Privacy Policy
This Privacy Policy applies to your use of smartech-platform.com (the “Website”). It tells you ("you", "visitors", "users") what to expect when we collect personally identifiable information about you, and what your rights are concerning the collection of your information. It is provided in accordance with our obligations under the EU General Regulations for the Protection of Personal Data (GDPR).
In this Privacy Policy, references to “Smartech”, “Company”, “we”, “us” or “our” are related to SNOWBARK B.V., a company incorporated under the laws of Curacao, residing at: 1, Dr. H. Ferguson Weg, Curacao.
The Policy aims to ensure that users are fully aware how the Company collects and processes their Personal data including use of the Website and any of the services and related matters. We do not knowingly collect data relating to minors and are not intended to be made available for them.
The Policy shall be read in conjunction with the Company’s Terms and Conditions. Thus, the maintenance of a contractual relationship with the Company, as regulated by the Terms and Conditions, and all matters between the Company and provision of any relating to services are deemed to fall within the subject matter of processing and data collection under this Policy.
Users shall inform the Company if their Personal data changes during the relationships with us. If a user fails to do so, the Company will be forced to stop providing Services to such a user.
We reserve the right to make changes to the Policy in the future. Any changes shall be duly notified to users.
The present Policy is designed to elaborate on the following aspects:
The Personal Data Collected
Smartech is the controller and accounts for users’ Personal data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, share and disclose different kinds of Personal data about users which (for purely indicative purposes) we have grouped together as follows:
In case if a user either fails to provide the data requested, or provides incomplete or insufficient data, the Company may not be able to use our services, including account opening.
What Personal Data is collected
We collect information about you when you input it into the Services or otherwise provide it directly to us.
Registration:
We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services.
For example, you provide your contact information and, in some cases, billing information when you register for the Services. You also have the option of adding a display name, profile photo, job title, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
Content you provide us through using our products:
The Services include the Smartech products you use, where we collect and store content that you post, send and receive. This content includes any information about you that you may choose to include.
Examples of content we collect and store:
Content you provide through our websites:
The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include sports social media or social networking websites, sports clubs operated by us.
For example, you provide information about you to us when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events provided by our platform.
Information you provide through our technical support channels:
The Services also include our technical support, where you may choose to submit information regarding a problem you are experiencing with the Service.
Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team.
You will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Deposits, bets, transactions and payouts information:
We collect certain payment and billing information when you register for certain paid Services.
For example, we provide a back/front office service.
In this case we process all the data about your customers including
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the services:
We keep track of certain information about you when you visit and interact with any of our Services.
This information includes:
Your devices and connection to Smartech services:
We collect information about your computer, phone, tablet, or other devices you use to access the Smartech services.
This information includes:
How much of this information we collect depends on the type and settings of the device you use to access the Smartech services.
Cookies and other tracking technologies:
Smartech and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices.
More information about how to control or to refuse Cookies control and tracking technologies can be found in our Cookies Policy.
Information we receive from other sources:
We also receive information about you from other users of our services, from third-party services, from our related companies, as well as from our business and trading partners.
Other users:
Other users of our services may provide information about you when they provide you information on our forum.
For example, you answered or mentioned something in a forum thread that was started by another person, not you.
We will also receive your email address from other users of our services and services when they invite you to use our services.
In addition, your administrator can provide their and your contact information when identifying those responsible for finance or technical regulations of use of our platform by your organization.
Third-party services:
We receive information about you when you or your administrator tries to integrate or link third-party services with our betting platform or our services.
For example, you or your administrator can integrate other services that you need into our platform, and you use them with the help of our services.
For example, you can allow third party access to our platform to integrate third-party services that you acquire from third parties.
You can allow access to our platform to the regulatory authorities in your jurisdiction in order to synchronize the list of customers and personal accounts for reporting purposes.
The information that we receive when you integrate third-party services with our platform depends on the policy, access rights and confidentiality settings controlled by that third party.
You should always check the notification and privacy settings of the services of these third parties in order to understand which of your details can be transferred to us or can be used in conjunction with our services.
Smartech and its affiliate companies and partners:
Smartech receives information about you from the companies , which are owned or managed by Smartech, in accordance with their terms and conditions and policies.
We work with a network of partners that provide advice, help with implementation and training, as well as various other services related to our betting platform.
Some of these partners also help us with the promotion of our betting platform in various world markets, finding potential customers for us, and selling or renting out our platform and our services.
We receive the following types of information from such partners:
Usage of Personal Data
Disclosure of Personal Data
To third parties
In processing your transactions, we may share some of your Personal Data with our third-party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Services or as required by law. By using Website or services you consent to the disclosure of your Personal Data as described in this Privacy Policy.
Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. Company’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law.
We ensure that such third parties will be bound by terms no less protective those described in this Privacy Policy, or those we are subject to under applicable data protection laws.
To legal authorities
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:
Personal Data Security
We have developed appropriate security measures to prevent your Personal data from accidental loss, an unauthorised usage or access, alteration or disclosure. We also continuously review and, where possible, improve upon these security measures.
We also give access to your Personal data only to those employees, agents, contractors and third parties that have a professional ''need-to-know''.
How long we keep information
The period that we collect and keep information about you depends on the type of information, as described in further detail below.
After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information:
We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services.
We also retain some of your information as necessary to:
Personal Data Retention
We retain Personal Information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain account and other Personal Information for at least five years after termination of respective agreement.
User’s Rights
Users hold a right to withdraw consent to usage of their Personal Data at any time. You have the following rights:
Contact Information
All additional feedback, comments, technical support requests, and other communications about the Smartech’s website should be sent to compliance@smartech-platform.com.
In this Privacy Policy, references to “Smartech”, “Company”, “we”, “us” or “our” are related to SNOWBARK B.V., a company incorporated under the laws of Curacao, residing at: 1, Dr. H. Ferguson Weg, Curacao.
The Policy aims to ensure that users are fully aware how the Company collects and processes their Personal data including use of the Website and any of the services and related matters. We do not knowingly collect data relating to minors and are not intended to be made available for them.
The Policy shall be read in conjunction with the Company’s Terms and Conditions. Thus, the maintenance of a contractual relationship with the Company, as regulated by the Terms and Conditions, and all matters between the Company and provision of any relating to services are deemed to fall within the subject matter of processing and data collection under this Policy.
Users shall inform the Company if their Personal data changes during the relationships with us. If a user fails to do so, the Company will be forced to stop providing Services to such a user.
We reserve the right to make changes to the Policy in the future. Any changes shall be duly notified to users.
The present Policy is designed to elaborate on the following aspects:
- Kind of personal data that we collect;
- What actions we carry out with personal data;
- With whom we might share personal data;
- Period for how long we keep personal data;
- What rights our users have in terms of personal data.
The Personal Data Collected
Smartech is the controller and accounts for users’ Personal data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, share and disclose different kinds of Personal data about users which (for purely indicative purposes) we have grouped together as follows:
- when you register for an account and provide us with your personal data
- when you use our Services and products
- when other sources provide it to us, as further described below.
In case if a user either fails to provide the data requested, or provides incomplete or insufficient data, the Company may not be able to use our services, including account opening.
What Personal Data is collected
We collect information about you when you input it into the Services or otherwise provide it directly to us.
Registration:
We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services.
For example, you provide your contact information and, in some cases, billing information when you register for the Services. You also have the option of adding a display name, profile photo, job title, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
Content you provide us through using our products:
The Services include the Smartech products you use, where we collect and store content that you post, send and receive. This content includes any information about you that you may choose to include.
Examples of content we collect and store:
- your testimonials, summary of the problem,
- pages you create in support team service,
- pages you share with Smartech analytics,
- your repositories,
- your requests to the support service of the platform, as well as your comments with regards to possible incidents after an upgrade or during the normal operation of the platform, and any feedback,
- files and links you upload to the Services and updates.
- we collect feedback you have provided directly to us via our Services;
- we collect information using hash and filter analysis methods to exclude information that can identify you, your organization, or your customers;
- we collect data how do you interact with Smartech back office.
Content you provide through our websites:
The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include sports social media or social networking websites, sports clubs operated by us.
For example, you provide information about you to us when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events provided by our platform.
Information you provide through our technical support channels:
The Services also include our technical support, where you may choose to submit information regarding a problem you are experiencing with the Service.
Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team.
You will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Deposits, bets, transactions and payouts information:
We collect certain payment and billing information when you register for certain paid Services.
For example, we provide a back/front office service.
In this case we process all the data about your customers including
- name and contact information, upon registration,
- account number in our system and monetary flow on it,
- bet and payment information, payment details of bank cards are collecting via safe services after payment processing only.
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the services:
We keep track of certain information about you when you visit and interact with any of our Services.
This information includes:
- the features you use;
- the links you click on;
- the type, size and filenames of attachments you upload to the Services;
- frequently used search terms;
- and how you interact with others on the Services.
Your devices and connection to Smartech services:
We collect information about your computer, phone, tablet, or other devices you use to access the Smartech services.
This information includes:
- device type;
- connection type;
- settings when you install, access, update, or use our Services.
