Kambi Player Fair Processing Notice
This Kambi Player Fair Processing Notice (“the Kambi Player FPN”) is applicable to players only. By players we mean registered users who have an account or profile with a gambling operator who uses the Kambi sports betting platform (“Operators”).
Kambi Group plc is a company registered in Malta and listed on First North at NASDAQ, Stockholm, with a registered address at Level 3, Quantum House, Abate Rigord Street, Ta’ Xbiex, XBX1120 (“Kambi HQ”). Kambi HQ, working with the other Kambi entities (including those entities listed in the "Contact Us" section below - together “Kambi”, “we”, “us” and/or “our”), provides a sports betting platform solution for Operators. The solution involves Kambi reviewing and managing the bets placed through an Operator’s website (which uses the Kambi platform) so as to manage the risks associated with those bets. This Kambi Player FPN explains how we handle your Personal Data where you are a player and your bet has been moved through our platform. Please read this Kambi Player FPN carefully to understand how we will treat your Personal Data. This Kambi Player FPN is supplementary to any other privacy notice published by each Operator.
For the purposes of this Kambi Player FPN, Kambi is the “Controller” of your Personal Data. This is because when we process your Personal Data, we will (either acting alone or jointly with the Operators) make determinations about why and how your Personal Data is processed.
Types of data we collect/process:
We will collect certain information about you when you are a player. This information originates from the Operator you hold an account with. We get this information from them when they sign up to use our services and pass your information to us. Alternatively, we will collect this information directly from you by virtue of obtaining information about the device which you use to make a bet, which is then linked to the other information which we hold about you, as well as information about the actual bets you make. Additionally, there may be some information which we generate about you in order to provide our services.
By Personal Data, we mean information which, either by itself or when combined with other information that we hold or which is available to us, can be used to identify you.
The type of information we receive, collect, or otherwise process about you is as follows:
- technical information from your computer/laptop/tablet/smartphone, including:
- your IP address;
- a unique device identifier;
- your device operating system;
- broad geographic location;
- how your device has interacted with our platform;
- the number of bets you place;
- time of bet;
- nature of the event on which bets are placed;
- your Operator username (if the Operator has provided this to us);
- your Operator identification number;
- your Kambi issued identification number;
- other player details, which may include age, gender, city, first part of post code, currency for payments, country of residence, account balance and bet history;
- recommendations about your credit limit; and
- risk profile.
As you will note, Kambi does not, as a matter of course, hold your name, or contact information. The Personal Data which we process is restricted to the device you use to place bets, your Operator and Kambi unique identifiers, and information relevant to your playing behaviour. What this means is that the only way we can identify you by name, will be when the personal information which we have is combined with personal information which an Operator has. As noted, if you have used your real name as your username or if the Operator shares additional identity data with us, then the information we hold about you may be directly identifiable.
Kambi does not collect or process special category personal data (i.e. information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning your health, sex life or sexual orientation).
How we use your Personal Data:
Kambi will use your information in the following ways:
- providing access to our platform and services;
- tracking your betting activity;
- profiling including:
- analysing your betting patterns;
- creating risk profiles about you by matching your information to your behaviour;
- adjusting your betting limits depending on your risk profile;
- in extreme circumstances, preventing any further betting actions;
- reporting your activity back to the Operator;
- validating your information (and in some cases matching it against information that has been collected by an Operator);
- fulfilling our obligations to Operators;
- enhancing our services and the services that our Operators offer players;
- detecting fraud and managing other risks associated with betting;
- complying with applicable laws, including laws that regulate gambling and gaming, fraud and money laundering.
When we apply a risk profile to a player, it is confirmed or amended by our analysts. We continue to monitor a player's risk profile and we use automated processing to recommend if a player's risk profile should change. Any proposed changes are confirmed or amended by our analysts.
We also apply automated risk management to assess the risk of particular betting activities. If a bet falls outside of a player's risk profile, our analysts will review it.
