Privacy Statement of Smart Gaming B.V.

1 November 2025

During the processing of personal data Smart Gaming B.V. works conform the requirements of the applicable data protection legislation, like the General Data Protection Regulation. This means we:

clearly specify our purposes before we process personal data, by using this privacy statement;
limit our collection of personal data to only the personal data needed for legitimate purposes;
first ask for explicit permission to process your personal data in cases where your permission is required;
take appropriate security measures to protect your personal data and we demand the same from parties who process personal data on our behalf;
respect your right to access, correct or delete your personal data held by us.

Smart Gaming B.V. is the party responsible for all data processing. In this privacy statement, we will explain what kind of personal data we collect and for which purposes within our website smartgaming.info. We recommend that you read it carefully.

If you have any questions regarding the processing of personal data, you can find the contact details of Smart Gaming B.V. at the end of this privacy statement.

2. Smart Gaming B.V. uses this personal data for the following purposes:

Sending newsletters

We have a newsletter to inform those interested about news, tips and information regarding our products and services. Your e-mail address is added to the list of subscribers, only with your permission.

Personal data used:

Identification and contact details: name, e-mail address

We do this on the basis of your consent. We store this information until you cancel your subscription. You may cancel your subscription at any time. Each newsletter contains a link to unsubscribe.

Use of Smart Gaming B.V. branding
Smart Gaming B.V. uses its branding for physical materials such as branded merchandise, corporate gifts, and other initiatives for employees and business partners.

Personal data used:

Identification and contact details: name, address, e-mail address, telephone number (for delivery or contact regarding participation)

The processing takes place because we have a legitimate business interest in promoting our brand and maintaining good relationships with employees and partners.

Processing of applicant data
When individuals apply for a position with our organisation, we process the personal data they provide solely for the purpose of managing the recruitment process.

Personal data used:

Identification and contact details: name, address, e-mail address, telephone number
Application and employment data: CV, cover letter, interview notes, employment history, education, references, and any other information the applicant voluntarily provides
In some cases: copy of ID or proof of residence (if legally required before employment)

The processing takes place on the basis of our legitimate interest in assessing and handling job applications in an efficient and fair manner. Applicant data is retained only as long as necessary to complete the selection procedure and comply with any legal obligations. With explicit consent, data may be kept on file for future job opportunities.

Employee images and videos
Smart Gaming B.V. may create and use photographs or video recordings in which employees are visible for legitimate business purposes, such as internal communication, corporate events, or external promotional materials. Such processing only takes place after obtaining the employee’s explicit consent. Employees have the right to withdraw their consent at any time.

Personal data used:

Visual data: photographs, video recordings
Identification and contact details: name or position (if mentioned or displayed)
Employee or partner information: department or function title (if relevant in the context)

Cookies
Our website uses cookies to store information, so that you do not have to fill in that information again and to analyse website usage.

Personal data used:

Marketing and usage data: IP address, device type, browser settings, website activity, preferences, and cookie identifiers

The first time you visit our website, we will show you a notification explaining our cookies and may ask for your permission. You can disable cookies through your browser settings, but some parts of our website may not function properly.

Contact forms
Smart Gaming B.V. collects and processes personal data submitted through online contact forms to respond to inquiries, provide requested information, or maintain business correspondence. The information provided is used solely for communication and follow-up purposes related to the subject of the inquiry.

Personal data used:

Identification and contact details: name, email address, phone number (if provided)
Communication content: message text, subject, or other information included in the contact form
Technical data: date and time of submission, IP address (for security and anti-spam purposes)

The processing is based on our legitimate interest in responding to inquiries and maintaining effective communication with customers, partners, and other interested parties.

Other Processing Activities
In addition to the specific processing activities described above, Smart Gaming B.V. also processes personal data as part of its general business operations.

Personal data used:

Identification and contact details: name, address, e-mail address, telephone number (for communication with customers, partners, or suppliers)
Administrative data: invoices, payment details, customer or supplier references
Correspondence data: content of e-mails or letters, contact history
Legal and compliance data: records related to fraud prevention, legal claims, or internal investigations
Technical data: system logs, IP addresses, user credentials for IT access, and website security data

All these activities are based on our legitimate interest in operating and managing our business efficiently and securely, ensuring proper communication, and complying with our legal obligations, only to the extent that this does not disproportionately affect your privacy.

3.Data Processors
To support our operations, Smart Gaming B.V. may engage carefully selected third parties that process personal data on our behalf. These parties act as data processors within the meaning of the General Data Protection Regulation (GDPR) and are bound by strict contractual obligations to handle personal data only according to our documented instructions and in compliance with data protection requirements.

The categories of data processors we use include:

IT and Hosting Providers: for the secure hosting, maintenance, and technical management of our websites, systems, and databases.
Email and Communication Service Providers: for sending newsletters, service notifications, and other legitimate communications.
Recruitment and HR Support Services: for managing recruitment processes, candidate data, and, where applicable, employee administration.
Marketing and Analytics Partners: for measuring website performance, analysing visitor behaviour, and supporting legitimate marketing activities.
Cloud Storage and Collaboration Tools: for secure document storage, internal communication, and workflow management.

All processors engaged by Smart Gaming B.V. are assessed for their reliability and data protection measures. Data processing agreements are concluded with each processor to ensure appropriate safeguards, confidentiality, and compliance with applicable data protection legislation.

4. International Data Transfers
Your personal data is, as much as possible, processed on secure servers within the European Economic Area (“EEA”).

The transfer of your personal data to a third party outside the EEA may first be legitimized on the basis of an adequacy decision by the European Commission, which determines that the relevant (part of the) third country ensures an adequate level of data protection. In the case of transfers to the United States, the transfers may be legitimized under the EU–U.S. Data Privacy Framework.

