KYC Policies, Privacy & Management of Personal data of betonred.ng operated by DXG HOSPITALITY LIMITED.

INTRODUCTION

This KYC and Privacy Policy sets out the «Know your Customer» and data processing practices carried out by betonred.ng. Here at betonred.ng we like making things simple and easy for our customers and that includes being clear, transparent and open about what we collect, and how and why we use the data we collect, so this page goes into great details

Our Policy explains how we use your personal data, whether you are just visiting, making a deposit or playing one of our games. This policy includes information you may not already know about your data privacy rights, circumstances in which we share and obtain information about you and how we use it to personalize the marketing you receive, so please take time to read all the sections carefully.

Please note that all our employees undertake regular training on Information Security and are required to comply with confidentiality obligations as well as internal policies and procedures whenever they handle your information.

We hope you will find this page helpful, but should you have any concerns or questions, regarding Data Protection, please feel free to contact our Data Protection Officer at support@betonred.ng.

We hope you will find this page helpful, but should you have any concerns or questions, regarding Data Protection, please feel free to contact our Data Protection Officer at dpo@betonred.ng.

SECTION 1. KYC

The Company reserves the right to carry out verification procedures for each client at first withdrawal. Such verifications may for example include copies of a player’s passport, national Identity Card, copies of a player’s utility bills, and/or copies of the debit/credit cards used to deposit.

It's the responsibility of the player to ensure that all documents as a part of the KYC process are genuine. Faked or fraudulent documents provided may result in a confiscation of deposits and potential winnings of the player.

In order to make a withdrawal, a player must play through active deposited amounts at least once prior to withdrawal. This procedure is in line with anti-money laundering practices.

The Company reserves the right to use additional procedures and means to verify a client's identity (Know Your Client) when effecting deposits into the account. This could include (but is not limited to) a selfie with a document or form of identification. In order to verify a player`s account, sport betting management requires documents (ID, payment systems, utility bills еtc) in Latin or Cyrillic alphabet. In case a player doesn’t have an opportunity to provide documents in above-mentioned alphabets, the reserves the right to demand video verification where the player shows his/her documents.

The Company reserves the right to make a phone call to the number provided in the client's account, which can be a necessary part of the KYC procedure. Until the account is fully verified, no payouts will be processed.

SECTION 2. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

We collect personal information when you interact with us and use our services (the "Services"). Sometimes, this information is provided to us by you – like when you register for the first time and when you make use of our products or get in touch with us. Sometimes third parties or publicly available sources provide us information about you.

SECTION 3. INFORMATION YOU PROVIDE TO US

At registration:

Your personal details, such as your name, email address, postal address, telephone or mobile number, gender or date of birth;
Photographic identification and proof of address documents (to carry out due diligence)
Banking and financial details (to establish the source of funds where a transaction is involved)
Your account login details, such as your username and password

Through your use of our Services:

Information about how you interact with our products
Information about your online browsing behavior on the Website – please see our Cookies Policy for more details;
Information about any devices you have used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier)
Recording phone calls – we may monitor or record phone calls with you. We might do this to check that we have carried out your instructions correctly; to resolve queries or issues; for regulatory purposes; to help improve our quality of service; to help us train our staff; or to help detect or prevent fraud or other crimes.
Information you shared with us voluntarily or else, made public, like social media profiles.

Special categories of data

Personal data collected by Betonred.ng may include so-called “special categories of data”, such as data revealing health (responsible gambling related) (see Section «Why do we collect your Personal Data and on what basis»).
We have in place additional measures to protect your sensitive personal data and its confidentiality (see Section «Security of your data and confidentiality»).

SECTION 4. WHY DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT BASIS?

We recognize the trust and confidence our customers place in us as a service provider. In return, betonred.ng is open about why we collect your data. First and foremost, collecting your information is essential for providing you the services and products you want. In addition, your data is used to personalize and improve your experience using our services, and to contact you from time to time with important information. In some cases, we need to collect and use your information to comply with the law. Under data protection laws, we also need to identify a specified lawful basis upon which we are processing your personal information. We rely on different bases for different processing activities.

