Privacy Policy

This Privacy Policy explains how Betonred, operated through the website https://betonredbet-ca.com, collects, uses, discloses, and protects personal information of players and website visitors from Canada. It applies to all users who access or use our website, register an account, or otherwise interact with our services. By using our services, you agree to the practices described in this Privacy Policy. This Privacy Policy is effective as of January 1, 2026 and supersedes any previous versions for Canadian users.

Who We Are

OBSERVE: Identify the operator, legal entity, and contact points responsible for privacy compliance.

EXPAND: Clarify corporate structure, licensing, and designate a point of contact for data protection matters relevant to Canadian players.

REFLECT: Provide a clear statement of identity and accountability to support transparency obligations under applicable privacy laws.

Betonred is the Canadian-facing brand of the online gaming website operated at https://betonredbet-ca.com (the "Site"). The Site is owned and operated by:

• Operator: Uno Digital Media B.V.
• Legal form: Private limited company (B.V.) incorporated under the laws of Curaçao
• Company registration number: 157147
• Registered and legal address: Johan Van Walbeeckplein 24, Willemstad, Curaçao
• Gambling license: Curaçao eGaming Master License 1668/JAZ, authorized by the Government of Curaçao; in transition under Curaçao Gaming Control Board framework (reference OGL/2023/109.0075)

For certain payment processing activities, the operator may act through:

• Payment processor (affiliate company): UDM Processing Services Ltd, incorporated in Cyprus, which supports processing of fiat transactions for North American players on behalf of Uno Digital Media B.V.

Data Protection Contact

We have appointed an internal contact point for privacy and data protection matters (Data Protection Officer / Data Protection Contact).

• Data Protection Contact: Data Protection Department, Uno Digital Media B.V.
• Email: [email protected] (please include "Privacy request - Canada" in the subject line)
• Postal address for privacy correspondence: Data Protection Department, Uno Digital Media B.V., Johan Van Walbeeckplein 24, Willemstad, Curaçao

All requests, questions, or complaints concerning this Privacy Policy or our handling of personal information can be directed to the contact details above.

What Personal Data We Collect

OBSERVE: Identify the types of information collected from Canadian users through the Site, games, and related services.

EXPAND: Distinguish categories of data (identity, technical, financial, behavioral, cookies) and note when data is provided directly by you or generated by our systems.

REFLECT: Present categories clearly so users can understand what is collected and for what general purposes, supporting transparency and informed consent.

Categories of Personal Information

• Identification and contact data:
  • Full name, date of birth, place of residence and country
  • Postal address (where required for verification or payments)
  • Email address and phone number
  • Account credentials (username, encrypted password, security questions/answers)
  • Copies or details of identification documents (passport, national ID, driver's licence) and proof of address for KYC/AML purposes
• Account and usage data:
  • Account registration details, account status, language and currency preferences
  • Login history, session duration, activity logs within the account area
  • Customer support communications (emails, live chat logs, complaint records)
• Technical and device data:
  • IP address and approximate location derived from IP (e.g., province, city)
  • Device identifiers (e.g., device ID, operating system, browser type and version)
  • Device settings, time zone, network provider, screen resolution
  • Log files, access timestamps, referring/exit pages, and error reports
• Payment and financial data:
  • Deposit and withdrawal records, including amounts, currencies, and methods used
  • Partial payment instrument details (e.g., masked credit/debit card numbers, expiry month/year) where required for processing, chargeback, and anti-fraud checks
  • Payment transaction identifiers and related confirmations from banks, card schemes, e-wallet and other payment providers
  • Limited financial history relevant to assessing affordability and preventing fraud or money laundering, where required by applicable regulations
• Gaming and behavioral data:
  • Betting history and game activity (games played, time spent, stakes, wins and losses, bonuses used)
  • Clickstream data and navigation paths on the Site
  • Responsibility tools usage (deposit limits, loss limits, time-outs, self-exclusion), including related behaviour and preferences
  • Interactions with marketing content (email opens, link clicks, banner impressions)
• Verification and compliance data:
  • Results of age, identity, sanctions, politically exposed person (PEP), and adverse media checks performed through third-party verification tools
  • Internal risk scores and flags for anti-fraud, AML, and responsible gambling monitoring
  • Documentation and notes created in the context of regulatory or dispute investigations
• Cookies and similar technologies data:
  • Unique cookie identifiers associated with your browser or device
  • Information about pages viewed, features used, session source/medium, and engagement metrics
  • Advertising identifiers (where permitted) and tracking related to marketing campaigns

Where we collect personal information from third parties (e.g., payment providers, verification services, affiliates, marketing partners), we do so in accordance with applicable law, and we combine such information with the data we already hold about you, as allowed by law and this Privacy Policy.

