KYC Policies, Privacy & Management of Personal Data


KYC Policies

PURPOSE

By implementing the presented Policy, the Company aims to achieve the following outcomes:

  • processes and controls are put in place to mitigate the risk arising for the Company to be used, intentionally or unintentionally, for ML/TF purposes;
  • potential risk customers are identified;
  • the Company successfully fulfills the AML/CTF-related and other statutory obligations and effectively applies its Anti-Money Laundering Policies and Procedures, Underage Policy, Customer Interaction Policy and Responsible Gambling Policy.

 

GRANTING THE CUSTOMER STATUS

The customer means any natural person that formed a business relationship with the Company, by creating an online account at xsportsbet.com website. In that respect, Company's operational or reputational risk is generally based on that natural person's economic activity and/or source of wealth, that can be assessed from the information at the disposal upon the registration process.

The player can also be denied access to the website when it's deemed by the MLRO. Usually the denial or the end of the business relationship happens in the following instances:

  • The player has connections to a jurisdiction that is of high risk to the company either by ML/CFT or business standards
  • The customer provided fake documents in the CDD procedure
  • The customer used fake credit/debit cards which resulted in chargeback requests from the payment provider
  • There are indications that the customer is using multiple accounts to his/her advantage
  • If the customer sends expired ID documents, or sends a document that is ripped or unclear in some manner
  • The customer declines to send the requested CDD documents
  • If it is determined upon registration that the customer is underage
  • If the customer is a PEP, and the Board members do not allow him to continue the business relationship

 

 

KEY CUSTOMER ACCEPTANCE CONDITIONS

 

Upon initiating or assessing and before concluding or terminating a business cooperation with the customer (assigning or suspending the player status) the Company conducts the following verifications:

 

Age verification

 

No person under the age of 18 is allowed to be accepted as our customer, to register and place bets at the xsportsbet.com website. However, if, after registering, there is reasonable doubt arising or strong evidence indicating the approved customer is underage, that user's customer status is suspended.

 

Geographic origin verification

 

Residence and place of birth of customers are taken into account upon the registration process, as these data might indicate substantial geographical risk arising from such natural persons. Potential customers originating from high-risk countries are considered as a threat by the Company and as such prohibited to be granted the status of our customers.

 

 

Customer risk verification

 

If, subsequent to the registration, there is a reasonable doubt pointing out at some form of at-risk interaction with the player, namely:

- the player uses double accounts;

- the source of wagered funds may indicate an ML-issue;

- the player may have criminal records or adverse media

- the player is a PEP or a close relative thereof

- occupation and employment status

 

The Company, as per its legal obligations and internal corporate policies, helped by various CDD tools, reserves the right to refuse further service to such customers, as well as to freeze or suspend the customer's account until satisfactory feedback is obtained. Additionally, the customer type of play on the website is taken into the consideration, as well.

 

Product/interface risk verification

 

The Company acknowledges that certain games offered may pose a higher/lower threat of ML/TF. xsportsbet.com offers a variety of online casino and online sports betting games to players, and categorizes the risk by the game itself. Besides the game, the Company acknowledges that the risk can arise from delivery channels risk or interface risk, such as products or services offered to non-face-to-face customers or online services.  

 

Payment/Transaction Risk

 

The Company has in its general offer on the website a variety of payment methods that a customer can use at all times. The methods vary from credit/debit cards to e-wallets and vouchers. The multiple use of all payment methods can point to a higher risk behavior given that the customer is trying to hide the trace of these transactions.

 

 

Privacy Policy

 

You hereby acknowledge and accept that it is necessary for the Company to collect and otherwise store Your personal data in order to allow You access and use of the Website and in order to allow You to participate in Games. You hereby acknowledge and accept that all telephone calls made by you to the Company shall be recorded for Your own protection and benefit.

The Company hereby acknowledges that in collecting Your personal details as stated in the previous provision, we will protect your personal information and respect your privacy in accordance with best business practices and applicable laws.

Our Privacy Policy marks out the way in which Xsportsbet.com is managing the information and data you provide to us in order to manage the relationship with our website.

All the personal information and data provided by your side is processed and otherwise held by Xsportsbet.com in accordance with this Privacy Policy. We collect the personal information and data by your side through various ways:  website, mobile application, email, chat, telephone calls or any other means.

By accepting this Privacy Policy you hereby acknowledge and accept the use of your personal information and data as set out in this Privacy Policy. By accepting the Privacy Policy you understand that is necessary for Xsportsbet.com to collect, hold and otherwise handle your data in order to allow you the access to the website and participate in our offer. If you do not agree with this Privacy Policy please do not use Xsportsbet.com website or provide us in any other way with your personal information and data.

The capitalized terms not defined in this Privacy Policy shall be as defined in the General Terms and Conditions, for avoidance of any doubt, unless the context otherwise requires.

 

Protecting Your Personal Data

Xsportsbet.com protects and keeps your personal information and data in accordance with the high standards of our company and with Positive Business Practice. The Positive Business Practice define that we can only process your personal data when there is a legal basis for processing, including the “legitimate interest” proposed by our side. The legal basis for processing may be one of the following:

  • When you have consented to the processing
  • When it is necessary for the entry into or performance of any contract that we have with you
  • When it is necessary for compliance with a legal obligation under national law, including Anti-Money Laundering laws and regulations
  • When it is necessary for the purposes of legitimate interests pursued by us (or by a third party), unless it is overridden by your interests, fundamental rights and freedoms.
  • When it is necessary to protect your vital interests or of another natural person
  • When it is necessary to perform a task carried out in the public interest

 

Legitimate Interests

The legitimate interests for processing your data is when we have a business or commercial reason to do so. Your personal data is protected on the same level as the data collected for regulatory reasons and any other legal basis, and we will not process it in a way that would be unfair to you or your interests.

