SB LIVE PRIVACY POLICY

GLOSSERY

Term	Meaning
Anonymised Data	Data sets that cannot be used to identify an individual.
Data Controller	A natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is to be processed.
Data Processor	A natural or legal person which processes Personal Data on behalf of the Data Controller.
Data Protection Laws	Data Protection Act 2018 and the EU General Data Protection Regulation 2018 (GDPR), and any other applicable laws or regulations relating to the protection of Personal Data.
Legitimate Interests	Processing Personal Data for our business interests, activities and needs including providing you with the best service and experience we can offer. We balance our interests against any possible impact on you (both positive and negative), your rights and your freedom. Where our business interest and needs are overridden by your interests, rights or freedom, we will not process your Personal Data (unless you have provided us with your consent or unless required by any applicable laws or regulations).
Personal Data	Information relating to an identifiable person, who can be directly or indirectly identified in particular by reference to an identifier.
Special Category of Personal Data	Personal Data revealing details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, sex life, political opinions, trade union membership, and information about your health, genetic and biometric data.

1. IMPORTANT INFORMATION

We are RedDigital OÜ, company number 14628699, registered offices at Suur-Patarei 13, Tallinn 10415, Estonia.

When we mention "SB Live", "we", "us" or "our", we are referring to RedDigital OÜ and all relevant companies in the Yolo Group responsible for processing your data. You can find out more about the Yolo Group by contacting us using the details set out in Section 11.

SB Live respects your privacy and is committed to protecting your information. This privacy notice will inform you as to how we look after your information when you (a) sign-up to receive our newsletter(s) or information about our products and services; (b) sign-up for any SB Live event or competition; or (c) visit and/or use our platforms (including but not limited to our desktop websites (including https://sblive.io/), desktop applications, mobile websites and native mobile applications (including the "SB Live" application) (collectively, our “Platforms”)). These are collectively referred to as our “Services” in this privacy notice.

This privacy notice applies to your use of our Platforms and Services (regardless of where you visit from or otherwise access our Services) and tell you about your privacy rights and how Data Protection Laws protect you.

SB Live is the Data Controller of your Personal Data.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how SB Live collects, uses, discloses, transfers, stores and processes your information when you use our Services, including any data you may provide through your use of our Services.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other policies and is not intended to override them.

If you have any questions about this privacy notice, please contact us using the details set out in section 11.

CONTACT DETAILS

Our address is Suur-Patarei 13, Tallinn 10415, Estonia.

To contact us, please visit https://sblive.io/, https://yolo.com/ or write to us at sblive@reddigital.io

THIRD-PARTY LINKS

Our Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every website you visit or third-party mobile applications you may use.

2. INFORMATION WE COLLECT ABOUT YOU

When you use our Services, we may collect Personal Data about you.

We have set out below what data we may collect and how we collect it.

You are under no obligation to provide Personal Data to us. However, certain Personal Data is essential for the provision of and the quality of the products and services we offer, and you might not be able to obtain certain services if you do not provide the information required for those services.

Information we do not collect:

We do not collect any information about criminal convictions or offences.

Information we do collect:

Type of Data	Description
Your personal and contact details	Information including your name, home address, email address, telephone number, username and password.
Account information	Information about your account with us if you register with us, including your login details for our Site and Apps, date of birth, unique account number, unique customer identification, marketing preferences, complaints details and any notes added to your account.
Visual images	Such as videos and photographs of you provided in your interactions with us in social events we host and your profile image on social media if you choose to enable this through your social media account.
Financial information	Such information that allows us to understand and verify you and your age to play our free to play games including bank account or payment card details.
Account History	Such as, what games you have participated in, information and communications on forums on the Platforms, including chat rooms and message boards, profile comments, in-game challenges and chat messaging with game operators or other users.
Lifestyle and demographic	Such as information available publicly on your social media profile where you connect with or contact us through your social media account.
Your communications via our Site and Apps	Such as chat conversations via the Site and Apps, your recorded telephone conversations with our customer support staff and emails.
How you use the Site and Apps	Such as which pages you visit, which content you view and what links and buttons you click, URLs visited before and after you use our Service. This information may be collected through cookies or similar technologies. For more information, please see our Cookie Policy
General Location information	The device or computer you use to access the Site or the Apps will provide us with your internet protocol (IP ) address. The IP address tells us which city, state or country you are accessing the Site or Apps from, but does not give us detailed information about your location
Device and other technical information	Such as the unique device identifier and logs of installation and deletion of the Apps, and other information about the device’s hardware and software. Technical information may include browser information, browsing actions and patterns, time zone setting and location, information about operating system, platform and other technologies on the devices you use to access our Services.
Advertising and direct marketing preferences and responses	Your response to marketing campaigns from us or through our third parties i.e. open/click on such emails. Your interaction with offers and competitions, including any requests to stop receiving marketing communications. This information may be collected through cookies or similar technologies such as eTags and web or browser cache. For more information, please see our Cookie Policy
Sensitive Information	We may also process data about you that is sensitive in order to meet our legal and regulatory obligations and to protect our business. This includes data as required by the License Conditions and Codes of Practice, the Gibraltar Gambling Commissioner License Conditions, the Anti-Money Laundering Regulations and the Proceeds of Crime Act and otherwise to fulfil our legal and regulatory obligations as a gambling operator in accordance with responsible gambling policies). This also includes biometric data (such as through photograph and CCTV) and information about suspected fraud, theft or offences. If you come to an event that we host, this also includes information you provide (such as dietary preferences or disability information).

