Privacy Policy - PenseBet

Last updated: September 27, 2024

This privacy policy for PENSEBET SAS (operating as PENSEBET) (“PENSEBET,” “we,” “us,” or “our”) outlines how and why we may collect, store, use, and/or share (“process”) your information when you access our services (“Services”). This includes instances when you:

Visit our website at https://pensebet.com or any other website of ours that refers to this privacy policy.
Download and use our mobile application (PENSEBET) or any other application of ours that refers to this privacy policy.
Engage with us through other related activities, including sales, marketing, or events.

If you have any questions or concerns, reading this privacy policy will help you understand your privacy rights and options. If you disagree with our policies and practices, please refrain from using our Services. Should you have further questions or concerns, please reach out to us at support@pensebet.com.

SUMMARY OF KEY POINTS

This summary highlights key aspects of our privacy policy. You can find additional details on each topic by clicking the links that follow or by navigating our table of contents below. You can also click here to access our table of contents directly.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information based on your interactions with PENSEBET, the choices you make, and the products and features you utilize. Click here for more details.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive information from third parties.
How do we process your information? We process your information to provide, enhance, and manage our Services, communicate with you, ensure security and fraud prevention, and comply with legal obligations. We may also process your information for other purposes with your consent. Processing will only occur when we have a valid legal basis to do so. Click here for more information.
In what situations and with which parties do we share personal information? We may share your information in specific scenarios and with designated third parties. Click here to learn more.
How do we keep your information secure? We implement organizational and technical measures to safeguard your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot assure you that hackers, cybercriminals, or other unauthorized entities will not manage to bypass our security measures to collect, access, steal, or alter your information. Click here for additional details.
What are your rights? Depending on your geographical location, applicable privacy laws may grant you certain rights regarding your personal information. Click here for further information.
How do you exercise your rights? The simplest way to exercise your rights is by completing our data subject request form available here: Contact support@pensebet.com. We will review and respond to any requests in line with relevant data protection laws.

Would you like to know more about how PENSEBET handles any information we collect? Click here to read the full policy.

TABLE OF CONTENTS

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

In Brief: We gather personal information that you provide voluntarily.

We collect personal information that you willingly share with us when you register for our Services, express interest in obtaining information about us or our products and Services, engage in activities on the Services, or when you reach out to us directly.

Personal Information Provided by You: The personal information we collect is dependent on the nature of your interactions with us and the Services, the choices you make, and the products and features you utilize. This may include:

Names
Email addresses
Usernames
Passwords

Sensitive Information: We do not process sensitive information.

Application Data: If you use our application(s), we may also collect the following information if you grant us access or permission:

Geolocation Information: We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to deliver certain location-based services. You can modify our access or permissions in your device’s settings.
Mobile Device Data: We automatically collect information from your device (such as mobile device ID, model, and manufacturer), operating system, version details, system configuration, device and application identification numbers, browser type and version, hardware model, internet service provider or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also gather details about the phone network associated with your device, your mobile device’s operating system or platform, the type of mobile device you utilize, your unique device ID, and information regarding the features of our application(s) that you access. This information is primarily required to ensure the security and functionality of our application(s), assist in troubleshooting, and for our internal analytics and reporting purposes.

You must ensure that all personal information you provide to us is true, complete, and accurate, and you are responsible for notifying us of any changes to that personal information.

Information Automatically Collected

In Brief: Certain information—such as your Internet Protocol (IP) address and/or characteristics of your browser and device—is collected automatically when you use our Services.

We automatically collect specific information when you visit, use, or navigate the Services. This data does not reveal your specific identity (such as your name or contact details) but may include device and usage information, including your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and details about how and when you use our Services. This information is primarily needed to maintain the security and functionality of our Services and for internal analytics and reporting purposes.

Similar to many organizations, we also gather information through cookies and other similar technologies.

