10bet, ‘us’ ‘our’ or ‘we’ are references to Blue Star Planet Ltd., a limited liability company registered under the laws of Malta with company registration number C 70661, and having its registered office address situated at ‘Dragonara Business Centre, 5th Floor, Dragonara Road, San Giljan STJ3141, Malta’. We will be the controller of your personal data. References to our “Group” includes Water Tree Limited and any other group companies of Blue Star Planet Ltd. (C 70661).

10bet provides the Services under a contract with you. The Services are provided through the following applications and platforms (collectively the “Platforms”):

• This internet website, including any subdomains and any affiliated websites;
• Apps which are distributed through mobile application stores, as well as PC and Mac desktop software which can be downloaded to your computer;
• Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.); and
• Facebook applications.

For the most part we collect personal data from you directly - for example when you set up a 10bet account, verify your identity, undergo know your customer checks and financial checks, interact with our customer services teams and/or otherwise communicate in any manner with us.

We also collect personal data related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings, as well as your participation in promotions, draws or contests.

Moreover, we also collect information regarding potential gambling problems or markers of harm, based on your gambling activity and communication with our customer services teams.

It is important to note, that we sometimes also receive personal data about you from other sources, and in turn process data created from your use of the Services, as set out below:

• Social networks: When you register through your social network account (such as your Facebook account) to use the Services or connect your player account with such social network account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture, friends list, as well as information you made publicly available on such account. In addition, when using the Services, you may be able to "Invite a Friend" to use the Services via your social network. Should the person accept your invitation, we may obtain personal data from him/her such as: name, email address, phone number and date of birth.
• Due Diligence Information: We collect information from third party providers, such as information about your credit history from credit agencies, and other financial information that is relevant to the provision of the Services. We also collect information that is gathered in order to verify your identity, age and prevent fraudulent or illegal activity, which may include information from publicly available sources.
• Self-exclusion information: If you self-exclude through GAMSTOP, the UK's national self-exclusion scheme, we will receive a notification in this regard. Section 5 below provides more information in connection with safer gambling.
• Device and technical information: We collect specific types of connection details and information with regard to your device, software or hardware, such as: the device’s unique identifiers (e.g. UDID, IMEI and MAC address), browser fingerprinting, IP address, geo-location, language preference, access time, the domain name of the website from which you linked to the Services, other software running simultaneously when you are using the Services and whether the connection you are using is a VPN or proxy.
• Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, and alerts.

This section explains how we use personal data in order to carry out the activities relevant to the provision of the Services and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose / Activity	Lawful basis for processing (including basis of legitimate interest)
To set up, manage and update your account and to provide and operate the Services.	Performance of a contract with you.
For identity verification process, to provide you with a responsible gaming environment.	Compliance with a legal obligation.
To meet the legal and regulatory obligations that we have as a gambling company. This includes licensing requirements, responsible gaming obligations and Anti Money Laundering (AML) Regulations.	Compliance with a legal obligation.
To monitor betting and gaming patterns and safer gambling activities such as self-exclusion, deposit limits and time-outs to identify potential issues related to safer gambling and provide you with a responsible gaming environment (See further information in section 5 below).	Compliance with a legal obligation – our basis for processing any special category data in accordance with this purpose is that it is in the substantial public interest for the safeguarding of individuals at risk and/or safeguarding of economic well-being of certain individuals.
For dispute resolution, exercise and establishment of legal claims and as required by the courts, regulator and law enforcement.	Compliance with a legal obligation and necessary for our legitimate interests (to assert our legal rights and defend ourselves legally and assist regulators and law enforcement)
To provide customer service (such as ensuring quality monitoring and assurance, ensuring operational efficiency, ensuring that quality standards are met in terms of support performance and users' satisfaction, etc.).	Necessary for our legitimate interests (for running our business, ensuring that the Services operate as intended).
Compliance monitoring.	Compliance with a legal obligation.
Recording and monitoring phone calls.	Necessary for our legitimate interests (for customer service and training purposes) and necessary to comply with a legal obligation (for compliance monitoring and detecting and preventing crime).
To send you direct marketing and promotional activities.	Consent of the data subject.
To understand better your preferences and behaviour, and the products which you most enjoy so that we can tailor our advertising and marketing to you.	Necessary for our Legitimate interests (to enable our advertising and marketing to be specific to our customers’ preferences)
To share some of your information with social media platforms for targeted advertising and to enable us to reach new audiences.	Legitimate interests
To provide targeted advertising through our use of cookies and similar technologies.	Consent of the data subject
To prevent fraudulent or illegal activity.	Compliance with a legal obligation.
To enhance the functionality of the Services and to provide you with a better user experience.	Necessary for our legitimate interests (for running our business, ensuring that the Services operate as intended, including providing and improving our administration and IT services).
To investigate violations of our policies and Terms and Conditions as well as to enforce our policies and our Terms and Conditions.	Performance of a contract with you and our legitimate interests (for the proper running of our business)
To troubleshoot errors and bugs.	Necessary for our legitimate interests (for running our business, ensuring that the Services operate as intended, including providing and improving our administration and IT services).
To conduct analytics and to undertake statistical research, in order to improve and customise the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services).	Necessary for our legitimate interests (for understanding our customers and adapting our Services accordingly).
To share information with law enforcement where we believe it is reasonable and necessary.	Compliance with a legal obligation (where such sharing is required) and necessary for our legitimate interests where we consider the request to be reasonable and proportionate (to assist law enforcement in investigations).
To share information with the Gambling Commission (or other regulators) where we are required to do so.	Necessary to comply with a legal obligation.
To anonymise and delete data.	Compliance with a legal obligation.

