Privacy - Policy
TABLE OF CONTENT
1. Principles
2. Data Protection
3. Information Security
3.1 A safe gaming environment
3.2 Error or vulnerability report
3.3 Cookies
4. Whose data do we process?
5. Which personal data do we collect and process?
6. How do we collect your personal data?
7. How do we use your personal data?
7.1 Business operations and service delivery
7.2 Contractual obligations
7.3 Communications
7.4 Personnel management and recruitment
7.5 Comply with legal and compliance obligations
7.6 Profiling of players
8. Why and with whom do we share personal data?
9. Where do we store and process your personal data?
10. How long do we keep your personal data?
11. Technical and organisational measures
12. Security of your transactions
13. Your rights as a data subject: you can control your personal data
14. How to contact us?
15. Changes to this Data Protection Statement
1. Principles
SAGEVAS S.A. is a public limited company with a capital of 2,161,500.00 EUR registered at the Crossroads Bank for Enterprises under number 0832.457.166, whose registered office is located at Avenue Louise, 209A 1050 Brussels, Belgium, and licensed by the Belgian Gaming Commission (“BGC”) under numbers FA116764 and FA+116764.
SAGEVAS S.A. is the controller of your personal data and is licensed and regulated by the BGC to offer online betting services (hereinafter referred to as “betFIRST”, “we”, “us”, “our”).
betFIRST’s Cookie Policy can be found here. This Data Protection Statement complements the Cookie Policy.
betFIRST respects the protection of personal data, the individual privacy and values the confidence of its customers, players, employees and interns, suppliers, contractors, business partners and the general public.
That is why betFIRST strives to collect, use and disclose personal data in a manner consistent with the laws of the countries in which it does business. In particular, we want to protect the data of the players, our customers, visitors of our website, subcontractors and suppliers, among others, against loss, leaks, errors, unauthorized access or unlawful processing.
We want to inform you about the collection and processing of your personal data by means of this Data Protection Statement.
This Data Protection Statement addresses information we collect via our website, offline via our land-based business operations and for our (direct) marketing activities. It explains what personal data we collect from you and how we use it.
This Data Protection Statement also applies to the betFIRST services offered both online (for example sports betting via the website, website forms and portals) and offline (for example customer support, customer administration). References to betFIRST services in this statement include betFIRST sports betting, online and offline services, apps, software and devices.
We ask that you read this Data Protection Statement carefully, as it contains essential information about how your personal data are processed and for what purpose. You are not obliged to disclose your personal data, but you understand that the provision of certain services, customer support or other assistance becomes impossible if you do not consent to its collection and processing.
Please ensure that you provide us with accurate personal data and inform us of any necessary updates. We make every effort to ensure the accuracy of the data we process. If you notice an error or a change in your data, we invite you to inform us as soon as possible.
2. Data Protection
betFIRST is committed to being compliant to the EU General Data Protection Regulation (“GDPR”) and the local data protection legislation in Belgium, i.e. namely the law of 30 July 2018 on the protection of individuals with regard to the processing of personal data.
3. Information Security
The management of betFIRST recognises the importance of identifying and protecting the information assets of the organisation, avoiding destruction, improper disclosure, improper modification or unauthorised use of any information relating to its customers, employees, pricing, strategy, management, or other related concepts.
betFIRST 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.
3.1 A safe gaming environment
As a highly secure website, betFIRST guarantees the online security of its players. Our software is designed to be downloaded and installed on your computer safely. The optimum security we offer you is provided by the technology we use to protect our programs and to maintain game transparency.
3.2 Error or vulnerability report
Despite the care we take to secure our systems, errors or vulnerabilities may happen. In case you see an error or a vulnerability, please inform us thereof so that we can remediate. You can report a security issue here.
3.3 Cookies
Cookie controls are described in our Cookie Policy.
4. Whose data do we process?
– Players
As part of our services and activities, we collect and process the identity and contact details of our players on the betFIRST website. The purposes of this processing are the (i) execution of agreements with our players (clients) by providing the services and carrying out our business operations, (ii) players management, (iii) accounting, (iv) players assistance and support, (v) business intelligence and trading of activities, and (vi) direct marketing activities in the limit of what is authorised by applicable laws. The legal grounds are the execution of the agreement, the fulfilment of legal and regulatory obligations, and our legitimate interest (see below).
– Customers, suppliers, outsourcing partners, services providers and subcontractors
We collect and process the identity and contact details of our customers, suppliers, outsourcing partners, service providers and subcontractors, as well as of certain of their staff, employees, appointees and other useful contact persons. The purposes of these processing operations are the execution of the agreement with them, the fulfillment of legal and regulatory obligations, the management of the contractual relationship, administration, assessments/audits, fiscality and accountancy. The legal grounds are the execution of the agreement, the fulfilment of legal and regulatory obligations and/or our legitimate interest.