A) Under the contract – when it is necessary for the performance of a contract to which you are a party. Our T&Cs, which you have accepted at registration, set out the terms of the contract and the services we will provide:

To make our services available to you as part of our contract

to provide gaming and betting services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
for 'service administration purposes', such as password reminders, service messages, such as site maintenance, updates to our Privacy and Cookies Policy or T&Cs, to let you know if your betonred.ng account has become dormant and to ask if you would like to use it again before we close it;
to process your transactions;

B) Under legitimate interests - It is necessary to process your data for the purposes set out below, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine if we can process your data on this basis, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.

To personalize your experience

to offer a more relevant, tailored service; for instance, we could use your playing history to provide personalized recommendations and products;
If you are signed-in or subscribed to our marketing offers, you will receive a personalized service. If you don’t want to receive these services you can unsubscribe from marketing offers, or disable personalization by contacting our Customer Service or sending an email to our Data Protection Officer

To improve our services and products

to provide you with the most user-friendly online navigation experience;
for analysis and research purposes so that we may improve the services offered by betonred.ng;
testing new systems and checking upgrades to existing systems;
evaluating the effectiveness of marketing and for market research and training;
customer modeling, statistical and trend analysis, with the aim of developing and improving products and services.

To contact and interact with you

Contact you about our services, for example by phone, email or post or social media;
Manage promotions and competitions you choose to enter;
Invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by betonred.ng and by other organizations on our behalf (We carry out market research to improve our services, however, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice and this will not affect your ability to use our services);
Respond to your queries and complaints.

To make your game safer and more enjoyable

to deter, prevent or detect the use of third party software in peer-to-peer gambling;
to deter, prevent, or detect any activities conducted in breach of our T&Cs;
to perform affordability checks to ensure you have sufficient funds to use our Services.

C) Under your consent

Marketing and market research

We will send you relevant offers and news about our products and services in a number of ways including by email, sms, phone call, post, social media targeted advertising, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.

If you don’t want to be shown targeted advertising messages from us, some third party sites allow you to request not to see messages from specific advertisers on that site in future. If you want to stop all personalized services from us, including targeted advertising messages on third party sites you can contact our Customer Service or email our Data Protection Officer to disable personalization. We also like to hear your views to help us to improve our services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

D) Special categories of data

We will only process such data if:

you have given us your explicit consent;
it relates to personal data which you have made public;
it is necessary for the establishment, exercise or defense of legal claims;
is necessary for reasons of substantial public interest, on the basis of Nigerian law.

SECTION 5. COOKIES AND SIMILAR TECHNOLOGIES

Betonred.ng’s website uses cookies for various purposes.

We use cookies for the following purposes:

to identify the Account Holder's preferred language, so it can be automatically selected when the Account Holder returns to the Website;
to ensure that bets placed by the Account Holder are associated with the Account Holder's betting coupon and Account;
to ensure that the Account Holder receives any bonuses for which they are eligible, and
for analysis of the Website traffic, to allow Betonred.ng to make suitable improvements.

SECTION 6. WHEN DO WE SHARE YOUR PERSONAL INFORMATION?

We do not share your personal information to third parties outside the Company for marketing purposes. However, there are circumstances when we share your personal data with other companies, with third parties that provide services to you on our behalf, and with other third parties in the course of complying with our legal obligations. Other examples of when we share your personal information include when we enter any kind of merger or business sale, as customers’ personal information is likely to be included in the sale/transfer. We would inform you prior to affecting such transfer of personal data. Even when it is shared, we ensure that your personal information will only be used for the purposes outlined in this Privacy policy.

