Privacy Policy

PRIVACY AND DATA PROTECTION POLICY

 

Version 2.0 – October 1, 2024

 

Dear user, we are very pleased to have you here at Suprema Bet. You are very important to us, and that is why we handle your data securely, ensuring that you have the best experience on our platform. This Privacy and Personal Data Protection Policy (“Policy”) reaffirms Suprema Bet’s (“We,” “our”) commitment to protecting the personal data of our customers, visitors, and interested parties (“User,” “You”).

For this reason, this Privacy and Data Protection Policy is regularly reviewed to ensure compliance with laws, regulations, and new technologies, reflecting any changes in our operations and business practices. Therefore, it is essential that You regularly access our policy and note the date of its latest update.

By using the website www.suprema.bet.br (“Website”), You acknowledge and agree to the entire content of this Policy.

THE USER ACKNOWLEDGES THAT THEY PROVIDE PERSONAL INFORMATION CONSCIOUSLY AND VOLUNTARILY THROUGH THE SUPREMA BET WEBSITE.

Throughout this Privacy Policy, “SUPREMA BET,” “we,” “our,” and “us” refer to SUPERJOGOS N.V., a company duly incorporated under the laws of Curaçao, registered under number 157878, with its address at New Haven Office, Emancipatie Boulevards, Dominico Martina, 31, Willemstad, Curaçao. We are registered as a “Controller” in Curaçao. A “Controller” is a person or company that determines how and why your personal information is used. Your information is stored by us on servers located in Luxembourg and other locations from time to time.

 

FOR CHILDREN AND ADOLESCENTS UNDER THE AGE OF 18

 

Registration with Suprema Bet is allowed ONLY for individuals who are over 18 years of age, provided they fully agree with this Privacy and Data Protection Policy. Suprema Bet offers services that are intended for adult entertainment and amusement, and therefore applies controls to prevent children and adolescents from accessing its services.

 

Therefore, if You are under 18 years old, DO NOT REGISTER OR USE OUR SERVICES, and if Suprema Bet identifies any inconsistency or fraud in your age declaration, your registration will be immediately deleted, and You will not be able to receive any winnings, in addition to being reported to regulatory authorities regarding the committed fraud.

 

 

  1. ABOUT THE DATA WE COLLECT FROM YOU

Data

CLASSIFICAÇÃO

DADOS COLETADOS

Registration Data
  •  Full name;
  • Date of birth;
  • CPF number;
  • Email address;
  • Phone number.

Identification Data
  • Name;
  • Nickname;
  • Player registration (ID);
  • Profile picture.

Digital Identification Data

IP address and originating logical port, device (operating system version), geolocation, date and time logs of each action You take, which screens You accessed, session ID, and cookies.

If You do not wish to share this information with us, we recommend changing the Cookie settings on your device.

Banking Data

Bank account number;

Branch number;

Bank.

 

FOR THE "KNOW YOUR CUSTOMER" ("KYC") PROCEDURE

Identity Confirmation

In addition to the Registration Data, we collect data such as gender, phone number, date of birth, nationality, parentage, address, identity number, and CPF.

 

We also request a valid, government-issued photo ID, unexpired photo ID in good condition, a selfie, and a copy of your proof of address.

 

Why do we collect data? And when do we collect it?

Your information, including Personal Data, may be collected when You submit it or when You interact with the Website, as outlined below:

  1. Visits to the Website: Your Digital Identification Data is collected;
  2. Contact with Suprema Bet through communication channels: When the User contacts Suprema Bet through any communication channel, Registration Data will be requested to facilitate communication;
  3. Access to Bets: Your Registration Data, Banking Data, and Identification Data are collected to register the User, allowing limited access to Suprema Bet's services;
  4. Account Verification: To make withdrawals and/or deposits exceeding the limits set in our Anti-Money Laundering Policy or whenever it is necessary to verify the user's identity, Identity Confirmation documents will be requested.