The information we collect includes:

Log and Usage Data: This data comprises service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or utilize our Services and record in log files. Depending on your interactions with us, this log data may include your IP address, device information, browser type and settings, and information about your activities within the Services (such as date/time stamps related to your usage, pages and files viewed, searches, and other actions taken, including which features you use), as well as device event information (such as system activity, error reports—often referred to as “crash dumps”—and hardware settings).
Device Data: We gather device data such as information regarding your computer, phone, tablet, or other devices used to access the Services. Depending on the device, this data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider or mobile carrier, operating system, and system configuration information.
Location Data: We collect location data, which can be either precise or imprecise, regarding your device’s location. The amount of information collected depends on the device type and its settings. For instance, we may use GPS and other technologies to gather geolocation data indicating your current location (based on your IP address). You can opt out of allowing us to collect this information by refusing access or disabling the Location setting on your device. However, opting out may limit your ability to use certain features of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Brief: We process your information to deliver, enhance, and manage our Services, communicate with you, ensure security and prevent fraud, and comply with legal requirements. We may also process your information for additional purposes with your consent.

We process your personal information for various reasons depending on how you interact with our Services, including:

Facilitating Account Creation and Authentication: We may process your information to enable you to create and log into your account and to maintain your account in good standing.
Providing Services: We may process your information to deliver the services you have requested.
Marketing and Promotional Communications: We may use the personal information you provide for marketing purposes, provided this aligns with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
Protecting Vital Interests: We may process your information when necessary to safeguard or protect an individual’s vital interests, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Brief: We process your personal information only when we deem it necessary and when we have a valid legal basis to do so under applicable law, such as your consent, compliance with laws, provision of services, fulfillment of contractual obligations, protection of your rights, or pursuit of our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to specify the valid legal bases we rely on to process your personal information. Accordingly, we may rely on the following legal bases:

Consent: We may process your information if you have provided us with permission (i.e., consent) to use your personal information for a specific purpose. You may withdraw your consent at any time. Click here to learn more.
Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract.
Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, provided that these interests do not outweigh your interests and fundamental rights. For example, we may process your personal information to:
- Send users information about special offers and discounts on our products and services.
Legal Obligations: We may process your information when we believe it is necessary for compliance with our legal obligations, such as cooperating with law enforcement or regulatory agencies, exercising or defending our legal rights, or disclosing your information as evidence in litigation.
Vital Interests: We may process your information when necessary to protect your vital interests or those of a third party, especially in situations involving potential threats to the safety of any individual.

If you are located in France, this section applies to you.

We may process your information if you have given us explicit permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, but not limited to:

If collection is clearly in the interest of an individual and consent cannot be obtained in a timely manner.
For investigations and fraud detection and prevention.
For business transactions, provided certain conditions are met.
If it is contained in a witness statement and collection is necessary to assess, process, or settle an insurance claim.
For identifying injured, ill, or deceased persons and communicating with next of kin.
If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.
If it is reasonable to expect that collection and use with consent would compromise the availability or accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of Canadian law.
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court regarding the production of records.
If the information was produced by an individual in the course of their employment, business, or profession, and the collection aligns with the purposes for which the information was produced.
If the collection is solely for journalistic, artistic, or literary purposes.
If the information is publicly available and specified by regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Brief: We may share information in certain situations outlined in this section and/or with the following third parties.

We may need to disclose your personal information in the following circumstances:

Business Transfers: We may share or transfer your information in connection with or during negotiations for any merger, sale of company assets, financing, or acquisition of all or part of our business by another entity.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Brief: We may utilize cookies and other tracking technologies to collect and store your information.

We may employ cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific details regarding our use of these technologies and how you can decline certain cookies are provided in our Cookie Notice.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Brief: We retain your information only as long as necessary to achieve the purposes specified in this privacy notice unless otherwise mandated by law.

We will maintain your personal information only for as long as it is required for the purposes outlined in this privacy notice, unless a longer retention period is mandated or permitted by law (such as for tax, accounting, or other legal obligations). No purpose described in this notice will require us to retain your personal information longer than the duration for which users maintain an account with us.

When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize such information. If deletion is not possible (for instance, if your personal information is stored in backup archives), we will securely store your personal information and isolate it from further processing until deletion is feasible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Brief: We strive to protect your personal information through a combination of organizational and technical security measures.

We have established reasonable and appropriate technical and organizational security measures to safeguard the personal information we process. 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 completely secure. Thus, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized parties will not be able to bypass our security measures and unlawfully collect, access, steal, or modify your information. While we endeavor to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services in a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Brief: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit information from or market to children under 18 years old. By using our Services, you confirm that you are at least 18 years of age or that you are the parent or guardian of a minor and consent to their use of the Services. If we become aware that we have collected personal information from users under the age of 18, we will deactivate the 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 children under 18, please contact us at support@pensebet.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Brief: In certain regions, such as the European Economic Area (EEA), the United Kingdom (UK), and Canada, you have rights that grant you greater access to and control over your personal information. You can review, modify, or terminate your account at any time.

