Privacy Policy

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit or use betplays-play.ca and related review pages operated under the project name Bet Plays (the "Service"). It applies to visitors, registered players, and anyone who interacts with our platforms, regardless of whether they complete registration. By using the Service, you agree to the practices described in this Policy. Effective date: 1 January 2026.

Who We Are

The Service operated under the project name Bet Plays for Canadian users is provided by:

• Operator (data controller): Creative Alliance N.V.
• Legal form: Naamloze Vennootschap (N.V.) - public limited company under Curaçao law
• Registered office / legal address: Abraham de Veerstraat 9, Willemstad, Curaçao
• Company registration number: 153106 (Curaçao)
• Gaming licence: 365/JAZ (Sub-licence GLH-OCCHKTW0701272021), issued under Gaming Services Provider N.V., Curaçao
• Primary website for this project: https://betplays-play.ca
• Market note: The Service is offered to Canadian players as an offshore, grey-market casino. It is not regulated or licensed in Ontario and is considered unregulated/illegal for Ontario residents. Nothing in this Privacy Policy should be interpreted as authorizing use of the Service where it is prohibited by law.

Data Protection Contact

Creative Alliance N.V. is responsible for your personal information as data controller for the Service. For privacy-related questions, requests, or complaints, you may contact our data protection contact point (Data Protection Officer / privacy team) using the following channels:

• Postal address (for privacy matters): Data Protection Officer, Creative Alliance N.V., Abraham de Veerstraat 9, Willemstad, Curaçao
• Support email channel: via the support email address and help centre indicated in your account or on betplays-play.ca (please add "ATTN: Data Protection Officer" in the subject line)
• Live chat: live chat support available on the website; request that your query is forwarded to the Data Protection Officer
• Phone: support line at +44 (support number as published on betplays-play.ca) - availability may vary

What Personal Data We Collect

We collect the minimum personal information necessary to operate the Service, meet legal requirements, and improve user experience. The categories include, but are not limited to:

• Identification and account data: full name, username, date of birth, nationality, residential address, email address, phone number, gender (if provided), language and currency preferences, account ID, and verification status.
• KYC/AML documentation: copies and data from government-issued IDs (passport, national ID card, driver's licence), proof of address (utility bill, bank statement), source-of-funds information, and any other documents requested for identity verification, anti-money laundering (AML), and responsible gambling checks.
• Payment and financial data: partial payment card details (card type, masked number, expiry date), e-wallet identifiers, bank account details (where applicable), transaction identifiers, deposit and withdrawal records, chargeback information, and payment verification records. We do not store full raw card data where our payment partners process it directly.
• Technical and usage data: IP address, country and approximate location derived from IP, device identifiers, device type, operating system, browser type and version, language settings, access times, referral URLs, login timestamps, session duration, and server logs.
• Behavioral and gaming data: betting and game history, wins and losses, wager amounts, bonuses used, session length, clicks, visited pages, referral and affiliate information, marketing campaign identifiers, and interaction with in-site messages.
• Communication data: records of communications with customer support (email, live chat, phone logs), complaints, dispute documentation (including submissions to third-party complaint portals such as AskGamblers or Casino Guru if you involve them), and responses provided.
• Marketing and preference data: opt-in/opt-out status for email, SMS, push notifications, and other marketing channels; interests and preferences derived from your use of the Service where permitted by law.
• Cookies and similar technologies: unique identifiers stored through cookies, web beacons, pixels, and similar technologies that track your interaction with the Service for functional, security, analytics, and marketing purposes. For details, see the "Cookies & Tracking Technologies" section below.

