Privacy Policy

Last Updated: 4 October 2023

Buddybet Social LLC (EIN 30-1293558), a limited liability company pursuant to the Limited Liability Company Act of the State of Delaware, having its registered office at Corporation Trust Center, 1209 Orange Street, Wilmington 19801, Delaware, United States of America (“Buddybet”, “we”, “us”, “our”) is committed to privacy protection.

By accessing Buddybet USA (“www.buddybet.com/us”), the related mobile app, and any other features, services, tools, materials, or other services offered from time to time by Buddybet or its affiliate companies (“Platform”), you are trusting us with your information. We understand the importance of keeping personal information private and secure, and we are committed to ensuring the protection of your information.

This privacy policy (“Privacy Policy”) generally describes:

what personal information we may collect about you;
how we collect and hold your personal information;
the purposes for which we collect, hold, use and disclose your personal information;
how we may disclose your personal information; and
how you can update, manage, export and delete your personal information.

Some laws require companies to communicate the legal grounds on which they rely to process your personal information. To the extent those laws apply, we process your personal information.

This Privacy Policy is to be read in conjunction with our Platform Terms and Conditions.

Consent

We require your knowledge and consent to collect, use and/or disclose your personal information, except as required or permitted by applicable law. You are under no obligation to provide us with your personal information. However, if you choose not to provide us with certain personal information, we will be unable to assist you in setting up an account to provide you with our services.

By accessing our Platform, you are consenting to the collection and use of your information, as outlined in this Privacy Policy.

Except in specific circumstances, you may withdraw your consent to our use of your personal information at any time. All requests for withdrawal of consent must be directed to the Privacy Officer by email using the email address or by writing to us at our mailing address, provided below.

Collection of personal information

We want you to understand the types of personal information we collect as you use our Platform. We collect this information to provide various services to all our users.

Initially when you open an account with us, the types of personal information we may collect from you includes:

name and date of birth;
residential and postal addresses;
telephone numbers and email addresses;
driver’s licence information or other identification information;
information that identifies which phone contacts hold a Buddybet account, enabling you to follow them (if you request to synchronise your contacts); and
any other information that you provide to us by you during your account creation process, including images and photographs.

In addition to the information we collect when you initially open an account, we may also collect the following types of personal information:

content you post or publish on our Platform or receive from others when using our Platform, including images, video and photographs. Other users may also access to, store, display, reproduce, publish, distribute and share your content (including with third parties) without attributing it to the user;
information about the browsers and devices you use to access our Platform, which helps us provide features like automatic product updates. This information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number; and
information about your activity on our Platform, which we may use to do things like recommend a particular area of interest you might like. The activity information we collect may include:
- terms you search for;
- views and interactions with content and ads;
- with your express consent, voice and audio information when you use audio features on our Platform;
- wagering activity; and
- people with whom you communicate or share content.

By posting or publishing content to our Platform, you warrant that the content does not contain personal information relating to a person who has not consented to the publication and use of this content on our Platform.

So that we can adhere to our legal obligations, we may also collect information about your location when you use our Platform. Your location can be determined with varying degrees of accuracy by:

Global Position System (GPS);
Internet Protocol (IP) address;
sensor data from your device; or
information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth enabled devices.

How we collect your personal information

Buddybet will only collect personal information that is necessary for us to conduct our business as a provider of online social media and wagering services. We collect personal information about our users in various ways. For example, we collect information that you provide to us, information that we collect through your use of our Platform, and information that we collect from publicly available sources or third parties.

Information that you provide to us

We collect personal information that you provide to us about yourself when you:

use our Platform, including (without limitation) when you:
- create a user account;
- add information to your user profile;
- add reviews, forum or chat room messages or comments in any elements of our Platform that permits user-generated content; or
- complete an online contact form to contact us;
provide information to us by telephone; or
send us an email or other communications.

Information that you provide to us

In addition to the information you provide to us directly, we may collect personal information about your use of our Platform. This may include usage information, such as the time and duration of your use of the Platform and other information about your interaction with content offered on our Platform.

