Highbet B.V. and its affiliated companies (hereinafter collectively referred to as “ChilliGames”, “we” and/or “us”), is a company based in Curacao. The company (number 148202), which has its registered office at Abraham Mendez Chumaceiro Blvd.50, Willemstad, Curacao, complies with the Personal data Protection Act of Curacao (2013) and the European Parliament’s 2016 ‘Regulation EU 2016/679’ act on the use of Personal data and data protection (General Data Protection Regulation[“GDPR”]).

In this document, ChilliGames explains how we collect, process and store Personal data from customers (hereinafter referred to as “you”) using the ChilliGames Website: http://chilli-games.betinvest.me/ (the “Website”). This document also forms an integral part of the Terms & Conditions (T&C”) for using the ChilliGames Website.

For the purposes of this document, the terms below have the following meanings:

“Consent” means freely given, specific and unambiguous indication of your agreement to the processing of your Personal data by ChilliGames.

“Controller” means a natural or legal person, which alone or jointly determines the purposes and means of the processing of Personal data. Highbet B.V. is a Controller in the meaning of the GDPR and this Privacy Policy.

“Data subject” means an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to their Personal data. You are a Data subject in the meaning of the GDPR.

“Personal data” means any information relating to you that helps us directly or indirectly identify you as a Data subject.

1. WHAT PERSONAL DATA DO WE COLLECT?

Personal data that we may collect, store and process includes:

• Information that you provide to us by filling in forms on the Website or any other information you might submit to us via the Website, email, telephone, Skype and/or Live Chat (e.g. first name, surname, ID number, address, email, payment details).
• Record of correspondence, whether via the Website, email, telephone or other means.
• Details of the transactions you carry out with us, whether via Website, telephone or other means.
• Details of your visits to the Website, including traffic data, location data, activity logs and other communication data.
• Information we get from your devices (IP address, cookies, computer model, operating system and its version, serial numbers).
• Your telephone/Skype/Live Chat conversations – either when placing a bet or contacting customer service.
• Information and communications on Website forums, including chat rooms and message boards, profile comments, in-game challenges and chat messaging with game operators and/or other users.
• Your responses to marketing campaigns from us.

2. HOW WILL WE USE YOU PERSONAL DATA?

ChilliGames will legally use and process your personal information and other data together with other information, in the following way:

• as a legal obligation  according to the gaming legislation, AML legislation or any other specific law that is relevant to the ChilliGames business activity;
• in our own legitimate interests for commercial and business reasons. Please note that the processing of Personal data is necessary and we will perform a relevant balancing test to ensure that such processing is lawful and conducted only for specific and legitimate purposes, e.g. anti-fraud measures, risk management, network security, customer support, service personalisation and web analytics;
• under the terms of the contract ChilliGames entered into with you (by your acceptance of ChilliGames T&C) and any third party (by signing relevant documents). However, processing of your Personal data is strictly limited to legal requirements stated in the above-mentioned agreements. 
• upon receiving your Consent only for the period during which we have your Consent to process your Personal data and for the purposes you agreed to.

We process your Personal data for the purpose of providing services and also for business-related purposes explained below:

• Processing your bets, including card and online payments.
• Setting up and managing your account, plus verification of your identity.
• Complying with our legal and regulatory duties.
• Complying with risk management procedures and monitoring transactions for the purpose of preventing fraud, irregular betting, money laundering and cheating.
• Identification of system problems and administration of the Website.
• Involving you in surveys and polls relating to the services we provide.
• Providing you with information about promotional offers and the products and services available.

3. WHO IS YOUR PERSONAL DATA SHARED WITH?

We share your Personal data with:

1. The Affiliates of Highbet B.V.“Affiliates” for the purpose of this Privacy Policy includes all direct or indirect subsidiary enterprises of Highbet B.V., its joint venture partners, and their related companies. We may share your Personal data with our Affiliates for set-up, verification and management of your account, for marketing research and data analysis, to conduct relevant risk management and comply with legal and regulatory obligations.

2. Third Parties (customer services software providers, marketing agencies and other trusted partners). ChilliGames is always keen to give customers the best service possible. One of the ways of doing this is to use customer services software providers. ChilliGames also uses data analysis, research and surveys to identify and satisfy customer needs. To help with this, we may also transfer some of your Personal data to relevant marketing agencies. All of the above-mentioned entities will receive only the data they require for the provision of services and compliance with their legal and regulatory obligations. For the protection of your Personal data, relevant measures will be taken by ChilliGames prior to transfer of data to the above-mentioned parties.

