Effective Date: April 7, 2023
1. SCOPE AND APPLICATION
2. COLLECTION OF INFORMATION
We collect the following categories of information when you use our Services (including when you download or launch our mobile applications, or when the application is running on your device in the background):
- Information you provide directly to us.
- Identifiers: We collect information that can be used to identify you, such as your first and last name, phone number, address, username and password, email address, postal address, IP address, driver’s license number, social security number, and day and month of your birthday.
- Financial Information: We may collect information such as your bank account details, payment card information (credit card number, expiration date, and credit card security code, where needed to complete a transaction), billing address, and tax documents.
- Commercial Information: We may collect information about your transactions on our website or mobile application including records of the products and Services you purchased, obtained, or considered.
- Geolocation Information: We may collect information about your location of your device, such as information derived from your device (e.g., based on a browser or device’s IP address).
- Correspondence: We may collect correspondence you send to us or through the Services and other information you provide, including information that you provide us with when you fill in forms or answer questions when using any of our Services, contact us through Betr contact information listed on our Services, interact with us through our social media accounts, or respond to messages and communications that we send you.
- Information we collect automatically.
- Electronic network activity information: We may collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including your device type; mobile device and advertising identifiers, or other unique identifiers and usage information for the device used to access the Services; device and connection information, such as browser type and version, browser plug in types and versions, operating system, and platform; IP address; Internet service provider and/or mobile carrier; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use the Services; the technology on the devices you use to access these Services; standard server log information; language preferences; and location data from your device.
We also receive the categories of information described above from other sources, including from users of our Services, advertising partners, internet service providers, data analytics providers, operating systems and platforms, social networks, and publicly available sources. For example, if you access any social media or similar services through the Services to login or to share information about your experience on our Services with others, we may collect information from these third-party services.
Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.
3. USE AND PURPOSE OF DATA COLLECTION
Betr may use and otherwise process the information it collects about you for the following business purposes:
Legal basis for processing, including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessity to comply with a legal obligation
(c) Necessity for our legitimate interests (for instance, to keep our records updated)
To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates and trusted business partners.
(a) Necessity for our legitimate interests (to grow our business)
To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.
(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud; in the context of a business reorganization or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)
(b) Necessity to comply with a legal obligation
Where legally required and we have no other valid legal basis to process your information, we will obtain consent, which may subsequently be withdrawn at any time by contacting us at firstname.lastname@example.org. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.
Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or Services). In this case, we may cancel a product or Service you have with us.
4. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand how we use the information we collect and when and with whom we may share that information. We may disclose your information as needed to fulfill the purposes described above and as permitted by law:
- Authorized third-party vendors and service providers. We share identifiers, commercial information, electronic and network activity, and geolocation and precise geolocation information, as described above, with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
- Federal and State Taxing Authorities. If your earnings from gaming activities exceed a certain threshold, we will disclose information to the United States Internal Revenue Service and other appropriate taxing authorities in accordance with our interpretation of applicable law.
- Corporate affiliates. We may share your information with our corporate affiliates.
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Betr, our affiliates, users, or the public.
- With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services–such as social media services or third-party single-sign on tools– through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Services, in accordance with their own privacy policies.
You should be aware that any information that you have made public, such as when you have engaged in public activity on the Services, can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas or otherwise make public.
5. ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES
The following types of cookies are used on our Services:
- Essential cookies. These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure.
- Preference cookies. These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance cookies. These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt out selection in your browser.
Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.
Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
6. YOUR RIGHTS AND CHOICES
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, to request that we export or transfer your information, to withdraw your consent (where processing is based on consent) and to request access to, know, correction, and deletion of your information or more information about our information practices. Requests should be submitted in writing as set out below by emailing us at email@example.com. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. We will endeavor to respond to your request within 45 days of receipt or such other period defined by applicable law.
Depending on the jurisdiction in which you live, you may also have the right to opt out of the sale and sharing of your personal information for cross-context behavioral or targeted advertising purposes. Where we provide you with these choices, you can exercise these rights by clicking on the relevant opt-out link in the footer of the applicable website or in the settings of the applicable mobile app.
You may be entitled, in accordance with applicable law, to submit a request through an authorized agent or to appeal a refusal to take action on your request. To designate an authorized agent to exercise your rights and choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. To appeal a refusal to take action on your request, please submit your appeal in writing as set out below. We will endeavor to respond to your appeal within 60 days or such other period defined by applicable law. You also may be able to control our collection and use of your location information through your mobile device or app settings.
Under local law, you may also be entitled to lodge a complaint with your local data-protection authority. For example, you may be entitled under Massachusetts law to file a complaint with the Massachusetts Gaming Commission, Office of Consumer Affairs and Business Regulation, Office of the Attorney General, or other Massachusetts law enforcement entities regarding the use of your information, or you may be entitled under Virginia law to file a complaint with the Virginia Attorney General/Virginia Lottery.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you. Any difference in the Services are related to the value provided.
7. INTERNATIONAL TRANSFERS
We do not knowingly collect, sell, or share any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.
9. DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as reasonably necessary and proportionate for the purposes set out above based on criteria such as the length of time we need to provide the services to you, and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements, in accordance with applicable laws.
We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
11. CONTACT INFORMATION