 

To place Bets and access Online Games, You must be registered on the website, and to deposit funds into your digital account on the website (“Graphical Account”), You must provide the details of a bank account in your name opened at an authorized financial institution (“Registered Account”).

 

Suprema Bet’s platform collects your Digital Identification Data when You access the website and perform activities on it to comply with regulatory rules.

 

Additionally, You may contact Suprema Bet’s team to report a violation of Suprema Bet's Policies and Terms and Conditions. To do so, access the support icon at the bottom of the page and follow the steps provided by the Virtual Assistant.

 

We also collect information about your gaming activity on the Website, including records of all deposits and withdrawals made from your player account.

 

We may collect personal data through surveys conducted by us or companies contracted by us for this purpose. Additionally, we collect information about your use of our websites and services. We also collect other necessary information to process your personal data for the purposes set forth in this Privacy Policy.

 

  1. LEGAL BASIS FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA

Os Dados de Cadastro e Dados de Identificação são coletados com base no consentimento do Usuário, o qual manifesta interesse em ter acesso aos serviços disponibilizados pela Suprema Bet.

The Registration Data and Identification Data are collected based on the User's consent, who expresses interest in accessing the services provided by Suprema Bet.

As for the Registration Data, its collection is only possible because the User has consented to the sharing of their information to access the Site’s Services. The processing of this data, however, is carried out to fulfill legal obligations, as Suprema Bet has a duty to handle this information, record all account activities, and share them with regulatory bodies that oversee online betting and gaming.

Additionally, Suprema Bet collects the data for the following purposes:

  1. Establish, administer, and manage the user’s account;
  2. Allow You to play on the Platform;
  3. Receive and respond to your communications and requests;
  4. Prevent unauthorized individuals from acting on the User’s behalf, as part of the anti-fraud and associated risk policy;
  5. Send notifications regarding important updates to our website and services;
  6. Comply with obligations under applicable laws (including gaming legislation and regulatory and licensing requirements related to gaming licenses);
  7. Identify and report any suspected illegal, fraudulent, or improper activity connected to our website and services (including money laundering), based on, among other things, the public interest in preventing, detecting, and protecting against unlawful acts;
  8. Monitor gaming patterns and identify any potential responsible gaming concerns;
  9. Identify any fraudulent use of our services;
  10. Identify any violation of our terms of use;
  11. Conduct market research campaigns and assess the responses provided by the user;
  12. Share your personal information with other partners and companies that assist in service delivery, as well as professional advisors, such as lawyers and consultants;
  13. Share your personal data with social media services to provide You with advertisements on social media websites, unless You have opted out of receiving such advertisements or revoked your consent;
  14. Share your personal data with third parties for identity and geolocation verification purposes, including for fraud detection and money laundering purposes;
  15. Share your personal data with national self-exclusion databases if You have self-excluded;
  16. Share your personal data with gaming regulators to assist and comply with any investigation;
  17. Send marketing emails, newsletters, copies of Terms and Policies, Regulations, inform You of changes to internal Policies, and other communications and advertisements between the User and Suprema Bet;
  18. Comply with the obligation to collect and retain connection data.

Finally, Digital Identification Data is collected to analyze the user’s journey, map heat areas, profile the User’s interests, enrich their experience, and enhance products and services. It is also collected to comply with the legal obligation to retain the User’s connection data.

Many of the services directly depend on some of the Data provided above, especially Registration Data and Identification Data. If the User decides not to provide some of this Data, Suprema Bet may be unable to fully or partially provide the services offered.

  1. MARKETING

 

If You have subscribed to services offered by us, we may send You direct marketing regarding other services we offer, provided that You have given your consent to receive such marketing.

 

We may also use the information You provide to show You relevant advertisements and personalized content about our services on certain third-party social media platforms, made available to us through relevant service providers.

 

If You do not wish to see these advertisements, You can change your settings on Social Media Sites. If You do not wish for us to share this information with Social Media Sites, You can contact us directly.