Legal Basis for Processing

Because Bet Plays serves users in multiple jurisdictions (including Canada and potentially users in the EU/EEA and Mexico), we rely on several legal grounds for processing personal data. These include:

• Consent:
  • When you register, access the Service, or actively provide information, you give meaningful consent to the collection, use, and disclosure of your personal information as described in this Policy, consistent with Canadian privacy laws (e.g., PIPEDA) and comparable frameworks.
  • We seek separate, explicit consent for certain activities, such as receiving marketing communications, using non-essential cookies, or processing sensitive documents not strictly required for core services.
• Contractual necessity:
  • We process data where necessary to create and manage your account, provide games and related services, process deposits and withdrawals, verify your identity, handle bonuses, and fulfill our contractual obligations to you.
• Compliance with legal and regulatory obligations:
  • To meet KYC/AML requirements, combat fraud, comply with Curaçao licensing rules, respond to lawful requests from authorities, maintain accounting records, and meet applicable tax and reporting obligations.
  • For users in the EU/EEA, we rely on Article 6(1)(c) GDPR for such processing where EU law applies. For users in Mexico, we act under the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) and related regulations where applicable.
• Legitimate interests:
  • To prevent fraud and abuse, secure our systems, monitor for suspicious activity, and protect the integrity of games.
  • To improve our services, perform analytics, personalize content, and understand how users use betplays-play.ca.
  • To defend or exercise legal claims and manage business operations (for example, dealing with disputes via third-party platforms like AskGamblers or Casino Guru when you choose to involve them).
  • Where required by GDPR, we balance these interests against your fundamental rights and freedoms and apply additional safeguards if you are in the EU/EEA.

Purpose of Processing

We use your personal information only for specified, explicit, and legitimate purposes and do not process it in ways incompatible with those purposes. In particular, we use data to:

• Provide and operate the Service:
  • Create and manage your account, provide access to games, enable deposits and withdrawals, process bets and payouts, manage promotions and loyalty programs, and deliver customer support.
• Verify identity and ensure legal compliance:
  • Perform KYC/AML checks, age and location verification, responsible gambling assessments, and compliance monitoring pursuant to Curaçao licensing conditions and applicable laws.
• Improve and personalize the Service:
  • Analyze gameplay and interaction data to improve usability, performance, game selection, and site design; personalize content, recommendations, and offers within legal limits.
• Marketing and communications:
  • Send service messages related to your account, security, or changes to our terms and policies.
  • With your consent where required, send promotional messages (email, SMS, push, on-site) and tailor marketing campaigns, including via affiliates.
• Security and fraud prevention:
  • Detect and prevent fraudulent activity, bonus abuse, account takeover, money laundering, and other illegal or suspicious behaviour.
  • Maintain logs and technical safeguards to protect our systems and your data.
• Analytics and reporting:
  • Produce aggregated statistics and reports for internal management, business planning, regulatory reporting, and compliance with licensing requirements.
• Dispute resolution and legal claims:
  • Investigate and resolve complaints, including those submitted via independent complaint portals; respond to requests from regulators and law enforcement; enforce our terms; and defend against legal claims.

Disclosure & Sharing

We do not sell your personal information. We may disclose personal data to carefully selected third parties only when necessary and subject to appropriate safeguards:

• Group and operational partners:
  • Entities involved in operating the Bet Plays brand and betplays-play.ca, strictly for purposes described in this Policy.
• Payment service providers and banks:
  • To process deposits, withdrawals, and refunds; to perform payment verification and fraud checks; and to comply with AML and chargeback procedures.
• Identity verification, AML, and risk management providers:
  • Third-party KYC vendors, fraud detection tools, geolocation providers, and sanctions screening services that help us verify your identity, prevent fraud, and comply with regulatory obligations.
• Technology and infrastructure providers:
  • Hosting providers, content delivery networks, security and monitoring services, analytics providers, and customer support platforms that enable the technical functioning of the Service.
• Marketing and affiliate partners:
  • Advertising networks, affiliate partners, and campaign tracking tools, but only as necessary to run, measure, and optimize marketing campaigns, and in accordance with your consent and cookie settings where required by law.
• Regulators and public authorities:
  • Curaçao gaming and supervisory authorities, tax authorities, courts, law enforcement, and other governmental bodies when we are legally required to do so or when permitted to protect our legitimate interests or the rights of others.
• Dispute resolution and complaints platforms:
  • Independent complaints platforms (such as AskGamblers or Casino Guru) and any alternative dispute resolution bodies you choose to involve, but only where you initiate such a complaint or authorize us to share relevant information to handle your case.
• Professional advisers and business transferees:
  • Lawyers, auditors, consultants, and similar professionals under confidentiality obligations.
  • In case of a merger, acquisition, restructuring, or asset sale, personal data may be transferred to the relevant successor entity subject to this Policy or a substantially similar policy.

