Palsar Capital Limited, henceforth referred to as “We” “Our” “Us” provides an affiliate programme to promote our clients on whose behalf We administer and manage the affiliate program. In this policy “affiliate” “you” and “your” refers to the individual entity that has agreed to promote the brands we provide marketing services for, in accordance with this Privacy Policy.
This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.
This privacy policy should be read in conjunction with the Affiliate Programmes Terms and Conditions. By entering into any kind of contract with Palsar Capital Limited, you agree to the contents of this privacy policy. If you do not agree with any section of this privacy policy, you should not attempt to use our service.
The Data Controller is Palsar Capital Limited t/a Raven of Glassworks, 1 Back Turner Street, Manchester, M4 1FR
All queries in regards to this privacy policy should be addressed to the Data Protection Officer at the above address, who can also be contacted directly at compliance@raventrack.com
We collect and process the following data from (and about) you:
We implement effective processes to identify, manage, monitor and report risks and internal control mechanisms. These controls include secure systems and networks, and clear processes for privilege access rights. All data is stored securely.
Our lawful basis for processing personal data include:
We may disclose your personal data to:
All processing of information will be governed by the appropriate data protection laws.
We will not send promotional or direct marketing, inclusive of email, SMS, or automated calls, without first obtaining your specific consent.
The consent requires a positive Opt-In either in electronic format, verbally or in writing. The consent will be clear and specific, granular, separate from other Terms and Conditions, name any third parties relying on the consent, and be easily withdrawable.
We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:
You may request that your Personal Data be anonymised in the following circumstances:
We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.
You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. If you wish to receive a copy of this information, please contact your account manager, or the DPO directly, and allow up to thirty calendar days for the information to be collated and provided to you. Please note that your identity will need to be confirmed in order to complete a SAR, which may include the disclosure of other personally identifiable documentation in order to prove your identity (such as a passport scan, or valid proof of address) before commencing with the process.
By using the Raven website, you consent to our use of ‘cookies’. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. We use cookies and the information gained from them to analyse site usage, with this information used accordingly to improve our content and site layout and to remember your onsite preferences.
If you prefer, you can disable cookies in your web browser. The ‘help’ menu on the menu bar of most browsers will have a functionality to disable cookies.
Palsar Capital Limited do not use any automated systems in order to make decisions regarding your account which have any legal effect on You.
Please let us know if you are unhappy with how we have used your personal information in writing to the Data Protection Officer, who will be able to assist further with your complaint or concern. You also have the right to complain to the Information Commissioner’s Office.
This Privacy Policy is kept under continued review by Palsar Capital Limited and can be amended by Us at any time, and without notice to you. Whenever a change is made to the privacy policy which will affect your rights as a data subject, or change the intended processing purposes, then you will be notified directly and asked to agree to the new privacy policy. If you disagree with the changes made to the privacy policy, you retain the right to withdraw consent for future processing, as stated in the introduction to this policy.
This version of the Privacy Policy is effective as of September 20th 2018.
CUSTOMER PRIVACY NOTICE – BOLABET (Company Limited), (Zimbabwe (Private) Limited), (Limited).
1. Purpose of This Privacy Notice
Bolabet (Bolabet Company Limited), (Bolabet Zimbabwe (Private) Limited), (Bolabet Limited). (hereinafter referred to as "Bolabet," "we," "our," or "us") is dedicated to protecting and respecting your privacy. This Privacy Policy details how we collect, use, disclose, and safeguard your information when you visit our website www.bolabet.co.zm, www.bolabet.co.zw, www.bolabet.mw or use our services.
This privacy notice explains how we collect, use, and process your personal information through your use of this website, including any information you may provide when registering a Bolabet account. We ensure that the personal information we collect from you is protected and processed carefully and responsibly.
It is important that you read this privacy notice in conjunction with any other privacy notices we may provide on specific occasions when we are collecting or processing personal information about you, so you are fully aware of how and why we are using your information. This privacy notice supplements other notices and privacy policies and does not override them.
2. Who It Applies To
This notice applies to all customers of (Bolabet Company Limited), (Bolabet Zimbabwe (Private) Limited), (Bolabet Limited) and its related entities. We may need to update this privacy notice periodically and encourage you to check it regularly, so you remain informed about how we process and protect your personal information.
If you have any questions about this notice, please email us at support@bolabet.co.zm, support@bolabet.co.zw, support@bolabet.mw.
