Privacy Policy

No hidden agendas. No burying the important bits in paragraph 47. Effective Date: March 1, 2025 | Last Updated: February 28, 2026 - **Data Controller: All Bettors OÜ, registered in Estonia** - Applicable Regulations: GDPR (EU/EEA/UK) • CCPA/CPRA (California) • LGPD (Brazil) • PIPEDA (Canada) • PDPA (Thailand, Malaysia) • Privacy Act (AU/NZ) • APPI (Japan) • DPDPA (India) • POPIA (South Africa) - Covered Markets: United States • Latin America • Europe (excl. Netherlands & Belgium) • United Kingdom • Australia • New Zealand • Asia (excl. China, South Korea & Singapore) - Contact: [privacy@all-bettors.com](mailto:privacy@all-bettors.com) ## 1. LET’S BE STRAIGHT Privacy policies are famous for being written to confuse you. Dense paragraphs. Passive voice. Important decisions buried where no one reads. We’re not doing that. This policy tells you exactly what data we collect, why we collect it, who we share it with, how long we keep it, and what you can do about any of it. No corporate non-speak. No “we’ve heard your feedback.” Real information, in plain language. This Privacy Policy describes how All Bettors OÜ (“All Bettors”, “we”, “us”, “our”) handles personal information when you use the Platform at all-bettors.com and any related apps (the “Platform”). Using the Platform means you’ve acknowledged this Policy. If you don’t agree with how we handle data, don’t use the Platform. That’s a legitimate choice. This Policy doesn’t cover third-party services linked from the Platform. What they do with your data is their business. Check their policies directly. ## 2. WHO’S RESPONSIBLE All Bettors OÜ is the data controller. We decide what data is collected and how it’s used. We’re registered in Estonia, which means GDPR governs us by default. One of the stricter data protection frameworks on the planet. We didn’t choose it reluctantly. Any privacy question, request, or complaint comes here: **All Bettors OÜ, Data Protection** Email: [privacy@all-bettors.com](mailto:privacy@all-bettors.com) Support: [support@all-bettors.com](mailto:support@all-bettors.com) Legal: [legal@all-bettors.com](legal@all-bettors.com) Website: [https://www.all-bettors.com](https://www.all-bettors.com) We respond within the timeframe your jurisdiction requires, typically 30 days, extendable to 60 where permitted. ## 3. WHAT DATA WE COLLECT We collect what we need to run the Platform. Nothing else. ### 3.1 What You Give Us Directly #### When You Create an Account - Full name and username; - Email address; - Date of birth (required for age verification); - Country of residence; - Password and account credentials. #### When You Buy Curv Coins Purchases go through our PCI-DSS compliant payment processor. Full card numbers never touch our servers. We receive: - Transaction history and Curv Coin purchase records; - Billing address; - Payment confirmation data from our processor; - Bank account or digital wallet identifiers where applicable. #### When We Verify Your Identity For age verification or fraud prevention in certain circumstances: - Government-issued ID documents; - A selfie or facial image for document matching; - Proof of address. #### When You Talk to Us - Content of your support messages; - Survey responses or feedback; - Social handles if you reach us through social channels. ### 3.2 What We Collect Automatically When you use the Platform, our systems collect: #### Device and Technical Data - IP address and approximate geolocation derived from IP, not GPS; - Device type, operating system, browser type and version; - Device identifiers like mobile advertising IDs; - Network and connection type. #### Usage Data - Pages and features you use, and time spent; - Prediction Events you participate in, outcomes, and Curv Coin balances; - Social Casino Games played and in-game activity; - Daily login streak activity and bonus claim history; - Clicks, interactions, and navigation paths; - Referring and exit URLs. **Note on Curv Coin balance data:** Curv Coins are a licensed virtual currency owned by All Bettors, not a financial asset or property of users. Curv Coin balance and transaction records collected through the Platform are operational data used to deliver the service, not financial account records. #### Tracking Technologies We use cookies, web beacons, pixel tags, and local storage to maintain sessions, analyse performance, and support advertising where you’ve consented. Full details in Section 8. ### 3.3 What We Get from Third Parties - Single sign-on providers (Google, Apple, Telegram, MetaMask): your name, username and email if you use their sign-in; - Payment processors: transaction confirmation; - Identity verification providers: verification status and check results; - Analytics providers: usage metrics; - Fraud prevention services: risk scores and flagged activity indicators; - Publicly available sources: used to verify identity or compliance. ## 4. WHAT WE DO WITH IT Every use of your data has a purpose and a legal basis. Here they are. ### 4.1 Running the Platform Legal basis: Contract performance; Legitimate