Whenever we share personal information with third parties, we require them to process it only on our instructions, to maintain confidentiality, and to implement appropriate security measures.

International Transfers

Because Creative Alliance N.V. is based in Curaçao and relies on global service providers, your personal information may be transferred to and processed in countries other than the one where you reside, including:

• Curaçao (primary location of the operator and some systems);
• Canada (for users located in Canada and certain service providers);
• Member States of the European Economic Area (EEA) and the United Kingdom;
• The United States and other countries where our or our partners' servers and support teams may be located.

These countries may have data protection laws that differ from those in your jurisdiction and that may not be considered as providing an equivalent level of protection. When we transfer personal data internationally, we implement appropriate safeguards, such as:

• Contractual protections based on standard contractual clauses or similar data transfer agreements approved or recognized by relevant regulators (for example, by the European Commission for EU personal data);
• Technical safeguards, including strong encryption, access controls, and minimization of data shared with any given provider;
• Organizational controls, including strict internal policies, access limitation on a "need-to-know" basis, and vendor due diligence procedures.

Where local laws (for example, the GDPR in the EU/EEA or Mexican data protection law) impose specific requirements for cross-border transfers, we will comply with those requirements to the extent they apply to our processing of your data.

Data Retention

We keep personal information only for as long as necessary to fulfill the purposes described in this Policy, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements. Typical retention periods include:

• Account and identification data: stored for the lifetime of your account and normally up to 5 years after account closure, subject to longer retention where required by AML, tax, or regulatory rules.
• KYC/AML documentation: retained for at least 5 years after the end of the business relationship or last transaction, or longer if required by applicable AML or licensing regulations.
• Payment and transaction data: kept for at least 5 - 7 years to satisfy accounting, auditing, and anti-fraud requirements and to handle potential disputes.
• Gaming and behavioural data: maintained for the account lifetime and for a period (typically 3 - 5 years) after closure for responsible gambling analysis, fraud prevention, and regulatory record-keeping.
• Marketing and preference data: retained while you maintain your account or until you withdraw consent or object to processing; certain records of your opt-out request may be kept longer to ensure we respect your preferences.
• Technical logs and security data: stored for a shorter period (often 6 - 24 months) unless needed longer in relation to security incidents, investigations, or legal claims.
• Complaint and dispute records: retained as long as reasonably necessary to manage and document the resolution of the dispute and comply with applicable limitation periods.

When personal information is no longer required for any legitimate purpose, we will delete it, anonymize it, or, if deletion is not technically feasible, securely store and isolate it from further processing until deletion is possible.

Your Rights

We aim to respect and support your privacy rights under applicable laws, including Canadian privacy legislation (such as PIPEDA and substantially similar provincial laws), the EU General Data Protection Regulation (GDPR) where it applies, and Mexican data protection regulations (including the Federal Law on Protection of Personal Data Held by Private Parties - LFPDPPP) for users located in Mexico.

