1. Introduction
Welcome to HugoBets. We are committed to safeguarding your privacy and ensuring the security of your personal data. This Data Privacy and Cookie Policy (the "Policy") outlines how we collect, use, disclose, retain, and protect your information. It also explains your rights regarding your personal data and how you can exercise these rights, including how to access most of your data directly and instantly through your Cashier. This Policy complies with the General Data Protection Regulation (GDPR) and other relevant gaming, anti-money laundering, and data protection regulations applicable to HugoBets.
1.1 Age Restriction
HugoBets is only available to individuals who meet the minimum legal age for online gambling in their jurisdiction (18 or over, or higher where local law requires it). It is prohibited for anyone below this age to access, register on, or use our Website in any manner. We use the data described in this Policy, including identity verification data, to confirm your age and eligibility to play.
1.2 Definitions
- “Company”, “we”, “us”, or “our” refers to HugoBets or the relevant group entity responsible for processing your data.
- “Player”, “you”, or “your” refers to any user who registers, accesses, or plays on HugoBets.
- “Data Controller” is the entity that determines the purpose and means of processing your personal data.
- “Data Processor” is a third party that processes personal data on our behalf, under our instructions.
- “Personal Data” means any information relating to an identified or identifiable natural person.
2. Information We Collect
We collect various types of information to provide, secure, and improve our services, and to meet our legal and regulatory obligations. The categories of information we collect include:
- Identity Data: your name, address, date of birth and payment details.
- Contact Data: your username, email address, phone number, and postal address.
- Account Data: username, password, gaming preferences, real and bonus balances, deposits, withdrawals, average deposit and withdrawal, bonuses, reserved bets, maximum balance, and account income.
- Activity Logs: login session activity, betting history, game sessions, game rounds, total bets, total wins, and IP address at time of activity.
- Game Analytics: Free Rounds and Free Spins activity, games played, most played and favourite provider, biggest win, and average rounds or income per session.
- Technical Data: device and browser type, IP address, operating system, time zone, and other technical identifiers used to access our services.
- Usage Data: pages visited, time spent on our site, and cookie data collected in line with our Cookie Policy.
- Account Limits and Restriction Data: any limits you set, and any account restriction activated by you or our Support Team on your behalf. While a restriction is active, you will not be able to access your account until the chosen period expires.
- Communications: records of your Customer Support correspondence with HugoBets, including emails and LiveChat, kept to ensure service quality and to assist with any future queries or disputes.
- Know Your Customer (KYC) Data: requested on a case-by-case basis in line with our Terms and Conditions and anti-money laundering obligations, including valid ID, proof of address, bank statements, source of funds or wealth documentation, and politically exposed person (PEP) status.
- Publicly Available Information: information from third parties or public sources, such as Google searches, where required for us to meet our legal and regulatory obligations.
As a rule, we do not collect or process special categories of data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, health data, or data concerning sex life or sexual orientation. If you voluntarily share this type of information with us, for example through chat or email, we will only retain a record that you made such a disclosure, and we may need to restrict or close your account for your own protection.
3. How We Use Your Information
We use your information for the following purposes:
- Providing Services: to open and manage your account, process your transactions, and deliver customer support.
- Improving Services: to understand how you use our services and to enhance and personalise your experience.
- Compliance and Safer Gambling: to comply with legal and regulatory obligations, including anti-money laundering checks, age and identity verification, and to detect and respond to signs of problem gambling using analytical and behaviour-monitoring tools.
- Fraud and Security: to identify and prevent fraud, misuse of our systems, and other unlawful activity.
- Marketing: to send you promotional materials and updates about our services, where you have given your consent.
Where required by law, we may process your data through automated means, including profiling, for the purpose of meeting our anti-money laundering and problem-gambling monitoring obligations. As a rule, we do not make decisions that produce legal or similarly significant effects on you based solely on automated processing.
4. Legal Basis for Processing
Our legal basis for collecting and processing your personal data includes:
- Contractual Necessity: processing is necessary to perform our contract with you under our Terms and Conditions.
- Consent: obtained for specific processing activities, such as marketing communications.
- Legitimate Interests: for purposes such as improving our services, managing risk, and preventing fraud, provided these interests do not override your rights.
- Legal Obligations: necessary to comply with anti-money laundering, gaming, tax, and other regulatory requirements.
5. How We Share Your Information
We only disclose your personal data to third parties where lawful to do so, including to:
- Service Providers: payment processors, identity verification providers, and customer support tools that assist us in delivering our services, bound by confidentiality and data protection obligations.
- Regulatory Authorities and Law Enforcement: as required by law, court order, or regulatory request.