Our Platform may also collect Internet Protocol (IP) addresses. IP addresses are assigned to devices on the internet to uniquely identify them within the global network. Buddybet collects and manages IP addresses as part of the service of providing internet session management and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, our Platform.

Information from third-party sources

We may acquire or receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to our Platform through that site or from identity verification services, as required or authorised by law or regulation.

Cookies

A cookie is a small amount of data, often including a unique identifier, that is sent by a web server to your web browser and stored on your hard drive to identify and interact more effectively with your device. There are two (2) types of cookies that may be used on our Platform: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the “Cookies” folder on your device and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to our Platform. A session cookie is held temporarily in your device’s memory and disappears after you close your browser or turn off your device. In some cases, cookies may collect and store personal information about you. Other similar files such as clear GIFs, web beacons and pixel tags work in the same way and we use the word ‘cookie’ in this policy to refer to all files that collect information in this way. Buddybet extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.

Buddybet uses cookies to help personalise your experience whilst using our Platform, including presenting registered users with a personalised version of the Platform, enabling them to carry out transactions and have access to information about their account.

We may collect or use the information obtained from cookies to help us monitor and analyse usage and traffic on our Platform. Examples of how we use cookies include:

Session Management – cookies are essential to enable use of our Platform, they manage session information and enable you to navigate through the Platform.

Fraud Prevention – cookies store information which helps us stop fraudulent use of the Platform.
Functionality – cookies store information which enables us to remember your preferences. They are also used to improve your experience.
Tracking – cookies enable us to store information about how users arrived on the Platform.
Analysis – cookies allow us to recognise and count users of our products and to see how users move around our Platform. This helps us to improve the way our products work for you, by ensuring that you can find what you are looking for easily and to deliver adverts and information which are more relevant to you and your interests and to monitor the effectiveness of such adverts and information.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. The ‘Help’ function within your browser should tell you how to restrict or block cookies. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers. Please note that, as the allaboutcookies.org website is not owned or operated by us, we are not responsible for any of the content on them. Please be aware, if you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

Third party cookies

In some cases, third parties may place cookies through our Platform. For example:

Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on our Platform and the pages that they visit, in order to evaluate and improve user experience on the Platform;
Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
third party social media applications (e.g. Facebook, Twitter, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in our Platform.

Interest-Based Advertising

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Platform in order to provide you with tailored advertisements. This is a common marketing practice referred to as interest-based or online behavioural advertising. These companies may collect information about your activity across your different devices on our Platform and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.

Use of personal information

We collect, process and use information we collect from you via our Platform for the following legitimate business purposes:

Providing our services and products – including our social media services, enabling you to connect with our users on our Platform.
Developing new services – we use the information we hold to help us improve our existing services and to develop new services. For example, we use this information for customising the content/layout of our Platform for users and personalising our services for individual customers.
Communicating with you – we use contact information, like your email address, to interact with you directly. For example, if you sign-up to receive marketing communications, we may send you information about our products, Platforms, offers or competitions, or the products or services of our partners that we believe may be of interest to you, unless you have indicated that you do not wish to receive these materials.
Protecting us, our users and the public – we use your information to help improve the safety and reliability of our services. This includes detecting, preventing and responding to fraud, abuse, security risks and technical issues that could harm us, our users or the public.
Measuring performance – we use your information to keep track of how our business is performing, including, for example, to conduct analysis on our Platform’s usage or monitor Site usage and traffic.
Verifying your identity – there may be times that we are obliged by law or by our contractual commitments to use your information to verify your age and identity.

From time to time, we may also email our users with news, information and offers relating to our services or those of selected partners. Your personal information may also be collected so that we can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease use of our Platform. If you do not wish to receive any marketing communications from us, you may opt out of receiving those communications by updating your settings when you log in to our Platform. You may also opt out by clicking the “Unsubscribe” link in any marketing email that we may send to you. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “How to contact us about privacy” section below. Please note that you may continue to receive transactional or account-related communications from us.

