Privacy Policy

1. Introduction

Otis Media Europe Kft, the operator of TopBets Kenya (“we,” “us,” or “TopBets”), is committed to protecting the privacy of users of our website topbets.co.ke and other online services (collectively, our “Services”). This Privacy Notice explains why we collect information concerning the users of our platforms (each a “user,” “you,” or “your”), what type of information we collect, and how we use that information. This Privacy Notice applies to any such information collected via any platform which displays it (or a link to it).

By using our Services, you are accepting the practices described in our Privacy Policy, including our use of cookies, web beacons, and similar online tools. If you do not agree to the terms of this Privacy Policy, please do not use our Services. We reserve the right to modify or amend the terms of our privacy policy from time to time without notice. Your continued use of our Services following the posting of changes to these terms will mean you accept those changes.

Please note that our Services are under constant development. This Privacy Policy may therefore be modified and updated on an ongoing basis. Please check back to this page regularly.

This notice has been last updated in May 2024.

2. What Data We Collect

When a user interacts with any of the platforms, we may collect certain data about that user. This data falls into two broad categories: (i) data about a user themselves, which the user gives us; and (ii) data about the user, or the way a user interacts with the platforms or Services, which is collected by us electronically (collectively “User Information”).

2A. Information You Provide to Us

There are a number of circumstances in which you may be required or invited to supply us with personal information, such as when you: subscribe to our newsletters and other content; create a login or register for any of our Services; create a profile; use an interactive feature; interact with our bots or other interactive content; submit content or post a comment; or send us an email, pitch, or request for information.

2B. Your Use of Services and Interaction with the Platforms

We collect the following User Information in accordance with applicable law:

• Information that users provide to us, directly or via a third-party registration service for the purpose of registering with us or our group companies;
• A user’s entry details for a competition or promotion;
• Information users provide to us when users interact with our customer service team;
• Information users provide when users participate in our surveys or marketing promotions;
• Information from a user’s social media profile to populate their profile on our platforms, and where the user chooses to register with us using their social media login(s);
• Information users provide relating to reviews or ratings, favourite sports, tournaments, teams, events or personalities, and/or other subjects of interest to sports fans;
• Information about user interactions with our platforms, and any direct communications the user receives from us (such as emails);
• Device IDs or unique identifiers, location data, device and software characteristics (such as type and configuration), connection information, statistics on page views, referral URLs, ad data, website and app navigation, IP address and standard web log information;
• The language choices made by users in relation to their use of the Service, which may include information relating to their location when using the Service;
• The details of any third-party digital property (such as a website) that referred or linked a user to the platforms, together with information about how a user interacted with any online and email marketing campaigns related to the Service;
• Information and communications on forums on the platforms, including chat rooms and message boards; and
• Information about how users behave on our platforms (such as the type of content they view, how frequently, at what times, etc.).

We may also collect personal information from:

• A variety of third-party sources: These include social networks (subject to the user’s privacy settings and the privacy policy of the social network, and adopting a “two-click” solution where required), service providers which allow us to verify, enhance or supplement the User Information collected on our platforms, and business partners to whom we are offering a service.
• Publicly or commercially available sources: Certain third parties make available
• Information from our affiliates: We may receive information from within our family of affiliated businesses.

3. How & Why We Use the Data We Collect

We use the User Information for three main purposes: (i) to operate and improve the platforms and to ensure that we can provide the Services; (ii) to optimize the content on the platforms and enhance your experience of the Services; and (iii) send marketing and show advertising to our users.

More specifically, we will use the User Information to do one or more of the following things:

• Administer our platforms;
• Provide the Service requested by the user;
• Improve the browsing experience by personalizing the Service to the user;
• Recommend goods, services or promotions which may be of interest to the user or contact users in order to conduct market research (with the consent of the user, where necessary). For these purposes, we may conduct research on our users’ demographics, interests and behaviour, including performing statistical analysis of our users, their use of the Services, and their purchasing patterns. We do this to optimize and improve the Services, our products, and our operations and we will create a profile about your interests and preferences which will enable us to increase our advertising and communication relevance;
• Prevent, detect and investigate potentially prohibited or illegal activities, including fraud, cheating, and money laundering and enforce our terms;
• To notify users about changes to our Service;
• Send out email alerts, text message notifications or device notifications in relation to our Service;
• Send users prizes won via the platforms, and supply services purchased via our platforms;
• Send notices and invoices to users, and collect payments from them;
• Provide third parties with statistical and other information about our users as required to operate the platforms or Services;
• Deal with enquiries and complaints;
• Provide our commercial partners with information about users’ use of co-branded services, including historical use data;
• Comply with any legal or regulatory requirements and otherwise respond to any relevant regulator or competent authority as required by law;
• Understand user trends and patterns; and
• Develop aggregate analysis in respect of our users and business intelligence that enables us to operate, protect, make informed decisions and report on the performance of our business.

The platforms we operate are designed to attract as many users as possible. In our case, our users are typically sports fans or interested in sports news and other sports-related content. The creation of this content, and the work that goes into ensuring that the platforms continue to be class-leading digital sports destinations, are funded by advertising revenues which we receive as a result of showing users advertising or other sponsored or branded content on the platforms. We have a legitimate interest in ensuring that we deliver this advertising in a responsible way, and in allowing us to deliver it to the users most likely to be interested in it, and in doing so we employ User Information, such as the user’s location, how the user engages with the platforms and the content that the user views.

