PRIVACY POLICY

General

As a data controller, we have a legal obligation under gambling regulations to process personal data from players in order to allow them to participate in games and provide them with ancillary services. This Privacy Policy explains what personal data we collect from players, why we collect it and how we utilise it.

If you have any other questions regarding this Privacy Policy or protection of your data, please feel free to contact our Data Protection Officer at [email protected].

By registering a Player Account with the Website you confirm your consent with this Privacy Policy. If you do not agree with the terms of this Privacy Policy and do not wish to provide us with the personal information we require, please do not use this website.

About us

WillBet is operated by Novisoft NV, a company registered in Curaçao with Company Number 163608 and with a registered address at: Zuikertuintjeweg Z/N, Curaçao. Novisoft NV ("Company"; "We"; "Us"; "Our") is licensed and regulated by the Curaçao Gaming Control Board (GCB) under License Number 0GL/2024/1394/0725, issued on 11/Nov/2024. Trust Services are represented by IGA Group.

This Privacy Policy is intended to describe the WillBet services (as defined in the WillBet’ Terms of Use) and our privacy practices that display or reference the principles. This Privacy Policy sets out how WillBet will manage your personal data which we collect as a result of your membership of WillBet, your use of our websites located at https://WillBet and any pages or websites under the WillBet’s brand including any mobile phone or tablet applications that are owned and/or operated by us or whenever we otherwise deal with you. We are committed to ensuring that the personal information we collect about you is protected and is used, stored, and disclosed in accordance with the applicable privacy Act and this Privacy Policy.

Please note that this Privacy Policy constitutes an agreement between you and the Company. We may periodically make modifications to this Policy. While we will do our best to notify you of such changes, we recommend that you revisit this Privacy Policy regularly. Your continued use of the Website and/or its services will constitute your consent to the Privacy Policy. 

This Privacy Policy applies only to our online activities and is valid for visitors to our Website with regards to the information that they shared and/or collected at willbet.com. This Privacy Policy is not applicable to any information collected offline or via channels other than this website.

Consent

We ask for your consent to process your information for specific purposes and you have the right to withdraw your consent at any time. However, by using our website, you hereby consent to our Privacy Policy and agree to its terms.

Privacy

We are committed to protecting your personal information. This Privacy Policy lets you know what information we collect when you use our services, why we collect this information, and how we use the collected information.

Please note that this Privacy Policy will be agreed upon between you and WillBet. (“We,” “Us,” or “Our,” as appropriate). This Privacy Policy is an integral part of WillBet’s Terms and Conditions.

We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on our platforms. We recommend that you revisit this Privacy Policy regularly.

Informations Collected

By “personal data” shall be understood any information relating to an identified or identifiable person; an identifiable natural person is the one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, email or an online identifier. In some cases, WillBet may collect "sensitive" personal information. (including information about race and national origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership, and information about sex life or sexual orientation), or health information, and where permitted by law relating to, alleging or substantiated criminal information.

We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address. The source of the contact data is our registration form, contact form, and information provided in your Account.

We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, account creation and modification dates, website settings. The primary source of the account data is you; some elements of the account data may be generated by our website.

We may process information relating to “technical and financial data, usage data”. Meaning, when you visit our Website and/or use our Services, we may collect technical and financial information about you, which may include: IP address, locale, registration date, log-in dates, associated affiliate, affiliate-related statistics (the source of your traffic to our Site, data on your views and clicks on our promotional materials), self-exclusion dates and periods, ban dates and periods, failed log-in attempts count and time, Account balance, Account bonus funds, Account real money funds, transaction dates, transaction values, transaction identifiers, total bonus amount, total bonus count, total deposit amount, total deposit count, total withdrawal amount, total withdrawal count, pending withdrawal amount, pending withdrawal count, error withdrawal amount, error withdrawal count, deposit/withdrawal ratio, total income, games played and games’ IDs, player ID, number of bets, casino stake, game session statistics (session ID, game name, provider name, rolls, session start time, session finish time, vendor round ID, total bet, real money bet, bonus money bet, total win, teal win, bonus win, total balance after, bonus balance after), pages visited, device used, nick name (alias), session identifier, chat data when you communicate with us (your IP address, domain, browser type, operating system type, first name and last name (if nessesary), email, title, username, chat history, contact details), other information which may be used to identify your transactions with us (operation ID, transaction ID, start date, end date, sum, order number, transaction number, method, status, processing system, payment system and technical parameters of your device and software you use to access our Website.