interests. - Creating and managing your account; - Enabling your participation in Prediction Events and Social Casino Games; - Processing Curv Coin transactions and managing your balance; - Delivering streaks, bonuses, and Platform features; - Responding to support requests; - Keeping your account secure. ### 4.2 Keeping It Fair Legal basis: Legitimate interests; Legal obligations. - Detecting and preventing fraud, cheating, collusion, and abuse; - Enforcing our Terms, including catching bots, multi-accounters, and manipulators; - Age verification; - Investigating fair play violations; - Meeting anti-money laundering obligations where applicable. ### 4.3 Making It Better Legal basis: Legitimate interests; Consent where required. - Analysing how people use the Platform to improve it; - Internal research and product development; - Measuring performance and engagement; - Generating anonymised statistical insights. ### 4.4 Talking to You Legal basis: Consent where required; Legitimate interests for existing users. - Transactional emails: confirmations, security alerts, purchase receipts; - Promotional updates where you’ve opted in or where law permits; - Personalised experience based on your activity; - Targeted advertising on third-party platforms where you’ve consented. ### 4.5 Legal Compliance Legal basis: Legal obligation; Legitimate interests. - Complying with laws, regulations, and court orders; - Maintaining legally required records; - Defending or exercising legal claims; - Cooperating with law enforcement when required. ## 5. WHO WE SHARE IT WITH >We don’t sell your personal information. Full stop. ### 5.1 Service Providers Third-party companies that help us run the Platform. Bound by contract to use your data only as we direct. This includes: - Payment processors; - Cloud hosting and infrastructure providers; - Customer support platforms; - Identity verification and KYC/AML providers; - Analytics and product intelligence tools; - Email and communications platforms; - Fraud detection and security services; - Marketing and advertising platforms. ### 5.2 Advertising Partners With your consent where required, we may share identifiers (hashed email addresses, device IDs) with advertising technology partners to serve relevant ads on third-party platforms. Opt out any time. See Section 8. ### 5.3 Legal Requirements We may share your data with authorities when required to: - Comply with a legal obligation, subpoena, or court order; - Protect the rights, property, or safety of All Bettors, our users, or the public; - Detect, prevent, or address fraud or security issues; - Enforce our Terms. ### 5.4 Business Transfers If All Bettors is acquired or restructured, your data may transfer to the new entity. We’ll tell you if your data becomes subject to a materially different privacy policy. ### 5.5 With Your Consent For anything else, we ask first. ### 5.6 Anonymised Data Aggregated, anonymised data that can’t identify you may be shared for research, analytics, or product development. ## 6. MOVING DATA ACROSS BORDERS We’re based in Estonia and operate globally. Your data may cross borders. When it does, we make sure it’s protected. For transfers from the EU/EEA, UK, and other restricted jurisdictions, we use: - Standard Contractual Clauses (SCCs) approved by the European Commission; - The UK International Data Transfer Agreement (IDTA) for UK data; - Adequacy decisions where applicable; - Other lawful mechanisms required by local law. Want the specifics on your transfer mechanism? Email privacy@all-bettors.com. ## 7. HOW LONG WE KEEP IT We don’t keep data longer than we need to. Here’s how that works: - Account information: Duration of your account plus five (5) years after closure; - Transaction and payment records: Seven (7) years from the transaction date; - Identity verification records: Five (5) years from verification or closure, whichever is later; - Usage and behavioural data: Two (2) years from collection; - Marketing consent logs: Until consent is withdrawn, plus three (3) years; - Support communications: Three (3) years from resolution; - Legal hold data: Duration of any proceedings, plus applicable limitation periods. When data is no longer needed for any lawful purpose, we securely delete or anonymise it. ## 8. COOKIES AND TRACKING ### 8.1 What We Use - Strictly Necessary: Required for the Platform to function. Can’t be turned off. Includes authentication tokens and security cookies. - Functional: Remember your preferences, language settings, and login state. - Performance and Analytics: Understand how the Platform is used and improve it. Data is aggregated. - Marketing and Targeting: Deliver relevant ads and measure campaign effectiveness. Only with your consent where required by law. ### 8.2 Third-Party Tracking Some advertising networks, analytics providers, and social platforms place their own tracking on the Platform. We allow this within consent controls. We’re not responsible for their practices, but we vet who we let in. ### 8.3 Your Choices - Our consent banner on first visit; - Your browser