Zambia Sports Interactive Ltd, trading as Sportybet Zambia (“Sportybet Zambia”, “We”, “Us”, “Our”), is committed to protecting the privacy and security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website (the “Website”), use our mobile application (the “App”), and utilize any of our services (collectively, the “Services”).
By accessing or using our Services, you signify your understanding of and agreement to the terms of this Privacy Policy. If you do not agree with any aspect of this Privacy Policy, you should not use our Services.
1. Data Controller
For the purpose of applicable data protection legislation, the data controller of your personal data is: Zambia Sports Interactive Ltd 123 Independence Avenue, Business District, Lusaka, Zambia, 10101 Registration Number: ZB12345678 Email for privacy inquiries: [email protected]
2. Information We Collect
We may collect and process the following types of personal information about you:
2.1. Personal Identification Information: * Full name, date of birth, gender, residential address, email address, phone number. * Copies of identification documents (e.g., National ID, passport, driver’s license) for Know Your Customer (KYC) and age verification purposes.
2.2. Financial Information: * Details related to your payment methods, such as mobile money account details, bank account information, or payment card details (typically processed securely by our third-party payment providers; we may store partial information like the last four digits of a card). * Transaction history, including details of deposits, withdrawals, and bets placed.
2.3. Technical Information: * Internet Protocol (IP) address, login data (username, password – in hashed form), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
2.4. Usage Data: * Information about how you use our Website, App, products, and Services, including betting patterns, games played, pages visited, and interaction with customer support.
2.5. Communications Data: * Records of your communications with us, including emails, live chat transcripts, phone call recordings (where applicable and with notice), and survey responses.
2.6. Marketing and Communications Preferences: * Your preferences in receiving marketing communications from us and our third parties.
3. How We Collect Your Information
We collect information about you through various methods, including:
3.1. Directly from You: When you register for an Account, complete your profile, provide KYC documents, make deposits or withdrawals, place bets, participate in promotions, or contact our customer support. 3.2. Automatically: As you interact with our Website or App, we may automatically collect Technical Data and Usage Data through cookies, server logs, and similar tracking technologies. 3.3. From Third Parties: We may receive information about you from third-party service providers, such as: * Payment service providers for transaction processing. * Identity verification services for KYC and fraud prevention. * Analytics providers and publicly available sources.
4. How We Use Your Information (Purposes of Processing)
We use your personal information for the following purposes:
4.1. To Provide and Manage Our Services: * To set up and manage your Account. * To process your bets, deposits, and withdrawals. * To provide customer support and respond to your inquiries. * To deliver game content and ensure the functionality of our Platform.
4.2. For Legal and Regulatory Compliance: * To verify your identity and age (KYC procedures). * To comply with our legal and regulatory obligations, including anti-money laundering (AML) and counter-terrorist financing (CTF) requirements. * To detect and prevent fraud, cheating, and other illegal activities. * To adhere to responsible gaming policies.
4.3. To Improve Our Services: * To analyze usage patterns and trends to improve our Website, App, game offerings, and user experience. * For internal research, development, and quality assurance.
4.4. For Marketing and Promotional Purposes: * To send you information about new products, services, promotions, and special offers that may be of interest to you (where you have consented or where permitted by law). You can opt-out of marketing communications at any time.
4.5. To Ensure Security: * To protect the security and integrity of our Platform, systems, and data.
5. Legal Basis for Processing Your Information
We process your personal information based on the following legal grounds:
5.1. Performance of a Contract: Processing is necessary for the performance of the contract (our Terms and Conditions) to which you are a party, or to take steps at your request before entering into such a contract (e.g., creating and managing your account, processing bets). 5.2. Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject (e.g., KYC, AML, responsible gaming regulations). 5.3. Legitimate Interests: Processing is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests (e.g., fraud prevention, service improvement, network security). 5.4. Consent: Where required by law, or for certain types of processing (such as some marketing communications), we will obtain your explicit consent. You have the right to withdraw your consent at any time.
6. Data Sharing and Disclosure
We may share your personal information with the following categories of third parties:
6.1. Service Providers: Companies that provide services to support our operations, such as payment processors, identity verification services, IT infrastructure providers, software providers, marketing agencies, and customer support services. These providers are contractually bound to protect your data. 6.2. Regulatory and Law Enforcement Bodies: If required by law, or to comply with a legal process, we may disclose your information to government authorities, regulatory bodies, or law enforcement agencies. 6.3. Professional Advisors: Our lawyers, auditors, and other professional advisors, where necessary. 6.4. Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
We do not sell your personal information to third parties for their own independent marketing purposes without your explicit consent.
7. International Data Transfers
Your personal information may be transferred to, and processed in, countries outside of the Republic of Zambia where our service providers or group companies may be located. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable data protection laws, including implementing appropriate safeguards for such transfers.
8. Data Security
We have implemented appropriate technical and organizational security measures to protect your personal information from accidental loss, unauthorized access, use, alteration, or disclosure. These measures include encryption, access controls, secure networks, and staff training. However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
9. Data Retention
We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, this means retaining data for the duration of your relationship with us and for a certain period thereafter as mandated by law (e.g., AML regulations may require data to be kept for 5-10 years after the business relationship ends).
10. Your Data Protection Rights
Under applicable data protection laws in Zambia, you may have certain rights regarding your personal information. These may include:
10.1. Right of Access: The right to request a copy of the personal information we hold about you. 10.2. Right to Rectification: The right to request correction of inaccurate or incomplete personal information. 10.3. Right to Erasure (Right to be Forgotten): The right to request the deletion of your personal information under certain circumstances. 10.4. Right to Restrict Processing: The right to request the restriction of processing of your personal information under certain conditions. 10.5. Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format and to have it transmitted to another controller, where technically feasible. 10.6. Right to Object: The right to object to the processing of your personal information under certain circumstances, particularly for direct marketing purposes. 10.7. Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us at [email protected]. We may need to request specific information from you to help us confirm your identity.
11. Cookies and Tracking Technologies
Our Website and App use cookies and similar tracking technologies (e.g., web beacons, pixels) to enhance your user experience, analyze traffic, and for advertising purposes. Cookies are small text files stored on your device. We use essential cookies (for basic site functionality), performance cookies (for analytics), functional cookies (to remember your preferences), and targeting/advertising cookies. You can manage your cookie preferences through your browser settings or any cookie consent tool provided on our Platform. For more detailed information, please see our Cookie Policy.
12. Third-Party Links
Our Website or App may contain links to other websites operated by third parties. This Privacy Policy does not apply to those external sites. We encourage you to review the privacy policies of any third-party sites you visit.
13. Children’s Privacy
Our Services are not intended for or directed at individuals under the age of 18 (or the legal age for gambling in their jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete such information as soon as possible.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. We encourage you to review this Privacy Policy periodically.