Last updated: 24thAugust 2018

  • 1.
    Purpose: The purpose of this privacy policy (“Privacy Policy”) is to enable you to understand how we collect, store, use, share and safeguard your personally identifiable information and to explain your rights in relation to that information and its use. Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an account on the website located at (the“Site”). You are required to accept and consent to the privacy practices described in this Privacy Policy if you want to access the Site. If you do not accept and agree with this Privacy Policy, you must stop using theSiteimmediately.
  • 2.
    Company: For the purposes of this Privacy Policy, the “Company” (i.e. the entity responsible for the capture, storage and use of personally identifiable information) is Decent Holdings Ltd. (“DBET”) a company incorporated in Maltawith registered office at The Penthouse, Office 2, Suite 2, Capital Business Centre, Entrance C, Triqtaz-Zwejt, San Gwann, Malta.In this Privacy Policy, when we say “”, “DBET”, “Company” ,“we” or “us” we are referring toDecentHoldings Ltd. and associated entities. We are the owner and operator of the Site.
  • 3.
    Protecting your Privacy: Protecting your privacy, along with your financial transactions, is at the core of DBET’s business.We are committed to maintaining the confidentiality of the personal information collected by us, utilizing ‘best in class’ information security technology and procedures, in accordance with applicable standards of data protection and the requirements of our gambling regulatory authorities.We will comply with the terms of applicable data protection regulations for the relevant license through which you access and use our Site (as such regulations may be amended from time to time) (collectively, “Applicable Law”), when processing personally identifiable information. Personally identifiable information may be also processed or transferred by us to other members of our group of companies, our affiliates, our agents and third parties providing services to us. In this event we will comply with the terms of Applicable Law that ensure that personal data is only transferred to such jurisdictions which comply with the various ‘adequacy’ requirements for data protection set out in Applicable Law.
  • 4.
    Agreement: By using the Site, you (“User” or “you”) agree to the terms of this Privacy Policy as may be amended by us from time to time. We reserve the right to amend this Privacy Policy from time to time. If we make changes, we will notify you by email and we will revise the last updated date at the top of this policy.Amendments will come into effect immediately upon such change being notified on the Site..
  • 5.
    What We collect: We collect, retain, and use information about you to protect and administer your account and funds; to comply with applicable Maltese and European Union (EU) laws and regulations; and to help us design, improve and provide products and services in order to better serve you. When you open an account with us or when you submit a request or electronically pass information to DBET, you may be asked to provide certain information, such as your name, e-mail address, mailing address, telephone number(s), identity card/passport number, identification documents, proof of address documents, date of birth, any other documents that we may require to provide you with our service as well as certification that you are at least 18 years old or older in jurisdictions in which the minimum age for use of the Site is greater than 18. In addition, it is important that you complete the account details with valid information, since it will be used for purposes described in this Privacy Policy. You must advise us of any relevant changes to personally identifiable information as provided to us and we do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the personally identifiable information that you have provided to us. We ask for this information in order to facilitate your requests, provide personalized services, and communicate separately with you. Without your written or electronic consent, we will not collect personally identifiable information over our system unless it is necessary to provide you with our services or to prevent unauthorized access to our Site or to comply with applicable Maltese or EU laws and regulations.
  • 6.
    Where we store your personal information: The Company is based in Malta and the information we collect is governed by Maltese law. By accessing the Site and using our services or otherwise providing information to us, you consent to the processing and transfer of information in and to Malta and other countries listed in this Privacy Policy. The information we collect is primarily stored on secure servers physically located in the U.S.A.
  • 7.
    Ongoing Data Capture: In addition, when you use the Site, we capture and store certain personally identifiable information including access times, pages viewed, your IP address and the web page that referred you to our Site. We also use ‘cookies’ and our ‘cookie’ policy is explained below.
  • 8.
    Data Retention: We retain personally identifiable information for as long as necessary for the purposes set out in this Privacy Policy which includes any period of historic retention that may be required for regulatory purposes. We do not collect any more personal information from our users than is necessary for our purposes and our data management policies include the deletion of any personal information we no longer required. Should you close (or if we shut down) your account with us, we will retain personally identifiable information only to the extent that is necessary to comply with Anti-Money Laundering requirements or with other applicable legal and regulatory obligations and to allows us to defend ourselves against any claims.