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this Privacy Policy accordingly, when we do this.

• Vital Interest
  We may process your personal data if it is necessary in order to protect your vital interests or the vital interests of another natural person, such as to prevent physical harm or threats that pose a risk of injury or other damage to the health of an individual.
• Special Categories of Personal Data
  Our processing activities may also involve special categories of personal data (as defined under Article 9 of the GDPR), such as health data. Where we collect this type of data, we will process it where necessary for the purposes of safeguarding individuals at risk and/or safeguarding the economic well-being of certain individuals (such as the detection and retention of information pertaining to those with responsible gambling issues) where it is in the substantial public interest
• Personal Data relating to Criminal Convictions and Offences
  Our processing activities may also involve data relating to criminal convictions and offences. We process data relating to criminal convictions and offences, and sometimes even disclose it to competent authorities (such as licensing bodies or law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) the prevention or detection of an unlawful act, or (ii) the prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes.

Your wellbeing is incredibly important to us, and as a result we want to ensure that you use our Services in a safe and responsible way. To achieve this, we will process your personal data, including special category data, in order to help us identify any markers of harm or safer gambling concerns, and take the necessary steps to decide whether further action is needed.

We use automated systems and processes to monitor customer activity in order to identify actual or potential harm, enabling us to reduce the risk of customers experiencing gambling-related harm.

We will also assess the amount you spend on our Services by requesting information about source of wealth or source of funds. We may also conduct customer due diligence to understand the affordability of customers (which may include CCJ checks and receiving information from credit reference agencies). This information will only be used for the purpose of ensuring that you are able to gamble safely with us and in order to comply with our legal obligations.

We also have a dedicated team which you can get in touch with at any time if you are having issues with your gambling on support@10bet.co.uk or +44 330-808-0555. If our analytics identify any vulnerabilities, we may ask for your consent to get in touch with you and discuss what would be the appropriate adjustments and protections to protect you from gambling-related harm.

Self-Exclusion

You have the option to self-exclude as part of our safer gambling tools - we will share this information with any Group companies licensed to provide gambling services so that we exclude you from all of your accounts with us.

Please note that 10bet uses the GAMSTOP service which is the UK's national self-exclusion scheme to help customers avoid online gambling websites which are run by companies licensed by the UK Gambling Commission, meaning that if a UK customer self-excludes through the GAMSTOP scheme, we will receive a notification of this and ensure that the wish to self-exclude is applied across our sites and apps. Processing this data for this purpose may include sharing information with our Group companies and receiving information from GAMSTOP in order to ensure that self-excluded customers are able to be properly excluded.

