with the Customer, either as an individual or in respect of our dealings with a legal entity Customer is authorized to represent or are a beneficial owner of.
2. Once the business relationship with Customers has ended, Company is required to keep the Customer’s data for a period of five years to meet regulatory and legal requirements. In some cases, this period may be extended.

When Company no longer needs personal data, it will securely delete or destroy it.

CUSTOMER’S RIGHTS

The customer has the right to request copies of their personal data. The information must be provided immediately and no later than one month after receipt. The company will be able to extend the deadline for a further two months if the requests are complex or numerous. In this case, we will inform customers within one month of receiving the request and explain why an extension is necessary.

Umbrella Development B.V. must provide a copy of the information free of charge. However, the Company can charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive.

The fee, if applicable, will be based on the administrative costs of providing the information and the costs of delivery if the Customer requests this information in hard copy. If we refuse to respond to a request at any time, we will explain to the Customer the reason for the refusal by informing them of their right to complain to the supervisory authority and to take legal action without undue delay and no later than within one month.

Other related information

Umbrella Development B.V. uses appropriate technical, organizational, and administrative security measures to protect any information stored in its archives against loss, misuse, as well as unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized access or use, hardware or software failure, and other factors may at any time compromise the security of Customer information.

Among other practices, the Customer’s account is protected by a password for the Customer’s privacy and security. Customers must prevent unauthorized access to Customer’s account and Personal Information by selecting and protecting Customer’s password appropriately and limiting access to Customer’s computer or device and browser by signing off after you have finished accessing Customer’s account.

Transmission of information via regular email exchange is not always completely secure. The Company however exercises all possible actions to protect Customers’ personal data, yet it cannot guarantee the security of Customer Data that is transmitted via email; any transmission is at the Customers’ own risk. Once the Company has received the Customer information it will use procedures and security features in an attempt to prevent unauthorized access.

RAISING A CONCERN

The customer has the right to be confident that Umbrella Development B.V. handles the Customer’s personal information responsibly and in line with good practice.

If a Customer has a concern about the way the Company is handling Customer’s information, or for example if a Customer feels we may not be:

• keeping Customer’s information secure;
• holds inaccurate information about you;
• has disclosed information about you;
• is keeping information about you for longer than is necessary;
• has collected information for one reason and is using it for something else.

We take all concerns seriously and will work with you to resolve any such concerns.

Any concerns and/or requests can be raised to the appointed Data Protection Officer whose contact details are below – Email: support@4rabet.com

The client has the right to take legal action or to escalate their complaint to the data protection regulator in their jurisdiction to protect their rights unless applicable law prescribes a different procedure for dealing with such claims.

CHANGES TO THIS PRIVACY STATEMENT

 The Company reserves the right to modify or amend this Privacy Statement unilaterally at any time in accordance with this provision.

If any changes are made to this privacy statement, we shall notify you accordingly. The revision date shown on at the end of this page will also be amended. We do however encourage you to review this privacy statement occasionally so as to always be informed about how we are processing and protecting Customer’s personal information.

COOKIES

The company’s website uses small files known as cookies to enhance its functionality and improve the Customer’s experience.

A cookie is a small text file that is stored on a Customer’s computer for record-keeping purposes. The company uses cookies on the Platform(s). Umbrella Development B.V. links the information it stores in cookies to any personally identifiable information Customer submits while on the Platform. Umbrella Development B.V. uses both session ID cookies and persistent cookies. A session ID cookie does not expire when the Customer closes his browser. A persistent cookie remains on the Customer’s hard drive for an extended period of time. Customers can remove persistent cookies by following directions provided in the Customer’s Internet browser’s “help” file.

The company sets persistent cookies for statistical purposes. Persistent cookies also enable the Company to track and target the location and interests of our customers and to enhance the experience of the Company’s services on the Platform.

If the Customer rejects cookies, the Customer may still use the Platform.

Some of the Company’s business partners use cookies on the Platform. The company has no access to or control over these cookies.

MONITORING AND REVIEW

The Company will monitor on a regular basis the effectiveness of this Policy and, in particular, the execution quality of the procedures explained in the Policy and, where appropriate, it reserves the right to correct any deficiencies.

In addition, the Company will review the Policy at least annually. A review will also be undertaken whenever there is a material change that affects the Company’s ability to continue to achieve the best possible result in the execution of Client Orders on a consistent basis using the sites included in this Policy.

The Company will inform its Customers of any material change to this Policy by posting an updated version of this Policy on its Website(s).