3. HOW IS YOUR INFORMATION COLLECTED?

We use different methods to collect information from and about you and / or your device including through:

Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your device, browsing actions and patterns. We collect this information by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies or those of our advertising partners (see below). Please see our cookie policy for further details. Browser settings that block cookies may have no effect on statistical identification technology.
From you (for example, when you create an account, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site or Apps
Third parties or publicly available sources. Third parties who provide advertising and related services may give us your Personal Data (including Technical Data). These third parties include analytics providers based within and outside the EU (such as Google) and ad networks.
Third parties where you have provided your consent or for co-branded services. Third parties may give us your Identity Data, Contact Data and/or Profile Data where you have provided your consent to that third party to share your information with us (such as for marketing purposes or where the third party is providing recruitment services to us). In addition, where we offer co-branded services such as competitions, promotions or events with or in association with a third party, that third party may share the information you have provided to them with us for the purpose of providing the co-branded services in accordance with your consent preferences.
Information collected from you. You may give us your Identity Data, Contact Data and/or Profile Data by contacting us via our Platforms.

4. HOW DO WE USE YOUR INFORMATION

We use your Data in the following ways, and for the following reasons:

What we use your data for	The basis on which we can use your data
To register you as a new user on the Site or Apps	We need to process this information to meet our contractual obligations.
To allow you to use our services (including managing any payments).	We need to process this information to meet our contractual obligations and to comply with our legal and regulatory obligations.
To target our Services to users that are aged over 18 (or any other age as required by applicable laws and regulations)	We need to process this information to comply with our legal and regulatory obligations.
To make available cookie consent management tools to you and enable our third party providers such as Quantcast and M32 Connect to track what data you wish to be collected by our Platforms.	We need to process this data as it is in our legitimate business interests to provide you with a personalised experience when you use our services. Where necessary, we process this data based on your consent.
To communicate with you about updates to the Site or Apps, our services, and any changes to our terms and conditions or Privacy Policy.	We need to process this data to meet our contractual obligations; to comply with our legal and regulatory obligations; and it is in our legitimate business interests to keep accurate records.
To receive feedback from you on our products and services.	We need to process this data to meet our contractual obligations and it is in our legitimate business interests to understand how we can improve our products and services. You do not have to provide us with this information.
To run our loyalty and VIP programs, and other promotional events such as competitions and offers which may be of interest to you. We may send you marketing material about our offers and events via email or text. You may opt out of direct marketing at any time (see below).	We need to process this data as it is in our legitimate business interests to provide you with a personalised experience when you use our services. Where necessary, we process this data based on your consent.
To provide customer support services.	It is in our legitimate business interests to respond to any communications we receive from you. If you do not wish to provide us with this information, we may not be able to respond fully to your queries.
To train our staff (for example our call staff).	It is in our legitimate business interests to provide you with a helpful service.
To maintain and administer our Site and Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	It is in our legitimate business interests to maintain our IT services, network security, to maintain our system; and we need to process this information to comply with our legal and regulatory obligations.
To improve our Site and Apps, products and services, and experiences, such as by understanding analytics.	It is in our legitimate business interests to better understand your preferences, update our Site and Apps, and develop our business strategy.
To protect our business from money laundering, terrorist financing and other illegal activities. We may identify you electronically using technology such as cookies.	We need to process this information to comply with our legal and regulatory obligations under gambling, anti-money laundering, anti-fraud and anti-terrorism laws. We also process this information in the public interest, and it is in our legitimate business interests to protect our business from any illegal or abusive use of our Site or Apps.
To provide you with advertising, which is relevant to you, and to understand your advertising preferences.	It is in our legitimate business interests to understand how you use our Site or Apps and how we should develop our marketing strategy.
Surveys and polls	If you choose to participate in a survey or poll, any personal information you provide may be used for marketing or market research purposes in accordance with our legitimate interests.
In relation to a legal action, or when acquiring or selling a business.	It is in our legitimate business interest to be able to protect ourselves through legal action and to develop the business through acquiring or selling parts of our business.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Platforms may become inaccessible or not function properly. For more information about the cookies we use and how to manage your preferences, please see our cookie policy

MARKETING

You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. We will obtain this information from you when we first collect your data and we will ask you what kind of communication you would like to receive from us.

