1. Introduction
1.1. We are committed to protecting your privacy and your Protected Personal Information and therefore warrant that no information collected by Sunbet shall be used for any other purposes other than stipulated in these Terms.
1.2. By accessing or using the Sunbet services and website, you expressly consent to Sunbet collecting and Processing of your Protected Personal Information, which permission is restricted as set out herein, you may revoke this permission in writing at any time by sending an e-mail to this effect to the following e-mail address support@sunbet.co.za.
1.3. You acknowledge that you have read these Terms and in particular the privacy policy contained herein and that you understand and accept the consequences of the consent with respect to your Protected Personal Information and that you are giving such consent voluntarily and without any undue influence from Sunbet.
2. Processing of your Protected Personal Information
2.1. To enable Sunbet to provide premium services and benefits to its customers, it requires up-to-date and correct personal information of its Customers. Protected Personal Information includes the prescribed information falling within the definitions of personal or special personal information as set out in the Protection of Personal Information Act, 2013, as may be amended.
2.2. The Protected Personal Information of Customers which Sun International may process include the following:
2.2.1. Names, identity numbers, contact details, addresses, occupations;
2.2.2. Information regarding whether Customers are politically exposed or prominent influential persons; and
2.2.3. Preferences and opinions.
3. Purpose of and Consent to Processing Protected Personal Information
3.1. Sunbet will not collect or Process your Protected Personal Information for any purpose, other than the purposes disclosed to you herein, unless you give us express written consent to do so, or unless we are permitted or required to do so by any Applicable Law, and we will at all times remain responsible for determining the purposes and means for Processing your Protected Personal Information and disclosing such purpose to you to the extent that it has not done so in these Terms and Conditions. With your express written consent to the sharing of your Protected Personal Information by us (strictly for the purposes disclosed to you herein).
3.2. By entering into, opening an Player Account and/or placing a bet on Sunbet’s website, you hereby give your express consent to Sunbet and Sun International’s group of companies, to obtain, process and further process your Protected Personal Information for any lawful purposes including:
3.2.1. allow you to register and transact with Sunbet;
3.2.2. provide premium service and benefits;
3.2.3. verify your identity;
3.2.4. process loyalty benefits (where applicable);
3.2.5. monitor and analyse your conduct on your Player Account and profile for fraud, compliance and other risk-related purposes;
3.2.6. carry out statistical and other analyses to identify potential markets and trends and/or develop new products and services; and
3.2.7. to carry out certain marketing activities.
3.3. You hereby agree and consent to Sunbet retaining your Protected Personal Information for such periods as Sunbet may determine is necessary for its legitimate business security and record keeping purposes. Specifically, you expressly consent to Sunbet to disclose your Protected Personal Information –
3.3.1. to any person that provides services (which services may include verifying, updating and processing Protected Personal Information) to Sunbet or acts as Sunbet’s agent or to whom Sunbet have transferred or propose to transfer any of its rights and duties in respect of its goods and services (some of these persons may be located outside of the Republic of South Africa), and share your Protected Personal Information with Sunbet’s service providers, locally and outside the Republic of South Africa, as necessary. Sunbet may ask persons who provide services to Sunbet to agree to applicable privacy policies if it requires to access any Protected Personal Information to carry out their services;
3.3.2. to Sunbet’s legal advisors, financial advisors, auditors or a competent court in legal proceedings; and
3.3.3. to any entity which is part of Sun International's group of companies for purposes to provide any goods and services or for other purpose permissible by law.
3.4. You consent to checks being made against appropriate third party databases to verify identity, personal details or credit card information, and any other information supplied by the Customer that Sunbet deems necessary to acquire independent verification. The parties with which Sunbet contracts for the verification of information may keep records of all data requests and data submitted to them by Sunbet.
4. Updating of your Protected Personal Information
4.1. You may update your Protected Personal Information online (where applicable) by visiting Sunbet’s official website www.sunbet.co.za. The access to and deletion of Protected Personal Information is subject to processes set out in Sun International's PAIA manual which is also available at www.suninternational.com/investors/governance.
4.2. You hereby accept that Sunbet takes reasonable and practical steps to safeguard Protected Personal Information in your possession.
4.3. All information supplied is strictly confidential, and the Customer agrees to be bound by Sunbet’s privacy policy.
5. Security
5.1. All customer personal information is stored securely by Sunbet and will not be shared with third parties, other than information required to process third party checks and payments, which will be transmitted securely to Sunbet’s processors. You acknowledge that Sunbet will be required to supply his/her personal details and transaction records to The Western Cape Gambling and Racing Board and any other statutory body that legally requests or requires access to such data. You acknowledges that although every endeavour has been made to ensure yourdata privacy, Sunbet makes no guarantees, and will to the best of our ability ensure that information supplied by you is not made available to any third party except as required or permitted by law.
