Effective Date: October 21st, 2024

At SMS2Bet (SMS2Bet Betting Services (Pty) Ltd) we value and respect your privacy. This Privacy Policy outlines how we collect, use, share, and protect your personal information when you use our website and services. We comply with the Protection of Personal Information Act, 2013 (POPIA) and the Promotion of Access to Information Act (PAIA), ensuring that your information is handled in accordance with South African law.

1. Definitions
   Personal Information: Information relating to an identifiable, living individual, including but not limited to names, addresses, ID numbers, account details, and gaming activity.
   Special Personal Information: Includes race, health, religious or philosophical beliefs, political persuasion, sex life, biometric information or their criminal behaviour of a data subject.

• Processing: Any operation or set of operations concerning personal data, such as collection, storage, alteration, and transmission.
• Data Subject: The individual whose personal information is being processed.
• Responsible Party: SMS2Bet, as the entity determining the purpose and means of processing your personal information.
• Operator: Any third-party service provider processing information on behalf of SMS2Bet.
• Information officer: An individual, the CEO of SMS2Bet by default or other person authorized by the CEO of SMS2Bet, registered with the Information Regulator responsible for overseeing compliance with data protection laws.
• Regulator: a public authority established under POPIA for providing education regarding the protection and processing of personal information; monitoring and enforcing compliance with the provisions of POPIA; consulting with interested parties and acting as mediator; receiving, investigating and attempting to resolve complaints; issuing enforcement notices and codes of conduct; and facilitating cross-border cooperation.

2. Types of Personal Information We Collect
We may collect various types of personal information, including:

• Registration Details: Name, ID/passport number, email address, physical address, date of birth, and contact information.
• Account and Financial Data: Bank account details, payment card information, withdrawal and deposit history, winnings, and transaction details.
• Gaming Information: Data related to your gameplay, wagers, bets, wins/losses, and game preferences.
• Location Data: IP address, geolocation information, and device data to ensure compliance with regulatory requirements (e.g., responsible gambling policies).
• Verification Information: Documentation required for age and identity verification (e.g., ID copies, proof of address).
• Cookies and Tracking: Online identifiers, including cookies, device identifiers, and browsing patterns to enhance your gaming experience.

3. How We Collect Personal Information
Personal information is collected:

• Directly when you register for an account, use our services, or interact with us (e.g., via customer support or chat).
• Automatically through the use of cookies and similar technologies when you visit our website or app.
• From Third Parties such as regulatory bodies, credit reference agencies, fraud prevention agencies, and partners involved in delivering our services.

4. Purpose of Processing Personal Information
We process your personal information for the following purposes:

• Account Management: To create and manage your account, verify your identity, and ensure you meet legal gambling age requirements.
• Payment Processing: To process deposits, withdrawals, and payouts in a secure manner.
• Gameplay and Service Delivery: To enable you to participate in games, track wagers, monitor gaming activity, and provide customer support.
• Regulatory Compliance: To comply with legal obligations, including anti-money laundering (AML) regulations, responsible gambling practices, and reporting to gambling authorities.
• Marketing: To send promotions, bonuses, and other marketing communications (with your explicit consent).
• Fraud Prevention: To detect, prevent, and investigate fraud, abuse of our services, or other illegal activities.
• Enhancing User Experience: To improve our website, app, games, and services based on analytics and feedback.

5. Legal Grounds for Processing
We rely on the following legal bases under POPIA to process your personal information:

• Contractual Necessity: To provide our services under the Terms and Conditions you agreed to upon registration.
• Legal Obligation: To comply with various gambling and financial laws.
• Legitimate Interest: To protect the integrity of our gaming platform, prevent fraud, and ensure the security of our services.
• Consent: For direct marketing and other activities requiring explicit consent (e.g., cookies).

6. Sharing Your Personal Information
We may share your personal information with:

• Affiliates and Service Providers: For payment processing, customer support, game provision, and system administration.
• Government and Regulatory Authorities: To meet our legal and regulatory obligations, including reporting to the South African Gambling Board.
• Anti-Fraud and Credit Agencies: To conduct identity checks, prevent fraud, and verify your financial information.
• Marketing Partners: With your consent, we may share your information for marketing purposes with partners who help promote our services.
• Third Parties: In case of mergers, acquisitions, or the sale of our business, provided they follow similar data protection standards. International Transfers: If we transfer your personal information outside South Africa, we will ensure that such transfers are conducted under appropriate safeguards, such as contractual agreements or ensuring the recipient country has adequate data protection laws.

7. Data Retention
We retain your personal information only as long as necessary to fulfil the purposes outlined in this policy or to comply with legal requirements. We are required by gambling or AML regulations to retain your financial transaction history for at least 5 years. Once your information is no longer required, we will securely delete or anonymize it.