– betFIRST personnel
We process the personal data of our employees and trainees as part of our personnel management and payroll administration. In view of its specific nature, this processing is described more comprehensively in an internal Employee Data Protection Statement.
– Candidates who apply for a job at betFIRST
For our recruitment activities, betFIRST may ask you for certain information. In addition, betFIRST may collect information from third parties, for example in connection with a background or employment check and/or an employment reference.
– Other Persons
In addition to the above listed persons, we also process personal data of other persons, such as possible new customers/prospects, useful contacts within our sector, network contacts, expert contacts, contacts of persons representing the regulator or government agencies, etc… The legal basis of processing may be the execution of a contract, compliance with the law or our legitimate interest (see below).
5. Which personal data do we collect and process?
– Players
. First name, last name, date of birth, gender, country of residence and contact information (such as address, city of residence, telephone number and email address)
. Copy of your identification document (passport or identity card) and all information on such identification document, nationality and national identification number (rijksregisternummer)
. Images (pictures), video and audit registration of your image
. Biometrics data : fingerprints (TouchID) and facial recognition (FaceID)
. Telephone recording
. Geolocation and data of your visit to the website
. Gaming activity
. Gaming behavior and behavior on our website
. Involvement in incidents, complaints and problems, as well as the content thereof
. Bank account number, name bank, name account holder
. Transaction information (bank transfers)
. All other information you share in your interaction with us: for instance preferences and lifestyle information (your family situation, home situation, interests or demographic characteristics)
When you contact betFIRST by telephone, this telephone call may be recorded. We record these telephone calls for educational, quality, legal and security reasons. Only a limited number of employees in the customer service department, as well as the legal and compliance department, may have access to the recordings. Telephone recordings are automatically deleted after a time period between 1 to 5 years depending on the purpose of the processing, except if betFIRST is bound to keep them longer according to legal obligations or in order to defend its interests in court.
betFIRST may also collect other information through your interaction with us and non-betFIRST 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.
– Customers, suppliers, outsourcing partners, services providers and subcontractors
. First name, last name, professional contact information (employer, function title, telephone number and email address)
. For individuals: Bank account number, name bank, name account holder, transactions/bank transfer, billing
. All other information you share in your interaction with us for the execution of the contract between us and for fulfillment of accountancy, legal and fiscal obligations
– betFIRST personnel
All information required and permitted under applicable law to execute the employment agreement and our legal obligations towards employees, payment of salaries/employee benefits and related administration and fiscality.
– Candidates who apply for a job at betFIRST
. First name, last name, professional contact information (employer, function title, telephone number and email address)
. Education and employment
. Job Preferences
. Professional qualifications
. Jobs you wish to apply for
. CV
. Diploma
. Employment references and related information
. Compensation expectations or requests
. If required for the function: result of background checks and screening
. All other information you share in your interaction with us during the application process and interviews for the job
– Other Persons
. First name, last name, professional contact information (employer, function title, telephone number and email address)
. All other information you share in your interaction with us for the execution of the contract between us and for fulfillment of legal, fiscal, regulatory or other obligations
6. How do we collect your personal data?
We collect personal data in variety of ways directly from you when you:
. communicate your personal data verbally or in writing to us;
. visit our website;
. create a player account, log in, and purchase our services, directly or indirectly;
. participate in games, contests, commercial promotions or marketing campaigns;
. participate in market research, surveys or other evaluation actions we launch;
. contact us via a webform;
. contact us via e-mail, chat, social media or telephone.
We may also collect personal data from third parties and partners who can demonstrate that the transfer of data to us is based on a legal basis, such as your consent.
7. How do we use your personal data?
betFIRST uses the collected personal data for the purposes described in more detail below.
7.1 Business operations and service delivery
– Players
We use personal data to provide and improve our services and perform essential business operations. This is based on betFIRST’s obligation to execute a contract it has with you.
Processing which is not strictly required for the execution of a contract is based on betFIRST’s legitimate interest.
We may collect biometric data (Face ID and fingerprint) for the purpose of online identification when accessing our software applications. This processing is based on your consent.
betFIRST has a legitimate interest in using your personal data in order to be able to offer you to best user experience possible, in compliance with the law and our Terms and Condition. betFIRST takes care that the impact on each player’s protection of personal data and privacy is proportional to its own interests:
1. User experience improvement: we improve our services by analysing user behavior and potential problems as user may encounter. Furthermore, we may display different games or matches depending on the players’ preference to offer a personalized experience.
