PRIVACY NOTICE

This document (hereinafter referred to as the “Notice”) describes the principles of processing and protection of Personal Data, as well as other important information related to the collection and use of your data while using our services and website (ggbet.ua) or application, regardless of the device (computer, mobile phone, tablet, etc.) used by you (hereinafter referred to as the “Visitor”).

We are responsible for processing your data while you use our services and website and therefore act as the Personal Data Controller (as defined below and referred to as «we», «us», or «our»).

Contact details: GGBET LLC, legal entity identification code: 44912194, registered address: 02002, Ukraine, Kyiv, Yevhena Sverstiuka Street, building 17, office 601.

By using our Services, you confirm that you have read this Notice and understand how and for what purposes your personal information will be processed. If you have any questions regarding this Notice or the processing of your personal data, please contact us at: privacy@ggbet.ua

DEFINITIONS

Data Controller — a natural or legal person who independently or jointly with others determines the purposes and means of processing Personal Data.
Personal Data — any information that allows us to identify you as a Visitor or User.
Services — the services provided by us. A detailed list of such services is available in the Public Offer at: https://ggbet.ua/en/public-offer
Visitor - a natural person who visits our website.
User - a natural person who has a registered account on the website.

Categories, Purpose, and Legal Grounds for Data Processing

• Information You Provide to Us:

Registration data: last name, first name and patronymic (if available), age (date of birth), email address, mobile phone number, password to the Client Account.

Identification data: information regarding a passport or other identity document together with a photograph and/or scanned copy of the document, citizenship information (for non-residents), taxpayer identification number (RNOKPP), phone number, email address, place of residence/place of stay (for non-residents), electronic signature data, BankID, MobileID (if used for identification), Unique Record Number in the Unified State Demographic Register (UNZR) (if available), etc.

Verification data: photo and/or video recording of the User with a passport or other identity document and the photo/scan copy of such document, payment card and photo of the payment card, documents confirming place of residence and/or place of stay (for non-residents), information on the source of funds (if required by law for certain individuals), etc.

Communication data: date, time, method, content of communication, status of issue resolution, etc.

Self-exclusion data (if you apply for self-exclusion and inclusion in the Register of persons restricted from access to gambling establishments and/or participation in gambling): last name, first name, patronymic (if available), age (date of birth), place of residence, citizenship, passport or identity document details, taxpayer identification number (RNOKPP), contact details, signature image.

• Information We Collect Automatically When You Use the Website, Application, and Services:

Access logs: IP address, browser type, operating system.

Tracking technologies: cookies; detailed information about cookies is available in our Tracking Technologies Notice.

Cookie consent: optional cookies (e.g., analytics and marketing cookies) are used only if you give your consent via the cookie banner on our Website. We do not request cookie consent through the registration form checkbox. You can manage your cookie preferences through the cookie banner and/or your browser settings (see the Tracking Technologies Notice for details).

Gambling activity data: date, time, type, name, amount, odds of the bet, expected winnings, specific conditions (if any), bet result, win/loss amount, information on bonus usage, etc.

Profile data: preferences regarding bet types, games, events, bonuses, communication language, service satisfaction, self-exclusion status, profile comments, etc.

Transaction data: deposits, winnings, date, time, transaction amount, currency, account balance, payment methods.

Marketing data: information on interaction with advertising messages, promotions, bonuses, and preferred communication channels.

Website/Application usage data: IP address; unique device identifier for advertisers (with your consent or in accordance with app store rules); information about installation and first launch of the Application/Website; interaction data (visited pages, time spent on pages, etc.); information about ads viewed and clicked; and technical characteristics of the device, operating system type and version.

• Information We May Receive from Third Parties and Other Sources:

Payment data: we receive the date and time of the transaction, payment status, payment method used, transaction amount and currency, transaction code, and other payment-related information from payment providers.

Social media data: If you log in to the Website using a social media account, with your consent we receive profile data required for account registration, including your name, contact details and other data you have permitted access to.

Data from official sources: information regarding your inclusion or absence in the Register of persons restricted from gambling; inclusion or absence in terrorist lists or sanctions lists of the National Security and Defense Council of Ukraine (NSDC); information on politically exposed person (PEP) status; information on close ties with the Russian Federation; and any other data necessary to comply with Ukrainian legislation or protect business interests.

Other: to comply with Ukrainian gambling regulation and financial monitoring laws and to protect our business from fraud and other illegal activities, we may obtain information about you from publicly available sources (social networks, search engines, etc.).