8. Your Rights as a Data Subject
You have several rights regarding your personal information under POPIA, including:

• Right to Be Informed: You have the right to be informed about what personal information we collect and for what purposes before the start of such processing.
• Right to Access: You can request access to your personal information held by us at any time. Download the PAIA manual for this purpose.
• Right to Correction: You may request corrections or updates to your personal information if inaccurate.
• Right to Object: You have the right to object to processing, particularly for direct marketing or profiling for marketing purposes.
• Right to Erasure: In certain circumstances, you can request that we delete your personal information, subject to legal limitations.
• Right to Data Portability: You can request that your data be provided to you in a structured format for transfer to another service provider.
• Right to Withdraw Consent: If you’ve provided consent for specific processing activities (e.g., marketing), you may withdraw your consent at any time. To exercise your rights, please contact our Information Officer.

9. Data Security
We implement robust security measures to safeguard your personal information. This includes encryption of sensitive data, access controls, firewalls, and regular security audits. Despite our best efforts, no online platform can guarantee 100% security. You are responsible for keeping your login credentials secure. In the event of a data breach, we will notify affected users and the South African Information Regulator where required by law.

10. Use of Cookies and Similar Technologies
We use cookies and similar tracking technologies to enhance your experience, monitor website performance, and serve personalized content. Some of the cookies we use are necessary for the website to function properly, while others require your explicit consent. You can manage your cookie preferences through your browser settings or through our Cookie Policy.

11. Minors
Our services are strictly for individuals aged 18 and above. We do not knowingly collect personal information from anyone under 18. If we become aware that personal information from a minor has been collected, we will delete it immediately. Parents or guardians may contact us if they suspect their child has shared such information with us.

12. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy to reflect legal requirements or changes to our business practices. We will notify you of any significant changes by posting an updated version on our website. Your continued use of our services after changes are posted will constitute acceptance of the updated Privacy Policy.

13. Contact Information
For questions regarding this Privacy Policy or to exercise your rights under POPIA, please contact our Information Officer:

• Email: [email protected]
• For complaints, you may also contact the South African Information Regulator:
• Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Email: [email protected]
• Phone: 010 023 5200

Cookie Policy
This Cookie Policy complements our Privacy Policy (link). Its purpose is to explain what cookies are, why we use them, and how you can control them when you visit or use our website. When you visit our website, our system automatically gathers information like your browser type, IP address, and the website that referred you. This collection may be carried out in cooperation with our platform providers and partners. We may receive general demographic or usage data from them regarding visitors to our Website.

What are Cookies?
Cookies are small data files that websites ask your browser to store on your device, like a computer or smartphone. They help remember information about you, such as your preferences (like language settings) or details about your device. Depending on how long they are stored, cookies can be categorized as either session cookies or persistent cookies.

• Session cookies: These are stored only during your use of the website and are deleted once you leave.
• Persistent cookies: These remain on your device for the duration specified in the cookie settings or until you manually delete them.

Types of Cookies We Use and Their Purposes

1. Required Cookies: These cookies are essential for navigation and basic functionality of the website, such as accessing secure areas.
2. Functional Cookies: These cookies enhance your experience by saving the settings or configurations you’ve made on the website. They remember your preferences and provide additional features and personalized content.
3. Advertising Cookies: These cookies help us evaluate the effectiveness of our content marketing efforts. Provided by our partners, they track website visits and new player registrations via advertisements. While we do not share personal data like your name or email with these partners, your website visit data may be combined with other information collected from different sources. The processing of this data is subject to the privacy policies of the third-party providers.

Due to the technical structure of our Website, the cookies we use can be divided into three main categories:

1. Cookies set by back-end applications
2. Cookies set by front-end applications
3. Third-party cookies

Additionally, we work with third-party service providers who also set cookies on this website to offer services, such as tracking your activity, improving the website experience, measuring the website’s performance, and evaluating our marketing campaigns.

How to Control Cookies Most browsers automatically accept cookies, but you can modify your browser settings to block or delete them if you prefer. However, we recommend that you do not block or delete cookies, as this may limit your ability to use some features of our website.

You can manage cookies through your browser settings. The help section in your browser should provide instructions on how to do this.

For more information about cookies, visit https://www.aboutcookies.org.

Here are helpful links for managing cookies in various browsers:

• Chrome: Managing cookies in Chrome
• Firefox: Managing cookies in Firefox
• Internet Explorer: Managing cookies in Internet Explorer
• Safari for Mac: Managing cookies in Safari
• Opera: Managing cookies in Opera
• Microsoft Edge: Managing cookies in Edge