1. Introduction

As a nostrabet user (‘you’) have the complete freedom to share opinions and information on free bets, get reviews of bookmakers, check the match statistics, compete with other tipsters, search tips and share opinions about sports matches. You will get more information about this in our Terms and Conditions.

This Privacy Policy will help you to understand how we collect fully, process, consult and use your personal data collected on this platform, www.www.cnwindpower.com/en-ke/ (nostrabet). This privacy policy applies to the processing of your personal data on nostrabet Kenya, but not to any data processing that may take place on other platforms.

2. Data Controller and Data Subjects

You may have to disclose certain pieces of information when you use our website, nostrabet and many of them may be personal data. You become the data subject when we process your personal data on nostrabet. You also have certain rights over those personal data as guaranteed by the EU Data Protection Law and other rights we will explain this Privacy Policy. You should always bear in mind that we have the sole right to determine the means and purpose of data processing on nostrabet. You also need to be aware that we are the controller over the personal data you have provided on our platform. As the data controller, we have the sole right to process your data and also have the responsibility to protect such personal data in line with the UE Data Protection Law, especially the General Data Protection Regulation (GDPR), as well as the content of this Privacy Policy.

3. Types of Data and Reasons for Processing

We may have to process different forms of data disclosed by you, the end user of our platform as such data processing helps us to provide the best service to you, maintain the normal function of our website, improve the development of the website and make the website even more secure. You can find more details about the data processed on our platform and the purpose for which we process such data in the remaining part of this write-up.

3.1 Identification data

Personal Identifiable Information (PII) – During the process of account creation on nostrabet, we will request for some personally identifiable details, like your email address, display name, and username. Our website will automatically generate a User ID for you, and we can also request for this to complete your registration process. Other sets of data we can request for are:

• Phone number
• Mobile phone number
• Surname
• Last name
• Address

However, the second set of data is not compulsory, but we will process them if you provide them on your profile. In some instances, we may be compelled to also ask for the screenshot or a scanned copy of your government issued ID. The data helps to verify your real identity.

We process your PII to help distinguish between you and other end users on our platform. We use your email address to communicate with you about any change we effect on your account and to send you to push notification and newsletter, provided you consent to such.

You are free to either reveal your surname, first name, phone number, mobile phone number, address or not reveal them. If you reveal them, they can improve the personalisation of your account and our communication with you. If you are entitled to a prize from us, we have to request for your surname, first name, a scanned copy of your government-issued ID and your phone number; we use the details to process and send the prize to you.

Electronic Identification Data- after you have logged into nostrabet, we will process your operating system, browser version, and your IP address. If you log in using social networks, ion the other hand, our system will generate a ‘social token’ for you and this will take the place of an authentication data processed on our platform anytime you log in via a social network account.

Processing the IP addresses of the device you have used to log in to your account ensure unfettered communication between our server and your computer. The IP address processing equally helps in determining your approximate geolocation, which we can also use to customise the services we provide to you, like the language preferences and the choice of gambling contents acceptable in your country. We equally use your geolocation information for analytical purposes. You can find more details about how your data is used for the analytical purpose in our Cookie Policy. We need to process your operating system and type of browser since it helps us to provide our services regularly to you. The data also help us in resolving any emerging technical problem.

If you are logging into our website using your social network accounts, we will not use or process any of the data on your social media accounts. We will instead generate social network token for you, and this will be used to authenticate your account with us.

3.2 Special financial data

Financial Identification data- If you win any cash prize, we will have to request for your PayPal or Skrill account details so that we can send your prize money to you.

3.3. Recordings

Images- We need you to upload a profile picture on our website. You can either upload your real picture or any other picture, and we will save it to your profile; this will help us personalise your profile on our platform.

3.4 Private habits and interests

Tips – You will need some public use of information for some of your activities on our website, especially when you posy tips. We will need to process the tip you have posted, like the date and time of the event, your clarifying comment about the tip, tip language, and the events relating to the tip. We equally create various statistics about how successful your tips are, as well as how you compare with other tipsters on our platform; this will help to determine how reliable your tips are.

The information processed about posted tips is highly necessary to make such tips available to the users of nostrabet. The statistics are made public so that competitions among our tipsters can be fair and transparent.

Preferences – We process all the data about the tipsters that you follow on our website; we also process data about your specific interests, like the content you prefer on nostrabet and the services you use.

Circumstances may equally compel us to process the data that you have provided on your ‘About Me’ page; this includes your social media account details and your specific betting interests.

Every end user of nostrabet can access the details about your preferred tipsters and followers we always promote transparency of all the activities going on here on nostrabet. We make the details available publicly so that all the visitors to our website can gauge your success and reliability as a tipster.

Processing details about your specific interest help us to identify your personal preferences, which enable us to communicate with you more effectively. We may have to use the details for commercial communication. You can check more detail about this in our Cookie Policy. If you prefer not to be subjected to automated decision making, like profiling, you can check of additional information in the ‘Right to Object for the Processing of Your Data’ and ‘Right Not to be the Subject of Automated Decision Making’ subsections, both of which you can find under ‘Your Rights’ in the Privacy Policy.

4. Our Use of Cookies

We give cookies to all the internet browsers that visit our website. The cookies help us to provide the best possible services to our clients and give them top line on-site experiences. The cookies are used for processing standard internet log details and behavioural pattern of the visitor. We equally use the cookies to provide content from their parties, promote our products, analyse the activities of the visitors to our website and improve navigation on our website. You can check out Cookie Policy to learn more about how we use cookies and how you can opt out of it.