Our lawful basis for processing personal data and special category data for safer gambling purposes is that it is necessary to comply with a legal obligation including regulatory requirements under a gambling licence. We also process this data for the safeguarding of individuals at risk and/or the safeguarding of the economic well-being of certain individuals in the substantial public interest.

We will use your personal data for the purpose of sending you direct marketing in accordance with your consent and your product and channel preferences. You can change these preferences at any time via your account, and you can unsubscribe via the instructions in any such communication or via your account.

Where we engage third parties to support our marketing efforts (collectively referred to as the 'Marketing Affiliates'), they act as independent data controllers. As such, we do not share your personal data with them.

Additionally, if you download any of our mobile applications to your device from the Apple AppStore or Google Play, the only way to disable notifications is by changing the notification settings directly on the device itself.

Introduction

When you visit or access any websites or applications operated by us, or when you interact or engage with our Services, we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other similar technologies (collectively and individually “cookies”). Unless the cookies are strictly necessary for us to provide our Services, these cookies are only used where you have provided your consent via our consent management platform.

Cookies allow us to automatically collect information about you, your online behaviour, and your device (for example your computer or mobile device), in order to enhance your navigation, improve our performance and customize your experience in connection with our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our users, advertisers, publishers, customers and partners.

We also allow third parties to collect information about you through cookies.

Cookies may also be used for online advertising and targeted advertising, as outlined below.

What are cookies?

Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. You can find more information about cookies and how to disable them at www.allaboutcookies.org or https://ico.org.uk/for-the-public/online/cookies/.

Storing Cookies

We use cookies when you visit or access our Services (for example when you are visiting our websites) – these are called "First Party Cookies". Cookies are also stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Cookies".

Both types of cookies may be stored either for the duration of your visit on our Services or for repeat visits.

What types of cookies do we use?

There are four main types of cookies:

• Necessary cookies – These cookies are essential for basic website functions like navigation and security. The site cannot function properly without them, and they cannot be disabled.
• Functional cookies – These cookies store your preferences, such as language and region, to provide a more personalized experience.
• Performance cookies – These cookies collect anonymous data on how you use the site to improve speed, usability, and overall performance.
• Marketing cookies – These cookies track browsing activity across websites to display relevant ads and measure advertising effectiveness.

We are currently making use of the following Cookies, which list shall be continuously updated accordingly.

Cookies	Type	Purpose
Analytics Cookies	First party Cookies	Performance cookies These cookies are used to collect information regarding how you interact with the content on our Services, attribution purposes (for example, the referral URL), etc. We use this information to compile reports, calculate the revenues due to us and, help us improve the Services and to offer personalized products and content.
Google Analytics	Third party Cookie	Performance cookies This cookie is used to collect information about how visitors use our Services. We use the information to compile reports and to help us improve the Services. The cookies collect the number of visitors to the Services, where visitors have come to the Services from and the pages they visited, and other data. Google Privacy Policy
Google Tag Manager	Third party Cookie	Performance cookies This cookie is associated with Google Tag Manager which we use to load scripts into our website pages. Google Privacy Policy
Google AdWords	Third party Cookie	Marketing cookies We use Google AdWords which uses cookies to help us determine how many people who clicked on our Google Ads end up contacting us through our websites. This tracking cookie is set on your browser only when you click on a Google Ad and these cookies help us increase the website’s effectiveness for our visitors. Google Privacy Policy
Bing	Third party Cookie	Marketing cookies We use Bing Ads to show you personalized ads. These cookies keep track of your surfing behaviour and help us understand how our Bing campaigns perform by tracking actions on our websites once ads have been clicked. Microsoft Privacy Policy
Income Access	Third party Cookie	Necessary cookies We utilize Income Access, an affiliate marketing services, to help record the performance of the affiliate services provided. Income Access may record unique identifiers associated to your device to follow your activity within our website or app. This information is used to analyse and improve our services and to measure the effectiveness of our advertising campaigns. Income Access Privacy Policy
Zendesk	Third party Cookie	Necessary cookies We use Zendesk as our customer support platform to provide you with assistance and improve your experience. Zendesk may use cookies to track interactions, store preferences, and analyse support requests to enhance our service quality. These cookies help us understand how users engage with our support system and optimize our responses.
Meta	Third party Cookie	Marketing cookies We use Meta (Facebook and Instagram) pixel to show you personalized ads. These cookies keep track of your surfing behaviour and help us understand how our Meta campaigns perform by tracking actions on our websites once ads have been clicked. Meta pixel policy.