Purpose and Legal Basis for Data Processing

Data Subject	Data Description	Purpose	Legal Basis
User	Registration data Identification data Website/Application usage data	Account registration	Performance of a transaction
Visitor	Access logs Tracking technologies Website/Application usage data	Providing access to the Website/Application	Performance of a transaction
User	Registration data Identification data Communication data	Verification	Compliance with legal requirements in the field of gambling and financial monitoring
User	Communication data Tracking technologies Profile data Registration data Identification data	Providing support	Performance of a contract
User	Registration data Identification data Verification data Website/Application usage data Gaming activity data Transactional data Communication data Payment data	Use of the Website Services, including placing bets, crediting and paying out winnings	Performance of a contract
User	Communication data Social media data Profile data Tracking technologies	Engagement in loyalty programs	Legitimate interest
User	Tracking technologies Access logs Website/Application usage data Verification data Identification data	Prevention, detection, and termination of suspicious and fraudulent behavior	Compliance with legal requirements in the field of gambling and financial monitoring
User	Website/Application usage data Registration data Identification data Verification data Communication data Profile data Self-exclusion data Data from official sources Other	Monitoring compliance with responsible gaming rules	Compliance with legal requirements in the field of gambling and financial monitoring
User	Website/Application usage data Registration data Identification data Verification data Communication data Profile data Self-exclusion data Data from official sources Other	Performance of actions stipulated by law regarding players entered in the Register of persons with restricted access to gambling establishments and/or participation in gambling	Compliance with legal requirements in the field of gambling and financial monitoring
User	Identification data Verification data Payment data Transactional data Data from official sources Other	Accounting and tax reporting activities	Compliance with legal requirements
Visitor, User	Access logs Tracking technologies Website/Application usage data Marketing data Registration data Gaming activity data Profile data	Analytics of interaction with the Website/Application and marketing campaigns to improve the Services	Legitimate interest
Visitor, User	Registration data Gaming activity data Profile data Tracking technologies Marketing data	Sending marketing communications	Consent

Who we share Personal Data with

We may share your Personal Data in the following ways:

1. Service Providers: we share Personal Data with our service providers who assist with IT and system administration, recruitment, hosting, research and analytics, marketing, customer support, and data enrichment, to the extent necessary for the purposes and on the legal grounds set out in this Notice.

2. Professional advisors: in specific cases, we may disclose Personal Data to professional advisors who provide Services on our behalf.

3. Public authorities: we may share Personal Data with public authorities when this is necessary to comply with legal obligations.

Cross-border transfer of Personal Data

We may process Personal Data within Ukraine and the European Union (EU) or the European Economic Area (EEA). If it is necessary to transfer your Personal Data outside the EEA (for example, to use services of subprocessors and technical infrastructure provided from or located in the United States, the United Kingdom, Germany, or Poland), such transfer of Personal Data will be carried out in accordance with the requirements, principles, and safeguards defined in the General Data Protection Regulation (GDPR), such as reliance on adequacy decisions issued by the European Commission or standard contractual clauses approved by the European Commission.

Your rights regarding

You have the following rights regarding your Personal Data:

Right	Description
Right of access	Individuals may submit requests to us regarding the type, purpose, and duration of processing of their personal data and receive the relevant information within 30 days
Right to rectification	Individuals may contact us to supplement or amend their personal data
Right to erasure	Individuals may request that we delete their Personal Data in whole or in part
Right to restriction of processing	Individuals may request that we fully or partially restrict the processing of their personal data
Right to data portability	Individuals have the right to obtain a copy of their personal data and transfer such data to other controllers
Right to object	Individuals have the right to object to the processing of their data
Right to withdraw consent	Individuals may withdraw their consent to the collection and processing of their personal data
Right to data portability	Individuals may request a copy of their personal data in a structured, machine-readable format
Right to lodge a complaint	Individuals may lodge a complaint with data protection authorities if they believe that we have violated any of their rights. To exercise your rights regarding personal data in Ukraine, you may submit a complaint to the Ukrainian Parliament Commissioner for Human Rights using the contact details available at: https://ombudsman.gov.ua/en/zayavniku

If you wish to exercise any of these rights, please contact us by email at: privacy@ggbet.ua

You do not need to pay any fees to exercise your rights. We will respond to your request within 30 days from the date of its receipt. To submit a complaint, please contact us using the contact details provided in this Notice. To help us thoroughly understand and resolve your issue, we ask you to provide as much relevant information as possible.

Data Protection

We are committed to protecting your Personal Data and have implemented a range of technical and organizational measures to prevent unauthorized access, disclosure, alteration, or loss. These measures include, among others, the use of encryption (HTTPS) to protect data during transmission, storage of information on servers with restricted access and monitoring systems, and granting access to users’ personal data only to employees who genuinely need it. We also conduct regular security audits and update internal procedures. These security measures ensure the protection and integrity of the Personal Data we process.

Minors

We collect and process personal data only of adults. If you believe that we have mistakenly collected Personal Data of a minor, please contact us, and we will immediately delete such data from our systems.

Data Retention

As a primary financial monitoring entity, we are required to store information on financial transactions with Users for at least five years after the termination of business relations with them (Clause 18, Part 2, Article 8 of the Law of Ukraine “On Prevention and Counteraction to Legalization (Laundering) of the Proceeds of Crime, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction” dated December 6, 2019, No. 361-IX).
Data related to marketing activities, collected based on your consent or legitimate interest, are stored until you withdraw your consent or for the period specified in the cookies table, namely in the Tracking Technologies Notice.
Other data, including data related to account registration and your activity history, are stored for 3 (three) years from the date of your last contact with us, in accordance with the statute of limitations requirements under Ukrainian law.
After the relevant retention period expires, your Personal Data will be deleted. If complete deletion is technically impossible, we will implement appropriate measures to ensure the secure storage of such data and cease their use for any purposes.