Legal Basis for Processing

OBSERVE: Determine and clearly state the primary lawful grounds under which we process personal data of Canadian users.

EXPAND: Connect each main processing activity (account operation, payments, verification, marketing, analytics, fraud prevention) to a suitable legal basis such as consent, contract, legitimate interest, or legal obligation.

REFLECT: Provide a structured explanation that aligns with international best practices (including GDPR-style principles) to ensure transparency and defensibility.

Our Legal Grounds

• Performance of a contract or steps prior to entering into a contract:

  We process your personal data when it is necessary to create and manage your gaming account and to provide you with our services, including:

  • Registering your account on betonredbet-ca.com and verifying your eligibility to play
  • Enabling you to access games, place bets, participate in promotions, and manage your account
  • Processing deposits and withdrawals and providing transactional confirmations
  • Providing customer support and handling your requests or inquiries
• Compliance with legal and regulatory obligations:

  As a licensed online gaming operator, we are subject to anti-money laundering, counter-terrorist financing, fraud prevention, and responsible gambling requirements, as well as record-keeping obligations. We therefore process your data to:

  • Carry out identity, age, source-of-funds, and other KYC/AML checks
  • Monitor transactions, game activity, and behavioural patterns for suspicious or high-risk activity
  • Maintain statutory records for defined retention periods, including transaction and gaming logs
  • Cooperate with supervisory and regulatory authorities, law enforcement, and courts when required
• Legitimate interests:

  We process certain data where this is necessary for our legitimate business interests, and where these interests are not overridden by your privacy rights. These legitimate interests include:

  • Securing our systems, preventing fraud, abuse, and cheating
  • Maintaining and improving the quality, performance, and user experience of our Site and services
  • Conducting internal analytics, statistics, and reporting on product performance and user behaviour (in anonymized or aggregated form where possible)
  • Defending and establishing our legal rights, including in connection with disputes and claims
• Consent:

  Where required by law, we rely on your consent to process personal data for specific purposes, for example:

  • Sending you marketing communications by email, SMS, push notification, or other electronic means
  • Using certain categories of cookies and similar technologies for analytics and advertising purposes (beyond what is strictly necessary)
  • Sharing limited data with affiliates and advertising networks for personalized offers, if and where applicable

  You may withdraw your consent at any time, as described in the "Your Rights" and "Cookies & Tracking Technologies" sections. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Purpose of Processing

OBSERVE: Identify the core reasons for which personal information is processed in connection with Betonred.

EXPAND: Connect purposes to specific operational and regulatory needs: delivery of gaming services, risk management, marketing, analytics, and service optimization.

REFLECT: Present the purposes in a clear, categorized manner so users can understand how their information enables and supports the services they use.