If you are located in the EEA, UK, or Canada, you have certain rights under applicable data protection laws, which may include the following:

Right to Access: You may request access to and obtain a copy of your personal information.
Right to Rectification or Erasure: You can request the correction or deletion of your personal information.
Right to Restrict Processing: You may request a restriction on the processing of your personal information.
Right to Data Portability: If applicable, you may request to receive your personal information in a structured, commonly used, and machine-readable format.
Right to Object: You may have the right to object to the processing of your personal information under certain circumstances.

To exercise any of these rights, please contact us using the details provided in the section titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any requests in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to lodge a complaint with your local data protection supervisory authority. You can find their contact details here.

For residents of Switzerland, contact details for the data protection authorities are available here.

Withdrawing Your Consent: If we are processing your personal information based on your consent, which may be express and/or implied depending on applicable law, you have the right to withdraw that consent at any time. You can do so by contacting us using the details provided in the section titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

Please note that withdrawing your consent will not affect the legality of processing that occurred prior to the withdrawal, nor will it affect the processing of your personal information conducted based on lawful grounds other than consent.

Opting Out of Marketing Communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send or by contacting us using the details provided in the section titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. Even if you opt out, we may still communicate with you regarding service-related messages necessary for the administration and use of your account, respond to service requests, or for other non-marketing purposes.

Account Information: If you wish to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove cookies and reject cookies. Please note that if you choose to remove or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/.

If you have any questions or comments about your privacy rights, you may email us at support@pensebet.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

In Brief: Most web browsers and some mobile operating systems include a Do-Not-Track (DNT) feature that allows you to signal your privacy preference to not have your online browsing activities monitored and collected. Currently, no uniform technology standard for recognizing and implementing DNT signals has been established. Therefore, we do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Brief: Yes, California residents have specific rights regarding access to their personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with whom we shared personal information in the preceding calendar year. If you are a California resident and wish to make such a request, please submit your request in writing using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request the removal of unwanted data that you publicly posted on the Services. To request the removal of such data, please contact us using the contact information provided below, including the email address associated with your account and a statement indicating that you reside in California. We will ensure that the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

Every individual who is in the State of California for other than a temporary or transitory purpose.
Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What Categories of Personal Information Do We Collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal Information Categories Listed in the California Customer Records Statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected Classification Characteristics Under California or Federal Law	Gender and date of birth	NO
D. Commercial Information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric Information	Fingerprints and voiceprints	NO
F. Internet or Other Similar Network Activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation Data	Device location	YES
H. Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information	Images and audio, video, or call recordings created in connection with our business activities	NO
I. Professional or Employment-Related Information	Business contact details for providing our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences Drawn from Other Personal Information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about an individual’s preferences and characteristics	NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail, including:

Receiving help through our customer support channels.
Participation in customer surveys or contests.
Facilitation in the delivery of our Services and to respond to your inquiries.

How Do We Use and Share Your Personal Information?

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at support@pensebet.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will Your Information Be Shared with Anyone Else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered “selling” of your personal information.

PENSEBET SAS has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. PENSEBET SAS will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your Rights with Respect to Your Personal Data

Right to Request Deletion of the Data: You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to Be Informed: Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information.
- The categories of personal information that we collect.
- The purposes for which the collected personal information is used.
- Whether we sell your personal information to third parties.
- The categories of personal information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
- The business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights: We will not discriminate against you if you exercise your privacy rights.

Verification Process

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have the information in our system. These verification efforts may require you to provide information so that we can match it with information you have previously provided us. Depending on the type of request you submit, we may ask you to provide certain information to match with the information we have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for verification and for security or fraud-prevention purposes. We will delete any additionally provided information as soon as we complete the verification.

Other Privacy Rights

You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof of valid authorization to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasible, but no later than fifteen (15) days from the date of request submission.

To exercise these rights, you can contact us by email at support@pensebet.com, or by referring to the contact details at the bottom of this document. If you have an issue or complaint about how we handle your data, we would like to hear from you.

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at contact@pensebet.com.

14. How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at support@pensebet.com.