2. Service development and improvement: calls to our customer service department are recorded and used for these purposes. We may evaluate your customer satisfaction and/or identify your wishes as a customer by asking you about your experience. We may evaluate the market and perform market research or trend analysis by involving our customers. You can participate in this voluntarily and such results will be used for service improvement. Where possible, we pseudonymise and aggregate personal data and will up front assess our projects based on principles of privacy by design. The Data Protection Officer advises and supervises these usages of personal data.
3. Detect and prevent internal or external fraud and criminal activities.
4. Aggregate analysis and business intelligence: this enables us to operate, to protect our services, to 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 services (see below)) and report on the performance of our business and the services.
– Customers, suppliers, outsourcing partners, services providers and subcontractors
We use personal data to receive suppliers, services or works from suppliers, outsourcing partners, service providers and subcontractors and to manage those parties when they execute their contract towards us.
7.2 Contractual obligations
– Players
Contract with betFIRST. When you create a player account and accept our <Terms and Conditions, you will enter into a contract with betFIRST. In order to execute the obligations of betFIRST under that contract, betFIRST will use your personal identification data and transactional data in order to:
. provide you with the betFIRST services you subscribed to;
. provide you with customer support: reply to your request, offer technical and other assistance, handle a complaint, etc.;
. inform you and send you messages related to your contract with us and our services (service messages, support, chat,…);
. implement and ensure a responsible gaming policy to protect you as player;
. provide you with other assistance such as answering data subject requests, issues of responsible gaming, etc.
Bets, winnings and withdrawals
The bets, winnings and withdrawals of players are kept in strictest confidence. All bets, winnings and withdrawals are recorded on our secure system. betFIRST keeps records of user wins and losses and will disclose them to a third party only when there is a legal basis to do so, for instance if that third party is part of the BGC, or a member of a judicial or government body or agency.
– Customers, suppliers, outsourcing partners, services providers and subcontractors
We use personal data to execute our contract with suppliers, services or works from suppliers, outsourcing partners, service providers and subcontractors (communications, instructions, complaints, invoicing, payment, etc…).
7.3 Communications
– Players
Based on your consent, we use data we collect to deliver our communications or those of our Belgian group companies with you via email, SMS, push notifications, on-site communication, calls or social media. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from betFIRST or its group companies by email, SMS, push-notifications, social media and telephone calls (including direct marketing and promotional communications (news/modifications/maintenance/promotions and contests etc.)). With regard to direct marketing, betFIRST or its group companies might send you information about its services via marketing messages (information, offers,…) or generalized publicity and information. We hope this will increase your player’s experience.
Communications Preferences
You can choose whether you wish to receive promotional communications from betFIRST or its group companies. If you receive promotional emails from us and would like to opt out, you can do so by clicking on the unsubscribe link or updating your preferences in your account settings.
Opt-out options for email, SMS, phone calls and post/partners are available in the preference center to be found in your user account. You can withdraw your consent to process your personal data for commercial communications quite simply via the preference center in your account, or by getting in touch with our Customer Service or Data Protection Officer. Opt-outs for web pushes can be managed in your browser. Opt-outs for app notifications can be managed on your device. Opt-outs for inbox notifications can be managed in the inbox window after log-in.
When you unsubscribe from commercial communications, we will remove you from the list as quickly as possible and maximum within 3 working days. You may still receive the communications that were already scheduled before your request to unsubscribe.
Consent
We will obtain your prior consent before processing your information for our 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 betFIRST 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 will not be under the obligation to reverse the processing.
– Customers, suppliers, outsourcing partners, services providers and subcontractors
We use personal data to communicate with suppliers, services or works from suppliers, outsourcing partners, service providers and subcontractors regarding the execution of the contract and new requirements for purchasing, tenders or assignments.
7.4 Personnel management and recruitment
We use personal data from our personnel for our personnel management, the execution of the employment contract and compliance with our legal obligations as an employer. For candidates for recruitment, we collect to communicate with you, to manage betFIRST’s recruiting and hiring processes, and for compliance with legal and regulatory requirements. If you are hired, the information may be used in connection with employment and personnel management.
7.5 Comply with legal and compliance obligations
– Players
betFIRST uses your personal data to comply with mandatory requirements imposed by the applicable gaming, gambling and betting legislation and/or the BGC:
. The law of 7 May 1999 on gambling, betting, gaming establishments and player protection
. The Royal Decrees executing the gambling law . The Act of 18 September 2017 on the prevention of money laundering and terrorist financing (the “AML Act”) . All other commercial and corporate legislation applicable to betFIRST and its activities (accountancy, finance, fiscal, administrative, consumer protection, commercial, etc…).