If we are required to process personal data in a country that does not benefit from an adequacy decision, we ensure that such personal data is processed in accordance with Chapter V of the GDPR. This may include entering into data processing agreements and applicable model contracts (Standard Contractual Clauses) with the relevant party. A model contract is a standard agreement approved by the European Commission to ensure the protection of your personal data, with annexes completed by the parties involved. See this link for the various model contracts. Where necessary, additional measures will be implemented.

In certain situations, we may also rely on the derogations set out in Article 49 of the GDPR to legitimize the data transfer. This means that we may transfer your personal data: (i) with your explicit consent, (ii) where necessary for the performance of a contract concluded with you or in your interest, or (iii) where necessary for the establishment, exercise, or defense of legal claims. Finally, in exceptional cases, we may also transfer personal data where the transfer is necessary for our compelling legitimate interests, which are not overridden by the interests or rights and freedoms of the data subject.

You can contact us if you would like additional information about how we legitimize the transfer of your personal data to countries outside the EEA.

Our contact details can be found at the bottom of this Privacy Statement.

5.Providing personal data to third parties
We only share your personal data with third parties when we have a valid legal basis for doing so. Any disclosure of personal data is carefully assessed to ensure it is necessary, proportionate, and in accordance with applicable data protection laws.

We always take appropriate measures to safeguard your information and only engage with third parties that offer sufficient guarantees of data protection and confidentiality.

Our website also includes social media buttons, which may allow the providers of these platforms to collect your personal data.

6.How we obtain your personal data

We collect personal data in several ways:

Directly from you, for example, when you contact us, or subscribe to our newsletter.
Automatically through your use of our website, such as via cookies and similar technologies that collect information about your device, IP address, and browsing behaviour.
From third parties, for instance from advertising or analytics partners that help us improve our website and services.

7.Retention of personal data
Smart Gaming B.V. does not retain personal data for longer than is necessary for the purpose for which it was collected. Once the data is no longer needed, it will be securely deleted or anonymised.

In some cases, we are required by law to keep certain information for a specific period of time, for example, to comply with tax, accounting, or regulatory obligations. In such cases, the data will be retained only for as long as the applicable legal retention period requires.

When determining appropriate retention periods, we take into account the nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, and our legal and contractual obligations.

8.Security
Smart Gaming B.V. takes appropriate technical and organisational measures to protect your personal data. We ensure that these measures remain in line with the current state of technology. At a minimum, the following safeguards have been implemented:

Physical security: We have implemented physical measures at our business premises to prevent unauthorised access to documents, workstations, and servers. Internal company policies are in place to minimise the risk of unauthorised access to and/or loss of personal data.
Employee awareness: All employees receive regular training under our Information Security Management System (ISMS) to ensure awareness of security and privacy obligations.
Confidentiality: All employees are bound by strict confidentiality obligations.
Secure transmission: We use SSL (Secure Socket Layer) technology where necessary to encrypt sensitive data and personal information (such as account passwords or other identifiable information) during transmission.
Encrypted storage: Sensitive information is stored in encrypted form wherever reasonably possible.
Data backups: Regular backups of personal data are made where reasonably necessary to ensure data integrity and availability.
Software security: Vulnerabilities in our software are addressed and resolved as quickly as possible once identified.

Where we engage third parties who act as processors of personal data on our behalf, these processors are contractually required to implement appropriate technical and organisational measures to protect personal data.

While we make every effort to maintain a high level of data security, it is important to note that absolute security when storing or transmitting personal data over the internet can never be fully guaranteed.

9.Data protection officer
We have appointed a so-called data protection officer. This person is responsible for privacy matters within our organisation. Our data protection officer is available by e-mail (fg@betnation.nl) for all your questions and requests. (Betnation is a subsidiary of Smart Gaming B.V.)

10.Inspection and modification of your data
You can always contact us if you have any questions regarding our privacy policy or wish to review, modify or delete your personal data.

You have the following rights:

Right of access: you have the right to see what kind of personal data we processed about you;
Right of rectification: you have the right to rectify any personal data we have processed about you, if this information is (partially) wrong;
Right to complain: you have the right to file a complaint against the processing of your personal data by us, or against direct marketing;
Right to be forgotten: you can file a request with us to remove any personal data we have processed of you;
Right to data portability: if technically possible, you have the right to ask us to transfer your processed personal data to a third party;
Right to restriction of processing: you can file a request with us to (temporarily) restrict the processing of your personal data.

If you exercise any of the rights mentioned above, we might ask to identify yourself with a valid ID, to confirm it is your personal data. If so, it is important that you hide your social security number and photo.

We will usually respond to your request within one month. This term can be extended if the request is proven to be complex or tied to a specific right. You will be notified about a possible extension of this term.

11.Complaints
If you want to file a complaint about our use of personal data, please send an e-mail with the details of your complaint to contact@smartgaming.info. We will look into and respond to any complaint we receive.

If you think that we are not helping you in the right way, you have the right to file a complaint with the supervisory authority. For Malta, this is the Office of the Information and Data Protection Commissioner (IDPC).

12.Contact details
For questions or comments about our processing of personal data, or to exercise your rights, you can contact us at:

Smart Gaming B.V.
Office 13, Soho St. Julians, Punchbowl, Centre,

Elia Zammit Street, St. Julian’s, STJ 3154, Malta
Chamber of Commerce number: 84398019

Malta Business Registry: OC1581

www.smartgaming.info
contact@smartgaming.info

13.Changes to this privacy statement
We reserve the right to modify this statement. We recommend that you consult this statement on a regular basis, so that you remain informed of any changes.

Privacy Statement of Smart Gaming B.V.

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