Privacy Policy

For the purposes of this Privacy Policy, the following definitions apply in accordance with the LGPD:

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Sensitive Personal Data" means personal data concerning racial or ethnic origin, religious belief, political opinion, trade union membership, health, sexual life, genetic or biometric data.
• "Data Subject" or "User" means the natural person to whom the personal data refers.
• "Controller" means the natural or legal person, public or private, that makes decisions regarding the processing of personal data. BetInsights acts as the Controller of your personal data.
• "Processor" or "Operator" means the natural or legal person, public or private, that processes personal data on behalf of the Controller.
• "Processing" means any operation performed with personal data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, control, modification, communication, transfer, diffusion, or extraction.
• "Consent" means the free, informed, and unambiguous expression by which the Data Subject agrees to the processing of their personal data for a specific purpose.
• "ANPD" means the Autoridade Nacional de Proteção de Dados (National Data Protection Authority), the Brazilian regulatory body responsible for overseeing compliance with the LGPD.

BetInsights acts as the Controller of personal data collected through the Platform:

The Data Protection Officer is responsible for receiving communications from Data Subjects and the ANPD, providing guidance to employees regarding data protection practices, and performing other duties as determined by the Controller or established in complementary regulations.

We collect personal data in various ways when you interact with the Platform. The categories of personal data we collect are as follows:

In accordance with Article 7 of the LGPD, we process your personal data based on the following legal bases and for the following purposes:

When processing is based on legitimate interest, we conduct a balancing test to ensure that your rights and freedoms are not overridden. You have the right to object to processing based on legitimate interest at any time.

We use cookies and similar tracking technologies to collect and store information when you access the Platform. These technologies help us provide, protect, and improve our services.

We do not sell, rent, or trade your personal data to third parties for their marketing purposes. We may share your personal data in the following circumstances:

BetInsights participates in affiliate marketing programs with licensed bookmakers. This means we may receive compensation when you click on links to bookmaker websites or register for accounts through our Platform.

When you interact with affiliate links:

• Tracking cookies may be placed on your device to attribute the referral
• Referral identifiers may be shared with the bookmaker
• We may receive information about whether you completed registration or met qualifying criteria
• We do not receive information about your betting activity or account balance at bookmaker sites

Our affiliate relationships do not influence the accuracy or objectivity of the information, odds data, or analysis provided on our Platform. We are committed to transparency and clearly identify affiliate relationships in accordance with applicable consumer protection laws.

Some of our service providers may be located outside of Brazil, which means your personal data may be transferred to and processed in countries with different data protection laws.

In accordance with Article 33 of the LGPD, international transfers of personal data are only permitted when:

• The receiving country or international organization provides an adequate level of data protection
• The Controller offers and proves guarantees of compliance with the principles, rights, and data protection regime through specific contractual clauses, standard contractual clauses, or binding corporate rules
• The transfer is necessary for international legal cooperation between public intelligence, investigation, and prosecution bodies
• The transfer is necessary to protect the life or physical safety of the Data Subject or third party
• The ANPD has authorized the transfer
• The Data Subject has provided specific and highlighted consent for the transfer

We implement appropriate safeguards, including standard contractual clauses approved by the ANPD or equivalent mechanisms, to ensure that your personal data remains protected in accordance with Brazilian law when transferred internationally.

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law.

The retention periods are determined based on:

• Account Data: Retained for the duration of your account and for up to 5 years after account deletion for legal compliance purposes
• Transaction Records: Retained for 5 years in accordance with Brazilian tax and commercial law requirements
• Communication Records: Retained for 2 years from the date of communication
• Analytics Data: Aggregated and anonymized data may be retained indefinitely; identifiable usage data is retained for up to 2 years
• Marketing Consent Records: Retained for 5 years from the date of consent or withdrawal

Upon expiration of the retention period, or upon your valid request for deletion, we will securely delete or anonymize your personal data, unless retention is required for compliance with legal obligations, exercise of rights in legal proceedings, or transfer to third parties as permitted by law.

Under the LGPD (Articles 17-22), you have the following rights regarding your personal data:

• Right to Confirmation: You may request confirmation of the existence of processing activities concerning your personal data.
• Right to Access: You may request access to your personal data that we hold.
• Right to Correction: You may request the correction of incomplete, inaccurate, or outdated data.
• Right to Anonymization, Blocking, or Deletion: You may request anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD.
• Right to Portability: You may request the portability of your data to another service provider, in accordance with ANPD regulations.
• Right to Deletion: You may request deletion of personal data processed with your consent, except in cases where retention is legally required.
• Right to Information about Sharing: You may request information about public and private entities with which we have shared your data.
• Right to Information about Consent: You may request information about the possibility of denying consent and the consequences of such denial.
• Right to Withdraw Consent: You may withdraw your consent at any time through a free and easy procedure. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Object: You may object to processing based on legitimate interest if you believe your fundamental rights and freedoms are being violated.
• Right to Review Automated Decisions: You may request review of decisions made solely based on automated processing of personal data that affect your interests, including decisions intended to define your personal, professional, consumer, or credit profile.

To exercise any of the rights described above, you may contact us through the following channels:

When submitting a request, please provide:

• Your full name and email address associated with your account
• A clear description of the right you wish to exercise
• Any additional information that may help us locate and process your request

We will verify your identity before processing any request to ensure the security of your data. We will respond to your request within 15 (fifteen) days, as required by the LGPD. If we are unable to comply with your request, we will provide a reasoned explanation.

If you believe that your rights have been violated or that our response is unsatisfactory, you have the right to file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd.

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental or unlawful destruction, loss, alteration, communication, or any form of improper or unlawful processing, in accordance with Article 46 of the LGPD.

Our security measures include, but are not limited to:

• Encryption of data in transit using TLS/SSL protocols
• Encryption of sensitive data at rest
• Access controls and authentication mechanisms
• Regular security assessments and vulnerability testing
• Employee training on data protection and security
• Incident response procedures
• Secure development practices
• Physical security measures for infrastructure
• Contractual security requirements for service providers

While we take all reasonable precautions, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to protecting your data to the best of our ability.

In the event of a security incident that may result in relevant risk or damage to Data Subjects, we will notify the ANPD and affected individuals in accordance with Article 48 of the LGPD.

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. Access to sports betting-related content is restricted to adults in compliance with Lei 14.790/2023 and the Brazilian Statute of the Child and Adolescent (Law No. 8,069/1990).

If we become aware that we have collected personal data from a minor without appropriate parental consent, we will take immediate steps to delete such information. If you believe we have inadvertently collected data from a minor, please contact us at privacy@betinsights.com.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last updated" date at the top of this Policy
• Notify you by email (if you have an account) or through a prominent notice on the Platform
• Where required by law, obtain your consent to the updated Policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of the Platform after any changes indicates your acceptance of the updated Policy.

This Privacy Policy is governed by and construed in accordance with the laws of the Federative Republic of Brazil, including but not limited to:

• Lei Geral de Proteção de Dados Pessoais (LGPD - Law No. 13,709/2018)
• Marco Civil da Internet (Law No. 12,965/2014)
• Código de Defesa do Consumidor (CDC - Law No. 8,078/1990)
• Lei das Apostas Esportivas (Law No. 14,790/2023)
• Applicable ANPD regulations and guidelines

Any disputes arising from or relating to this Privacy Policy shall be submitted to the competent courts of Brazil. In accordance with Article 101, I of the Consumer Defense Code, consumers may elect the jurisdiction of their domicile.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

We are committed to working with you to resolve any concerns about your privacy and our handling of your personal data.