B&M SA respects individual privacy and values the confidence of its customers, employees, suppliers, contractors, business partners, and the general public.

That is why B&M SA strives to collect, use and disclose Personal Data in a manner consistent with the laws of the countries in which it does business.

B&M SA, owner of the betFIRST Casino brand, is committed to being compliant to the EU General Data Protection Regulation.

The management of B&M SA recognizes the importance of identifying and protecting the information assets of the organization, avoiding destruction, improper disclosure, improper modification or unauthorized use of any information relating to its customers, employees, pricing, strategy, management, or other related concepts.

B&M SA is therefore committed to develop, implement, maintain and continually improve its information security management system in order to ensure the confidentiality, availability and integrity of personal data and information in general.

A safe gaming environment betFIRST Casino is run by B&M SA, holder of a gaming licence accorded to them by Gambling Commission and in adherence with the new legislation concerning gambling and betting. We are a business registered in Belgium under company registration number 0437.057.848 and licensed by the Gambling Commission under number B+ 8524.

As a highly secure website, betFIRST Casino guarantees the online security of its players. Firstly, our software is virus-free and can be downloaded and installed on your computer in complete security. The optimum security we offer you is provided by the technology we use to protect our programmes and to maintain game transparency.

Your privacy is important to us. This privacy statement addresses information we collect at our web sites and in off-line sales and marketing activities. It explains what personal data we collect from you and how we use it.

This statement applies to the B&M SA products offered both online as offline. References to B&M SA products in this statement include B&M SA website, online and offline services, apps, software and devices.

Personal Data We Collect

B&M SA collects data to operate effectively and provide you the best experiences with our services and products. Through your interaction with us, B&M SA may collect Personal Data, which is information that identifies an individual or relates to an identifiable individual. Personal Data may include, but is not limited to, your name, physical address, telephone number, e-mail address, financial data, online behavior, use of certain services, social media profile and associated interests.

In order to register with betFIRST Casino, we need some personal information. The principal information needed to register is the following: name, surname, postal address, email, phone number and date of birth to ensure you are old enough to bet on our sites.

For our recruitment activities, B&M SA may ask for certain data, including educational and employment background, contact information and preferences, job qualifications, and jobs for which you would like to submit an application. You also may choose to provide B&M SA additional information, such as your CV, resume, or transcripts; employment references and related information; and compensation requests. In addition, B&M SA may collect information from third parties, for example, in connection with a background or employment check and/or an employment reference.

B&M SA may also collect other Information through your interaction with us and non-B&M SA websites, which does not reveal your specific identity or does not directly relate to an individual. Other Information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information.

Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data.

You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a service, product or feature, you may not be able to use that service, product or feature.

B&M SA will collect only Personal Data which is relevant for the purposes for which it is to be used. B&M SA will take reasonable steps to ensure that Personal Data is relevant, accurate, complete, and current, to its intended use.

Our use of Personal Data

B&M SA uses the data we collect for three basic purposes, described in more detail below: (1) to operate our business and provide (including improving and personalizing) the products and services we offer, (2) in order to improve the quality of our service and (3) to send communications, including direct marketing and promotional communications (news/modifications/maintenance/promotions and contests etc.).

Business Operations: We use data to provide and improve the products and services we offer and perform essential business operations. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions (including profiling which is fully automatic decision making by our software applications and tools in order to provide you with more personalized offers and information), and report on the performance of our business and the services our customers’ desire.

Communications: We use data we collect to deliver and personalize our communications with you via e-mail, sms or social media. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from B&M SA by email, telephone or social media.

Recruitment: We use data we collect to communicate with you, to manage B&M SA’s recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

Winnings and withdrawals: The winnings and withdrawals of players are kept in strictest confidence. All winnings are recorded on our secure system. betFIRST Casino keeps records of user wins and losses and will reveal them to a third party only when that third party is regulatory or government body.