Main Purposes

• Provision and management of gaming services:
  • Creating and maintaining your account on betonredbet-ca.com
  • Allowing you to access casino games and related services, place bets, and participate in tournaments and promotions
  • Managing bonuses, loyalty or VIP programs, and related rewards
  • Providing customer support and resolving technical or account issues
• Payments and financial operations:
  • Processing deposits, withdrawals, and refunds, including through our payment partners and processors such as UDM Processing Services Ltd
  • Performing payment verification, chargeback assessment, and financial reconciliation
  • Maintaining accurate financial records for accounting and compliance purposes
• Regulatory compliance, risk management, and fraud prevention:
  • Conducting KYC/AML checks and ongoing monitoring of game and payment activity
  • Detecting and preventing fraud, bonus abuse, collusion, money laundering, and other prohibited conduct
  • Monitoring responsible gambling behaviours and applying protection measures when needed (e.g., limits, self-exclusion)
  • Responding to legal requests and cooperating with regulatory and governmental authorities
• Service improvement and analytics:
  • Analyzing how users interact with our Site and games to improve functionality, usability, and content
  • Testing new features, products, and user interfaces
  • Producing aggregated statistics for business planning, performance tracking, and reporting
• Marketing and personalization (where permitted):
  • Sending you promotional communications about our games, bonuses, and special offers, subject to your preferences and legal requirements
  • Customizing the content and offers you see on betonredbet-ca.com based on your previous activity
  • Measuring the effectiveness of marketing campaigns and optimizing targeting strategies
• Security and integrity of our services:
  • Protecting the Site, systems, and user accounts from unauthorized access and cyber threats
  • Conducting security monitoring, logging, and incident response
  • Verifying the technical compatibility of your device with our services

Disclosure & Sharing

OBSERVE: Identify the categories of third parties with whom personal data may be shared in the course of operating Betonred.

EXPAND: Distinguish operational service providers, payment partners, affiliates, regulators, and advertising partners, and explain circumstances of disclosure.

REFLECT: Provide a transparent overview of data flows to third parties, including safeguards and limitations, ensuring users understand that data sharing is controlled and lawful.

Third Parties and Circumstances of Disclosure

• Payment partners and financial institutions:
  • Banks, card schemes, e-wallet providers, and other payment service providers involved in processing deposits and withdrawals
  • UDM Processing Services Ltd and other affiliated processors acting on behalf of Uno Digital Media B.V. for payment and risk processing
  • These parties receive only the data necessary to process transactions, prevent fraud, and comply with financial regulations
• Service providers and technical vendors:
  • IT hosting providers, cloud infrastructure services, and content delivery networks
  • Game content providers and platforms that supply casino games accessible through betonredbet-ca.com
  • Customer support tools (e.g., live chat, ticketing systems) and communication platforms used to interact with you
  • Analytics, monitoring, and security service providers that help us analyse performance and detect threats
  • These parties act as data processors under contractual obligations to process personal data only according to our instructions and with appropriate safeguards.
• Regulators, supervisory authorities, and law enforcement:
  • Gambling regulators, including Curaçao eGaming / Curaçao Gaming Control Board, where necessary to demonstrate compliance with licensing conditions
  • Law enforcement agencies, courts, and governmental authorities where disclosure is required by applicable law, regulation, legal process, or official request
  • Other competent authorities in connection with investigations into fraud, money laundering, or other illegal activity
• Affiliates and group entities:
  • Companies within the same corporate group as Uno Digital Media B.V. (including UDM Processing Services Ltd) where needed for internal administration, payment processing, risk management, or consistent service delivery
  • Disclosure is limited to what is necessary and subject to intra-group data protection agreements
• Advertising networks and marketing partners (with consent where required):
  • Marketing service providers and affiliates who promote betonredbet-ca.com on our behalf
  • Advertising networks and platforms, to the extent permitted, for measuring campaign performance and, where allowed, delivering targeted advertising
  • Such sharing occurs only where lawful and, where required, based on your explicit consent or opt-in to marketing.
• Professional advisers and transactional partners:
  • Legal advisers, auditors, consultants, and accountants, where necessary to protect our rights and comply with legal obligations
  • Potential buyers, investors, or partners in the context of corporate transactions (e.g., mergers, acquisitions), subject to confidentiality and data protection safeguards

We do not sell your personal information as that term is generally understood (i.e., exchanging personal information for money). If local law treats certain disclosures as a "sale" or "sharing," we will comply with applicable requirements, including providing appropriate notices and options where required.

International Transfers

OBSERVE: Recognize that data processing involves multiple jurisdictions outside Canada, including Curaçao, the European Union, and potentially other regions.

EXPAND: Explain that data may be stored or accessed in foreign countries and outline the safeguards used to protect such transfers consistent with international standards.

REFLECT: Provide reassurance that, despite cross-border transfers, personal information remains subject to robust security and contractual protections.