settings, though blocking strictly necessary cookies may break things; - Industry opt-out tools: optout.networkadvertising.org and optout.aboutads.info; - Google Analytics opt-out add-on: tools.google.com/dlpage/gaoptout. Opting out of targeted advertising doesn’t stop ads. It stops them being tailored to you. ## 9. SECURITY We take security seriously. Our measures include: - Encryption in transit (TLS 1.2+) and at rest; - Multi-factor authentication for all production system access; - Role-based access controls and least-privilege principles; - Regular security assessments and penetration testing; - Payment data handled exclusively by PCI-DSS compliant processors; - Incident response procedures for detecting, containing, and reporting breaches. No system is impenetrable. We won’t pretend otherwise. In the event of a breach that poses a high risk to your rights, we’ll notify you and relevant regulators as the law requires. ## 10. CHILDREN The Platform is for adults. 18 and over (US states: AL & NE 19+, MS 21+). We don’t knowingly collect data from anyone under 18. If we find out we have, we delete it and close the account immediately. Think we may have collected data from a minor? Tell us immediately at [privacy@all-bettors.com](privacy@all-bettors.com). >In EU member states where the consent age for data processing is 16, we apply the higher locally applicable threshold for consent-based processing. ## 11. YOUR RIGHTS You have rights over your data. We honour them. No runaround. ### 11.1 Rights for Everyone We Serve - Access: Ask for a copy of the data we hold about you; - Correction: Tell us something is wrong and we’ll fix it; - Deletion: Ask us to delete your data, subject to legal retention obligations; - Withdraw Consent: Pull back any consent at any time. This doesn’t affect processing that already happened; - Opt Out of Marketing: Hit unsubscribe on any marketing email, or email [privacy@all-bettors.com](privacy@all-bettors.com). ### 11.2 EU/EEA and UK Users (GDPR / UK GDPR) - Right to Restrict Processing: Ask us to pause processing in specific circumstances; - Data Portability: Receive your data in a machine-readable format; - Right to Object: Object to processing based on legitimate interests, including direct marketing; - Right to Complain: To the Estonian Data Protection Inspectorate ([www.aki.ee](https://www.aki.ee)) or your national authority. ### 11.3 California Residents (CCPA/CPRA) - Right to Know: What we collect, why, and who we share it with; - Right to Delete: Request deletion, subject to exceptions; - Right to Correct: Request correction of inaccurate data; - Right to Opt Out of Sale/Sharing: We don’t sell your data. We don’t share it for cross-context behavioural advertising without consent; - Right to Limit Sensitive Data Use: Limit our use to what’s necessary; - Right to Non-Discrimination: Exercising your rights won’t affect how we treat you. Submit California requests to [privacy@all-bettors.com](privacy@all-bettors.com), **subject line:** California Privacy Request. We verify identity first. ### 11.4 Brazilian Users (LGPD) Rights under Brazil’s LGPD: access, correction, anonymisation, blocking, deletion, portability, information about sharing, and consent revocation. Contact [privacy@all-bettors.com](privacy@all-bettors.com), **subject line:** LGPD Request. ### 11.5 Canadian Users (PIPEDA) Rights to access and correct your personal information. Contact [privacy@all-bettors.com](privacy@all-bettors.com), **subject line:** Canada Privacy Request. ### 11.6 Australian and New Zealand Users Australian users have rights under the Privacy Act 1988 (Cth) and the Australian Privacy Principles. New Zealand users have rights under the Privacy Act 2020. Contact [privacy@all-bettors.com](privacy@all-bettors.com), **subject line:** AU/NZ Privacy Request. Australian users can also contact the OAIC at www.oaic.gov.au. ### 11.7 Asian Markets Users in Japan (APPI), Thailand and Malaysia (PDPA), India (DPDPA), and other covered Asian markets have access, correction, and deletion rights under applicable local laws. Email [privacy@all-bettors.com](privacy@all-bettors.com), **subject line:** Asia Privacy Request. ### 11.8 How to Submit a Request - Email [privacy@all-bettors.com](privacy@all-bettors.com), include your jurisdiction in the subject line; - We may verify your identity before processing; - We respond within the timeframe your jurisdiction requires, generally 30 days; - No fee unless your request is manifestly unfounded or excessive. ## 12. THIRD-PARTY LINKS We link out sometimes. We’re not responsible for what’s on the other side. Their privacy policies govern their data. Read them. Using “Sign in with Google” or similar? That provider’s privacy policy applies too. ## 13. WHERE YOU ARE MATTERS The following supplements apply by jurisdiction. Where there’s a conflict with the main policy, these take precedence. ### 13.1 European Union and EEA All Bettors OÜ is established in Estonia. Our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, [www.aki.ee](https://www.aki.ee)). Our legal bases