2. INFORMATION WE COLLECT
When you register an account on Surebet or when you contact us, we ask for your full name and your email address.
When you buy a subscription, we may have to collect some financial information, as it is necessary process the payment.
3. HOW WE USE INFORMATION WE COLLECT
We process this data for the purpose of:
Offer a support and information service.
Providing you with a better service.
Allowing you to buy a subscription.
We process this information given our legitimate interest in in conducting our business and improving the Website and our users’ experience and where it is necessary for the adequate performance of the contract with you.
In some cases, we may use your data also to:
Contact you in relation to promotions, products or services that you may be interested in from time to time, but only where you have consented to receive such marketing communications.
Carry out certain profiling of you and your activity on the Website in order to personalize, measure, and improve our marketing and to send you more relevant marketing communications.
In such cases we will process your personal information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can always opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Account.
4. SHARING AND DISCLOSURE
4.1 COMPLIANCE WITH LAW, RESPONDING TO LEGAL REQUESTS, PREVENTING HARM AND PROTECTION OF OUR RIGHTS
We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability.
The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights and proper protection of our business against risks.
4.2. THIRD PARTY SERVICE PROVIDERS
We use third party service providers to help us provide services related to the Website. Service providers may be located inside or outside of the Republic of Kenya.
We may share some of your information with such third parties service providers in order to ensure the adequate performance of our contract with you, for our legitimate interest and to comply with our legal obligations. We will require your consent when needed.
4.3. CORPORATE AFFILIATE
We may share your information, including personal information, to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.4. AGGREGATED DATA
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4.5 BUSINESS TRANSFERS
5. DATA SUBJECT RIGHTS
Under the General Data Protection Regulation, you have the right to access, rectify, port and delete some of your data. You also have the right to object to and restrict certain processing of your data. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.
Please note that we may ask you to verify your identity before taking further action on your request.
Please be aware that whilst we will try to accommodate any request you make in respect of your rights they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
Access to personal data: You have a right to request a copy of the personal information that we hold about you.
Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect.
Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.
Right to data portability: This right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.
Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you.
Right to lodge a complaint: You have the right to lodge complaints about the data processing activities carried out by the Data Controller before the competent data protection authorities. Please refer to Section 7 for further information.
6. OVERSEAS TRANSFER OF YOUR INFORMATION
The Website uses 'cookies' to assist the functionality of the Website. A cookie is a small file of text which is downloaded onto your computer when you access the Website and it allows us to recognize when you come back to the Website.
Information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website.
8. CONTACT US
If you have questions about this Policy or our information handling practices, or if you are seeking to exercise any of your rights contact us through 0700926210 or email us at firstname.lastname@example.org.
9. FILING A COMPLAINT
If you are not satisfied with how we manage your personal data, you also have the right to lodge a complaint with the Data Protection Authority.
10. BEST PRACTICES
We apply best practices as per various regulators including but not limited to Data protection Authority, Communication Commisiion of Kenya and others.
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