You can opt-out from receiving marketing communications from us at any time by following the instructions below:

Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences through the “Account Details” section of the Site or App.
SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences through the “Account Details” section of the Site or App.
Call Marketing: to opt-out from being contacted by telephone for marketing purposes, you can manage your preferences through the “Account Details” section of the Site or App.
Push notifications: to opt-out from receiving push notifications, you can disable push notifications on your device or browser settings.

Please be aware it may take up to 28 days for your request to take effect. Please note you will still receive other important information about our product and services.

For certain marketing communications where we are relying on a soft opt in to offer similar products or services, you can opt-out from receiving these marketing communications at any time or update your preferences as to which marketing communications you receive at any time by contacting us using the details set out in Section 11 or by following these instructions:

email marketing: to opt-out from emails, use the ‘Unsubscribe’ link provided within any email you receive. You can also update your preferences by using the ‘Manage Preferences’ link provided with any email you receive;
app push notifications: to opt-out from receiving push notifications from our Platforms’ native mobile applications, you can disable push notifications in your device settings or via the ‘Notifications’ page in the ‘Settings’ page of our Platforms’ native mobile applications where you can also update your preferences;
web push notifications: to opt-out from receiving push notifications via your browser, you can disable push notifications using your browser settings or via the ‘Settings’ page of our Platforms’ desktop websites and mobile websites where you can also update your preferences;
SMS marketing: to opt-out from receiving SMS marketing, you can use the STOP code provided in any SMS you receive
call marketing: to opt-out from being contacted by telephone for marketing purposes, you can contact us using the details set out in Section 11.

Social Media Marketing. We may also use information you provide to us to show you relevant advertising and personalised content on certain third party social media platforms made available to us through those services (e.g. Facebook, Twitter, Instagram). We do not control the way these social media platforms operate and collect your information and you should read their respective privacy notices online to understand how they use your personal information. If you no longer want to receive personalised and targeted advertisements from the social media platforms, you can manage your advertising preferences and decide what you want or do not want to see using the settings in your relevant social media platform account.

Profiling. We may also carry out certain profiling of you and your activity on our Platforms in order to send you more relevant marketing communications. This may include profiling the way in which you engage with advertisements that may be served on our Platforms or included in our marketing communications of the brands of our Platforms, our group companies and our carefully selected third parties. This profiling will be undertaken based on your use of our Platforms and your selected preferences for marketing communications. You can opt-out of such profiling by contacting us using the details set out at Section 11.

5. DISCLOSURES OF YOUR INFORMATION

Your information will only be disclosed to companies within the Yolo Group and third parties outside this Group in accordance with the terms of this privacy notice.

SB Live may transfer your information to:

another company if it restructures its business.
a third party if the operator of the App changes, or if there is a sale of all or any part of our business or its assets. In the event of any of these transfers occurring, the party who acquires the data will assume the rights and obligations described in this privacy notice.
business partners and other organisations to help us meet our contractual and regulatory obligations, including audit, legal and compliance services.
affiliates and third parties which you have opted out of marketing communications with, have been barred or have self-excluded, so that we can ensure that you do not receive unsolicited promotional material.
identity verification and fraud prevention agencies such as other gambling operators, banks, credit card companies and similar agencies which investigate and prevent underage, fraudulent, criminal or suspicious activity, or any other behaviour we are legally required to investigate. We will also pass on your information if we have reason to believe you have undertaken such activity.

We partner with Firebase and Google Analytics to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Firebase and Google Analytics collect and use your data, visit the Privacy Statement here: https://policies.google.com/privacy.

SB Live may engage the services of third party service providers and suppliers for certain activities including, but not limited to, processing your information and providing technical support to our Services. For example, we engage service providers to host our Platforms, store data, send marketing communications, carry out data cleansing to suppress our marketing lists, carry out marketing data segmentation, and perform data analytics to measure and understand our audience, tailor our marketing and trading services, and improve your experience of our Platforms. SB Live will take steps to ensure that arrangements with third party service providers protect your privacy by ensuring that these third parties comply strictly with instructions when they are processing your information. SB Live may share your Personal Data with third parties who process your Personal Data on our behalf when they provide services to us, for example data analytics, ad networks, financial services and for the purposes of recruitment. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected.