 

Type of data we collect and process

By visiting our website and/or using our app, registering to use any of our services offered by us through our website/app, or contacting us this Privacy Policy will apply.

The personal data we collect from you may include the following:

  • information you provide to us when registering for our services by filling in forms on the website or any other information you submit to us via the website or email;
  • information you provide to us in any correspondence and a record of any correspondence we have with you;
  • details of your visits to the website including, but not limited to, traffic data, location data, weblogs and other communication data;
  • information about any possible criminal, fraudulent, or anti-money laundering activity;
  • details of transactions you carry out with us;
  • information about your use of our Services;
  • information you provide to us through surveys you complete or competitions you enter;
  • information about your preferences;
  • information about your betting history and patterns;
  • telephone calls to and from our Customer Support Team are recorded for training and security purposes along with the resolution of any queries arising from the service you receive.

Where it is reasonable or required for us to do so and not damaging to your rights and freedoms, we also collect personal information and data from publicly available sources such as internet searches, public records, and broadcast media.

 

How we use your personal data

We will process your personal data for the following purposes and in accordance with the following lawful conditions:

  • To enable us to set up and operate your account so that you can make full use of all of the features of our services (necessary for the performance of the contract)
  • To enable us to receive questions and comments from you through our help center, and for us to be able to respond to them (necessary for the performance of the contract)
  • To comply with relevant regulations regarding your registration and to verification of the personal data you provide to us, including disclosure of such information to third parties (including financial institutions, age verification, and credit reporting agencies) in connection with such purposes (legal obligation)
  • When you set deposit limits we will use automated means to track your deposit amounts to make sure that we fulfil your request (consent)
  • Preparing statistics, providing analytical reports and analysis relating to the use of the services by you and other customers (legitimate interests)
  • Periodically sending written communications to you to announce important service changes, technical issue updates and changes to the General Terms, including this Privacy Policy (necessary for the performance of the contract)
  • To send you offers and promotions which may be of interest to your (but only when you have given your consent)
  • To provide you with personalized use of our services so that we can offer you a better service. To profile you so that we can better understand your preferences and which products and offers would be most suitable for you and customers similar to you (legitimate interests).
  • To comply with requested measures to identify and investigate any suspected unlawful, fraudulent or improper activity connected with the services, including possible money laundering, the use of proceeds of crime and fraud (legal obligation)
  • To comply with the responsible gambling and social responsibility obligations we will monitor gambling and/or deposit patterns that may indicate concern in respect of responsible gambling. We may use automated decision-making processes to help us to identify such patterns (legal obligation).

If you choose not to provide your Personal Data or to withdraw the previously given consent it may prevent us from meeting legal obligations, fulfilling a contract, or performing services required to run your account. You may withdraw your consent at any time. Not providing your personal data may mean we are unable to provide you with products or services.

 

Updating your information

It is important that the information we hold about you is accurate and up to date in order for us to comply with our regulatory obligations and also to provide you with the best service possible. We therefore request that you ensure your personal data is up to data at all times.

 

Data Retention

The data you have provided to Xsportsbet.com is kept for the period that you are our customer.

If you are no longer a customer of Xsportsbet.com, we will keep your data for the minimum length of time required to comply with the applicable legal or regulatory obligations. Xsportsbet.com will not retain the data beyond the AML/CFT requirements.

 

Personal Data shared with others

The data can only be shared with the following organizations:

  • Law enforcement agencies, regulators and other authorities
  • Fraud prevention agencies Credit reference agencies
  • Identity verification agencies
  • Sports governing bodies
  • Third parties you require from us to share your data with
  • Third parties necessary to provide products or services which you have requested

We will appoint certain third parties including but not limited to analytics companies, advertising agencies, risk and fraud agencies to process your personal data on our behalf when required.  These third parties will only process your personal data in accordance with our instructions and we will ensure that adequate measures are in place to ensure that your personal data is processed only in accordance with this Privacy Policy and kept secure at all times.

 

Your rights over your Personal Data

Please note that in accordance with the Positive Business Practice you have the following rights in regards to Xsportsbet.com handling your personal data:

  • You may withdraw your previously given consent at any time; however, this will not invalidate any previously consented processing. Also, the withdrawal of the consent can result in closing your account if the withdrawal of the consent is not in accordance with the legal basis on which we are processing such data.
  • Filing a complaint with any relevant Data Protection Authority
  • Access to your Personal Data that we process
  • Correction of any Personal Data that is incorrect or out of date
  • Erasure of the Personal Data that we process
  • Right to restrict processing of your Personal Data in certain circumstances
  • Right to transfer your data to a third party proposed by your side

 

Updates and modifications to the Privacy Policy

Please note that Xsportsbet.com may update this Privacy Policy occasionally, so we recommend reviewing it frequently.

If there are any material changes made to this Privacy Policy we will do our best to inform you in advance by email, notification on the website or other communication channels agreed upon, giving an appropriate amount of time for you to consider and understand the changes before they come into effect.

We will not enforce material changes to the Privacy Policy without your consent. If you decline to accept the changes to the Privacy Policy, or otherwise do not accept the changes within the appropriate time period, we may not be able to continue to provide some or all products and services.