Where Your Data May Be Processed

• Primary locations:
  • Curaçao - corporate registration, licensing, and core operational management by Uno Digital Media B.V.
  • European Union / European Economic Area - hosting, payment processing, and support services may be provided from EU/EEA countries, including Cyprus through UDM Processing Services Ltd and other vendors.
• Other jurisdictions:
  • Third-party service providers, including cloud and content delivery networks, may process data from additional countries, depending on their infrastructure locations.

Protection Measures for Cross-Border Transfers

• We use contractual safeguards such as standard contractual clauses or equivalent data transfer agreements, where required by applicable data protection laws, for transfers from regions that regulate cross-border data transfers.
• We require our service providers and group companies to implement appropriate technical and organizational security measures to protect personal information, irrespective of where it is processed.
• We limit transfers to what is strictly necessary to provide our services, operate our business, and meet legal obligations.

By using betonredbet-ca.com, you understand that your information may be transferred to and processed in countries outside of Canada, which may have different data protection laws than those in your home jurisdiction. In such cases, we take steps to ensure that your privacy rights continue to be adequately protected.

Data Retention

OBSERVE: Identify the categories of data and the minimum and maximum timeframes for which they must be kept.

EXPAND: Align retention with regulatory obligations (e.g., AML, licensing) and business needs while supporting data minimization and user rights.

REFLECT: Provide clear retention principles and indicative periods, including criteria for deletion or anonymization after the end of the retention period.

Retention Principles

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required or permitted by applicable laws and regulations. When determining retention periods, we take into account:

• The nature of the personal data and the purposes for which it is processed
• Regulatory requirements, including anti-money laundering, financial, tax, and gambling-licence record-keeping rules
• The existence of actual or potential disputes, investigations, or claims
• Technical and operational considerations for securely deleting or anonymizing data

Indicative Retention Periods

• Account and identification data:
  • Core account details, identification documents, KYC/AML records, and basic contact information are typically retained for the duration of your active account and, after account closure, for a period of up to 5 - 7 years, depending on applicable regulatory requirements and limitation periods for legal claims.
• Transaction and gaming data:
  • Payment records, betting history, and game logs are generally retained for at least 5 years after the relevant transaction or account closure, as required by anti-money laundering, tax, and gambling laws.
• Marketing and communications data:
  • Records of marketing consent, communication preferences, and engagement data are retained while you maintain an account and for up to 2 years after you unsubscribe or close your account, to demonstrate compliance and manage opt-out lists.
• Technical logs and security data:
  • System logs, access records, and security-related events are typically kept for 6 - 24 months, unless a longer period is necessary for security incident investigations or legal obligations.
• Customer support and complaint records:
  • Support tickets, complaint files, and related correspondence may be stored for up to 5 years after resolution, to manage disputes and demonstrate compliance to regulators.

Deletion and Anonymization

• When personal data is no longer required for any lawful purpose, we will either securely delete it or irreversibly anonymize it so that it can no longer be associated with you.
• If you request deletion of your data, we will comply where feasible and lawful, but may retain certain information where necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Your Rights

OBSERVE: Recognize that individuals have rights over their personal information, inspired by international standards such as GDPR and comparable principles in other jurisdictions.

EXPAND: Describe key rights (access, correction, deletion, restriction, objection, portability, and withdrawal of consent) and how Canadian users can exercise them in practice.

REFLECT: Provide clear procedures, including timeframes and cost (free of charge), while noting that some rights may be limited due to legal and regulatory obligations.

Overview of Your Rights

Subject to applicable law and certain limitations, you may have the following rights in relation to your personal information:

• Right of access: To obtain confirmation as to whether we process your personal data and, if so, to receive a copy and information about our processing.
• Right to rectification: To request that inaccurate or incomplete personal data be corrected or completed.
• Right to erasure ("right to be forgotten"): To request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (if applicable), or where processing is unlawful, subject to our legal and regulatory retention obligations.
• Right to restriction of processing: To request that we temporarily suspend processing of your data, for example while the accuracy of the data is being verified or a complaint is being assessed.
• Right to object: To object to certain types of processing based on legitimate interests, including profiling, on grounds relating to your particular situation. You also have the right to object at any time to processing of your data for direct marketing purposes.
• Right to data portability: To receive certain personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible and where processing is based on consent or contract and carried out by automated means.
• Right to withdraw consent: Where processing is based on your consent (e.g., email marketing, certain cookies), you can withdraw that consent at any time. This will not affect the lawfulness of processing before withdrawal.