. Any other relevant guidance that the BGC issues in addition to the aforementioned laws and regulations.
betFIRST legal obligations are, amongst others:
. Gaming Law: to collect, verify and to store the personal identification and store transaction data of all of its players. betFIRST is also obliged to transfer these data to the BGC, tax authorities or other government authorities requesting player’s information and this without informing the player of such official request and the related data transfer.
. Anti-Money Laundering Law: prevention and disclosure of money laundering and criminal activities/fraud/ terrorism. betFIRST is obliged to store and verify the personal identification data and the financial transactional data of all of the betFIRST players. Suspicious transactions in terms of money laundering are to be reported to the Financial Intelligence Processing unit unit and this without informing the player of the related data transfer.
. Financial, accountancy, administrative and tax compliance.
– Customers, suppliers, outsourcing partners, services providers and subcontractors
. Financial, accountancy, administrative and tax compliance.
7.6 Profiling of players
In the course of our services and based on the customer’s consent with this Data Protection Statement, we will analyse your information to build individual profiles. Our profiling consists of making profiles of players to provide you better services and support.
We do not take significant decisions based on automated decision-making processes. This means that the way in which we draw up a profile has no legal consequences with a significant impact for you. 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.
8. Why and with whom do we share personal data?
– Players
We share your personal data in case we have a legal obligation to do so, for instance to the BGC, regulatory or government bodies or agencies, or in case of legal proceedings, a court order or other mandatory legal injunction.
We may also share personal data with your consent or as necessary to complete any transaction or provide a service you have requested or authorised.
In addition, we share personal data among betFIRST-controlled affiliates and entities for our service delivery, business operations, direct marketing and communications.
We also share personal data with suppliers, outsourcing partners, service providers, processors or agents working on our behalf for the purposes described in this statement.
For example (this list is not limitative):
. IT services companies;
. Providers of cloud and hosting infrastructure and services;
. Platform providers;
. Marketing companies, advertising agencies or market analysts;
. Providers of services and tools to assure regulatory compliance (such as the requirements under the AML Act);
. Connectivity, telecommunication and internet providers;
. Companies we have hired to provide customer service assistance;
. Companies we have hired to assist in protecting and securing our systems and services.
In such cases, these companies must abide by our data protection and security requirements and are not allowed to use personal data they receive from us for any other purpose, without legal basis.
We may also disclose personal data as part of a due diligence or corporate transaction such as a merger or sale of assets subject to the signature of strict confidentiality agreements with the receiver of the personal data.
Finally, we will access, transfer, disclose, and preserve personal data, including your content, when we are confident that doing so is necessary to:
. comply with applicable law (for instance: Gambling Act, AML Act, financial, accountancy, administrative and tax compliance) 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 to help prevent the loss of life or serious injury of anyone;
. operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
. protect the rights or property of betFIRST, 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 betFIRST, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.
Some of our services include links to services of third parties whose data protection practices differ from betFIRST’s. If you provide personal data to any of those services, your data is governed by their Data Protection Statements. In the event of a conflict between a betFIRST Data Protection Statement and the terms of any agreement(s) between a party and betFIRST, the terms of those agreement(s) will prevail.
– Suppliers, outsourcing partners, services providers and subcontractors
We share only professional information if we have a compelling reason to do so:
. comply with applicable law (for instance: financial, accountancy, administrative and fiscal compliance) or respond to valid legal process, including from law enforcement or other government agency;
. organize and facilitate collaborations between suppliers, outsourcing partners, service providers and subcontractors or between those parties and third parties which are interfacing with or complementary to them; or
protect the rights or property of betFIRST.
9. Where do we store and process your personal data?
Personal data collected by betFIRST may be stored and processed in the European Union or in any other country where betFIRST or its affiliates, subsidiaries, outsourcing partners or service providers maintain facilities. We take steps to ensure that the data we collect under this Data Protection 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 (EU Standard Contractual Clauses), to help ensure your rights and protections travel with your personal data.
10. How long do we keep your personal data?
betFIRST retains personal data in compliance with applicable laws.
Player’s data relating to AML obligations will be deleted after a period of ten years after the last transaction occurred. Other data may be stored for a maximum period of ten years after the contractual relationship, except for the personal data that we have to keep for a longer period based on specific legislation or in case of an ongoing dispute for which the personal data is still necessary.
Customer data and data of suppliers or subcontractors will in any case be deleted from our systems after a period of ten years after the termination of the contract or project, except for the personal data that we have to keep for a longer period based on specific legislation or in case of an ongoing dispute for which the personal data is still necessary.