- about your operating system,
- browser type,
- IP address,
- URLs of exit pages,
- device identifiers,
- crash data.
How much of this information we collect depends on the type and settings of the device you use to access the Smartech services.
Cookies and other tracking technologies:
Smartech and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices.
More information about how to control or to refuse Cookies control and tracking technologies can be found in our Cookies Policy.
Information we receive from other sources:
We also receive information about you from other users of our services, from third-party services, from our related companies, as well as from our business and trading partners.
Other users:
Other users of our services may provide information about you when they provide you information on our forum.
For example, you answered or mentioned something in a forum thread that was started by another person, not you.
We will also receive your email address from other users of our services and services when they invite you to use our services.
In addition, your administrator can provide their and your contact information when identifying those responsible for finance or technical regulations of use of our platform by your organization.
Third-party services:
We receive information about you when you or your administrator tries to integrate or link third-party services with our betting platform or our services.
For example, you or your administrator can integrate other services that you need into our platform, and you use them with the help of our services.
For example, you can allow third party access to our platform to integrate third-party services that you acquire from third parties.
You can allow access to our platform to the regulatory authorities in your jurisdiction in order to synchronize the list of customers and personal accounts for reporting purposes.
The information that we receive when you integrate third-party services with our platform depends on the policy, access rights and confidentiality settings controlled by that third party.
You should always check the notification and privacy settings of the services of these third parties in order to understand which of your details can be transferred to us or can be used in conjunction with our services.
Smartech and its affiliate companies and partners:
Smartech receives information about you from the companies , which are owned or managed by Smartech, in accordance with their terms and conditions and policies.
We work with a network of partners that provide advice, help with implementation and training, as well as various other services related to our betting platform.
Some of these partners also help us with the promotion of our betting platform in various world markets, finding potential customers for us, and selling or renting out our platform and our services.
We receive the following types of information from such partners:
- company name;
- jurisdiction;
- contact details for technical interaction;
- preferences and interests in cooperation with Smartech;
- what companies' services you have used
- payment information for invoices billing.
Usage of Personal Data
- We use Personal Data for the following actions:
- Sharing your data with other users of our services;
- Joint use of data with third parties;
- Compliance with enforcement requests and applicable laws;
- Fulfill our own legal or regulatory requirements;
- Verify your identity in accordance with the applicable legislation and the Company’s Anti Money Laundering policy, as well as address other law enforcement needs;
- Detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
- Analyze Website usage and experience in order to improve our Website;
- Respond to customer service requests and support needs;
- Conduct inquiries;
- Administer a contest, promotion, survey or other features as will be more explained on the Website;
- Carry out any other purpose or reason for which the information was collected.
Disclosure of Personal Data
To third parties
In processing your transactions, we may share some of your Personal Data with our third-party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Services or as required by law. By using Website or services you consent to the disclosure of your Personal Data as described in this Privacy Policy.
Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. Company’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law.
We ensure that such third parties will be bound by terms no less protective those described in this Privacy Policy, or those we are subject to under applicable data protection laws.
To legal authorities
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:
- compelled by court order, or other legal procedure;
- disclosure is necessary to report suspected illegal activity;
- disclosure is necessary to investigate violations of this Privacy Policy or any our agreement with you.
Personal Data Security
We have developed appropriate security measures to prevent your Personal data from accidental loss, an unauthorised usage or access, alteration or disclosure. We also continuously review and, where possible, improve upon these security measures.
We also give access to your Personal data only to those employees, agents, contractors and third parties that have a professional ''need-to-know''.
How long we keep information
The period that we collect and keep information about you depends on the type of information, as described in further detail below.
After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information:
We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services.
We also retain some of your information as necessary to:
- to comply with our legal obligations, to resolve disputes,
- to enforce our agreements, to support business operations,
- and to continue to develop and improve our Services.
Personal Data Retention
We retain Personal Information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain account and other Personal Information for at least five years after termination of respective agreement.
User’s Rights
Users hold a right to withdraw consent to usage of their Personal Data at any time. You have the following rights:
- the right to be informed about the fact that we’re processing your Personal Information and which data exactly we are processing,
- the right to data portability (in certain circumstances);
- the right to object the processing of your Personal Information.
- the right to access your Personal Information, to correct, update, and block inaccurate and/or incorrect data;
- the right to withdraw your consent of Personal Information processing;
- the right to delete your Personal Information from our servers upon your justified request (a right to be forgotten);
Contact Information
All additional feedback, comments, technical support requests, and other communications about the Smartech’s website should be sent to compliance@smartech-platform.com.
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