Sharing of your information

In the course of our business, and for the purposes set out above, we may share your personal information with organisations outside Buddybet (including third parties located in Australia, USA, Canada, India or other foreign jurisdictions) who help us to operate our business. These organisations may carry out or provide:

information technology services and advice;
customised marketing and advertising services and advice;
security services and advice;
identity verification services;
Platform and Site usage analysis; and/or
social media integration services.

In addition, we may share your information with:

our subsidiaries and affiliated companies;
your authorised representatives or legal advisers (when requested by you to do so);
fraud-checking agencies;
our professional advisers, including our accountants, auditors and lawyers;
government and regulatory authorities and other organisations (for example, sporting bodies), as required or authorised by law or regulation; and/or
a third-party in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Buddybet or as part of a corporate reorganization or other change in corporate control and/or
the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.

Your personal information may be disclosed to these organisations or persons only for legitimate business purposes related to our Platform, or as otherwise required or permitted by applicable law, and we take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

We may also disclose your personal information in other situations, with your consent.

People and accounts you share and communicate with

When you share and communicate using our Platform, you choose the audience for what you share. For example, when you post a bet, you select the audience for the bet, such as a group, all of your friends, the public, or a customized list of people. This may include users located outside of your country of residence.

Your network can also see actions you have taken on our Platform, including engagement with ads and sponsored content.

Public information can be seen by anyone on our Platform. This includes:

your username;
any information you share with a public audience;
information in your public profile, including your images and photographs; and
content you share on another user’s profile page or any other public forum.

You, other users, and we can provide access to, or send, public information to anyone, on or off our Platform, including in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Platform.

You can control your account visibility by editing your preferences in your Platform account settings.

How we store information and who has access to it

We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable technical, administrative, physical and organizational measures to protect your personal information from unauthorised use or alteration. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access our Platform within a secure environment.

In our business, personal information may be stored both electronically (on our computer systems, servers and platforms as well as those of our third-party hosting vendors) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, protect all our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information; for example, we enforce limitations on access to information within Buddybet with only certain Buddybet employees having access to your information, where necessary to perform their job function.

We will only retain your personal information for as long as it is necessary for the legitimate business purposes set out in this Privacy Policy, unless a longer period is required or permitted by law. If we no longer require the information we hold for any legitimate business purpose, we will take such steps as reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.

Third party websites

Our Platform may contain links to other third-party websites which are outside our control and are not covered by this Privacy Policy. If you access other third-party websites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours. We encourage you to read the privacy policies of these third-party websites or contact these websites directly for further information about their privacy practices. We are not responsible for third-party privacy policies or the practices of third-party owners.

How you can manage your information

Our Platform allows you to view, update and correct certain personal information on your account. Alternatively, you can contact us about accessing, updating or correcting your information.

Access to your personal information

Subject to applicable law, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the relevant laws. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address or by writing to us at our mailing address, provided below. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:

be unlawful (for example, where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
have an unreasonable impact on another person’s privacy; or
prejudice an investigation of unlawful activity.

We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings. If we refuse to give you access, we will provide you with reasons for our refusal.

Please note, we may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

Correcting your personal information

Buddybet will use reasonable efforts to ensure your personal information is up-to-date and accurate, but we ask that you update your information by contacting us at the contact information provided in the “How to contact us about privacy” section below, whenever your information is incomplete, out-of-date or otherwise changes. You may request that we amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

Account Security

It is extremely important that you keep your account information and other confidential account data protected and secure. Do not share your log-in information or leave your computer unattended when logged in to the Platform. Contact us immediately by email if you find believe your account information and/or other confidential data has been compromised.

Collection of personal information from minors

We do not knowingly solicit data from or market to persons under eighteen (18) years of age. By accessing and using our Platform, you represent that you are at least eighteen (18) years of age. If we learn that we have collected personal information from users who are less than eighteen (18) years of age, we will deactivate the users’ account and take reasonable steps to promptly delete such data from our records.

