betpawa Mozambique - Privacy Policy
Here at Hotspot Mozambique Lda, the licenceholder of the betPawa brand in Mozambique (“Company”, “we”, “us”, “our”), your privacy is important to us. When handling and using your personal information, we are subject to the applicable data protection legislation and regulations (“Data Protection Laws”).
Pursuant to our betPawa licence agreement, the company Pawatech IP Limited (“Pawatech IP”), with address in Remera, Gasabo, Umujyi wa Kigali, Rwanda, is the Data Controller and this policy sets out how we use and process your personal information when you use the betPawa Website (defined below).
The competent Data Protection Authority is the National Institute of Information and Communications Technology (the “Data Protection Authority”).
This Privacy Policy forms part of the Terms and Conditions (“Terms”) available on the Website.
We are deeply committed to safeguarding the privacy expectations of our users (“Client(s)”, “you” or “your”) in compliance with the Data Protection Laws.
Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your personal information, as well as your rights with respect to your personal information/data.
By using your personal information, we aim to improve your experience with our Website, apps and services. Ensuring the safety of your data is paramount to us; we employ stringent security measures for protection. Our approach is to be clear about our data collection and usage practices. We also acknowledge and respect your choices and rights related to your personal information.
This policy should be read and applied together with our Cookies Policy as well as our Terms available at the Website. We reserve the right to modify this Privacy Policy periodically and will inform you of such changes by posting the updated terms on our platforms and/or notify you. We recommend that you routinely check this Privacy Policy for updates.
We offer games of chance, including but not limited to sports betting and online casino (as per definition of “Services” in the Terms).
We provide our Services through different channels (collectively defined as “Website” in the Terms) such as:
This internet website, including any subdomains and any affiliated websites;
Downloadable applications and software, such as native applications which are distributed through mobile application stores, as well as PC and Mac desktop software which can be downloaded to your computer;
Non-downloadable online applications (e.g. flash applications, HTML5 applications, etc.).
This policy applies to all Clients of our Services, including players, visitors to our website, and individuals who interact with our games or related services.
We encourage you to carefully read the Privacy Policy before using the services provided and make informed decisions.
By visiting our Website, or by creating an account through our Services, you acknowledge to have read and understood this Privacy Policy.
The Company follows the rules of the Data Protection Laws. This means that whenever we handle your personal data, we always follow the principles arising from the Data Protection Laws:
1. Lawfulness, fairness and transparency: All personal data is processed lawfully, fairly and in a transparent manner
2. Purpose limitation: All personal data is collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes
3. Data minimisation: Collection of personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
4. Accuracy: We ensure personal data is accurate and kept up to date, with steps taken to rectify inaccuracies without delay
5. Storage limitation: We ensure personal data is not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the personal data is processed. We ensure data retention is limited to the appropriate retention periods and for the specified processing purposes
6. Integrity and confidentiality: We ensure personal data is processed in a manner that ensures its security, using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage
7. Accountability: We ensure compliance with applicable data protection laws by implementing suitable technical and organisational measures to protect personal data, maintaining records of processing activities, and cooperating with supervisory authorities to demonstrate adherence to data protection principles
We process your personal data in order to provide you with our Services. Taking into consideration data minimization, we will only collect necessary data and we only ever use it for lawful and specified purposes. We do not sell your information to anyone else.
We require your personal data:
to provide you with Services
comply with legal or regulatory requirements
safeguard the interests of you, us, the general public, or other third parties,
and occasionally for additional purposes when we have obtained your clear consent.
We utilise your personal information for activities such as:
analysing our Website usage
registering and verifying your account
managing payments and service delivery
engaging in customer operations
marketing initiatives
fraud prevention
promoting safer gambling practices
risk management
detecting anti-money laundering and counter-trafficking financing and
personalising your experience on our site or within our app.