We may share personal data with third parties in the following circumstances:

when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law;
we may instruct and authorize the Financial Institution with which an Account Holder's account is held to disclose any information as may be requested by the Regulator in respect of an Account Holder's account;
in order to establish, exercise or defend our legal rights;
for verification, affordability checks and fraud detection purposes, we may transfer your personal data to third parties);
with service providers to enable us to provide our services, such as companies that help us with technology services, storing and combining data, and processing payments or providing relevant online advertising for our products and services;
with external auditors who may carry out independent checks as part of our accreditations;
to an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organization receiving your personal data can use your personal data in the same way as us;
to any other successors in title to our business; or
With the relevant regulator regarding the self-exclusion issues.

SECTION 7. HOW LONG WILL BETONRED.NG KEEP MY DATA?

We will only retain your information for as long as needed to fulfill the purposes for which they are collected.

While you are a customer, we will need to retain your information to meet our legal and contractual requirements. However, when you cease using betonred.ng Services, we will still retain your personal information for a period of time. There are several reasons why we retain your information, these include:

To comply with legal obligations under Nigerian/local laws (for example, anti-money laundering regulations, or licensing regulations);

To establish or defend legal claims (for example negligence claims) which could be made against us;
To comply with our contractual obligations and rights in relation to the information involved;
Our legitimate interests where we have carried out balancing tests;
To comply with guidelines issued by relevant data protection authorities.

SECTION 8. YOUR RIGHTS & CHOICES OVER YOUR PERSONAL INFORMATION

We appreciate that by law and subject to certain conditions, you have a number of rights concerning the personal information we hold about you. If you wish to exercise these rights, you should contact our Data Protection Officer at our email support@betonred.ng. These rights include the right to access, amend and erase the personal information we hold about you, the right to object to the processing of your data, the right to withdraw consent, and the right to data portability. You also have the right to complain to your data protection authority if you are concerned with how we process your information. In addition, you have certain rights relating to automated decision-making and ‘profiling’.

The personal information we ask for on registration is compulsory (unless indicated in the forms as optional) and we need it to be able to process your registration, contact you and comply with gambling and financial laws to which you are subject. Unfortunately, therefore, if you do not want to provide such personal information, you will not be able to use our services.

Right to access and rectify the information we hold about you

You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent by email to our Data Protection Officer or by contacting Customer Services at our email support@betonred.ng.

Right to delete your data

In some circumstances, you can ask us to erase personal information we hold about you (‘the right to be forgotten’). This includes when:

the information is no longer necessary in relation to the purpose for which it was collected (as explained in our privacy notice);
if you previously gave consent to the use of your information, but decide to withdraw it and we cannot justify another legal ground for using it under data protection law;
we process your information based on our legitimate interests and we cannot demonstrate overriding legitimate grounds to continue processing the information;
we don’t have a lawful ground under data protection law to process your information;
the data has to be erased to comply with a legal requirement;

This right is subject to mandatory retention periods under local laws.

Right to restrict processing

You have the right to ask us to restrict (‘block’ or ‘suppress’) the processing of your personal information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future. This right is available to you when:

you dispute the accuracy of the personal information (while we verify matters);
the processing is unlawful, and you object to the erasure of the information and request that we restrict processing instead;
we no longer need the data, but you require it to establish, exercise or defend a legal claim; and
we process your information for our legitimate business interests but you object and while we verify the grounds for continued processing.

Right to Data Portability

You have the right to receive personal information you provide to us, in a ‘commonly used machine-readable format’. This allows you to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a different provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however, and only arises when the processing of your information is:

based on your consent or where it is necessary for the performance of a contract, and
when the information is processed by solely by automated means

Right to object

Based on your particular situation, you can object to the processing of your personal information, that is:

based on our legitimate business interests (including profiling); or
done for research and statistical purposes

You also have the right to object to the use of your personal information for direct marketing purposes (including profiling).