More specifically,

• Targeting/advertising – These cookies help us serve relevant advertisements and implement frequency capping procedures, (including interest-based advertising), promotions, and offers, on behalf of ourselves and our third-party advertisers, both on our websites and elsewhere and make other choices related to targeted advertising. We may also use your information to measure and report on the delivery of advertisements.

These types of cookies may also be placed on the platform by our business partners or service providers.

If you register with us or if you continue to use the platforms, you agree to our use of cookies. In some cases, when you arrive on the platform a pop-up message will appear asking for your consent to place advertising cookies on your device as required by applicable law. In order to provide your consent, please click ‘OK’. Once your consent has been provided, this message will not appear again when you revisit, unless you delete cookies via your browser settings or otherwise.

Most web browsers automatically accept cookies, but if you prefer, you can change your browser settings to prevent that, or opt-out as explained below. You may not be able to take full advantage of the platforms or use certain functions if you disable cookies.

5. Anonymous Identifiers

We collect statistical information about visitors to the Services, including which pages are visited and when they are visited. Information recorded may include your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, and search terms. This information is aggregated for statistical purposes, and is never connected to any personally identifiable information (PII) and remains anonymous. This analysis is provided and managed by Google Analytics. Any statistical information collected via Google Analytics for these purposes is not shared outside of this system. For more information about how Google Analytics uses your information please read here.

When you browse through our websites or use our mobile applications and when you enter your email address on these (either to log in, or to sign up to a newsletter, or similar) we may share personal or other information that we collect from you, such as your email address (in hashed, pseudonymous form), IP address, your mobile advertising ID or information about your browser or operating system, with our partner LiveRamp, Inc. and its group companies, acting as joint controllers. LiveRamp uses this information to create an online identification code for the purpose of recognizing you on your devices. This code does not contain any of your identifiable personal data and will not be used by LiveRamp to re-identify you. We place this code in our first-party cookie or use a LiveRamp cookie and allow it to be used for online and cross-channel advertising. It may be shared with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g., web, email, connected devices, and in-app, etc). These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them. Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy and opt-out here: https://liveramp.uk/privacy/service-privacy-policy/. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time.

6. Disclosure of User Information

We may share User Information with any member of the TopBets Group where this is necessary for business administration purposes in accordance with applicable law. We may also allow other members of the TopBets Group to contact users with relevant offers, competitions and latest news (where they have consented to doing so, if required by applicable laws).

We may also share User Information with selected third parties including:

• Business partners, suppliers, and sub-contractors in connection with providing Services to our users;
• Advertisers and advertising networks that require the data to select and serve relevant adverts to the user;
• Analytics and search engine providers that assist us in the improvement and optimisation of the platforms;
• If we decide to sell the business operating the Service or it is integrated with another business, we may disclose User Information to our advisers and any prospective buyer’s advisers as well as to the new owners of the business;
• If we are under a duty to disclose or share a user’s personal information in order to comply with any legal obligation, or in order to enforce or apply our terms; and
• In order to prevent fraud, cheating, and money laundering we may disclose User Information and betting and gaming history to third parties including, but not limited to, any relevant regulator, gaming and sporting bodies, financial institutions, and law enforcement agencies or any other body that deals with the investigation of alleged offences.

Where relevant, we will disclose User Information and anonymized information associated with a user’s use of and interaction with the platforms to the partner on whose behalf we operate that platform, for the purposes of marketing and advertising, and to promote their own products and services.

7. Your Right to Opt-Out

If you would like us to stop sending you marketing communications you may use the unsubscribe link in our marketing communications. You can also send us an email at info@topbets.co.ke to unsubscribe from our marketing communications.

If you, or another user of your device, wish to withdraw your cookies consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. You may also go to www.allaboutcookies.org or www.youronlinechoices.eu if you are in Europe, or to www.aboutads.info/choices if you are anywhere else for instructions on how to disable cookies. You may opt-out from Google Analytics here. In some instances, when you opt-out, a new cookie (Opt-Out-Cookie) is placed in your web browser. This tells the third-party provider to cease data collection from your browser and prevents advertisements from being delivered to you.

8. Security

We understand that the security of your User Information is important to you. When handling User Information, security is paramount and we seek to ensure that User Information is protected through appropriate technical and organisational measures.

We use reasonable administrative, logical, and physical controls, including password protection, to safeguard your User Information against loss, theft, and unauthorized access, use, or modification. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your User Information in accordance with applicable law, we cannot guarantee the security of your User Information.

9. International Data Transfers

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this notice.

Information which you provide may be transferred to our group companies, commercial partners, suppliers, or agents located outside your country. We will ensure adequate protection of personal data transferred outside of your country as required under applicable laws.

10. Parents and Guardians

Our platforms are not directly intended for children and should not be used by them unless supervised by a parent or guardian.

11. Contact

Questions, comments, and requests regarding this Privacy Notice are welcomed and should be addressed to:

Otis Media Europe Kft c/o TopBets Kenya info@topbets.co.ke

Affiliate Disclaimer

The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commission.

Further, TopBets is a participant in affiliate advertising programs designed to provide a means for sites to earn advertising fees by advertising and linking to affiliate sites.