In general, we will use the personal information we collect from you only for the purposes described in this Kambi Player FPN or for purposes that we or any of our Operators explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
Our legal basis of Processing:
Under applicable data protection laws, we have to have a legal basis to process your Personal Data. The legal basis which we have outlined in this Kambi Player FPN includes (as relevant):
- Processing that is necessary for our own legitimate interests or those of third parties (including the other companies within Kambi and our Operator clients). These interests are:
- the management and audit of our business operations to ensure that they comply with all applicable laws, and good business practices;
- making assessments on your betting behaviour, which is a fundamental part of the service which we provide to Operators;
- sharing your Personal Data with our service providers, such as:
- IT systems, network providers, data storage and backup providers;
- professional services providers (such as lawyers; accountants, auditors, consultants);
- for analysis and research in connection with improving our approach to risk management and betting analysis, as well as product development;
- fulfilling our contracts with our Operators;
- promoting our products and services;
- compliance with regulatory obligations and best practice guidelines; and/or
- anonymising the data to continue to assess and enhance our services and products.
- Processing that is necessary to comply with a legal obligation – including:
- to process any data subject rights requests in accordance with data protection laws;
- for compliance with legal and regulatory requirements (such as gambling regulations); and/or
- for activities relating to the prevention, detection and investigation of crime including fraud.
Who we may disclose your Personal Data to:
As outlined earlier in this Kambi Player FPN, Kambi will disclose to, or share your Personal Data with, the Operator you have an account with as part of the service we provide to them. We share reports and results of risk assessments we have conducted on you with our Operators. We will liaise with them where we need to limit your betting or make a decision on your account. We may also disclose your information to an Operator in connection with a data subject rights request (please see below for further information).
We act separately from Operators with respect to many of our processing activities where we act as a sole controller. We do however act as a joint controller with Operators for the purposes of determining your risk profile, revising your betting limit up or down and determining what risk parameters should be taken into account for the purposes of risk management. We have arrangements in place with our Operators to cooperate with respect to requests in connection with data subject rights in circumstances where we act together as joint controller.
Kambi will also disclose your Personal Data to law enforcement agencies, regulators, and other authorities with jurisdiction over us (or members of the Kambi group) if we have a legal obligation to do so, or it is in our legitimate interest, or is in the substantial public interest to do so. This includes exchanging information with government departments or gambling authorities.
We will also share your Personal Data, where it is lawful to do so, with:
- group companies, including the entities referred to in the "Contact Us" section below;
- third parties in the event of a corporate or other transaction involving the sale or transfer of all or part of Kambi, or as otherwise required for any restructuring of Kambi;
- third party service providers, such as IT systems, network and back-up and storage providers;
- professional advisors, such as lawyers, accountants, auditors and/or consultants.
If you require further information about the above recipients of your Personal Data, please contact us using the contact information provided below.
How long your Personal Data is stored for:
Kambi will retain your Personal Data for as long as it is necessary to fulfil the purposes for which it was collected, particularly the provision of our services to an Operator.
As such, your Personal Data shall be retained for the duration of our contract with an Operator. After such time, we will only hold the information for so long as it is necessary for us to comply with our own legal obligations, or as may be otherwise necessary for our legitimate interests. Where we are advised by an Operator that you have closed your account, or following termination of our agreement with an Operator, we will either anonymise your Personal Data, or we will ensure that it is deleted in accordance with our records retention practices and procedures. If you would like further information about the time period for retention, please contact us using the contact information provided below.
As noted above, Kambi generally uses a pseudonymised ID, rather than your real name or contact details, to identify you. If you cease to be a player for an Operator, or if an Operator ceases to use our services, we may anonymise the personal information that we hold such that you can no longer be identified, and the information can then be used, in anonymous format, for analysis purposes.
Keeping your data secure:
Kambi is committed to and maintains a high level of security to protect data, including Personal Data. Kambi has taken, and will continue to take reasonable steps to keep our data and Personal Data secure and free from unauthorised access by use of technology and internal systems which will be updated as new technology becomes available and is appropriate to our systems.
This also includes ensuring that any service providers that we use, and who assist us to provide our services are also equally obliged to implement and maintain high standards of security to protect Personal Data. These standards are embedded in our contracts with our service providers.
What are your rights?
