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  1. INTRODUCTION

    1. Entzone Limited trading as “Surebet247” (referred in this Policy as the “Company”, “Us”, “Surebet247”) is committed to safeguarding Players (“You”, “Your”, “Users”) personal information. This privacy policy (the “Policy”) provides details about the information collected, processed, stored, and utilized from Players.
    2. Users are advised to carefully read through this Policy before accessing or using Surebet247 online gaming platform. If you do not agree with the terms of this Policy, you may refrain from using our platform.
    3. Players who use Surebet247 services and products consent to the use of their personal information in accordance with this Policy.
    4. This Privacy Policy is subject to Nigerian Data Protection Regulation 2019 (NDPR) or any applicable legislation and should be read in conjunction with Surebet247’s Terms & Conditions, general rules, and any additional terms applicable on Surebet247’s online gaming platform.
  2. SCOPE

    1. This Privacy Policy is applicable when you visit or use Surebet247’s website or services but does not apply to third party websites or online services accessed through the Surebet247 platform that the company does not own or control.
  3. PLAYER’S PERSONAL INFORMATION

    1. Personal Information:
      1. To use Surebet247 services, Players will be required to provide certain personal information which helps to customize and continually improve our services; prevent abuse of our services and enable third parties to carry out certain functions on our behalf.
      2. This information includes:
        1. Personal Details: first name, last name, address, gender, location/state of residence, language, birth date, e- mail, phone number/mobile phone.
        2. Bank Account Details: account name, bank name and bank account number.
        3. Account Login Details: personalized username and password
        4. Personal information provided through interactions with Players/Users of Surebet247’s online gaming platform, including telephone conversations, SMS, emails, and social-media platform owned by Surebet247. It is pertinent to note that Surebet247 records and monitor calls and SMS for compliance and quality assurance purposes.
      3. Player has the right to make changes (edit, update, or correct) his personal data in the account settings of his profile or by contacting us at undefined.
    2. Use of Personal Information:
      1. Player’s personal information received through Surebet247’s website/services will be utilized for the following purposes:
        1. Account registration with Surebet247
        2. Compliance with legal and contractual obligations
        3. Monitor transactions and payments for prevention of fraud, irregular betting, cheating and money laundering
        4. Risk management assessment
        5. Conduct Anti-Money Laundering (AML) checks
        6. Prevention and detection of a crime
        7. Monitor gambling pattern to identify possible gambling addictions or vulnerabilities
        8. Provide Player support services
        9. Collate and analyse data collected with the use of Cookies Policy
        10. Carry out analysis for improving products and services provided to Users.
        11. Communicate about gaming activities, products, and services
        12. Personalize and enhance effective services delivery on Surebet247 platform
    3. Surebet247’s Disclosure of Player’s Personal Information:
      1. Personal information provided to Surebet247 by the Player shall not be disclosed without his/her prior consent.
      2. Personal information provided by or received from the Player may be divulged to a third party to the extent necessary to fulfil our contractual obligations. We may also be required by law, court order or government authority to disclose certain personal information.
      3. Surebet247 may share your personal information with the following:
        1. Regulatory authorities
        2. Third party suppliers and service providers
        3. Identity verification agencies
        4. Fraud prevention agencies,
        5. Law enforcement agencies and legal professionals
      4. Surebet247 will take all necessary steps to ensure the confidentiality of players’ information. Surebet247 shall also impose strict restrictions on how our partners and third parties can use and disclose players’ information.
      5. Where a Player uses a link to connect another website or service from Surebet247’s platform, our Privacy Policy will not be applicable to such third-party websites or services. Player’s browsing and interaction on any third-party website or services are subject to the third party's terms of use and policies.
  4. PLAYER’S RIGHTS
    1. The Players’ rights are:
      1. Right of access: Players have the right to request in writing for a copy of their personal information held by Surebet247.
      2. Right to rectification: Players have the right to request for rectification of erroneous information.
      3. Right to update of information: Players have the right to request for update of information provided
      4. Right to restrict processing: Players have the right to restrict or limit the purpose of processing of their personal information by Surebet247. Also, Players have the right to object or decline the use of their information for direct marketing or profiling.
      5. Right to object: Players have the right to object to the transfer of their personal information outside Nigeria without the express consent of the Player.
      6. Right to data portability: Players have the right to request that Surebet247 provides their personal information in machine readable formats to third parties.
      7. Right to withdrawal of consent: Players have the right to withdraw consent with respect to the personal information held by Surebet247. Withdrawal of consent will not affect the lawfulness of use of personal information prior to the withdrawal of consent.
      8. A Player has the right to be notified before a decision is reached on automated processing of data except where the decision is authorized by relevant law.
      9. A Player has the right to be notified of data breach within 48 hours of notifying the relevant authority.
  5. PROTECTION OF PLAYERS’ INFORMATION
    1. Surebet247 will treat Player’s personal information as confidential and protect such information through technical, structural, and administrative measures implemented to guard against accidental, unlawful, or unauthorized destruction, access, disclosure, or use.
    2. Surebet247 will review, supervise, and update these security measures to meet its business needs, changes in technology and regulatory requirements.
    3. Surebet247 does not warrant that the collection, transmission, and storage of information will be completely secure; however, Surebet247 shall ensure that necessary security measures are in place to protect Player’s information.
    4. Players are expected to take every reasonable measure to protect their account login details from unauthorized access. Players are expected to use the following instructions to keep account details protected:
      1. Ensure login details are kept confidential
      2. Change password regularly especially when it is believed to have been compromised
      3. Use unconventional passwords comprising of figures, characters and alpha numeric keys which will be easy to remember
      4. Desist from sharing your credentials with third parties
      5. Do not use same passwords for all operating systems/accounts or on other websites or services