We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. We may generate the metadata associated with communications made using the contact forms.

Use of Personal Data

We may combine and use information we hold about you (including information received on and off our Services) to understand how you use and interact with our Services and to understand who you are connected to and interested in. things to provide, personalize and improve our services. We may also use the information we hold about you globally for the following purposes:

• Provide, maintain, improve and develop related functionality, content and services.
• Analyze your content and other information.
• Fulfill your requirements and use when authorized by you.
• Help connect advertisers and application/website operators to provide relevant advertisements in their applications and websites.
• Match and serve targeted marketing ads (regardless of device or use of our services) and provide targeted marketing ads based on your device activity, estimated interests and targeting information.
• Contact you with account-related information or send marketing messages according to your wishes.
• Associate your activities on our various services and your different devices, and associate all accounts you may use on various WillBet services. We may associate activity and accounts under a single user ID.
• Conduct or support marketing promotion activities.
• Conduct research and support innovation.
• Provide analysis and reports on the usage and trends of our services and advertising to external parties (including partners, application/website operators, advertisers, applications, third parties and the public), including displaying and reporting to partners Trends related to public preferences, ad performance, and user experience information. These analyzes and reports may include aggregated or pseudonymized information.
• Provide services, ads, search results, and other content that match your targeting settings based on your targeting information.
• Combine the information we hold about you with information we obtain from business partners or other companies (such as your activity on other websites and apps).
• Processing your bets and transactions. This includes your use of credit card and online payment systems;
• Providing you with gaming and other ancillary services that you seek from our Website;
• Rendering customer support, such as assistance with setting up and managing your account;
• Identifying and performing the necessary verification checks;
• Providing registered players with information about our promotional offers, or providing promotional information from our selected business partners, associates and affiliates (only if players specifically consented to receiving such marketing material);
• Complying with legal responsibilities, including complying with anti-money laundering (AML) and combating the financing of terrorism (CFT) laws;
• Monitoring and investigating transactions for the purposes of preventing fraud, terms abuse, money laundering and other illegal or irregular gaming activities;

Unless it is required by law, your personal data will not be disclosed to third parties. As WillBet business partners or suppliers or service providers may be responsible for certain parts of the overall functioning or operation of the Website, personal data may be disclosed to them. The employees of WillBet have access to your personal data for the purpose of executing their duties and providing you with the best possible assistance and service. You hereby consent to such disclosures.

WillBet is using users’ information for marketing purposes. However, we respect users’ privacy. If users do not wish to receive any promotional materials, they can choose such an option during registration or unsubscribe at any time.

Log Files

WillBet follows a standard procedure of using log files. These files log visitors when they visit the website. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Our Use of Cookies

We may place and access certain Cookies on your computer or device. A Cookie is a piece of information in the form of a very small text file that is placed on an internet user's hard drive. It is generated by a web page server, which is basically the computer that operates a website. The information the Cookies contain is set by the server and it can be used by that server whenever the user visits the site.

Our servers use three different types of cookies:

• A ‘session-based’ cookie: This type of cookie is only allocated to your computer for the duration of your visit to our website. A session-based cookie helps you move around our website faster and, if you’re a registered customer, it allows us to give you information that is more relevant to you. This cookie automatically expires when you close your browser.
• A ‘persistent’ cookie: This type of cookie will remain on your computer for a period of time set for each cookie. Flash cookies are also persistent.
• Analytical’ cookies: This type of cookie allows us to recognize and count the number of visitors to our site and see how visitors use our services. This helps us improve the way our sites work, for example, by ensuring you can find what you are looking for easily.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether.