5.2. Sunbet tracks and stores information regarding your use of the Sunbet website, including the IP address of the computer used to place bets. If you require access to information on what data is held about you, this can be obtained by contacting us (in accordance with the Promotion of Access to Information Act No. 2 of 2000).
5.3. Sunbet secures all customer information, both online and offline.
5.4. Sunbet shall take all reasonable steps to protect your Protected Personal Information from loss of, damage to, unauthorised use of, or misuse or alteration of your Protected Personal Information. The Protected Personal Information shall be stored in databases that have built-in safeguards to ensure the privacy and confidentiality of that information.
5.5. A variety of security measures are used to maintain the safety of the Protected Personal Information when an order is placed or Protected Personal Information is entered, stored, recalled or accessed. All supplied sensitive Personal Information including, but not limited to personal particulars are transmitted via Secure Socket Layer (SSL) technology and then encrypted into the database. Such information will only be accessible by the authorised personnel of such payment provider with special access rights to such systems, and such individuals are required to keep the information confidential.
5.6. Sunbet may however disclose any information that we see fit to the relevant authority where we are required to disclose that information in terms of any Applicable Law.
6. Your Rights to Your Protected Personal Information
6.1. You have certain rights in relation to the Protected Personal Information that we hold about you.
6.2. You have a right to know what Protected Personal Information Sunbet holds about you and in some cases to have the information communicated to you.
6.3. If you wish to exercise this right please contact Sunbet to let it know that you wish to exercise your right of access and what Protected Personal Information in particular you would like to receive.
6.4. Sunbet reserves the right to ask for reasonable evidence to verify your identity before providing you with any information and any Applicable Law permits Sunbet to charge a fee for exercising this right of access.
6.5. Please note that Sunbet may not be able to provide all the Protected Personal Information you ask for, for instance if the information includes Protected Personal Information about another person.
6.6. Where Sunbet is not able to provide you with information that you have asked for, Sunbet will endeavour to tell you why. Sunbet will try to respond to any request for a right of access as soon as possible, upon receipt of your request, evidence of identity and any applicable fee.
6.7. In some circumstances you have a right to have some of the Protected Personal Information that Sunbet holds about you deleted. Should you wish to have any information about you deleted, please contact us at the following e-mail support@sunbet.co.za.
6.8. Please note that to ensure that Sunbet does not collect any further Personal Information you should also delete your log-in credentials from all of your devices and clear our cookies from any device.
6.9. Where Sunbet deletes Protected Personal Information about you, Sunbet may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. Sunbet may also retain your Protected Personal Information in an anonymised form using your Protected Personal Information. Please note that such deletion shall be done in a manner similar to emptying the recycle bin on a computer and you understand and agree that the removed content may persist in backup copies for a reasonable period of time (but will not be available to others).
7. COOKIES
7.1. Sunbet uses cookies, which are small files that the Sunbet services may transfer to the hard drive of our device through your web browser (if you allow this), which enables Sunbet to recognise your browser and capture and remember certain information. You can disable cookies through your web or phone browser settings.
7.2. Sunbet uses cookies to help it remember, process and compile aggregate data about site traffic and site interaction so that Sunbet can offer you better site experiences and tools in the future. These technologies allow the collection of data, such as your device's model, operating system and screen size, the other applications installed on your device, and information about how you use the Sunbet services and website.
Kambi Player Privacy Notice
Kambi Player Privacy NoticeThis Kambi Player PrivacyNotice (“the Kambi Player PN”) is applicable to players only. By players we mean registered users who have an account or profile with a gambling operator who uses the Kambi sports betting platform (each, an “Operator”).
Kambi Group plc is a company registered in Malta and listed on First North at NASDAQ, Stockholm, with a registered address at Avenue 77, A4, Triq in-Negozju, Zone 3, Central Business District, Birkirkara, CBD 3010 XBX1120 (“Kambi HQ”). Kambi HQ, working with the other Kambi entities (including those entities listed in the “Contact Us” section below – together “Kambi”, “we”, “us” and/or “our”), provides a sports betting platform solution for Operators. The solution involves Kambi reviewing and managing the bets placed through an Operator’s website (which uses the Kambi platform) so as to manage the risks associated with those bets. This Kambi Player PN explains how we handle your Personal Data where you are a player and your bet has been moved through our platform. Please read this Kambi Player PN carefully to understand how we will treat your Personal Data. This Kambi Player PN is supplementary to any other privacy notice published by each Operator.