4.1 Personal Information
The first type of information is data that identifies or may reasonably identify an individual with reasonable effort (“Personal Information”). Personal Information may be gathered and may consist of the following:
Registration details: When you open an account and register to use the Website and Services, you may be asked to provide us with certain details about yourself, such as: first and last name, email address, gender, birth data, physical address, ID number, phone number, occupation, etc. In addition, we may collect certain information and documents as required under various Know Your Client ("KYC") and Anti-Money Laundering ("AML") regulatory requirements, such as your source of funds and source of wealth. Some of the information we process about you is necessary for us to meet the legal and regulatory obligations that we have as a gambling company. This includes licensing requirements, responsible gaming obligations and AML regulations.
Government-issued ID: In accordance with KYC and AML requirements, you may be requested to provide a copy of a government-issued ID for identity verification purposes in situations where you meet certain conditions based on your usage of Services or Website.
Gaming information: In order for us to provide the Services, we automatically record different information related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings, as well as participation in promotions, draws or contests.
We also collect information which may show potential gambling problems or addictions, based on your patterns of gambling across our Service, in order to ensure a responsible gaming environment and as required by law.
Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases etc.), payment information will be collected from you, such as your currency, or Payment Services Provider (“PSP”) related details.
Voluntary information: We also collect information that you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games. This includes information you are willing to share with us for the purpose of improving and developing our relationship with you, as well as for maintaining your satisfaction from our Services.
Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI and MAC address), browser fingerprinting, IP address and geo-location data, if applicable.
Telephone calls: We may record or monitor telephone calls for the following purposes:
Dispute resolution, exercise and establishment of legal claims;
Customer service (such as ensuring quality monitoring and assurance, operational efficiency, ensuring that quality standards are met in terms of support performance and Users' satisfaction, etc.);
Compliance monitoring;
Training purposes;
Detecting and preventing crime or fraudulent activities.
In any case, you will be notified at the beginning of the call that the conversation is being recorded
Events: During our events, we engage in activities that involve interviewing attendees, speakers, sponsors, and exhibitors, as well as capturing their photos and videos. We will obtain your consent before taking any photographs or videos where you are featured and prior to using such images or footage for promotional activities. Consent will also be sought before utilising any of your interview content for promotional purposes. While using the Services, you may invite a friend via your social network to join the Services. Should they accept your invitation, we may collect their Personal Information, such as name, email address, phone number, and date of birth, which will, with their specific consent, be processed according to this document and shared with third parties solely as specified in this Privacy Policy. For transparency reasons, notices will be included in adverts promoting any events to ensure that attendees are aware of the potential use of their images for promotional purposes.
Information we collect from third parties: We also collect Personal Information from third-party service providers, such as MoMo operators and other sources of financial information relevant to our Services, as well as information used to verify your identity and prevent fraudulent or illegal activities.
Technical, device and connection information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
If you download the Website to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Website for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.
4.2 Non-personal information
The second type of information is un-identified and non-identifiable information pertaining to a Client(s), which may be made available or gathered via the Client’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the Client’s operating system, type of browser, screen resolution, browser and keyboard language, the Client’s ‘click-stream’ and activities on the Services, the period of time the Client visited the Services and related timestamps, etc.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
We may process your Personal Information where any of the following legal basis apply, including:
Fulfilment of a contract, compliance with a legal obligation: It is necessary for us to process your Personal Information where it is necessary for the performance of a contract or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licences and complying with any AML and KYC legislation.