under GDPR Article 6: - Article 6(1)(a), Consent: marketing and non-essential cookies; - Article 6(1)(b), Contract: account creation, service delivery, transactions; - Article 6(1)(c), Legal obligation: compliance with applicable law; - Article 6(1)(f), Legitimate interests: fraud prevention, security, analytics, direct marketing to existing users. For special categories of data (e.g., biometrics for age verification), we rely on Article 9(2) GDPR: explicit consent or legal obligation. Our EU representative is AllBettors OÜ, Estonia. ### 13.2 United Kingdom We comply with UK GDPR and the Data Protection Act 2018. Supervisory authority: the ICO, [www.ico.org.uk](https://www.ico.org.uk). UK users have the same rights as EU users. We use the UK IDTA and/or Addendum to SCCs for UK data transfers. ### 13.3 United States We comply with applicable US federal and state privacy laws. California (CCPA/CPRA): See Section 11.3. Regulator: California Privacy Protection Agency, [cppa.ca.gov](https://cppa.ca.gov). Virginia, Colorado, Connecticut, Texas, and other state comprehensive privacy laws: Rights to access, correct, delete, and opt out of targeted advertising. Contact [privacy@all-bettors.com](privacy@all-bettors.com). Do Not Track: We don’t currently respond to browser DNT signals. No uniform industry standard exists. Use our cookie controls instead (Section 8.3). California Shine the Light (Civil Code §1798.83): We don’t disclose personal information to third parties for their own direct marketing purposes. ### 13.4 Latin America Brazil, LGPD: We process Brazilian users’ data in compliance with Lei Geral de Proteção de Dados Pessoais (Law No. 13,709/2018). Legal bases: consent, contract, legitimate interest, legal obligation. Regulator: ANPD, [www.gov.br/anpd](https://www.gov.br/anpd). Other Latin American markets: We comply with applicable national laws including Argentina (Law 25,326), Mexico (LFPDPPP), Colombia (Law 1581/2012), Chile (Law 19,628), and others. ### 13.5 Australia and New Zealand Australia: Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs). Complaints to the OAIC at [www.oaic.gov.au](https://www.oaic.gov.au). New Zealand: Privacy Act 2020 and Information Privacy Principles. Complaints to the Privacy Commissioner at [www.privacy.org.nz](https://www.privacy.org.nz). ### 13.6 Asia (Covered Markets) Japan, APPI: We comply with the Act on the Protection of Personal Information. Requests: [privacy@all-bettors.com](privacy@all-bettors.com), **subject line:** Japan, APPI Request. Thailand, PDPA: Personal Data Protection Act B.E. 2562 (2019). Legal bases: consent and contractual necessity. Malaysia, PDPA: Personal Data Protection Act 2010. We apply the seven data protection principles. India, DPDPA: Digital Personal Data Protection Act 2023. Rights to access, correction, grievance redress, and nomination. Other Asian markets: Indonesia (UU PDP), Vietnam (Decree 13/2023), Taiwan (PDPA), Hong Kong (PDPO), Philippines (Data Privacy Act 2012): we comply with applicable local law. Contact [privacy@all-bettors.com](privacy@all-bettors.com). ## 14. MARKETS WE DON’T OPERATE IN The Platform is geo-blocked in the People’s Republic of China and the Republic of Korea. We also don’t allow access from jurisdictions subject to comprehensive international sanctions. Circumvent our geo-blocking and we’ll terminate your account immediately. We may report the activity to relevant authorities. ## 15. WHEN THIS POLICY CHANGES When our data practices change or regulations require it, this Policy updates. When it does: - The “Last Updated” date changes; - The revised Policy is posted on the Platform; - If the change materially affects your rights, we’ll email you or post a prominent notice. Continued use after changes take effect means you accept the updated version. Don’t agree? Stop using the Platform and request account deletion. ## 16. WE’RE HERE Something’s not right? A question we didn’t answer? [Talk to us](https://all-bettors.com/support). AllBettors OÜ, Data Protection Email: [privacy@all-bettors.com](mailto:privacy@all-bettors.com) Website: [https://www.all-bettors.com](https://www.all-bettors.com) We take every privacy concern seriously. If we don’t resolve it to your satisfaction, you have the right to escalate to your jurisdiction’s supervisory authority: - Estonia (EU Lead Authority): Data Protection Inspectorate, [www.aki.ee](https://www.aki.ee) - United Kingdom: Information Commissioner’s Office (ICO), [www.ico.org.uk](https://www.ico.org.uk) - California: California Privacy Protection Agency (CPPA), [www.cppa.ca.gov](https://www.cppa.ca.gov) - Brazil: Autoridade Nacional de Proteção de Dados (ANPD), [www.gov.br/anpd](https://www.gov.br/anpd) - Australia: Office of the Australian Information Commissioner (OAIC), [www.oaic.gov.au](https://www.oaic.gov.au) - New Zealand: Office of the Privacy Commissioner (OPC), [www.privacy.org.nz](https://www.privacy.org.nz) © 2026 AllBettors OÜ. All rights reserved. | [privacy@all-bettors.com](mailto:privacy@all-bettors.com) | [all-bettors.com](https://www.all-bettors.com)