For the purposes of this Kambi Player PN, Kambi is the “Controller” of your Personal Data. This is because when we process your Personal Data, we will make determinations about why and how your Personal Data is processed.
If you are not a player, and are a visitor to our website, or receiving marketing or other services from us, please refer to the Kambi Website Privacy Notice, which provides information about how Kambi will handle your Personal Data in those circumstances.
Types of data we collect/process:
We will collect certain information about you when you are a player. This information originates from the Operator you hold an account with. We get this information from them when they sign up to use our services and pass your information to us. Alternatively, we will collect this information directly from you by virtue of obtaining information about the device which you use to make a bet, which is then linked to the other information which we hold about you, as well as information about the actual bets you make. Additionally, there may be some information which we generate about you in order to provide our services.
By Personal Data, we mean information which, either by itself or when combined with other information that we hold or which is available to us, can be used to identify you.
The type of information we receive, collect, or otherwise process about you is as follows:
technical information from your computer/laptop/tablet/smartphone, including:
As you will note, Kambi does not, as a matter of course, hold your name, or contact information. The Personal Data which we process is restricted to the device you use to place bets, your Operator and Kambi unique identifiers, and information relevant to your playing behaviour. What this means is that the only way we can identify you by name, will be when the personal information which we have is combined with personal information which an Operator has. As noted, if you have used your real name as your username or if the Operator shares additional identity data with us, then the information we hold about you may be directly identifiable.
Kambi does not collect or process special category personal data (i.e. information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning your health, sex life or sexual orientation).
How we use your Personal Data:
Kambi will use your information in the following ways:
Please note that we do not undertake decision-making based solely on automated processing which produces legal effects concerning players or similarly significantly affect them. We do however undertake profiling. To safeguard players’ rights and interests, we allow players to contest decisions that we make about risk profiling or to object to our use of profiling.
When we apply a risk profile to a player, it is confirmed or amended by our analysts. We continue to monitor a player’s risk profile, and we use automated processing to recommend if a player’s risk profile should change. Any proposed changes are confirmed or amended by our analysts.
We use technology to assess if a bet falls outside a particular pattern. This is part of our risk management. If the bet does fall outside a particular pattern, our analysts will review it and decide how to handle it. There is no automated decision-making taking place. All decisions are made by a person.
In general, we will use the personal information we collect from you only for the purposes described in this Kambi Player PN or for purposes that we or any of our Operators explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
Our legal basis of Processing:Under applicable data protection laws, we have to have a legal basis to process your Personal Data. The legal basis which we have outlined in this Kambi Player PN includes (as relevant):
Processing that is necessary for our own legitimate interests or those of third parties (including the other Kambi group companies and our Operator clients). These interests are:
the management and audit of our business operations to ensure that they comply with all applicable laws and good business practices;
making assessments on your betting behaviour, which is a fundamental part of the service which we provide to Operators;
Sharing your Personal Data with our service providers, such as:
Who we may disclose your Personal Data to:
As outlined earlier in this Kambi Player PN, Kambi will disclose to, or share your Personal Data with, the Operator you have an account with as part of the service we provide to them. We share reports and results of risk assessments we have conducted on you with our Operators. We will liaise with them where we need to limit your betting or make a decision on your account. We may also disclose your information to an Operator in connection with a data subject rights request (please see below for further information).
Kambi will also disclose your Personal Data to law enforcement agencies, regulators, and other authorities with jurisdiction over us (or members of the Kambi group) if we have a legal obligation to do so, or it is in our legitimate interest, or is in the substantial public interest to do so. This includes exchanging information with government departments or gambling authorities.
We will also share your Personal Data, where it is lawful to do so, with:
group companies, including the entities referred to in the “Contact Us” section below;
third parties in the event of a corporate or other transaction involving the sale or transfer of all or part of Kambi, or as otherwise required for any restructuring of Kambi;
third party service providers, such as IT systems, network and back-up and storage providers;
professional advisors, such as lawyers, accountants, auditors and/or consultants; and sports governing bodies.
If you require further information about the above recipients of your Personal Data, please contact us using the contact information provided below.
How long your Personal Data is stored for:
Kambi will retain your Personal Data for as long as it is necessary to fulfil the purposes for which it was collected, particularly the provision of our services to an Operator.