If you become aware of any data we may have collected from a person who is under the age of eighteen (18) years, please email us.

California-specific privacy rights

Under the California Consumer Privacy Act (“CCPA”), Californian residents may request additional information regarding how we collect, use, and share their personal information. The CCPA allows you to request:

information about:
- the categories of personal information we collect or disclose about you;
- the legitimate business or commercial purpose for collecting your personal information; and
- the categories of third parties with whom we share and/or disclose your personal information.
provision of access to and/or a copy of certain personal information we hold about you; and
deletion of certain personal information we hold about you.

To make a request, please contact our Privacy Officer, by email using the email address provided, with “Request for Californian Privacy Information” in the subject line of your message. We will action your request or provide the requested information to you at your email address in response. You are also permitted to designate an authorised agent to submit particular requests on your behalf. Prior to us accepting any request from an authorised agent, we require signed, written permission of an agent’s authority. Please be aware that not all information sharing is covered by the CCPA requirements and only authorised information will be included in our response.

We will not discriminate against you for exercising your rights under the CCPA.

Categories of information

Throughout this Privacy Policy, we outline, in detail, specific types of personal information we collect from and about users. Under the CCPA, we must also provide you with the “categories” of personal information under which these specific types of personal information belong.

The categories of personal information we may collect include:

identifiers (e.g. name, postal address, email address, driver’s license);
protected classification characteristics (e.g. date of birth and gender);
internet or other network or device activity (e.g. browsing history or Platform usage);
geolocation information (e.g. your Country and State, based on IP addresses);
commercial information (e.g. transaction information);
professional or employment-related data (e.g. as part of your profile);
audio information (e.g. if you participate in a customer support call and do not opt out of call recording);
in certain circumstances, information used to manage potential fraud or legal risk (e.g. employment status and criminal history);
inference data about you; and
other information that identifies or can be reasonably associated with you.

More information about the legitimate business or commercial purpose for collecting your personal information and the categories of third parties with whom we share and/or disclose your personal information can be found in this Privacy Policy.

Opt out of “sale” of personal information

Californian law broadly defines a “sale” in a way that includes the sharing of your information with third parties, such as sports leagues or teams, to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies, IP address and/ or browsing behaviour, to deliver targeted advertising on the Platform. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.

You may opt out of the “sale” of your personal information at any time by completing a Do Not Sell My Personal Information form. You can also submit a sale opt-out request by emailing us using the email address provided.

Deletion of personal information

If you request us to delete your personal information held by us, we will respect your request and take such steps as reasonable in the circumstances to delete the information, subject to certain exceptions required by law.

If you would like further information regarding your legal rights under the CCPA, you can visit the website of the CCPA.

Nevada-specific privacy rights

Under Nevada law (more particularly, NV Senate Bill 220), certain Nevada consumers may opt out of the sale of “covered information” by an operator, to a person, for the licensing or sale of such information to additional persons. “Covered information” is defined to include a person’s first and last name, physical address, email address, telephone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

You may opt out of the sale of your “covered information” at any time by completing a Do Not Sell My Personal Information form. You can also submit a sale opt-out request by emailing us using the email address provided.

How to contact us about privacy

Your privacy is very important to us. For that reason, if you have any questions about your privacy, you can ask us by reaching out to our Privacy Officer in the following ways:

By Mail – Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801, United States of America
By Phone – +61 1800 577 291
By Email – privacy@bb-wa-buddybet-website-prod-eastau-a9htdub8grfzfqgg.australiaeast-01.azurewebsites.net

If you are concerned about a possible interference with your privacy, please contact us and we will investigate it. Complaints to us must be made in writing. If you do not receive a response within thirty (30) days or if your concern is not resolved to your satisfaction, you can refer the matter to your relevant regulatory body.

You should be aware that before you can lodge a complaint with your relevant regulatory body, you will usually need to raise your concerns directly with us first.

Changes to this Privacy Policy

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the relevant law. We may notify you about changes to this Privacy Policy by posting an updated version on our Platform.

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