  • 9.
    Use of Information: We, our affiliates and third parties providing services to us or to you on our behalf will use personally identifiable information for the purpose of conducting our business and providing the Site to you. Specifically, this includes the following purposes, but we also reserve the right to use your personally identifiable information for any other purposes that are reasonably ancillary to the business of providing you with online gambling services: to assess your gambling activity for responsible gaming purposes; to verify whether you have registered with any mandatory self-exclusion bodies (as may be applicable), for responsible gaming reasons; to provide the Site to you; identification, verification and vetting purposes; statistical analysis and research; research and development; marketing, market research and customer profiling; data analysis; to comply with licensing and regulatory requirements and other applicable laws; to carry out batch testing of documents prior to the deployment of tools sourced from or provided by third parties; to combat against security risks and fraudulent activity; and to confirm your geographic location.
  • 10.
    Consent to Processing: We will process personally identifiable information for a variety of reasons, each of which is prescribed by relevant data protection laws. Our processing of personally identifiable information is necessary for us to provide you with the Site. On occasion we may ask for your consent to processing personal information in a discrete manner, in this instance personally identifiable information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
  • 11.
    Legitimate Interest for Processing: It may also be necessary for us to process personally identifiable information where it is necessary for the performance of a contract or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licenses and complying with any anti-money laundering legislation.Finally, we may also process personally identifiable information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (ii) where we identify certain companies can offer you additional benefits to our services or provide us with valuable information about your use of our Site; (ii) detection and retention of information pertaining to those with responsible gambling issues; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iv) safeguarding the integrity of on-line gambling by combating, reporting and sharing information related to suspicious betting patterns; (v) adhering to regulatory and statutory requirements; (vi) devising a tailored reward scheme for players.
  • 12.
    Disclosures of Information: We may disclose personally identifiable information to our employees, employees of affiliated companies, our agents and to third party service providers who use personally identifiable information to provide services to us in respect of you being a user of our Site as long as such third parties will be bound by the same obligations of this Privacy Policy and that they will apply appropriate security measures to protect your information. In some circumstances, we may disclose personally identifiable information as follows: to any recipient if required to do so by law or by regulatory authority;to any regulatory body or licensing body or authority;to third parties for the purposes of settling or making payment in connection with any wager;to third parties who provide services to us or on our behalf; to third parties for marketing purposes, provided you have consented or not objected, as the case may be; to any third party that purchases us or our business or any part of us or our business;if we believe in good faith that such action is necessary: to comply with any law or comply with legal process served on us; to protect and defend our rights or property.
  • 13.
    Legally Required Disclosures: Due to the legal, regulatory and security environment in which we operate, we may be required, under certain circumstances, to disclose personally identifiable information about our Users and we may not be permitted to inform you that we have done so. We will use reasonable endeavors to limit such disclosure to the following: (a) where we believe in good faith that we are required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights. Further, we can, and you authorize us to disclose your User identification, name, date of birth, street address, city, county, post code, country, phone number, email, account activity, transactions, communications with other Users, to our third party agents or official government bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.
  • 14.
    Group Marketing: We may use your email address and phone number for the purpose of providing you with news, promotions and other marketing offers from us. If you no longer wish to receive these promotional communications, newsletters and marketing offers, you may opt-out of receiving them either when you register with us initially, or subsequently by following the ‘opt-out’ instructions included in each communication. You are also, in addition, entitled at any time to notify us that you do not wish to receive any promotional communications from us.
  • 15.
    Third Party Offers of Goods and Services: Where you have provided us with your consent to do so, we may also share your email address and phone number with third parties so that they may send you offers of their goods and services. You may request at any time not to receive such offers. If you request not to receive these offers, we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you will need to unsubscribe separately from marketing communications sent by partners who have received your contact details from us prior to your request to be removed from these lists.
  • 16.
    Publicity: We will only use your name and details in publicity materials with your written consent.
  • 17.