3. International data transfers. ChilliGames runs its business activity worldwide (except for “Restricted areas” as stipulated in the T&C). However, some countries outside the European Economic Area (“EEA”), do not have effective laws regarding data protection. To ensure the appropriate level of protection, we add relevant contractual clauses, designed to offer the same level of protection of Personal data as within the EEA.

We would like to emphasize that ChilliGames makes every effort to ensure the protection of Personal data while cooperating with any third parties. In addition, we try to secure your rights and information, by verifying whether the data is processed in accordance with the GDPR standards and other legal requirements.

4. WHERE IS YOUR PERSONAL DATA STORED?

We store your Personal data in the data centres within the European Economic Area. While your information is being transferred to the data centres we limit its processing to a strictly necessary extent, in keeping with the procedures aimed at ensuring the network and information security. In addition, the security of any transfer of data is helped by using computer security incident response teams (CSIRTs), computer emergency response teams (CERTs) and other means to ensure a high level of protection.

Moreover, data centres use Operational Metrics (traffic data, cryptographically hashed file samples, clickstream information, logged snippets of transmitted content, IP trust scores and other server activity data and all analytic products derived therefrom). 

5. HOW LONG IS YOUR PERSONAL DATA STORED FOR?

ChilliGames will legally store your Personal data for the relevant retention period. Thus, such information will be processed until you delete your account on the Website and further within the reasonable period, in accordance with the terms of AML procedures, requirements for gambling operators and any other applicable legislative grounds. 

6. WHAT ARE YOUR RIGHTS?

GDPR entitles you to a range of specific rights with regards to your Personal data. Please make sure you examine the following list with due care. In addition, we would like to stress that some rights relate to specific circumstances only.

I. Right to be informed regarding your Personal data. By this Privacy Policy, ChilliGames tries to highlight the most crucial issues concerning the security of your Personal data to keep you informed. If the Privacy Policy is in any way changed, then this page will be updated accordingly. 

II. Right to access. It is your right to receive information from us regarding whether we are using your Personal data. You are also entitled to ask us to clarify which of your Personal data we have. In addition, you may request a copy of the Personal data which is being processed.

III. Right to alter incorrect data. You have a right to change inaccurate Personal data in our possession.

IV. Right to have data removed. You are entitled to erase your Personal data in our possession due to specific circumstances. Those would be if the data is no longer necessary for the stated purposes, you withdraw your Consent to data processing, your Personal data has been unlawfully used, there are no overriding legitimate grounds to process your information and/or your Personal data is to be erased for legal reasons. However, please, note that ChilliGames is not bound to comply with such a request if processing of your Personal data is necessary to exercise the right of freedom of expression and information, comply with a legal obligation in the public interest, exercise official authority and/or establish, exercise or defend legal claims.

V. Right to restriction of processing. You have the right to request the suspension of your Personal data being processed, for example, if the accuracy of the data is being questioned. 

VI. Right to data transfers. You are entitled to transfer your Personal data in our possession to any other data Controller. You also have a right to receive a report on your Personal data from ChilliGames in a structured, commonly used and machine-readable format. While transferring the above-mentioned data to you, ChilliGames will take all security measures necessary to ensure your Personal data is securely transmitted by using end-to-end encryption or any other strong authentication measures.

VII. Right to object. You have the right to object to the processing of your Personal data. However, where legitimate grounds to use your information outweigh your interests and rights, ChilliGames reserves the right to continue such processing.

VIII. Right not to be subject to automated decision-making. You are entitled not to be subjected to automated decision procedure. ChilliGames ensures that all important matters relating to your Personal data are resolved by our team. 

7. HOW COULD YOU EXERCISE YOUR RIGHTS?

To exercise any of the above-mentioned rights, you must provide us with a special request. Should you wish to make such a request, please, contact us via the following e-mail address: [email protected] Your application should include adequate identification details and appropriate documents to support your request. ChilliGames will deal with your concerns within 30 days and reply to you regarding each issue. If you do not receive a response to your request within the stipulated time period or are not satisfied with our processing of your Personal data, you are entitled to apply to your local data protection authority. 

8. CONSENT

By registering on the Website as a customer of ChilliGames and/or using our services, you Consent to the processing of your Personal data by ChilliGames and to the terms and conditions of this Privacy Policy. Please, make sure you understand all your rights and obligations stated here and in the T&C.

9. FURTHER INFORMATION

HighBet always aims to make its customers aware of their rights and obligations. Please, make sure you read carefully this Privacy Policy, T&C and other legal documents on the Website. If you have any doubts regarding our services or need any additional assistance, do not hesitate to contact us via following e-mail: [email protected].
 

10. UPDATE

Last update of this Privacy Policy: September 16, 2022