3. What Personal Information We Collect and Generate
Personal information means any information about a natural or legal person from which that person can be identified. It does not include information where the identity has been removed (anonymous information).
We collect the personal information required to register you as a customer and to communicate with you.
The information we collect includes:
Contact information: title, name, address, email address, mobile number
Gender
Identity document
Proof of address
Source of income
Banking details
Photographs and other visual images
Occupation and IP address
We generate information about you in the form of:
Betting records
Records of payments and withdrawals
Customer profiles
We may collect and process the following data about you:
Information You Provide
Information you forward through the website or email
A record of communications via the website, email, telephone, or other means
Your responses to surveys
Details provided during Account Registration, including your name, address, email address, place of residence, gender, phone number, and identification information, all in accordance with applicable regulations.
Automatically Collected Information:
Details about your visit to our website, such as your domain and host, IP address, browser, operating system, the date and time of access, the URL of the site through which you reached our website, location information, weblogs, and other communication data.
Information about your activities related to the use of our products.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric information).
4. When and Why We Collect and Process Your Personal Information
We process your personal information to meet our contractual obligations with you, as well as collect and use your personal information for the following purposes:
Allow you to register an account with us.
Process your bet when you submit a betting transaction offer.
Notify you of the outcome of your bet.
Process a payment you made or request a withdrawal from your account.
Reply when you contact us for support.
Investigate and resolve your query, complaint, or request.
Administer a promotional competition you may have entered and deliver your prize if you win.
Open, conduct, and manage your online account.
Verify information to maintain account continuity.
Comply with legal obligations, including those aimed at preventing money laundering.
Create a personal profile.
Conduct tests, surveys, and analyses.
Share information about promotional offers and our products/services.
Monitor transactions to prevent irregular betting, money laundering, and cheating.
Provide and improve our products and services.
Store your personal settings and preferences.
Assess the effectiveness of our promotional campaigns.
Determine the source from which you access our site.
Determine the source from which you access our site. Enhance the website and improve the customer experience and business management.
In some instances, we process your personal information because it is in our or your legitimate interest to do so. For example:
We may monitor our premises with CCTV cameras to ensure your and our safety.
We are legally required to collect and process certain information, including:
To identify and validate our customers and for purposes related to the prevention of financial crime, including sanctions screening, monitoring of anti-money laundering and financing of terrorist activities.
To report suspicious activity on your account to the relevant authorities.
To report to other governmental agencies, for example, the Zambia Revenue Authority.
When you register an account at Bolabet, you can choose if you want to receive promotional material from us. We may send you information about our services, products, and promotional activities via the communication channels you selected. You can unsubscribe at any time by following the unsubscribe link or by contacting us at support@bolabet.co.zm, support@bolabet.co.zw or support@bolabet.mw.
5. Children’s Information
You must be 18 years or older to use our services. When you register for an account, we will ask you to confirm that you are 18 or older. We do not knowingly collect the personal information of persons under 18 years of age.
6. We Only Share Your Information with Others We Trust
We only use service providers we trust and who have agreed to keep your personal information secure and confidential and to use it only for the purposes for which we shared it with them. We use service providers to assist with the following:
Communicate with you
Verify your identity
Verify your address
Monitor the effectiveness of our services
Store information
Manage our business, for instance, accountants and professional advisors
Provide IT services and infrastructure
Some of the service providers we use may be located in other countries. These countries may not have the same levels of protection of personal information as Zambia, Zimbabwe and Malawi in which case the foreign service providers must undertake to protect the personal information of our customers to the same level that we do. We provide for appropriate safeguards by means of contracts between us and our foreign service providers. By using our website, you agree to not being notified of details regarding the level of protection afforded to your information in the relevant country/countries.
We may be required to share your personal information with regulatory and law enforcement bodies. We may share your information with:
Regulators and Authorities: The collected data will be made available to regulators, sports, and other competent authorities, including the police, to conduct investigations related to fraud, money laundering, or issues with the integrity of the sport and to comply with legal obligations.
Service Providers and Partners: For service improvement and operational purposes.
Legal Requirements: If ordered by governing authorities or in the context of judicial proceedings, as required by law.
Our website may contain links to and from partner networks or advertisers. These sites have their own privacy policies, and we do not accept any responsibility for them. Please review their policies before submitting any personal data.