We also use Local Shared Objects or ‘flash cookies.’ ‘Flash cookies’ are similar to browser cookies. They allow us to remember things about your visits across our sites. Neither cookies nor flash cookies can be used to access or use other information on your computer. We only use these methods to track your use of our services. Cookies help us monitor traffic to the site, improve our services, and make it easier and/or more relevant for your use. We use flash cookies and third-party cookies to help us show you more relevant and desirable advertisements.

By using our Website, you agree to the use and storage of Cookies on your computer or device. If you do not wish our Website to use Cookies on your computer or device, you can at any time deactivate and delete Cookies through your browser settings. More information on Cookies and how to disable and delete them may be found at https://www.aboutCookies.org/Cookie-faq or http://www.allaboutcookies.org. Please note, however, that if you refuse or delete Cookies, certain portions of our Website may not function properly, and we may not be able to offer you certain services.

We use the following cookies:

“Necessary” cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

“Preferences” cookies enable a website to remember information that changes the way the website behaves or looks, like the region that you are in.

“Statistics” cookies help the website to understand how visitors interact with websites by collecting and reporting information anonymously.

“Security” cookies are used as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials and protecting our website and services generally.

“Authentication and status” cookies are used to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website.

“Marketing” cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user, and thereby more valuable for publishers.

We use both first-party and third-party Cookies. First-party Cookies are those placed directly by Us and are used only by us. We use Cookies to facilitate and improve your experience of the Website and to provide and improve our products and services. By using our Website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. In addition, we use analytics services, which also use Cookies. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling us to better understand how people use the Website.

The website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses Cookies to help the website analyze how users use the site. The information generated by the Cookie about your use of Our Site (including your IP-address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to analyze your use of the Website, compile reports on Website activity for us, and perform further services associated with Website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent third parties process these data on behalf of Google. You can opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: tools.google.com/dlpage/gaoptout.

Sharing of data

Due to the nature of our service, in order to process your data as explained above of this Privacy Policy, we may need to share your personal data with a number of trusted third parties. These third parties include:

Any member of the Group which requires access to your personal information in order to provide the services you request. Data we receive and collect on you maybe shared with any member of the Group and such data may be used by them for fraud and bonus abuse prevention, AML and Responsible Gaming Reasons in fulfillment of the Group’s legal obligations and legitimate business interests;

To all members of the Group for the purposes of such other group entities to contact you with information on their products and services, provided that you have consented to receive direct marketing related to other sites operated by the Group.

—Employees of the Company, more specifically Data Protection Officer, Money Laundering Officer, Payments & Anti-Fraud analysts, Customer Support agents, Customer Retention team members, VIP player managers as well as other selected employees, shall also have access to your Personal Information for the purpose of executing their duties and providing you with assistance as well as to provide the services you requested

Our employees who have access to, or are associated with the processing of the player’s personal information, have signed confidentiality agreements (NDA) to respect the confidential nature of the player’s information.

Game providers – sometimes our game providers would require access to select data attributes (such as username and IP address, for instance), in order to provide us with the games you play on our website. To check their privacy notice please visit the relevant website of Game provider;

When you play casino games developed by NetEnt, NetEnt’s Privacy Policy also applies. This policy can be found on NetEnt Privacy Policy page.

• Payments providers and related service providers – similarly, we may share some of your personal data with the payment providers you use to make and receive payments on our website. To check their privacy notice please visit the relevant website of Payment provider you’ve used;

If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies. (In particular, most banking card transactions are processed by Trustly whose Trustly privacy policy applies to such transactions. Transactions may also be processed by Bambora or Paysafe);