Personnel data is stored according to the maximum allowed retention periods according to the person’s location. Candidate’s recruiting data is deleted after a maximum period of two years. Candidates can ask for deletion of their data at any time, if they don’t wish to keep up their application by notifying the betFIRST recruiter or contacting the Data Protection Officer of betFIRST.
11. Technical and organisational measures
We take the necessary technical and organisational measures to process your personal data to an adequate level of security and to protect them against destruction, loss, falsification, alteration, unauthorised access or accidental notification to third parties, as well as any other unauthorised processing of these data.
betFIRST 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 unauthorised access, use or disclosure.
betFIRST is also committed to reducing risks of human error, theft, fraud, and misuse of betFIRST facilities. betFIRST’s efforts include making personnel aware of security policies and training employees to implement security policies. betFIRST 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.
betFIRST promptly evaluates and responds to incidents that create suspicions of unauthorised handling of data. If betFIRST determines that your data has been misappropriated (including by a betFIRST employee) or otherwise wrongly acquired by a third party, and if the breach is likely to result in a high risk to your rights and freedoms, betFIRST will promptly report such misappropriation or acquisition to you.
betFIRST will conduct annual compliance audits. Any employee that betFIRST determines is in violation of this Data Protection Statement will be subject to disciplinary action up to and including termination of employment.
Under no circumstances shall however betFIRST be held liable for any direct or indirect damage resulting from the incorrect or unlawful use of personal data by a third party.
12. Security of your transactions
betFIRST guarantees that your financial transactions are secure, no matter which payment method you use! betFIRST 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 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.
13. Your rights as a data subject: you can control your personal data
In accordance with the provisions of the General Data Protection Regulation, we inform you that you have the following rights:
. Right of access and inspection. You have the right to inspect, free of charge, the data that we hold about you and to check what they are used for.
. Right of rectification. You have the right to obtain rectification (correction) of your incorrect personal data, as well as to complete incomplete personal data.
. Right of erasure or limitation. You have the right to request us to erase or limit the processing of your personal data in the circumstances and under the conditions laid down by the General Data Protection Regulation. We shall refuse the deletion or restriction of any personal data which is necessary for us to fulfil a legal obligation, the performance of the contract or our legitimate interest, and this for as long as these data are necessary for the purposes for which they were collected.
. Right to portability. You have the right to obtain the personal data you have provided to us in a structured, common and machine-readable form. You have the right to transfer these data to another data controller.
. Right of objection. You have the right to object to the processing of your personal data for serious and legitimate reasons. Please note, however, that you cannot object to the processing of personal data which is necessary for us to fulfil a legal obligation, the performance of the contract or our legitimate interest, and this for as long as these data are necessary for the purposes for which they were collected.
. Right of withdrawal of consent. If the processing of personal data is based on prior consent, you have the right to revoke this consent. These personal data will then only be processed if we have another legal basis for doing so.
. Automatic decisions and profiling. You may object to profiling and fully automated decisions.
You can exercise the aforementioned rights by contacting the Data Protection Officer of betFIRST: dataprivacy@betssongroup.com. We will act on the request within 30 days. However, in certain circumstances, such as in the case of a complex request or an overload of requests, we will not be able to process such data within this initial 30-day period, but we will inform you of the reasons and propose a period of not more than 90 days.
14. How to contact us?
Customer service
You can contact betFIRST Customer Service at any time if you have any queries or if you need help (see the “Contact Us” panel on the betFIRST 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” panel. 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 consumer mediation service:
Consumer Mediation Service
North Gate II, Boulevard du Roi Albert II 8 Bte 1, 1000 Brussels
Tel: +32 (0) 2 702 52 20
Fax: +32 (0) 2 808 71 29
email: contact@mediationconsommateur.be
https://mediationconsommateur.be/contact/
Data Protection Officer
If you have a privacy concern or a question for the Data Protection Officer of betFIRST, please contact us by using the following email address: @ We will respond to questions or concerns without undue delay.
We make every effort to handle your personal data in a careful and legitimate manner in accordance with the applicable regulations. Nevertheless, if you believe that your rights have been violated and if you do not find an answer to your concerns within our company, you are free to lodge a complaint with the Belgian Data Protection Authority:
You may additionally address a court if you believe that you would suffer damage as a result of the processing of your personal data.
15. Changes to this Data Protection Statement
We will update this Data Protection Statement when necessary to reflect customer feedback and changes in our services. When we post changes to this Data Protection Statement, we will revise the “last updated” date at the top of the Data Protection Statement. If there are material changes to the Data Protection Statement or in how betFIRST 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 Data Protection Statement to learn how betFIRST is protecting your information.