The services mentioned in this section allow Suprema Bet to monitor and analyze web traffic and may be used to track user behavior.

 

  • Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the data collected to track and examine the use of SUPREMA BET, prepare reports on activities, and share them with other Google services.

Google may use the data collected to contextualize and personalize ads within its own advertising network.

  • Personal data collected: Digital Identification Data (and Cookies);
  • Processing location: USA – Privacy Policy – Opt-out.

 

  1. UPDATING AND ACCURACY OF DATA

You are solely responsible for the accuracy, truthfulness, or lack thereof regarding the Data You provide, as well as for keeping it updated. Please be aware that it is your responsibility to ensure the accuracy and to keep your information up to date.


Similarly, We are not obligated to process or handle any of your Data if there are reasons to believe that such processing or handling may result in any violation of applicable laws, or if You are using the Platforms for any illegal or unlawful purposes.

 

  1. SUPREMA BET'S DATABASE

 

The database formed through Data collection is our property and is under our responsibility. Its use, access, and sharing, when necessary, will be conducted within the business limits and purposes described in this Policy.


All Personal Data collected is accessed only by authorized professionals, respecting the principles of proportionality, necessity, and relevance to the objectives of our business, as well as a commitment to confidentiality and privacy protection as set forth in this Policy.

 

  1. TECHNOLOGIES USED

We use the following technologies:

  1. Cookies, and You are responsible for configuring your internet browser if You wish to block them. The Cookie Policy can also be consulted directly on the website. In such cases, some functionalities we offer may be limited.
  2. In addition to cookie-like technologies, such as tags and pixels, there are other technologies, such as GPS, which allow the collection of information, depending on the type of device used and the permissions You have granted to the Platform.

All technologies used will always comply with applicable legislation and the terms of this Policy.
In the case of geolocation, We may employ automated decisions to enhance the user experience during the use of the Application, as outlined in this Policy and in accordance with current legislation.

 

  1. DATA AND INFORMATION SHARING

The Data collected and activities recorded may be shared as follows:

  1. With competent judicial, administrative, or governmental authorities, whenever there is a legal requirement, request, requisition, or court order;
  2. Automatically, in cases of corporate transactions such as mergers, acquisitions, or incorporations involving Suprema Bet;
  3. With partner companies and suppliers, specifically those involved in technological development and service provision directed at You, provided they meet our strict security standards. These transfers involve only companies that demonstrate compliance with applicable laws and maintain a level of compliance similar to or stricter than ours;
  4. Data companies;
  5. Business partners, suppliers, and subcontractors;
  6. Affiliates and selected third parties, when You have expressly opted out of receiving marketing, have been banned or excluded, in which case we may share suppression lists with our affiliates and third parties;
  7. Members of Suprema Bet, service providers;
  8. Analysts and research service providers to improve our services;
  9. Financial operators.

 

 

Data of Brazilian Users: Suprema Bet is one of the sites authorized to access the Brazilian market, under Law No. 14.790/2023 and the Regulations of the Secretariat for Prizes and Betting of the Ministry of Finance of Brazil ("SPA/MF"). By law, Suprema Bet is required to share all player information and game data with the SPA through the Integrated SPA System ("SIGAP"), which will occur between October 1 and December 31, 2024.

In other words, if You access Suprema Bet's services while in Brazil, all of your information will be shared with the SPA through SIGAP. This constitutes data processing and sharing based on Suprema Bet’s legal compliance obligations.

 

Data Anonymization: For the purposes of market intelligence research, data disclosure to the press, advertising, and fostering new projects based on increased User demand, the data You provide will be shared in an anonymized form, meaning it will not allow for your identification.

 

Sharing of Your Data Domestically and Internationally: Suprema Bet is headquartered in Curaçao, and the personal data we collect in Brazil are governed by Brazilian law and the European Union's General Data Protection Regulation (GDPR) 2016/679. The international transfer of personal data of Brazilians is conducted by us in accordance with Article 33 of the Brazilian General Data Protection Law (LGPD).