Links to Other Websites

Our Website may contain links to third-party websites that operate under different privacy rules. If you follow any of these links or provide your Personal Data to such websites, that information will be processed in accordance with their respective policies and practices.

Changes to the Notice

We reserve the right to amend or supplement this Notice at any time. Any changes we make to this Notice in the future will be published on this page and, where necessary, communicated to you by email. In such cases, we will update the “Effective Date” specified in the preamble of this document.

Cookie Policy

This Policy is an integral part of our Data Processing Notice. Here we describe which cookies we use, what information they collect about you, and how long we store such information.

In addition to the Personal Data you provide through the Website, we may use various technologies, including cookies, which collect certain information each time you interact with the Website. Such usage information may include the device you use, your IP address, device identifier, anonymized traffic data, other unique identifiers, location data, and information about your use of the Website.

Consent for non-essential cookies (analytics/marketing) is provided via the cookie banner. A link to this Cookie Policy is available in the cookie banner and in the website footer. The registration form does not include a separate Cookie Policy link because cookie consent is obtained through the banner.

Types of Cookies We May Use:

Strictly Necessary Cookies	These cookies are essential to provide you with services available on the Website. They are usually set only in response to actions made by you, such as service requests. This includes setting your privacy preferences, logging in, or filling out forms. You can set your browser to block or alert you about these cookies, but please note that doing so may cause some parts of the Website to not function properly.
Functional Cookies	These cookies allow the Website to provide enhanced functionality and personalization. If you choose not to allow these cookies, some or all of these services may not function properly.
Marketing Cookies	These cookies may be set through our Website by our advertising partners. These companies may use them to build a profile of your interests and show you relevant advertisements on other websites. They do not store personal information directly but rely on the unique identification of your browser and internet device. If you choose not to allow these cookies, you may experience less personalized advertising.
Analytics Cookies	We use performance cookies to analyze how our Websites and applications are accessed, used, or performed to provide you with a better user experience and to maintain, operate, and continuously improve our Website. Analytics cookies allow us to continuously review and improve the layout and functionality of our Website to deliver the best possible experience, including:  • using data collected by such cookies to experiment with different design ideas for individual pages;  • improving our Website by measuring and identifying errors;  • conducting research and diagnostic activities to enhance Website functionality.

• Strictly Necessary

Cookie name	Purpose	Tool	Storage	Legal Basis
cookie-accepted	store the fact that the user has accepted the cookie banner	website	1 year	Performance of a transaction
uuid	store a unique user ID for authorization purposes	website	1 year	Performance of a transaction

• Functional

Cookie name	Purpose	Tool	Storage	Legal Basis
_spa-locale	storing the selected interface language (en)	website	1 year	Legitimate interest

• Analytics

Cookie name	Purpose	Tool	Storage	Legal Basis
_ga_HQJ...	identifying the user between visits for statistical purposes	Google Analytics	2 years	Consent
_ga	storing the client ID for traffic measurement	Google Analytics	2 years	Consent
_ga_AU	improved event tracking in GA4	Google Analytics	2 years	Consent
_hjHasCachedUserAttributes	to determine if there are cached user attributes	Hotjar	session	Consent
_hjSessionUser_...	storing a unique User ID for behavioral analytics	Hotjar	1 year	Consent
first_entry	to determine the user's first login or the source of the first login	Website	30-180 days	Consent
useOutside…	storing an internal clientID or attribution logic	Google Analytics	up to several days	Consent
uuid	storing a unique User ID for behavioral analytics	Website	Up to 1 year	Consent

• Marketing

Cookie name	Purpose	Tool	Storage	Legal Basis
test_cookie	checking whether advertising cookies are allowed	Third party: Google (DoubleClick)	1 day	Consent
_fbp	displaying and optimizing Facebook ads, tracking referrals	Facebook Pixel	3 months	Consent
_gcl_au	measuring conversions and A/B testing (Google)	Google Ads / Tag Manager	3 months	Consent
_gcl_aw	tracking referrals from Google ads (auto-tagging)	Google Ads	90 days	Consent
_gcl_gs	grouping sessions for conversion measurement	Google Ads	90 days	Consent
affdata	storing an affiliate ID to track partner referrals	Affiliate program partner	1 year	Consent
refCode	tracking referral codes, promo codes, and partner referrals	Website	30-180 days	Consent

Here is a list of links that will help you understand how to manage your cookie settings:

• Information about cookies in general;
• How to manage your cookies in Mozilla Firefox;
• How to manage your cookies in Chrome;
• How to manage your cookies in Safari;
• How to manage your cookies in Microsoft Edge;
• How to manage your cookies in Opera.