Available Rights

• Right of access: You may request confirmation of whether we hold personal data about you and obtain a copy of such data, together with information about how we process it.
• Right to rectification (correction): You may ask us to correct inaccurate or incomplete personal information. In many cases you can update certain details directly in your account profile.
• Right to erasure ("right to be forgotten"): In certain circumstances (for example, where data is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis), you may request deletion of your personal data. We may need to retain some information where required by AML, tax, or other legal obligations.
• Right to restrict processing: You may request that we restrict processing of your data (e.g., while we verify its accuracy or assess an objection) so that it is stored but not actively used.
• Right to object: Where we process your data based on legitimate interests or for direct marketing, you may object at any time. We will cease such processing unless we demonstrate overriding legitimate grounds or where processing is necessary for legal claims.
• Right to data portability: Where applicable (for example, under GDPR for processing based on consent or contract and carried out by automated means), you may request that we provide your personal data in a structured, commonly used, machine-readable format or transfer it to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications or certain optional features), you may withdraw that consent at any time through your account settings, unsubscribe links, or by contacting us. This will not affect the lawfulness of processing prior to withdrawal.
• Rights under Mexican law: If you are in Mexico, you may have ARCO rights (Access, Rectification, Cancellation, and Opposition) under LFPDPPP, which correspond closely to the rights described above. We will handle such requests in accordance with that law where it applies.

How to Exercise Your Rights

1. Submit your request: Contact us via the support email channel or live chat indicated on betplays-play.ca, or write to the postal address of the Data Protection Officer. Please clearly state that your request concerns privacy rights and indicate your country of residence.
2. Identity verification: To protect your data, we may ask for information or documentation to verify your identity (for example, by confirming certain account details or asking for additional KYC proof where necessary).
3. Assessment and response: We will review your request and respond within 30 days of receipt, or within any shorter period required by applicable law. In complex cases or when we receive multiple requests, this period may be extended in line with applicable legislation, in which case we will inform you of the extension and reasons.
4. Cost: We do not charge fees for handling reasonable, good faith requests. We may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, in accordance with applicable law.

If we cannot fully comply with your request (for example, because of legal retention obligations), we will explain the reasons and indicate what options remain available to you, including your right to complain to a supervisory authority.

Cookies & Tracking Technologies

We use cookies and similar technologies on betplays-play.ca and associated Bet Plays pages to ensure proper functioning of the Service, improve performance, and support marketing where allowed by law.

Types of Cookies

• Session cookies: Temporary cookies that exist only during your browser session and are deleted when you close your browser. They are used for core functions such as maintaining your login session and applying security checks.
• Persistent cookies: Cookies that remain on your device for a defined period or until you delete them. They help remember your preferences (e.g., language, saved logins where permitted) and allow us to measure site usage over time.
• First-party cookies: Cookies placed by betplays-play.ca to operate and improve the Service.
• Third-party cookies: Cookies set by external providers (such as analytics services, advertising networks, and affiliate tracking partners) to support analytics, campaign management, and, where applicable, personalized advertising.

Purposes of Cookies

• Strictly necessary / functional: Required for the site to function correctly, including authentication, security, load balancing, and keeping track of your session. These cannot normally be disabled without affecting the Service.
• Performance and analytics: To gather aggregated statistics on how users interact with the site (e.g., pages visited, time spent, error messages) so we can improve performance, usability, and game offerings.
• Personalization: To remember your choices and preferences, such as language, region, and certain gameplay settings, allowing for a more tailored experience.
• Advertising and affiliate tracking: To measure the effectiveness of marketing campaigns, prevent fraudulent affiliate activity, and - where permitted - deliver or optimize promotional content on our site or on third-party sites.

Managing Cookies

• You can manage or disable cookies via your browser settings. Most browsers allow you to refuse all cookies, accept only certain types, or delete existing cookies. Please note that blocking certain cookies may affect the functionality or availability of parts of the Service.
• Where available, we may provide an in-site cookie or privacy settings panel allowing you to adjust your preferences for non-essential cookies (such as analytics or advertising cookies).
• Opting out of cookies does not necessarily mean you will see no advertising; it means that ads may be less relevant to your interests.

Data Security

We implement technical and organizational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. While no system can guarantee absolute security, we maintain controls consistent with industry best practices and proportional to the risks involved.