 

  1. TEMPO DE ARMAZENAMENTO

Your Personal Data collected, as well as the records of your activities, are stored in a secure and controlled environment for a minimum period, as follows:

 

Registration Data, Identification Data, and Identity Confirmation: Stored for 5 years after the end of the relationship (in accordance with Articles 12 and 34 of the Consumer Protection Code (“CDC”) and Law No. 14.790/2023).

 

Suprema Bet may store such data in cases of suspected fraud, money laundering, terrorism financing, and other illegal activities, extending the processing period for the statute of limitations applicable to the investigated crime, without prejudice to reporting the facts to governmental authorities.

 

D igital Identification Data: Stored for 6 months (in accordance with Article 15 of the Brazilian Internet Civil Framework), unless used to support investigations into fraud on the Platform. In such cases, the data may be stored for 5 years after the end of the relationship (in accordance with Articles 12 and 34 of the CDC, Law No. 12.846/13, Decree No. 8.420/15, Law No. 12.683/2012, Law No. 9.613/98, and Law No. 14.790/2023).

Data related to your activities on the site: Stored for 5 years after the end of the relationship (in accordance with Articles 12 and 34 of the CDC, Law No. 12.846/13, Decree No. 8.420/15, Law No. 12.683/2012, Law No. 9.613/98, and Law No. 14.790/2023). Suprema Bet may store such data in cases of suspected fraud, money laundering, terrorism financing, and other illegal activities, extending the processing period for the statute of limitations applicable to the investigated crime.

Additionally, if You self-exclude from any of our services, we will retain that information for the above-mentioned periods. In the case of a legal dispute, we will retain your personal data throughout the dispute and for 6 years thereafter.

It is important to note that, for purposes of audit, security, fraud control, and the preservation of rights, we may retain your registration history for a longer period if required by law or regulatory standards, or for the preservation of rights.

The collected Data may be stored on servers located in Brazil or in cloud computing environments, which may require the transfer and/or processing of this Data outside of Brazil. Rest assured that your data will only be stored with companies that maintain the same level of security as Suprema Bet.

  1. YOUR RIGHTS

You have rights guaranteed by law, and Suprema Bet ensures that You can freely exercise them, as follows:

 

 

Access

 

You have the right to be informed and have access to which personal data is being processed.

 

Correction

 

You have the right to request the correction of data that is incomplete, inaccurate, or outdated*.

 

Anonymization

 

You have the right to request that any excessive personal data being processed be anonymized.

 

Blocking

 

 You have the right to request the suspension of processing of excessive data.

 

Deletion

 

You have the right to request the deletion of your personal data from our databases, except in cases where legal obligations authorize or require continued processing.

 

Data Portability

              

You have the right to request that personal data processed by us be transferred to another service provider as indicated by You..

Revocation of Consent

 

You have the right, at any time, to expressly revoke your consent for the processing of your data**.

 

*Please remember that You may only provide truthful data that corresponds with the reality of the facts, fully and unconditionally exempting Suprema Bet from any liability in case of any alleged falsification.

** It is important to note that if You withdraw your consent for purposes essential to the regular functioning of the Platforms and related services, those services may become unavailable to You.

 

You may request the deletion of your Personal Data, but we may need to retain it for a period longer than your deletion request, in accordance with Article 16 of the General Data Protection Law (LGPD), for the following purposes:

 

  1. compliance with legal or regulatory obligations;
  2. research purposes conducted by a research body;
  3. transfer to a third party (in compliance with the data processing requirements set forth by the same law). In all cases, efforts will be made to anonymize the Personal Data, if possible.

 

Once the retention period and legal requirements are fulfilled, the Personal Data will be securely discarded or anonymized for statistical purposes.