• Marketing partners—where you give us your consent to send you marketing and promotions, we may share your contact details (such as email address or mailing address) with our marketing partners who take care of sending out all our marketing material to you including promotional emails and SMS, direct mail, and at times to makes calls to you.
• Governmental or regulatory authorities—We may, if necessary or authoriяed by law, provide your personal data to law enforcement agencies, governmental or regulatory organizations, courts or other public authorities. We may dispute such demands when we believe that the requests are disproportionate, vague or lack proper authority, but we do not promise to challenge every demand;
• Client communication software – we use a third-party software to help us communicate with you. This software enables us to send you emails and chat with you on live chat whenever you have queries;
• AML and fraud verification tools, suppliers of age and identity verification tools and other suppliers that can verify Know Your Client (KYC) information generally– we may use third party software to conduct certain AML and fraud verification checks which are required to satisfy our legal obligations in this regard.
• In addition to the above, we may also release personal data if we acquire any new businesses. Should the Company undergo any changes to its structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that our customers’ personal data will be included within the sale or transfer. We will, as part of our Policy, inform our players by email prior to affecting such transfer of personal data.
• Selected third parties, under a data processing agreement with us that ensures the safeguard of your personal information, including:
• with our lawyers, advisors, consultants who we may engage from time to time to manage risks, obtain professional advice, or to establish and defend our legal claims, whether in court or in an out-of-court procedure. This may require to gain access to personal information;
• with governmental bodies, regulatory authorities who register problem gamblers or for any other responsible gaming purpose.
• with any company, governmental body, regulatory authority that maintains a register or database having the objective of preventing crime, money laundering or terrorist and proliferation financing.

We always ensure that any third party having access to your personal data is bound to respect the security of your personal data, and to process it in a lawful manner at all times and in compliance with our Privacy Policy and strict codes of conduct. We do not allow any third-party service providers to use your personal data for their own purposes. Processing by such third parties (also known as “Data Processors”) is solely carried out for specific purposes and in accordance with our instructions as Data Controller and on our behalf, and such third parties may only use your personal data to the extent to which we ourselves are entitled. Furthermore, in all cases, we strive to ensure that we do not share more data than is necessary to be shared for the service providers to carry out the processing activities in accordance with our instructions.

Releasing Data to Third Parties

We do not sell or rent your personal data to third parties.

We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party.

Personal data will only be disclosed to third parties in the following cases:

• Where we are required to do so by law;
• If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies. (In particular, most banking card transactions are processed by Paysafe whose privacy policy applies to such transactions);
• To comply with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;
• When the Company believes that disclosure is necessary to protect the Company’s or the player’s safety, or the safety of others, investigate fraud, or respond to a government request;
• If our marketing service providers require the data to carry out their tasks;
• To any other third party with the player’s prior consent to do so.

We use third-party data processors to process limited personal data on our behalf. Such service providers support the Website, especially relating to hosting and operating the websites, marketing, analytics, improving the websites, and sending email newsletters. We shall ensure that the transfer of the Personal Data to the recipient is compliant with applicable Data Protection Legislation and that the same obligations are imposed on the processor as is imposed on us under the respective Services Agreement.

Our websites may also include social media features (e.g. “share” or “like” buttons). Such features are provided by third-party social media platforms such as Facebook. Where data is collected this way, its processing is governed by the privacy policy of the respective social media platforms.

In addition to the above, we may also release personal data if we acquire any new businesses. Should the Company undergo any changes to its structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that our customers’ personal data will be included within the sale or transfer. We will, as part of our Policy, inform our players by email prior to affecting such transfer of personal data.

Please note our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

Data Retention

We shall only retain your personal data for as long as necessary in view of the purposes for which they were collected. Such purposes could include the satisfaction of any legal, accounting, or reporting requirements.

When determining the appropriate retention period applicable to your data, we take several factors into consideration, such as the purposes for which we collect and process such data, the applicable laws and/or regulatory requirements imposed on us, the nature and sensitivity of the personal data, and the potential risks surrounding the unauthorized use or disclosure of such data.

As stated under our Terms and Conditions both, you and the Casino can decide to have your Player Account closed at any time. Following closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.

We may also keep anonymized derivatives of your data to improve our content and marketing communications where no automated decision making is involved.