We use third-party advertising technology to deliver advertisements when you visit the Platform and use our Services. This is done only where you have provided your consent via our consent management platform.

For more information about your choices regarding targeted advertising, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp and www.aboutads.info/choices

We may share your personal data with the following third parties:

• Our service providers (known as processors) who are limited by contract only to process your personal data on our behalf and as set out in this Privacy Policy, such as cloud computing companies, identity verification providers and software providers who licence us casino games.
• Banks and payment providers to enable you to deposit and withdraw funds.
• Our Group companies.
• Credit referencing agencies as set out in this Privacy Policy. Any third party who may provide you with a tangible prize.
• Any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within the Group.
• Accommodation and airline companies (such as in the context of offline events and promotions).
• Auditors, contractors or legal/financial/other advisers of the Group.
• Any third parties, such as law enforcement (e.g. governmental authorities, police, banks and other investigatory organizations).
• Gambling addictions bodies.
• Licensing authorities (such as the Gambling Commission), governmental and regulatory bodies, in accordance with applicable laws and regulations.
• Potential purchasers, successors or investors in any of the companies within the Group, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Group (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy).

Since we operate globally, it may be necessary for the provision of the Services (and to the extent required for the specific purpose as stipulated in this Privacy Policy), to transfer your personal data to countries outside the UK, the European Union, or the European Economic Area, as long as these countries or territories have been deemed ‘adequate’ by the UK or European Commission (as applicable).

We use our best efforts to ensure that your personal data is protected in accordance with our Privacy Policy, and through binding corporate rules or contractual measures (such as contractual clauses), in each case as approved by the UK or European Commission for data transfers (as applicable).

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. The retention period depends on the type of data collected and on the applicable laws which may require us to keep certain data for a specified time, for example we would keep any information related to a self-excluded customer for a minimum of seven years. Once your data is no longer needed, we will securely delete or anonymise it. Please note, that there may be specific situations where we retain personal data for longer, such as to protect our legal rights or defend claims.

The Services are not intended for or directed at individuals under the age of 18. If you are under 18 years of age, you must not download or use the Services, nor should you provide any personal data to us.

We reserve the right to access and verify your age.

If you have any reason to believe that a minor has shared any information with us, please contact us at support@10bet.co.uk

We take great care in implementing and maintaining the security of our Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to ensure that the information we collect online is used correctly. These safeguards vary based on the sensitivity of the information that we collect and store.

We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

• Secure network topology, which includes intrusion prevention and Firewall systems.
• Encrypted communication.
• Authentication and Access Control.

Data protection laws provides data subjects with several rights in connection with the collection, handling and processing of their personal data. As a data subject, you have the right to request that:

• We provide you with a copy of the information we hold about you;
• We update any of your personal data if it is inaccurate or out of date;
• We delete the personal data we hold about you - (kindly note that if we are providing services to you and you ask us to delete your personal data, we may be unable to continue providing those services to you);
• We restrict the way in which we process your personal data;
• You object to the processing of your data for certain purposes;
• We stop processing your data if you have objections to processing undertaken on the basis of our legitimate interests;
• We withdraw consent where we rely on your consent for processing; and
• We transfer your data to another controller.

For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us at support@10bet.co.uk.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Your rights are not absolute and there may be situations in which we are unable to comply with a rights request.

If you have any questions or concerns about how we handle your personal data, you can contact our Data Protection Officer (DPO) via email at: support@10bet.co.uk

If you are unsatisfied with our response to any data protection issues you raise with us, you have the right to make a complaint to the relevant data protection regulator, including the Maltese Information and Data Protection Commissioner (IDPC) and the UK’s Information Commissioner’s Office (ICO). However, we ask that you always contact us in the first instance.