Right to withdraw consent

When we rely on your consent as the basis to process your personal information – such as for sales and marketing communications – you have the right to withdraw your consent at any time. We’ll always strive to make it easy for you to withdraw consent by choosing an “unsubscribe” option in every communication you receive from us. If you find this isn’t the case, then just get in touch with our Data Protection Officer at email support@betonred.ng, and we’ll try to fix things as soon as possible.

Rights related to automated decision making, including profiling

We sometimes use systems to make automated decisions based on your personal information. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the ability to use our services.

We may use automate decisions making in the following situations:

tailoring products and services – we may pace you in groups with similar customers (segments) to study and learn about preferences and your needs, and offer more tailored experience for you;
detecting fraud - we use your personal information to help decide and detect if your account may be being used for fraud or money-laundering. If we think there is a risk of fraud, we may block or suspend the account;
opening account - when you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position;
risk assessment connected to your bet.

Data protection law seeks to safeguard individuals against harm that may arise from decision-making - including profiling - that takes place without human intervention. You have the right not to be subject to a decision - including profiling - when it is based on the automated processing of your personal information and it has a legal effect or a similarly significant effect on you.

Please note that the right does not apply when the processing is:

necessary for entering into or for the performance of a contract with you; or
when it is authorized by law; or
when it is based on your explicit consent.

Any requests relevant to this Section must be addressed in writing to our Data Protection Officer at email support@betonred.ng.

We will respond to any of your requests relevant to this Section within two (2) weeks from their receipt. Upon prior notice, this period may be extended by a further one (1) month if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.

If your request does not meet the requirements of the data protection law, we reserve the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action; or (b) reject your request.

SECTION 9. SECURITY OF YOUR DATA AND CONFIDENTIALITY

We are committed to protecting the personal information you entrust to us. We take all reasonable steps to ensure that all information collected through betonred.ng is treated securely and in line with this Privacy Policy and strict data protection standards. Accordingly, we have adopted robust procedures and technologies to protect your data from unauthorized access and improper use.

Your credit card details are encrypted by our payment providers . We are dedicated to protecting our customers’ confidential information and, as part of doing so, we are collaborating only with top payment providers.

The security of our systems and applications are tested several times per year by third-party security experts. Furthermore we have an Intrusion Detection System that monitors all network traffic 24/7 for signs of attacks or intrusions.

We have a dedicated fraud department and advanced systems in place to detect and prevent suspicious activity, to ensure that the betonred.ng remains a secure playing-field. Any account involved in suspicious activity will be suspended and investigated to the fullest extent. Should you as a user have any doubts about the activity on your account, such as unrecognized transactions in the transaction history or surprising changes in the balance, please contact us immediately.

SECTION 10. COMPLAINTS

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by emailing our Data Protection Officer at email support@betonred.ng.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to your national data protection regulator.

SECTION 11. CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be updated from time to time to reflect changes in the way we work or the way our work is regulated - so you may wish to check it each time you submit personal information to us. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to submit personal information to betonred.ng or use our Services in any way. Otherwise, by continuing to do this, you will be deemed to have accepted the changes to the Privacy Policy. You can also delete your betonred.ng account at any time. If significant changes are made to the Privacy Policy, for instance affecting how we would like to use your personal information, we will provide a more prominent notice (including, for certain services, notification of Privacy Policy changes by email), and you will be required to expressly accept such a change in order to continue using the Services and the change will apply immediately following your acceptance thereof.

SECTION 12. YOUR OBLIGATIONS

By using betonred.ng and by providing your personal data, you acknowledge that you are required to provide your actual, accurate and complete data as requested by betonred.ng. Furthermore, you must inform us of any changes to your information so as to ensure it is kept up-to-date and accurate.

If you are found to be in breach of your obligations or if we have reasonable suspicion that the information you provide is false or incomplete or in any way contrary to Data Protection Law or this Privacy Policy, we retain the right to reject your application for registration or to suspend or terminate your account immediately without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.