5. How We Protect Your Data

We only collect and retain your personal data for as long as necessity demands. We also use the personal data for the purpose already discussed above.

We always follow organizational and technical measures in line with good industry practice when handling your personal data; this way, we ensure the complete security of the said personal data and also guard against any unlawful processing of the data, its unauthorized use, unauthorized access or disclosure of your data, theft, alteration or unlawful loss.

6. Your Rights

You hold the right to access information about how we process your data and details about our company, like our contact details, our identity, the purpose or reason for processing your personal data, the legal basis for this, those who receive the data and every other relevant detail needed for transparent and fair personal data processing.

6.1 Rights of access

You hold the right to be informed if we are processing your data or not. We can also provide you with details about the progress of the processing. You have the right to ask about the personal data we are processing also.

6.2 Right to rectification

If you want us to delete any inaccurate personal data that you have provided earlier, we are bound by law to accede to your request. You are also free to update any incomplete data at any time you deem it fit.

6.3 Right to erasure (Right to be forgotten)

You have the sole right to ask us to erase any of your personal data under the circumstances described below:

• If the data is not required anymore for the purpose of collecting it
• If you have declined to consent to the processing of such data, we are bound by law not to process that data anymore.
• If you express an objection to the processing of that data, we are bound not to process it except will have an overriding legal stand.
• If we process that particular data unlawfully.

We will not be bound by this obligation if it is not possible to comply with it or if we cannot prove it.

6.4 Rights to restrict processing

You have the right to ask for the restriction of your personal data in the circumstances below:

• If the data is not accurate, you can ask us to restrict its processing until its accuracy is verified.
• The data processing process is illegal.
• The data is not required anymore for the original purpose of collecting it, but it is still required for defending, exercising and establishing legal rights.
• If you raise an objection against the use of your personal data while you wait for its accuracy or legitimacy verification.

6.5 Right to object to the processing of your data

You have the right to oppose the processing of your personal data if it affected your peculiar situation. After you have objected, we will be compelled to withhold the data processing unless we have an overriding legal position against your fundamental rights and freedom.

6.6 Right not to be the subject of automated decision making

You can raise an objection to data processing for automated decision making, like profiling. We will no longer be able to process your data for automated decision making. You can equally ask for human intervention as regards the automated decision making about you.

6.7 Rights to data portability

You can receive the personal data that you have earlier provided us under some circumstances. You can ask of the data to be sent to anyone or any destination of your choosing. We will oblige you if such transmission is feasible technically.

6.8 Right to withdraw consent

We await your consent to send newsletter emails to you containing the latest offers and tips from our bookmakers. You equally cancel your consent for newsletter emails any time you feel like it; you do not owe us an explanation and you will not be charged for doing so.

6.9 How to Opt-out

If you want to opt out of newsletter emails from us, you should consider the points below:

• Scroll to the bottom of the newsletter email we have sent to you and click on the unsubscribe link there
• Visit our website and navigate to the preference center page where you can also unsubscribe.
• You can also cancel push notification in your browser’s settings.

6.10 Right to lodge a complaint

Do you feel that we have breached your personal data rights? Then you are free to lodge a complaint to that effect with the local data protection authority in your area or country. Your country or the place where the infringement took place is the place approved for the lodgment if you are from any of the EU Member States. We are located in Bulgaria, and you can get in touch with the Bulgarian Data Protection Agency to lodge the complaint.

6.11 How to exercise your rights

If you need any clarification about your data processing as explained in this Privacy Policy or you want to exercise your rights as we have outlined under ‘your Rights’ section, you can forward an email to [email protected].

7. Data Retention

We will continue to store your details in our database even if you cancel your account with us. However, we will not display your data publicly anymore. The tips you have already posted will still be displayed publicly since we have legal right over it as our intellectual property. Every other detail will be depersonalised; this means the tips will never be linked to your personal data anymore.

You can forward an erasure request to us if you want us to delete your personal data from our database.

8. Who Your Personal Data Can Be Shared With

Your personal data with us can be shared with third parties and we have categorized third parties as follows:

• Members of the Better Collective Group, including Better Collective A/S and its subsidiaries.
• Individuals that help with the development, marketing, maintenance, analysis and so on of our website.
• Law enforcement agencies and public authorities provided legal requirements permit us to do so.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

9. Transfer of Your Data to Third Countries

We can send your personal data beyond the coasts of the European Economic Area, but we only send it to countries where there is an assurance of security. We make sure that all the recipients provide top-line security. We also make sure that available security procedures are in line with all data protection laws applicable, including GDPR.

We can transfer your personal data to countries within the European Commission provided there is an adequate level of data protection. If we transfer the data to a recipient in the US, your data will be protected by the Privacy Shield mechanism. We will discuss Data Protection Agreement with the recipients of your data about the available security measures provided by the recipients.

10. Endnotes

We can modify this Privacy Policy from time to time. The modification can be either essential or minor.

Essential modifications are those that can affect your obligations and rights on our platform and related to the processing of your data for some other purposes apart from the already listed ones, implementation of new technologies, launching of new services and so on.

On the other hand, the minor modification has no effect on your obligations and rights and can include structural, grammatical and organisational modifications or changes to this Privacy Policy.