• Encryption in transit and at rest: Data transmissions between your browser and our servers are protected using TLS 1.2+ or equivalent encryption. Where feasible, sensitive data and backups are encrypted at rest using strong cryptographic standards.
• Access control and authentication: Access to personal data is restricted to authorized staff and service providers who require such access to perform their duties. We use role-based access controls, secure authentication mechanisms, and logging of administrative actions.
• Account security features: We encourage the use of strong, unique passwords and may provide or require additional security measures (such as multi-factor authentication) where appropriate. We may lock or restrict accounts in case of suspected compromise.
• Network and infrastructure security: Our systems are protected by firewalls, intrusion detection/prevention tools, anti-malware solutions, and regular security monitoring. We apply security patches and updates as appropriate.
• Risk management and audits: We periodically review our security controls, perform internal risk assessments, and may commission external tests or audits to evaluate the effectiveness of our safeguards, taking into account recognized frameworks such as ISO 27001 and SOC 2 as reference points (without implying formal certification unless explicitly stated on the site).
• Staff training and confidentiality: Employees and contractors with access to personal data are trained on data protection and security obligations and are bound by confidentiality commitments.
• Incident response: We maintain procedures for identifying, investigating, and responding to potential data breaches. Where required by law, we will notify affected individuals and relevant authorities of significant data breaches as soon as reasonably practicable.

Complaints & Contacts

If you have questions, concerns, or complaints about how we handle your personal information, or if you wish to exercise your privacy rights, you can contact us using the channels below.

How to Contact Us

• Data Protection Officer / Privacy team (primary contact):
  • Postal address: Data Protection Officer, Creative Alliance N.V., Abraham de Veerstraat 9, Willemstad, Curaçao
  • Online: via the support email and help centre indicated on betplays-play.ca, or via live chat (please clearly label your message as a "Privacy / Data Protection" request)
  • Phone: support line at +44 (support number as published on the website), during published support hours

Complaint Handling Procedure

1. Initial contact: Submit your concern or complaint using one of the channels above, including all relevant details (account ID, dates, screenshots, and a description of the issue).
2. Acknowledgment: We will normally acknowledge receipt of your complaint within 7 business days and provide a reference number where applicable.
3. Investigation: We will review your complaint, gather additional information if needed, and may contact you for clarification. We aim to provide a substantive response within 30 days, or within any shorter period required by applicable law.
4. Outcome: We will inform you in writing of our findings, any corrective measures taken, and options available if you remain dissatisfied.

Escalation to Supervisory Authorities

If you are not satisfied with our response or believe that your privacy rights have been infringed, you may have the right to lodge a complaint with a data protection authority in your jurisdiction. Examples include:

• Canada - Office of the Privacy Commissioner of Canada (OPC):
  • Website: https://www.priv.gc.ca/
  • Contact details: https://www.priv.gc.ca/en/contact-the-opc/
• Mexico - National Institute for Transparency, Access to Information and Personal Data Protection (INAI):
  • Website: https://www.inai.org.mx/
• European Union / EEA - Data Protection Authorities:
  • If GDPR applies to you (for example, you are in the EU/EEA), you may contact your local data protection authority. A list is available via the European Data Protection Board: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

You may also continue to use independent complaints channels (such as AskGamblers or Casino Guru) for gambling-related disputes; however, these are not substitutes for formal data protection authorities when the subject matter concerns your privacy rights.

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the functionalities of betplays-play.ca and associated Bet Plays pages.

• Notification of changes:
  • For material changes (for example, new categories of data collected, new purposes of processing, or significant changes to user rights), we will provide advance notice by:
    • Posting a prominent notice on the website (banner or pop-up);
    • Sending an email notification to the address associated with your account, where available; and/or
    • Displaying alerts in your account dashboard.
• Advance notice period:
  • For significant changes that materially affect how we process your personal information, we will endeavour to provide at least 30 days' notice before the revised Policy becomes effective, unless a shorter period is required or permitted by law (for example, where changes are mandated by urgent legal or security requirements).
• Your options:
  • If you do not agree with the updated Policy, you may close your account and stop using the Service before the changes come into effect. Continued use of the Service after the effective date of an updated Policy will constitute acceptance of the changes, to the extent permitted by law.
• Version control:
  • The current applicable version of this Privacy Policy will always be available on betplays-play.ca.
  • Last updated: January 2026.