How to Exercise Your Rights

1. Submission of request:
   • Contact us at [email protected] with a clear description of your request and include "Privacy request - Canada" in the subject line.
   • Alternatively, you may send a written request to our postal address: Data Protection Department, Uno Digital Media B.V., Johan Van Walbeeckplein 24, Willemstad, Curaçao.
2. Verification of identity:
   • For security reasons, we may need to verify your identity before acting on your request (e.g., by asking you to log into your account or provide additional information).
3. Response timeframe:
   • We aim to respond to all valid requests within 30 days of receipt. If your request is particularly complex or we receive multiple requests, we may extend this period by an additional 30 days, in which case we will notify you of the extension and reasons.
4. Fees:
   • We handle your requests free of charge. However, where allowed by law, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, repetitive, or excessive.
5. Limitations:
   • Some rights may be subject to restrictions due to our obligations to comply with anti-money laundering, gambling, tax, or other regulatory requirements. For example, we may not be able to delete certain transaction or KYC data before the end of the mandatory retention period.

If you are located in a jurisdiction with specific privacy regulations that grant you additional rights, we will respect such rights in accordance with applicable law.

Cookies & Tracking Technologies

OBSERVE: Identify the types of cookies and tracking technologies used and their purposes.

EXPAND: Distinguish between strictly necessary, functional, analytics, and advertising cookies and explain how users can manage them.

REFLECT: Provide users with practical tools and instructions to control cookies, supporting transparency and informed choice.

Types of Cookies We Use

• Session cookies:
  • Temporary cookies that are stored only during your browsing session and are deleted when you close your browser.
  • Used to maintain your logged-in status, manage sessions, and ensure secure navigation across the Site.
• Persistent cookies:
  • Remain on your device for a defined period or until you delete them.
  • Used to remember your preferences (e.g., language, odds format), improve user experience, and recognize returning visitors.
• First-party cookies:
  • Set directly by betonredbet-ca.com to support core site functionality and analytics.
• Third-party cookies:
  • Set by external providers (e.g., analytics and advertising partners) to measure site usage, prevent fraud, or deliver relevant content and advertisements, where permitted.

Purposes of Cookies

• Strictly necessary (functional) cookies:
  • Required for the website to function correctly, including enabling secure login, maintaining sessions, processing bets and payments, and protecting against fraudulent activity.
• Preference cookies:
  • Store your choices and settings (such as language, region, and display options) to personalize your experience.
• Analytics and performance cookies:
  • Help us understand how visitors use our Site (pages visited, time spent, navigation flows) so we can improve functionality and performance. Data is often aggregated and used for statistical purposes.
• Advertising and marketing cookies (where used and permitted):
  • Used to deliver relevant advertisements and track the effectiveness of our marketing campaigns, including interactions with promotional content from affiliates or advertising networks.

Managing Cookies

• Browser settings:
  • You can usually set your browser to accept, refuse, or delete cookies, or to alert you when cookies are being sent. The method varies by browser; please check your browser's "Help" or "Settings" section.
• Internal tools:
  • Where available, we may provide on-site controls (e.g., cookie banners or preference panels) allowing you to manage non-essential cookies (such as analytics or advertising cookies).
• Impact of disabling cookies:
  • If you disable or block certain cookies, some parts of betonredbet-ca.com may not function properly, and your user experience may be affected.

Data Security

OBSERVE: Recognize that processing personal and financial data in the online gambling context requires robust technical and organizational security measures.

EXPAND: Describe concrete safeguards such as encryption, access controls, monitoring, audits, staff training, and incident response, referencing recognized standards where applicable.

REFLECT: Assure users that, although no system is completely secure, we maintain reasonable and appropriate security measures proportionate to risk.