Profiling: In the course of our services, we will analyze your information to build individual profiles. These profiles will be used to predict future interests and display targeted (online) advertisement. The aim is to provide you with offers that are relevant and interesting for you. The profiling is based on your behaviour on the internet. This includes the viewing of advertisements, any interaction with them, and the overlap between desktop and mobile usage. We expect that this profiling will have no further impact, other than providing you with a more pleasant user experience when using our website and services.

Why We Share Personal Data

We share your personal data in case we have a legal obligation to do so, for instance to the Gaming Commission, and in other cases with your consent or as necessary to complete any transaction or provide any service or product you have requested or authorized. In addition, we share personal data among B&M SA-controlled affiliates and entities. We also share personal data with suppliers, processors or agents working on our behalf for the purposes described in this statement. For example, companies we have hired to provide customer service or assist in protecting and securing our systems and services may need access to personal data in order to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to:

• comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
• protect our customers, for example to prevent spam or attempts to defraud users of our services or products, or to help prevent the loss of life or serious injury of anyone;
• operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks; or
• protect the rights or property of B&M SA, including enforcing the terms governing the use of the services – however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of B&M SA, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.

Some of our services or products include links to products of third parties whose privacy practices differ from B&M SA’s. If you provide personal data to any of those services or products, your data is governed by their privacy statements.

Where Do we Store and Process Your Personal Data?

Personal data collected by B&M SA may be stored and processed in your region or in any other country where B&M SA or its affiliates, subsidiaries or service providers maintain facilities. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

When we transfer personal data from the European Economic Area to other countries, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data.

How long do we keep your Personal Data? Retention of Personal Data

B&M SA retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Recruiting data is stored according to the maximum allowed retention periods according to the candidate’s location. Candidates can ask for deletion of their data at any time, if they don’t wish to keep up their application by notifying their recruiter or contacting the Data Protection Officer of B&M SA.

Your rights as a data subject: You CAN Access & Control Your Personal Data

Upon request, B&M SA will grant individuals reasonable access to Personal Data that it holds about them. In addition, B&M SA will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Communications Preferences

You can choose whether you wish to receive promotional communications from B&M SA by email and telephone. If you receive promotional email from us and would like to opt out, you can do so by following the directions in that message. If you do not wish to receive telephone calls from us, do not provide a telephone contact number.

Browser-Based Controls

Cookie Controls. Relevant browser-based cookie controls are described in our Cookie Statement.

Security of Personal Data

B&M SA is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a password) over the Internet, we protect it through the use of encryption.

B&M SA is also committed to reducing risks of human error, theft, fraud, and misuse of B&M SA facilities. B&M SA’s efforts include making personnel aware of security policies and training employees to implement security policies. B&M SA employees are required to maintain the confidentiality of data. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.

B&M SA promptly evaluates and responds to incidents that create suspicions of unauthorized handling of data. If B&M SA determines that your data has been misappropriated (including by a B&M SA employee) or otherwise wrongly acquired by a third party, B&M SA will promptly report such misappropriation or acquisition to you.

B&M SA will conduct annual compliance audits. The audit will be conducted under the direction of the Data Protection Officer. Any employee that B&M SA determines is in violation of this privacy statement will be subject to disciplinary action up to and including termination of employment. Any agent or third party that violates this privacy statement shall be in material breach of all agreements with B&M SA and shall defend and indemnify B&M SA from claims related to such violations.

Security of your transactions

betFIRST Casino guarantees that your financial transactions are secure, no matter which payment method you use!

betFIRST Casino also uses sophisticated MD5 encryption technology in order to completely ensure the safe online transfer of any of the personal information to which we have access.

betFIRST Casino ensures that all its players can bet in security and comfort. In order to achieve this, betFIRST has a dedicated team of technicians whose exclusive task is to test and guarantee the correct functioning of the bets and the security of our server.

Your transactions have never been as safe and secure as they are with betFIRST Casino!

Consent

We will obtain your prior consent before processing your information for its own purposes, unless betFIRST has a legitimate interest or legal basis to process your information. If you have given your consent to the processing, you have the right to withdraw your consent at any time, by sending an email to that extent to: [email protected]. betFIRST Casino will discontinue the processing of your information upon receipt of your withdrawal. However, any processing performed prior to your withdrawal remains a legitimate processing based on a valid consent at the time. betFIRST Casino will not be under the obligation to reverse the processing.