7. Use of Your Personal Information When Entering Promotional Competitions
In the event you enter any of our promotional competitions, we will collect and process your personal information for the purposes of the competition. This will include communication from us and our partners in relation to the competition.
As required by the Competition and Consumer Protection Act, details of prize winners in any promotional competition held may be published on our various social media platforms, such as Facebook, Twitter, and Instagram. This will usually be your name and surname, but we will obtain your specific and informed consent in this case. On certain occasions, we may publish photographs of winners, but we will obtain your specific and informed consent.
You have the right to request that your personal information not be published on any of the social media platforms by sending an email to support@bolabet.co.zm, support@bolabet.co.zw or support@bolabet.mw.
8. Reasonable Steps Taken to Safeguard Your Personal Information
We take reasonable steps to protect your personal information against:
Loss
Interference
Unauthorised access
Use
Modification
Disclosure
Other misuse
These steps include password protection for electronic files, securing paper files, and physical access restrictions. We will continuously review our security controls and processes to ensure that security risks are identified and addressed.
If a data breach occurs, we will take the necessary steps to minimise the threat to your privacy and inform you if your personal information has been compromised. We will also let you know how you can help minimise the impact of a breach.
We implement appropriate technical and organisational measures to protect your data. However, no method of transmission over the internet or electronic storage is 100% secure.
9. We Do Not Keep Your Personal Information Longer Than We Need To
We will not keep your personal information longer than necessary unless legally required to do so. We consider legal requirements, contractual obligations, and the expectations and requirements of our customers when determining how long to retain information. When we no longer need your personal information, we will securely delete or destroy it in line with the Data Protection Act requirements.
10. Changes to the Privacy Notice and Your Duty to Inform Us of Changes
We keep our privacy notice under regular review and therefore encourage you to check it regularly, so you remain up to date on how we process and protect your personal information.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
You have the right to withdraw your consent to the processing of your personal data at any time by submitting a request with proof of identity to support@bolabet.co.zm, support@bolabet.co.zw, or support@bolabet.mw. Upon withdrawal, we will stop using your information unless required by law. Customer history records will be maintained in accordance with our privacy data retention policy. After the specified period, your information will be permanently removed.
11. If You Fail to Provide Personal Information
Where we need to collect personal information by law or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to allow you to place a bet). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
12. Cookies
Our website uses cookies, which are small text files transferred from your browser to your computer’s hard drive to store information about your activity on the browser. These cookies ensure a better customer experience when you browse our website and do not collect personal information, hence they are unable to identify you. These are uniquely assigned to you and may be shared with selected partners, in and out of Zambia, Zimbabwe and Malawi, to deliver interest-based ad placements through their digital display networks. You may refuse to accept cookies by changing your browser settings or deleting cookies already stored on your computer. Further information about cookies and how to delete them from your browser can be found at: www.allaboutcookies.org
Bolabet, our service providers, and advertising partners use cookies and tracking technologies to analyse the use of our online services, personalise your experience, and advertising. We are committed to using these technologies transparently and in accordance with your privacy.
Purposes of Cookies:
Keeping you signed in across devices.
Delivering advertising with your consent, including online behavioural advertising.
Determining the effectiveness of our marketing activities.
Enhancing website functionality and security.
Remembering your preferences and settings.
Understanding website usage to improve services.
You can change your Bolabet cookie settings at any time.
13. Access and Correction of Personal Information
You have the right to:
Be notified that your personal information is being collected;
Be notified of security compromises where reasonable grounds exist for us to believe that your personal information has been accessed or acquired by an unauthorised person;
Ask us what we know about you and request access to such information;
Ask what personal information was sent to our service providers or any other third party;
Ask us to update, correct, or delete any out-of-date or incorrect personal information we hold about you; where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
Unsubscribe from any direct marketing communications we may send you and object to the processing of your personal information;
Request us to delete or remove your personal information where there is no good reason for us to continue processing it, although this will be subject to Bolabet requiring the information for legal and legitimate reasons;
Request restrictions on the processing of your personal information;
Withdraw your consent at any time where we are relying on consent to process your personal information;
Submit a complaint to the Information Regulator.
You can request the correction or erasure of your personal data by submitting a request with proof of identity to support@bolabet.co.zm, support@bolabet.co.zw or support@bolabet.mw.
14. Contact Us
For any questions regarding this Privacy Policy or our data practices, please contact us at support@bolabet.co.zm, support@bolabet.co.zw or support@bolabet.mw.