As such, your Personal Data shall be retained for the duration of our contract with an Operator. After such time, we will only hold the information for so long as it is necessary for us to comply with our own legal obligations, or as may be otherwise necessary for our legitimate interests. Where we are advised by an Operator that you have closed your account, or following termination of our agreement with an Operator, we will either anonymise your Personal Data, or we will ensure that it is deleted in accordance with our records retention practices and procedures. If you would like further information about the time period for retention, please contact us using the contact information provided below.
As noted above, Kambi generally uses a pseudonymised ID, rather than your real name or contact details, to identify you. If you cease to be a player for an Operator, or if an Operator ceases to use our services, we may anonymise the personal information that we hold such that you can no longer be identified.
Keeping your data secure:
Kambi is committed to and maintains a high level of security to protect data, including Personal Data. Kambi has taken, and will continue to take reasonable steps to keep our data and Personal Data secure and free from unauthorised access by use of technology and internal systems which will be updated as new technology becomes available and is appropriate to our systems.
This also includes ensuring that any service providers that we use, and who assist us to provide our services are also equally obliged to implement and maintain high standards of security to protect Personal Data. These standards are embedded in our contracts with our service providers.
What are your rights?
Your rights are as follows:
Please note that some of the above rights are qualified, so they will not be applicable in all circumstances.
In particular, we are unable to comply with a request where we are unable to verify your identity. Where this is the case we will balance the rights of the request against the potential detriment that could be suffered where information is handed out to the wrong person, which would amount to a personal data breach. We recommend that, in the first instance, you make your request to the Operator with whom you have an account , as Kambi will need, at the very minimum, your unique Operator ID in order to match it against our Kambi ID as the first step in verifying your identity. Due to the limited information we hold on you, we are not able to identify you or verify you by name without your unique Operator ID. We suggest you review the privacy policy of the Operator with whom you have an account to understand how to make a request to the relevant Operator in the first instance.
Additionally, we are not required to provide you with a copy of your Personal Data undergoing processing (under your right of access) if it will adversely affect the rights and freedoms of others, including our own. We therefore will not provide you with a copy of your Personal Data where doing so would be likely to: (a) result in the disclosure of trade secrets or intellectual property; (b) cause us to be in breach of applicable laws and regulations; or (c) result in the disclosure of information about another data subject that we do not have the right to disclose to you. In particular, we strictly guard our risk management strategies and procedures as trade secrets and we therefore will not provide a copy of your Personal Data to the extent that it would or would be likely to reveal our risk management strategies or procedures. This may include certain procedures with respect to your risk profiling.
Transfers outside of the EEA:
Yes, as a provider of a global sports betting platform, your Personal Data will be transferred outside of the European Economic Area (EEA). We have to do this in order to provide our services to Operators, and you, regardless of the time of day when a bet is placed. In particular, your Personal Data will be transferred to:
Accordingly we will ensure that appropriate safeguards are in place to protect that transfer, such as contractual obligations being imposed on the recipients of your Personal Data. Those obligations require the recipient to protect your Personal Data to the standard required in the EEA. In some cases where you are dealing with one of our Operators based outside of the EEA, we may transfer your data to that Operator as necessary in order to perform our contractual obligations to that Operator and for your benefit. You should consult the privacy notices or information provided by your Operator to review what safeguards they offer for the protection of your Personal Data.
Cookies and similar tracking technology
We may use cookies and similar tracking technology (collectively, “Cookies”) on Our sports betting platform. Please contact your Operator you hold an account with for further information pertaining to Cookies.For information about the Cookies we use on our website, please refer to Privacy Preference Center at www.kambi.com
Contact us
If you have a query about any aspect of this Kambi Player PN or wish to have any part of it clarified, or in the event that you have a complaint about the way in which your details are used or stored by Kambi, please contact our Data Protection Team at – dataprotection@kambi.com. Due to the limited information we hold on you, we are not able to identify you or verify you by name without your unique Operator ID. We suggest you first review the privacy policy held with the Operator you have an account with if you any specific queries about your account.
The following Kambi entities are controllers for the purposes of this Kambi Player PN:
Kambi also acts as joint controller with each Operator if / when they use the Kambi Bonus System which allows Operators to manage bonus programs, reward templates and group-based rewards. We have arrangements in place with our Operators to cooperate with respect to requests in connection with data subject rights in circumstances where we act together as joint controller.
In relation to Kambi’s operations within the European Union, you have the right to complain to the local Data Protection regulator.
Updates to this Kambi Player PN
We may update this Kambi Player PN from time to time in response to changing legal, technical or business developments. You can see when this Kambi Player PN was last updated by checking the “last updated” date displayed at the bottom of this Kambi Player PN.
Last updated: 4 April 2023