      6. Do not write down or save passwords in your browser
      7. Do not leave your computer or mobile device unlocked/unsecured.
      8. Do not use public Wi-Fi
    5. Where a player believes that security has been compromised, the player should promptly change security details and notify Surebet247 at undefined.
  6. RETENTION PERIOD
    1. Surebet247 shall retain your personal data only for as long as it is reasonably required to fulfil the purpose for which it was collected and as required by the NDPR.
    2. Following the closure of player’s account, information will be retained for not more than five years.
    3. Players are advised to always provide current and accurate information and update such information provided whenever necessary. Players agree that, in the absence of any update, Surebet247 can assume that the information submitted is current and accurate.
  7. COOKIE POLICY
    1. Cookies are text files containing a small amount of information sent by website to Player’s computer or mobile device to record information or track the User’s browsing activity.
    2. Surebet247 uses cookies to:
      1. collect information about third party sites or services Players interact with before utilizing Surebet247 sites.
      2. collect information about server logs, which includes information about device IP address, app features or pages viewed, access dates and times, app crashes and other system activity, type of browser.
      3. collect information about Player’s mobile phone specifications, including, the hardware model, operating system and version, software, file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
    3. Data collected from Players will help Surebet247:
      1. evaluate whether its website/online gaming platform is at its best performance across a range of mobile devices
      2. identify its problems and performance enhancements.
      3. improve Player’s online experience and ensure that relevant content and functions are delivered and used more effectively.
      4. carry out research, surveys or to send communications via emails or other means of correspondence.
    4. A player has the option of allowing or refusing the use of cookies where it is indicated, although, cookies are not harmful to the Player’s device.
    5. Cookies Used by Surebet247
      1. Essential Cookies are required for the operation of the Surebet247’s online gaming platform/website. They are used to provide content, products, and services to Users. These cookies help Player’s device download or stream information, navigate Surebet247’s online gaming platform/website with ease. In a bid to function properly, these cookies may collect IP address, app features or pages viewed, access dates and times, app crashes and other system activity, type of browser. Note that essential cookies are deleted once you close your web browser/browser session.
      2. Functionality Cookies allows Surebet247’s websites to remember User's site preferences and choices made on the site including username, region, language, location, and marketing. Also, it collects Users personal information to enable Surebet247 remember selections in your bet slip, specific products used on the website and shows Users relevant “related article” links. Functionality cookies expire after a maximum duration of two years. It can however be deleted from Users’ browser history at any point before its expiry time.
      3. Analytical Cookies allows Surebet247 website store the traffic source and compiles visitor statistics, duration used, and pages visited on the website. It also helps to test and improve the performance of our website to provide a better user experience. These cookies perform functions such as assessing errors within the user experience and providing statistics on how frequent Surebet247’s website is used.
      4. Third Party Cookies by third party service providers is used to obtain information from Player’s use of their cookies for the following:
        1. To track browser across multiple websites
        2. To target advertisements which may be of particular interest to you
        3. To deliver direct marketing communications personalized to Player’s preferences
        4. Note that third party cookies cannot be associated with an individual’s name, residential address, or other Personal Data as such they are pseudonymized. Also, the validity period for third party cookies varies. Users can delete any existing cookies and/or alter their browser’s privacy settings. Please note that deleting or disabling cookies means you may not be able to access certain features on Surebet247’s website.
  8. MARKETING AND ADVERTISEMENT
    1. Surebet247 utilizes technology that helps profile a Player through direct advertisements by post, telephone, social media platforms, email, SMS, application notifications and quiet notifications to suite the Player’s preference.
    2. Surebet247 may also retarget its Users by utilizing Player’s personal information to carry out paid online advertisements.
    3. Players may contact Surebet247 to decline profiling involving direct marketing or to update preferences at undefined. Players can also decline advertisement notifications at any time by clicking on the "unsubscribe" link that appears in such notifications or by requesting that Surebet247 stops directing further notifications by any means.
    4. Surebet247 will permit other service providers to evaluate and analyse Player’s interactions with Surebet247’s platform with the intention of providing advertisements across the internet, to track and report the performance of such advertisement. These providers may use cookies, and other technologies to identify Player’s mobile device upon interaction with Surebet247’s platform and other online sites and services.
  9. TRANSFER OF PERSONAL INFORMATION OUTSIDE NIGERIA
    1. Surebet247 shall ensure that Player’s personal information where applicable or necessary is transferred and processed in accordance with Nigerian Data Protection laws.
    2. By virtue of services provided abroad, Surebet247 will transfer personal information to third party suppliers and/or service providers, agents, advisors, or consultants outside the jurisdiction in accordance with Nigerian Data Protection Regulations laws, and for the purposes set out in this policy.
    3. Surebet247 may transfer Player’s personal information abroad on any of the following conditions:
      1. Where consent has been obtained.
      2. Where the transfer is necessary to conclude a contractual obligation between Surebet247 and a third party in the Player’s interest.
      3. Where the transfer is necessary to protect the Player’s vital interest.
      4. Where the transfer is necessary for reason of public interest.
      5. Where the transfer is for the establishment, exercise, or defence of legal claims.
    4. Surebet247 will take measures to ensure and provide an appropriate level of data privacy protection when sharing Player’s personal information abroad.
  10. SUREBET247’S PRIVACY PROTECTION CONTACTS
    1. All questions, requests, comments, complaints, or suggestions in relation to this Policy, or any other concerns about protection of information provided by the Player shall be forwarded to the contact details below:
      1. Email: [email protected]
      2. Live Chat
  11. REVIEWOFTHEPOLICY
    1. Surebet247 shall review, amend, and update this Policy at least once every year and shall make assessments of the measures put in place to protect Players’ privacy on Surebet247’s online gaming platform.
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