Changes to This Privacy Statement

We will update this privacy statement when necessary to reflect customer feedback and changes in our products or services. When we post changes to this statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement or in how B&M SA will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how B&M SA is protecting your information.

Data Protection Officer: How to Contact Us

If you have a privacy concern or a question for the Data Protection Officer of B&M SA, please contact us by using the following contact information.

We will respond to questions or concerns within 30 days.

Stéphanie Heyman is the Data Protection Officer of B&M SA.

Registered Seat: LEEUW VAN VLAANDERESNTRAAT 15, 9550 WARSCHOOT

Company registration number: 0437.057.848

Email: [email protected]

Some services have their own, separate privacy agreements. In the event of a conflict between a B&M SA privacy statement and the terms of any agreement(s) between a party and B&M SA, the terms of those agreement(s) will control.

Contact

You can contact the betFIRST Casino Customer Service at any time if you have any queries or if you are in need of help (see the ‘Contact’ panel on the betFIRST Casino website). In order to improve our services, telephone conversations may be recorded or monitored by another member of the team.

If you have any complaints, please do not hesitate to contact us by using the contact forms in the Contact Us section. We will do everything possible to resolve the problem as soon as possible. If for any reason you are dissatisfied with the solution we have provided you with, you can make a formal complaint to the Gambling Commission (http://www.gamingcommission.fgov.be).

B&M/BETFIRST is preparing to be GDPR compliant across all of its services and processes, by the time the regulation comes enforceable

We have analyzed GDPR requirements and have put in place a dedicated internal team to drive our organization to meet them.

Some of our ongoing initiatives are:

• Identifying personal data – B&M/BETFIRST evaluate for all personal data the collection, usage, storage and disposal. Defining the processing activities for all personal data and documenting the various sources of data will go a long way in providing a roadmap for compliance in the days leading up to implementation.
• Providing customer support – An important aspect of GDPR is how the collected data is used. As a data controller, B&M/BETFIRST's key role is to provide our customers with the knowledge to effectively protect their user data. B&M/BETFIRST updates and concludes processing agreements where required and explores how processing activities are performed.
• Enhancing data integrity and security - Data privacy and data security are important aspects of the GDPR. B&M/BETFIRST will update processes, IT policies and procedures to ensure endto-end security.

What does this mean for our customers?

We understand that meeting the GDPR requirements will take a lot of time and effort.

As your provider of Betfirst services, works to ensure you that security best practices are implemented and Data Processing Agreements are put in place.

What are we doing to be GDPR-ready?

For GDPR compliance in our organization, we will do the following things:

• Appoint a DPO
• Create a data privacy team to oversee GDPR activities and raise awareness
• Review current security and privacy processes in place & where applicable, revise our contracts with third parties to meet the requirements of the GDPR
• Identify the personal data that is being collected and create a data register for the personal data
• Analyze how this information is being processed, stored, retained and deleted
• Assess the third parties with whom we disclose data
• Establish procedures to respond to data subjects when they exercise their rights
• Establish & conduct Privacy Impact Assessment (PIA)
• Create processes for data breach notification activities
• Continuous employee awareness is vital to ensure continual compliance to the GDPR

In April of 2016, the European Union approved a new data privacy regulation, the General Data Protection Regulation. The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to unify data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy. Enforcement of this regulation begins May 25, 2018. Any organization that works with EU residents' personal data in any manner, irrespective of location, has obligations to protect the data and data privacy. B&M/BETFIRST is well aware of its requirements and role in providing the right processes and applications to support our customers and internally meet the GDPR mandates.

At B&M/BETFIRST, we have always honored our customers' right to data privacy and protection. As a Belgian company, B&M/BETFIRST has a responsibility to ensure the data and privacy rights of its employees and customers are met.

B&M/BETFIRST has no necessity to collect and process customers' personal information beyond what is required for the delivery of its services.

We recognize that the GDPR will help us move towards the highest standards of operations in protecting customer data.