    Protecting Information: We have undertaken substantial efforts to protect the confidentiality of the identity, preferences and other information we have collected about Users and we will not knowingly allow access to this information to anyone outside of DBET other than to Users themselves or as described in this Privacy Policy. We have made a substantial investment in our server, database, backup, firewall and encryption technologies to protect the information that we collect and process. These technologies are deployed as part of state-of-the-art security architecture. However,you should also play your part in protecting personally identifiable information. Your login credentials are confidential and you are obliged to keep your login credentials secret and confidential at all times and to use your best efforts to protect their secrecy and confidentiality. You should also be aware that the transmission of data via email is not secure and therefore we ask you not to send personal data such as identification documents via email but to upload these documents via links provided by us or our service providers, which utilize SSL protocols to securely transmit data over the internet.
  • 18.
    Right to request information about you: We aim to keep our information about you as accurate as possible. You can contact us at any time to review, change, obtain a copy of your information or have your details altered, corrected or deleted in accordance with your rights under Applicable Law. In this event we may require evidence of and be satisfied as to your identity before we take any requested action. We may, in certain circumstances, levy a small charge to cover the cost of administration regarding any request made by you in this regard or deal with your query in accordance with Applicable Law.
  • 19.
    Additional Rights: You have the following rights in relation to personally identifiable data: (i) a right to object to processing that is likely to cause or is causing damage or distress; (ii) a right to object to decisions being taken by automated means; (iii) a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and (iv) a right to claim compensation for damages caused by a breach of Applicable Law.If you contact us in relation to your rights, we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.
  • 20.
    The Right to Lodge Complaints: You may lodge a complaint directly by sending an email to: [email protected] or by post to: Decent Holdings Ltd, The Penthouse, Office 2, Suite 2, Capital Business Centre, Entrance C, Triqtaz-Zwejt, San Gwann, Malta. Alternatively, you have the right to lodge a complaint with: the Office of the Data Commissioner of Malta at, or by telephone on +356 2328 7100 or by post at Information and Data Protection Commissioner, Level 2, Airways House, High Street, Sliema SLM 1549, Malta.
  • 21.
    How to Contact Us: In order to exercise your rights, you may contact us by email on [email protected] We will acknowledge receipt of your email at the earliest possible and will ask you to provide proof of your identity before proceeding with processing your request. We will try to provide a reply to your request within 30 days. If we encounter circumstances that will not allow us to reply within this time-frame we will notify you as soon as reasonably possible to inform you of the reason that we require additional time to reply to your request.
  • 22.
    Third Party Web Sites: The Site may contain links to other sites. DBET cannot be responsible for the privacy practices or the content of other sites. When linking to other sites, please review their security and privacy policies.
  • 23.
    Non-Personally Identifiable Information: When your computer or mobile device contacts our web servers (for example, when you visit the Site or view an HTML e-mail), our web servers automatically collect usage information. Such usage information includes information about how our visitors use and navigate the Site. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, and referrer data that identifies the web page visited prior and subsequent to visiting the Site. We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, e-mail, or advertising or promotional announcement or similar service. This information is used to analyze and improve the Site and to provide you with a more fulfilling and relevant experience.
  • 23.
    Browser Cookies: Like many websites, we use browser “cookies.” Cookies are a website’s way of remembering who you are. We use cookies to help us to identify account holders and to optimize their experience on the Site. Also, we will use cookies to monitor and maintain information about your use of the Site. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. If you decline to accept cookies, you may not be able to take advantage of or participate in certain features of the Site.
  • 23.
    Web Beacons: Our web pages or e-mail messages may contain a small graphic image called a web beacon, which is sometimes also called a "clear gif," which allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to, and the time the web beacon was viewed. We may use web beacons to count visitors to our web pages or to monitor how our users navigate the Site, and we may include web beacons in e-mail messages in order to count how many of the messages we sent were actually opened or acted upon. We use web beacons to compile aggregate statistics about the Site and our marketing campaigns.
  • 23.
    Third Party Cookies: We allow third-party companies to collect anonymous information when you visit the Site and to use that information to serve ads for DBET products or services or for products or services of other companies when you visit the Site or other websites. These companies may use anonymous information (e.g., navigational, non-personally identifiable information; click stream information; browser type, time and date; subject of advertisements clicked or scrolled over, etc.) during your visits to the Site and other websites in order to provide advertisements about our goods and services likely to be of interest to you. These parties may use a cookie or a third-party web beacon, or other technologies, to collect this information.

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