- Your Bank or Payment Provider: where you dispute a payment or loss charged to your account, we may disclose relevant KYC, Bank Account, Usage, and Account Data to your bank to help resolve the dispute.
- Other Group Entities: within the HugoBets corporate group, for the purposes described in this Policy.
- Business Transfers: in the event of a merger, acquisition, or sale of our business, your information may be transferred to the new owner.
- Advertising Partners: only with your consent, to deliver personalised advertising.
We only share the personal data that is necessary for these third parties to perform the relevant service, and we require them to keep your data secure and to process it solely on our instructions.
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes described in this Policy and to meet our legal and regulatory obligations, in particular under applicable anti-money laundering and gaming legislation. All data is maintained for the duration of your relationship with us. Following the closure of your account or the end of our relationship, we retain data in line with the following schedule:
- 5 years: Identity Data, Contact Data, Technical Data, Usage Data, KYC Data, Publicly Available Information, Self-Exclusion Data, and Financial Data, counted from the date the relationship ends.
- 10 years: Account Data, including account balances, deposits, withdrawals, bonuses, and activity logs.
- Indefinitely: records confirming a Player's indefinite self-exclusion or a documented problem-gambling concern, so that other operators and we can continue to honour that exclusion.
Where you request erasure of your data, we will action your request to the extent permitted by law. However, we are legally required to retain certain categories of data for the periods set out above, and we will not be able to delete such data before the applicable retention period has expired, even where you ask us to do so. Once the relevant retention period lapses, we securely delete or anonymise the data.
7. Data Security
We implement robust security measures to protect your data, including:
- Encryption: we use SSL (Secure Sockets Layer) and other advanced encryption techniques to protect your data during transmission and storage.
- Access Controls: access to your data is restricted to employees, agents, and contractors who have a genuine business need to know, and who are bound by confidentiality obligations.
- Regular Security Audits: we conduct regular security assessments to identify and address vulnerabilities.
- Breach Procedures: we have procedures in place to detect, manage, and, where legally required, notify you of any personal data breach.
8. Your Rights
Under GDPR, you have the following rights regarding your personal data:
- Right to Access: all your information, including your balances, deposits, withdrawals, bonuses, and activity history, is available to you directly and in real time through the Cashier section of your account once logged in, without needing to contact us.
- Right to Rectification: you can request correction of inaccurate or incomplete data by contacting our Support Team. Please note that your username cannot be changed.
- Right to Erasure: you can request deletion of your data where it was processed based on your consent or where the processing is no longer lawful. As set out in Section 6 (Data Retention), we are required by anti-money laundering, gaming, and tax legislation to retain certain data for defined periods. We are not able to erase this data before the applicable retention period expires, regardless of your request, and will inform you of this if it applies to your case.
- Right to Restrict Processing: you can request that we restrict processing in certain situations, for example while you contest the accuracy of your data.
- Right to Object: you can object to the processing of your data for specific purposes, such as marketing, at any time and without detriment to your relationship with us.
- Right to Withdraw Consent: where processing is based on your consent, you can withdraw it at any time by contacting our Support Team or the unsubscribe link in any marketing communication, without affecting the lawfulness of processing carried out before withdrawal.
To exercise these rights, please contact our Support Team. To protect your data from unauthorised access, we may need to verify your identity before actioning your request. We will respond within one month of receiving a valid request.
9. GDPR Compliance
As part of our commitment to GDPR compliance, we ensure the following:
- Data Protection Officer (DPO): we have appointed a DPO to oversee GDPR compliance and to act as a point of contact for data protection queries.
- Data Protection Impact Assessments (DPIAs): we conduct DPIAs for high-risk processing activities to identify and mitigate potential risks.
- Transparency and Accountability: we maintain detailed records of our data processing activities and regularly review our practices to ensure compliance.
- User Consent Management: we obtain explicit consent for specific processing activities and provide easy methods for you to withdraw it.
10. Marketing Preferences
Where you have consented to receive marketing, you can withdraw that consent at any time by clicking “unsubscribe” on any marketing communication you receive, or by contacting our Customer Support team, who will action your unsubscribe request on your behalf. Opting out of marketing will not affect any other part of your relationship with HugoBets.
11. Third-Party Links
Our Website may contain links to third-party websites and advertisers. We are not responsible for the privacy practices or content of these websites. If you follow a link away from HugoBets, you should review the privacy policy of that website directly.
12. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or in applicable law. Any changes will be published on this page, and we encourage you to review it periodically. In case of any discrepancy between the English version and a translated version of this Policy, the English version shall prevail.
13. Contact Us
If you have any questions about this Policy or wish to exercise any of your data protection rights, please contact our Customer Support team via LiveChat or [email protected].