Our Security Measures

• Encryption and secure transmission:
  • Data transmitted between your device and betonredbet-ca.com is protected using TLS 1.2 or higher encryption protocols to reduce the risk of interception.
  • Sensitive data, including passwords and certain financial information, is encrypted at rest using industry-standard algorithms.
• Access control and authentication:
  • Access to personal data is restricted to authorized personnel who require it to perform their duties and is governed by role-based access controls.
  • We encourage the use of strong passwords and may employ additional authentication mechanisms or checks where appropriate.
• Infrastructure and system security:
  • We use firewalls, intrusion detection/prevention systems, and other technical safeguards to protect our networks and servers.
  • Regular patching, vulnerability assessments, and, where relevant, external security reviews are performed to maintain system integrity.
• Monitoring, logging, and fraud detection:
  • We monitor systems for anomalies, suspicious login attempts, unusual transaction patterns, and other indicators of potential fraud or abuse.
  • Game and transaction logs are retained in line with our retention policies to support investigations and regulatory reporting.
• Staff training and confidentiality:
  • Employees and contractors with access to personal data are subject to confidentiality obligations and receive training on data protection, information security, and responsible handling of customer information.
• Incident response:
  • We maintain procedures for identifying, assessing, and responding to data security incidents, including investigation and remediation steps.
  • Where required by applicable law, we will notify you and/or relevant authorities of data breaches that may pose a risk to your rights and freedoms.

While we strive to protect your personal information, the transmission of data over the internet can never be guaranteed as completely secure. You are responsible for maintaining the confidentiality of your account credentials and for using appropriate security measures on your own devices.

Complaints & Contacts

OBSERVE: Recognize users' need for clear channels to raise questions or concerns about privacy and to escalate unresolved complaints.

EXPAND: Describe internal complaint handling processes, response times, and provide contact details, including escalation options to supervisory authorities where applicable.

REFLECT: Encourage users to contact us first for resolution while acknowledging their right to approach relevant authorities.

How to Contact Us

• Email (primary contact): [email protected] (include "Privacy complaint - Canada" in the subject line for complaints)
• Postal address: Data Protection Department, Uno Digital Media B.V., Johan Van Walbeeckplein 24, Willemstad, Curaçao

Complaint Procedure

1. Submit your concern:
   • Describe your issue in detail, including relevant account information and any supporting documentation.
2. Acknowledgment:
   • We will acknowledge receipt of your complaint as soon as reasonably practicable, usually within 5 business days.
3. Investigation and response:
   • We will investigate your complaint and aim to provide a substantive response within 30 days from acknowledgment.
   • If additional time is required (for example, due to complexity or the need to liaise with third parties or regulators), we will inform you of the delay and expected timeline.
4. Escalation:
   • If you are not satisfied with our response, you may request that your complaint be escalated internally for further review.

Escalation to Authorities

If you believe that we have not handled your personal information in accordance with applicable data protection laws, you may have the right to lodge a complaint with a competent data protection or privacy authority in your jurisdiction of residence, your place of work, or the place where the issue occurred.

For Canadian users, this may include your provincial or territorial privacy regulator, or the Office of the Privacy Commissioner of Canada (OPC). Contact details for the OPC can be found at: https://www.priv.gc.ca/.

Updates

OBSERVE: Recognize that privacy practices may evolve due to legal, technical, or business changes.

EXPAND: Describe how users will be informed about updates, including timing, notification channels, and their options.

REFLECT: Provide assurance that material changes will be communicated clearly and in advance where required, maintaining transparency and trust.

Changes to This Privacy Policy

• We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or data processing practices.
• When we make material changes, we will take appropriate steps to inform you in advance, such as:
  • Sending email notifications to the address associated with your account;
  • Displaying notices or banners on betonredbet-ca.com;
  • Providing alerts within your account dashboard.

Notice Period and User Options

• For significant changes that materially affect your rights or the way we process your personal data, we will provide, where practicable, at least 30 days' advance notice before the updated Privacy Policy becomes effective.
• If you do not agree with the updated Privacy Policy, you may:
  • Adjust your privacy or marketing preferences;
  • Stop using our services and request account closure; and
  • Where applicable, exercise your rights as described in the "Your Rights" section.

Last updated: January 2026

Any previous versions of this Privacy Policy remain available upon request for reference.