 

 

  1. DATA PORTABILITY AND AFFILIATE PROGRAM – BETTING CLUB

 

Suprema Bet’s Affiliate Program allows You to follow your favorite Affiliate (“Club”) wherever they go! This means that if your Club is no longer part of Suprema Bet, You can request the portability of your data to the site that your Club directs You to.

 

To do this, simply access the Support area at the bottom of the Suprema Bet page and follow the instructions from the Virtual Assistant. Alternatively, You can send an email to encarregado@suprema.group requesting data portability.

 

If You joined Suprema Bet through your Club, this was only possible because You provided CONSENT at the time of your registration. By giving explicit consent for your data to be transferred to Suprema Bet, from that moment, your data has been processed in accordance with this Policy.

 

If You would like to better understand data portability and the sharing of your personal information, please contact us immediately!

 

 

  1. HOW TO SELF-EXCLUDE

 

If You wish to delete your account on the Suprema Bet Site, simply follow these instructions:

 

  1. Access your profile on the Site;
  2. Click on “Personal Data”;
  3. Choose the "Delete Account" option;
  4. Select the reason why You want to deactivate your account;
  5. If You are sure, select the "Deactivate" option. If You do not wish to delete your account, choose the "Cancel" option.

 

After completing these steps, your current Suprema Bet account will be deleted. However, the Platform is legally required to retain your data for a period of 5 years, unless it identifies that You have committed fraud on the Site, in which case the retention period will be extended to protect Suprema Bet's interests, fulfill legal obligations, and investigate any misconduct on the platform.

 

 

  1. PROTECT YOUR DATA

 

It is essential that You help us safeguard your information, so we recommend the following:

    1. Use a strong password;
    2. Install and regularly update antivirus software;
    3. Do not share your password, even with family members;
    4. Do not write your password down on paper or store it in a digital file;
    5. Always log out when You are not betting.

If You notice that your account has been accessed by third parties, contact us immediately so we can assist You in recovering your password.

It is very important that You protect your Data from unauthorized access to your computer, phone, account, password, email, and personal documents. Avoid sharing the devices You use to access the Platforms. Additionally, be aware that we will never send emails requesting the full disclosure of your personal data, attachments that can be executed (e.g., .exe, .com files), or links for potential downloads.

External Links. When You use the Platform, You may be redirected via links to other websites or platforms that may collect your information and have their own Data Processing and Privacy Policies. It is your responsibility to read the Privacy and Data Processing Policies of such websites, platforms, and applications outside of the environments identified here, and it is your responsibility to accept or reject them.

We are not responsible for the Privacy and Data Processing Policies of third parties, nor for the content of any websites, content, or services linked to environments that are not our own.

  1. ABOUT THIS POLICY

 

You acknowledge our right to change the content of this Policy at any time, based on purpose or necessity, as well as to ensure compliance with legal provisions or regulations that hold equivalent legal authority. It is your responsibility to review this Policy whenever You access the Platform or use our services.

If updates to this document require a new collection of consent, You will be notified through the contact channels You have provided.

Inapplicability: If any part of this Policy is deemed inapplicable by a Data Authority or judicial body, the remaining provisions will remain in full force and effect.

Communication: You acknowledge that all communication made via email (to the addresses provided in your registration on the Platform), SMS, instant messaging applications, or any other digital form is valid, effective, and sufficient for the dissemination of any matter related to the services we provide, your Data, the conditions of service, or any other subject addressed herein, with exceptions only where this Policy specifies otherwise.

  1. COMMUNICATION

To optimize and improve our communication, when we send an email to You, we may receive a notification when it is opened, provided that this functionality is available. Please remain vigilant, as emails are sent only from the following domains: suprema.bet.br or suprema360.bet.

If You have any questions regarding the provisions of this Privacy and Data Processing Policy, You may contact us through the following support channels. Please note that we may take up to 3 (three) business days to respond:

Data Protection Officer (DPO)

The Data Protection Officer of Suprema Bet can be contacted at encarregado@suprema.group

Privacy Policy - Suprema Bet