Legitimate interests: We also process your Personal Information where we deem such processing to be in our legitimate interests (or the legitimate interest of a third party to whom the data is supplied) and provided always that such processing will not prejudice your interests, rights, and freedoms. Examples of us processing in accordance with legitimate interests includes:
where we disclose your Personal Information to anyone or more of our associate/subsidiary companies following a restructure or for internal administrative purposes, and such persons will also be bound by the confidentiality requirements required by the Data Protection Laws;
detection and retention of information pertaining to those with responsible gambling issues;
processing for the purposes of ensuring network and information security, including preventing unauthorised access to our electronic communications network;
safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities;
adhering to regulatory and statutory requirements;
devising a tailored reward scheme for players; and
sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
Consent: Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. On certain occasions, we may ask for your consent to processing Personal Information. In these instances, your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
Requirement by law: We may process your Personal Information without obtaining your explicit consent in instances where we are legally mandated to do so. This includes situations where relevant laws or regulations compel us to collect and process personal data in order to fulfil our legal obligations or to comply with governmental directives. Such situations may arise, for example, in tax reporting, criminal investigations, civil court proceedings, national security measures. We are however committed to ensuring that any processing conducted under these circumstances is done in accordance with applicable laws and regulations, and with due consideration for protecting your privacy and rights.
Vital Interest: We may process your Personal Information if it is necessary in order to protect your vital interests or the vital interests of another natural person, such as to prevent harm or threats that pose a risk of injury or other damage to the health of an individual.
Public Task: On certain occasions, we may process or disclose your Personal Information if it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority; for example, if we are requested by an officer of a public body competent for investigating crime to cooperate in an on-going investigation, or where we decide to proactively disclose data to a third party having such an official authority (such as competent law enforcement).
In all other circumstances, your Personal Information will be processed with your consent and you will be able to withdraw this consent in writing at any time.
The Services are intended solely for individuals who are 18 years of age or older, or the age of legal consent for using the Services, if higher ("Legally of Age"). If you do not meet this age requirement, you must refrain from using the Services and from submitting any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a Client who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us at data.protection@betpawa.com.
We use your Personal Information for the purposes listed below:
to set up, manage and update your account;
to provide and operate the Services (such as for betting, gaming and payment processing);
to communicate with you and to keep you informed of our latest updates to our Services and special offers;
to market our Services (see more below under “Marketing”), as well as to serve you advertisements, personalised content including behavioural advertising;
to conduct analytics, statistical and research purposes, in order to improve and customise the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services).
for customer relationship management purposes, and to support and troubleshoot the Services and to respond to your queries, including your requests to exercise your rights;
to enable us to further develop, customise and improve the Services based on users’ common preferences and uses;
to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardise or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
to assist us with meeting our regulatory obligations or as required by law or regulation (such as gambling regulations, KYC and AML regulatory requirements);
to comply with our legal and regulatory obligations
for internal business purposes:
for reset your password via Messaging Platforms: By requesting a password reset, you acknowledge and consent to receiving One-Time Passwords (OTPs) via your selected communication method, which may include voice call, WhatsApp, or Telegram, as applicable:
Live Chat Support: Any personal data, information, or content shared by you during the live chat will be collected and processed in accordance with this Privacy Policy. By using the live chat feature, you understand that the collection and processing of your data in line with the terms outlined in this Privacy Policy and the information shared during the chat will be used only for the purpose of providing customer support, resolving issues, or addressing inquiries as needed.
for other purposes as stated in this Privacy Policy.
The Company may use your Personal Information, with your prior consent, such as your name, home address, email address, telephone number etc., ourselves or by using our third party sub-processors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
We will use your Personal Information for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your consent to do so.
You are entitled to ask the Data Controller to cease processing your personal information if it is being used for direct marketing purposes, which encompasses profiling insofar as it pertains to that marketing. You may at any time decline receiving further marketing offers from us or from our Marketing Affiliates by contacting us at the provided email address or by unsubscribing from receiving marketing materials by following the guidelines available on the marketing communications (such as clicking on an “Unsubscribe” button).
Please note that unsubscribing from our marketing mailing list does not preclude the possibility of receiving non-marketing service-related updates and notifications from us.
If you download any of our mobile applications to your device from the Apple AppStore™ or Google Play™, the only way to prevent receipt of notifications is by changing the setting on the device itself.
We use third-party advertising technology to serve advertisements when you use the Services. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA").
For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp and www.aboutads.info/choices.
We do not rent or sell your Personal Information to third parties. We may share your Personal Information with third parties (“Recipients”) as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.