Your rights are as follows:
- the right to be informed about the Processing of your Personal Data;
- the right to have your Personal Data corrected if it is inaccurate and to have incomplete Personal Data completed;
- the right to object to Processing of your Personal Data;
- the right to restrict Processing of your Personal Data;
- the right to have your Personal Data erased (the “right to be forgotten”); and
- the right to request access to your Personal Data and to obtain information about how we Process it (the "right of access").
Please note that some of the above rights are qualified, so they will not be applicable in all circumstances.
Additionally, we are not required to provide you with a copy of your Personal Data undergoing processing (under your right of access) if it will adversely affect the rights and freedoms of others, including our own. We therefore will not provide you with a copy of your Personal Data where doing so would be likely to: (a) result in the disclosure of trade secrets or intellectual property; (b) cause us to be in breach of applicable laws and regulations; or (c) result in the disclosure of information about another data subject that we do not have the right to disclose to you. In particular, we strictly guard our risk management strategies and procedures as trade secrets and we therefore will not provide a copy of your Personal Data to the extent that it would or would be likely to reveal our risk management strategies or procedures. This may include certain procedures with respect to your risk profiling. Where we process a large quantity of information concerning you, we may also request that you specify the information or processing activities to which the request relates before we deliver the information to you.
Please note that we do not undertake decision making based solely on automated processing which produces legal effects concerning players or similarly significantly affect them. We do however undertake profiling. To safeguard players' rights and interests, we allow players to contest decisions that we make about risk profiling or to object to our use of profiling. If you object to our use of profiling and we are required by law to cease profiling as a result, then our Operators may not be able to continue allowing you to place bets using our services.
We are also not required to offer you the right to move, copy or transfer your Personal Data (“Data Portability”) as a result of our legal basis of processing.
Transfers outside of the EEA:
Yes, as a provider of a global sports betting platform, your Personal Data will be transferred outside of the European Economic Area (EEA). We have to do this in order to provide our services to Operators, and you, regardless of the time of day when a bet is placed. In particular, your Personal Data will be transferred to:
- the Philippines;
- the United States.
Accordingly we will ensure that appropriate safeguards are in place to protect that transfer, such as contractual obligations being imposed on the recipients of your Personal Data. Those obligations require the recipient to protect your Personal Data to the standard required in the EEA. In some cases where you are dealing with one of our Operators based outside of the EEA, we may transfer your data to that Operator as necessary in order to perform our contractual obligations to that Operator and for your benefit. You should consult the privacy notices or information provided by your Operator to review what safeguards they offer for the protection of your Personal Data.
Cookies and similar tracking technology
The following Kambi entities are controllers for the purposes of this Kambi Player FPN:
- Kambi Group plc (incorporated in Malta)
- Kambi Sports Solutions (Alderney) Limited (incorporated in Alderney)
- Kambi Malta Limited (incorporated in Malta)
- Kambi Spain plc (incorporated in Malta)
- Sports Information Services Limited (incorporated in Malta)
- Kambi Philippines Inc (incorporated in the Philippines)
- Sports Analytics Services SRL (incorporated in Romania)
- Kambi Australia Pty Ltd (incorporated in Australia)
- Kambi Sweden AB (incorporated in Sweden)
- Kambi Services Limited (incorporated in the United Kingdom)
- Kambi USA Inc. (incorporated in the United States)
Kambi also acts as joint controller with each Operator with respect to changes to each player's sports risk segment. The essence of the arrangement with each Operator is as described in this Kambi Player FPN.
In relation to Kambi’s operations within the European Union, you have the right to complain to the local Data Protection regulator, applicable to the relevant Kambi Entity which is processing your Personal Data. The UK Information Commissioner's Office is Kambi's lead supervisory authority for the purposes of data protection laws in the European Union. Further information about the UK Information's Commissioner's Office is available at www.ico.org.uk. (Contact details for other data protection authorities in the European Economic Area are available here.)
Kambi Malta Limited shall be designated as a European Union representative on behalf of Kambi Sports Solutions (Alderney) Limited, Kambi Philippines Inc, Kambi Australia Pty Ltd and Kambi USA Inc.
Updates to this Kambi Player FPN
We may update this Kambi Player FPN from time to time in response to changing legal, technical or business developments. You can see when this Kambi Player FPN was last updated by checking the “last updated” date displayed at the bottom of this Kambi Player FPN.
Last updated: 10 July 2020