Your rights

Data protection law gives you, as a data subject, certain rights in certain circumstances. In accordance with law, you have a right to:

• Request access to your personal data—This means that you have a right to request, free of charge, a copy of the personal data we hold about you;
• Request the correction of your personal data – This means that if any personal data we hold about you is incomplete or incorrect, you have a right to have this corrected. Keep in mind, however, that we may need you to provide evidence and documentation (such as your ID documentation or proof of address) to support your request. It can be declined due to our legal obligations
• Request the erasure of your personal data—This means that you may request the erasure of your personal data where we no longer have a legal basis to continue processing it or retaining it. Please be aware that this right is not absolute – meaning that we are not able to satisfy your request where we are obliged under a legal obligation to retain the data, or where we have reason that the retention of data is necessary for us to defend ourselves in a legal dispute;
• Object to the processing of your personal data where we rely on our legitimate interests (or those of a third party) to process your data and you feel that our processing of your data in such a manner impacts your fundamental rights and freedoms. However, in some cases, we may be able to demonstrate that we have a compelling legitimate ground to process your data which may override your rights and freedoms. You may submit your objections to processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our DPO;
• Request the restriction of the processing of your personal data – You may ask us to temporarily suspend the processing of your personal data in one of the following scenarios: (a) where you want us to establish the accuracy of the data, (b) where our use of the data is unlawful but you do not wish for us to delete it, (c) where you need us to retain your data even when we no longer need it in order for you to establish, exercise, or defend legal claims, or (d) where you have objected the use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• Request the transfer of your personal data (i.e. data portability) – This means you may request us to provide you with certain data we process about you so you may transfer it to another controller. This right only applies to data acquired through automated means which you initially provided consent for us to use, or where we used the data to perform our obligations under a contract with you;
• Withdraw your consent at any time where we rely on your consent to process the data—‘Opting out’ or withdrawing your consent will not affect the lawfulness of the processing carried out by us up until the time you withdraw your consent. Withdrawing your consent means that, going forward, you no longer wish for us to process your data in such a manner. This means that you may no longer consent for us to provide you with certain services (such as marketing. You may withdraw your consent at any time through the account profile settings on the website;
• Lodge a complaint with a supervisory authority;

In order to exercise your rights as explained above, we may need to request specific information about you to help us verify your identity. This is a security measure to ensure that we are certain that the person to whom we disclose your personal data is really you.

We will do our utmost to respond to all legitimate requests within a one-month timeframe from the submission of a request. If your request is particularly complex, or if you have made multiple requests in a certain time period, it may take us a little longer. In such a case, we will notify you of this extension.

Automated Decision Making

In establishing and carrying out our business relationship, we generally do not make use of fully automated decision making. If we use this procedure in individual cases, we shall inform you of this separately, provided it is a legal requirement.

Security of Your Data

We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Player Account, we are bound by strict legal provisions on the protection of personal data.

Consequently, we endeavour to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations. Being committed to providing secure services to players, and we will take all reasonable precautions to ensure that all the data that you have submitted to us remains safe.

Player Accounts can only be accessed with the player’s unique ID and password. You may also set up two-factor authentication (2FA) as additional protection from unauthorised use of your account. You are responsible for keeping your login information confidential and making sure it cannot be accessed by another person.

Changes to our Privacy Policy

We may make changes to our Privacy Policy in the future, however, the most current version of the policy will govern our processing of your personal data and will always be available to you. If we make a change to this policy that, in our sole discretion, is material, we will notify you by an update or email, where possible. By continuing to access or use our services, you agree to be bound to the terms of our Privacy Policy.

The WillBet is committed to protecting the privacy of your personal information online. If you have any questions or comments about our management of your personal information, please contact us at [email protected]. If you have any questions about this privacy statement, you can also report it to us through the above email address. If you are not satisfied with the response you receive, you can continue to report your concerns to us via the email address.

We will confirm your email within three (3) days and strive to resolve your problem within one (1) month after receipt or within an appropriate period not exceeding the legal requirements. If the relevant issue is more complex or a large number of issues are received, we will notify you that it will take more than 1 month to resolve the issue, and we will try to resolve your issue within 2 months after we first receive the issue. We may accept your question in accordance with the law. We may reject requests that are unreasonable or outside legal requirements, including requests that are highly impractical, require a disproportionate amount of technical effort, or may expose us to operational risks such as condoning fraud.

Children

Our services are not directed to individuals under the age of 18. If we become aware that we have collected Personal Information from individuals under 18, we will take steps to delete such information.

Contact Information

If you have any questions about this Privacy Policy, please contact us at [email protected].

NOTE : The English version shall take precedence. In the event of any discrepancy or objection, the English version shall prevail.