We share Personal Information with any of the following recipients:
Gaming providers;
Subcontractors and third-party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
Credit reference bureaus, financial services providers and KYC service companies, for conducting name, address and age checks. This includes:
Identity and contact data;
Shared payment details; and
Fraud prevention information.
PSPs, payment processors and banks;
Any third party who provides you with tangible prize or who organise offline events or tournaments on behalf of or in conjunction with Company;
Auditors, contractors or legal/financial/other advisers of any of Company’s business processes;
Gambling addictions bodies; and
Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations.
In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:
Storing such information on our behalf, for example by using cloud computing service providers;
Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
Performing research, technical diagnostics or analytics;
Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, in the section titled "Marketing"); and
Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies, protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.
The personal data we collect from you may be transferred to, and stored in third countries or with international organisations. It may also be processed by companies operating in third countries who work for us or for one of our service providers. For instance, the computer servers used to host a website could be located in a third country – this is not unusual given that the internet is a global environment.
We will only store your personal information in locations that guarantee a level of data protection at least equal to that afforded by the Data Protection Laws. We commit to taking all reasonable measures to uphold an appropriate degree of protection consistent with our Privacy Policy when transferring your data in this manner.
Any local or cross-border transfer of personal data to our service providers will be done in compliance with the relevant provisions of the Data Protection Laws.
For more information about the transfer of your Personal Data outside to third countries, please contact us directly at data.protection@betpawa.com.
When you visit or access our Services, we use (and authorise third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behaviour, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customise your experience on our Services. We also use this information to collect statistics about the usage of our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
We also allow third parties to collect information about you through Tracking Technologies. To learn more, see our Cookies Policy.
While using the Services you may encounter links to third party websites, services or applications (such as third-party messaging apps). Please keep in mind that this Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.
Please be advised that such third-party websites, services or applications are independent from us. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third-party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third-party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.
You should always review their privacy practices carefully before providing personal information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.
If you have registered with an account through our Services, we will retain your Personal Information during the period your account is active. In addition, we will retain your Personal Data for an additional period of 7 years, as strictly necessary to enable us to meet our legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations, as well as to meet our contractual obligations.
By agreeing to our Terms, you consent to the retention period set out in this Privacy Policy.
Upon expiry of the retention period, we will destroy or delete your personal data, or de-identify it, in a manner that prevents its reconstruction in an intelligible form.
You have the following rights which you can exercise by contacting us at any time by email to data.protection@betpawa.com:
To access or delete any Personal Information relating to you;
To correct or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
To restrict or cease any further use of your Personal Information;
We provide the Personal Information you volunteered to us in a machine-readable format.
To withdraw your consent to the processing of your Personal Information (such as for marketing purposes);
To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
To file a complaint with the Data Protection Authority.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
We commit to retaining your personal data only for as long as necessary to achieve the purposes for which it was collected and processed, unless otherwise required or authorised by law, contract, or consent.
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorised access, to maintain data security, and to correctly use the information we collect. These safeguards vary based on the sensitivity of the information that we collect and store.
We use industry standard procedures and controls to ensure the safety of users’ information, such as:
Secure network topology, which includes intrusion prevention and firewall systems;
Encrypted communication and storage of Personal Information;
Authentication and Access Control;
External and Internal audit tests;
Identify reasonably foreseeable internal and external risks to Personal Information
Establishment and maintenance of appropriate safeguards against identified risks
Regular verification of effective implementation of safeguards
Regular updating of safeguards in response to new risks or deficiencies.
Any data breach will be handled in compliance with the data breach notification process, as mandated by the Data Protection Laws.
We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently.
We will provide notice of substantial changes of this Privacy Policy by posting the updated terms on our Website.
The notification of substantial changes of this Privacy Policy might require an action of reading and acceptance from your end before continuing using the services in the next log in.
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at data.protection@betpawa.com.
If you are not satisfied with our response to your query, you can contact your local data protection authority who will be able to advise you on next steps.
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