If we offer co-branded services such as promotions, competitions or events, together with or in association with a third party, SB Live may share the information you provide with that third party. These co-branded services may be hosted by us or by a third party. The third party’s use of your information will be governed by that third party’s privacy notice, which you should always read. This may also provide information about how that third party’s service providers may process your Personal Data. We require all third parties to respect the security of your information and to treat it in accordance with the law. We do not allow our third party service providers to use your information for their own purposes and only permit them to process your information for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS

Third parties with whom we share your Personal Data may be based outside the combined area of the United Kingdom ("UK") and the European Union ("EU") and, as such, the processing of your Personal Data may involve a transfer of your Personal Data outside the combined area of the United Kingdom and the EU.

If your Personal Data is transferred outside the combined area of the United Kingdom and the EU, we take steps to make sure it has the same level of protection as it would have in the EU.

7. OUR ADVERTISING PARTNERS

Some of the advertisements you receive while using the Services are chosen and displayed to your device based on predictions about your interests generated from your visits to different websites in the browser you use and on other devices you may use. This type of ad customisation is sometimes called "online behavioural" or "interest-based" advertising. Such interest-based advertising helps support the free content, products and services you receive via our Services.

The advertising partners we currently work (or will shortly be working) with (together, the “Ad Partners”) are listed here:

SB Live’s Privacy Notice Ad Partners

●   …
●   …
●   …

Although we aim to keep the list of Ad Partners in this privacy notice updated, the Ad Partners we work with may change from time to time. Please contact us using the details set out at section 11 below if you would like to receive a complete and up-to-date list of our Ad Partners.

In order to deliver interest-based advertising that is more likely to be relevant to you, we deploy cookies, web beacons and similar technologies built by such Ad Partners that collect usage data, namely the IP address of your device and the websites visited using that device. Ad Partners then receive such usage data and use it to deliver the advertising of the Ad Partner's advertisers. The Ad Partners do not receive any directly personally identifiable information such as your name, address or contact details. Please refer to the Ad Partner's respective privacy policies (via the above links) for more information on how their services work.

If you would like to understand more about interest-based advertising and/or managing your cookies/opt-out options in relation to interest-based advertising, please see our policy further information on how to manage cookies via your website browser/mobile device can also be accessed via the following links:

http://www.networkadvertising.org/choices

http://www.aboutads.info

http://www.youronlinechoices.eu

http://www.youradchoices.com

If you are using the mobile app, you can manage certain preferences via your device's privacy setting (e.g., Apple iOS Limit Ad Tracking).

8. DATA SECURITY

We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

We will only retain your information for as long as necessary to fulfil the purposes we collected it for (e.g. such as providing you access to our Services), including for the purpose of satisfying any legal, accounting, or reporting requirements.

Where it is no longer necessary to process your Personal Data, we will delete it or anonymise it by removing all details that identify you in accordance with Data Protection Laws. For example, if you withdraw your consent to process your Personal Data, we will delete your Personal Data unless this is required to be retained to enable us to comply with Data Protection Laws.

The length of time for which we retain your Personal Data will depend on what we are using it for as set out in this privacy notice. For example, whilst you are using our products and services, we may need to use it to answer your queries about our products and services. We will also keep your email address whilst you have subscribed to receiving marketing communications but, even when you unsubscribe, we are required to continue to retain it to ensure that we do not send you any marketing communications in future.

If you want to know how long we retain information collected via the use of cookies, read our cookie policy.

Please note, however, that we may be subject to legal and regulatory requirements to keep Personal Data for a longer period, in particular pursuant to any applicable statutory limitation period.

10. YOUR RIGHTS

Under certain circumstances, you have rights under Data Protection Laws in relation to your Personal Data, including the right to:

Our Ad Partners do collect and use the usage data described in Section 7 above. If you wish to exercise any of the rights set out above in respect of such data, please contact the Ad Partners using the details in their privacy notice.

11. QUESTIONS

If you have any questions about this privacy notice or wish to otherwise exercise your rights (such as to withdraw your consent from receiving marketing communications), please contact us via https://sblive.io/, https://yolo.com/ or sblive@reddigital.io

12. CHANGES TO THIS PRIVACY NOTICE

We may, from time to time, change or update this privacy notice. All changes to this privacy notice will be published on this page of our App. Each change will become effective upon publication. We recommend that you revisit and read this privacy notice regularly to ensure that you are up-to-date with the current terms.

Naoki Nakagawa Vs Kousuke Ogura

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