Privacy Policy

Gamerly Holding Ltd is committed to protecting your Personal Data. This Privacy Policy explains what Personal Data we collect when you access or use our Services, the purposes for which we collect such data, and how we process, use, store, and disclose it.

This Privacy Policy constitutes an integral part of the Terms and Conditions of Citobet and shall be read in conjunction with them. By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

The website Citobet (the "Website", "Platform", or "Services") is owned and operated by Gamerly Holding Ltd, a company incorporated under the laws of the Autonomous Island of Anjouan, Union of Comoros, with registration number 16003 and registered address at PO Box 1212, Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros (the "Company", "We", "Us", or "Our").

We reserve the right to amend this Privacy Policy at any time in order to reflect changes in legal, regulatory, or operational requirements. Any updated version will be published on the Website, and the revised terms shall take effect upon publication. Continued use of the Services constitutes your acceptance of the updated Privacy Policy.

Information Collected

For the purposes of this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable individual, including but not limited to name, surname, date of birth, residential address, email address, telephone number, and any other information required for identification or verification purposes.

We may collect Personal Data when you access or use our Services, register an Account, make transactions, or otherwise interact with the Website. The categories of Personal Data we collect may include:

  • Identity Data: first name, last name, date of birth, and gender.
  • Contact Data: residential address, email address, telephone number.
  • Financial Data: payment method details, transaction history, deposits and withdrawals.
  • Gaming Data: gameplay activity, betting history, wagers, winnings, and losses.
  • Technical Data: IP address, device information, browser type, operating system.
  • Usage Data: information about how you use the Website and Services.
  • Compliance Data: documents and information collected for identity verification (KYC), anti-money laundering (AML), and fraud prevention purposes.
  • Communication Data: any correspondence with our customer support or feedback provided by you.

Your Personal Data is processed and stored on secure servers, which may be located within the European Economic Area (including Germany) and in other jurisdictions, depending on our operational requirements and those of our service providers.

When you interact with the Website, our systems automatically collect certain Technical and Usage Data. This may include your IP address, date and time of access, pages visited, language preferences, device type, browser type, and system activity logs. Such data is necessary for the operation, security, and optimization of our Services.

We collect Personal Data only where necessary for the provision of our Services, compliance with legal and regulatory obligations, and the protection of our legitimate business interests.

Means of Collecting and Processing Data

We collect and process Personal Data through various means in connection with your use of the Services. Personal Data may be collected directly from you when you:

  • Register and create an Account;
  • Use our gaming and sportsbook Services;
  • Make deposits and withdrawals;
  • Submit documents for identity verification (KYC);
  • Communicate with customer support or otherwise interact with us.

We also collect certain Personal Data automatically when you access or use the Website, including Technical and Usage Data as described in this Privacy Policy. In addition, we may receive Personal Data from third parties, including:

  • Payment service providers and financial institutions;
  • Identity verification and fraud prevention providers;
  • Gaming providers and platform partners;
  • Publicly available sources and databases, where applicable;
  • Third-party marketing partners, where you have lawfully consented to such sharing.

We may engage third-party service providers to support the operation of our Services, including payment processing, identity verification, fraud detection, technical infrastructure, and customer support. These providers may process Personal Data on our behalf and in accordance with our instructions.

Where Personal Data is shared with or processed by third parties, we take appropriate measures to ensure that such parties are subject to contractual obligations and safeguards to protect your Personal Data and to process it in accordance with applicable data protection standards and this Privacy Policy.

We may disclose Personal Data to third parties only where necessary for the purposes set out in this Privacy Policy, including compliance with legal and regulatory obligations, fraud prevention, and the provision of our Services.

Use of Personal Data

We process your Personal Data for the purposes of providing, operating, and maintaining our Services, as well as for compliance with legal and regulatory obligations. In particular, we may use your Personal Data for the following purposes:

  • To create, manage, and operate your Account;
  • To provide gaming and sportsbook Services;
  • To process deposits, withdrawals, and other financial transactions;
  • To verify your identity and conduct KYC (Know Your Customer) and AML (Anti-Money Laundering) checks;
  • To detect, prevent, and investigate fraud, money laundering, and other unlawful or irregular activities;
  • To ensure the security and integrity of our Platform;
  • To provide customer support and respond to inquiries;
  • To monitor gameplay and betting activity for responsible gaming purposes;
  • To comply with applicable legal and regulatory requirements.

Where necessary for the provision of our Services, we may share your Personal Data with authorized third parties, including payment service providers, identity verification providers, fraud prevention agencies, and gaming or platform partners, in accordance with this Privacy Policy.

Where you have provided your consent, or where otherwise permitted by applicable law, we may use your Personal Data for marketing purposes, including:

  • Sending you promotional communications regarding our products and Services;
  • Informing you about offers, bonuses, and campaigns;
  • Providing information about products and services offered by our partners.

You have the right to opt out of receiving marketing communications at any time.

From time to time, we may invite you to participate in surveys, promotions, or contests. Participation is voluntary, and any Personal Data provided in this context will be used for the administration of such activities.

Where permitted by applicable law, and unless otherwise restricted, acceptance of any prize or winnings may constitute your consent to the use of your name and/or username for promotional and advertising purposes without additional compensation.

Disclosure of Personal Data

We may disclose your Personal Data where required by law or where we reasonably believe that such disclosure is necessary to:

  • Comply with any applicable law, regulation, legal obligation, or request from regulatory authorities, including licensing bodies in the Autonomous Island of Anjouan;
  • Respond to lawful requests from public authorities, law enforcement agencies, or courts;
  • Protect and defend our rights, property, or the integrity of our Services;
  • Prevent, detect, and investigate fraud, money laundering, or other unlawful or prohibited activities;
  • Protect the safety, rights, and security of our Users or the public.

Where we determine, at our sole discretion, that you have engaged in fraudulent, abusive, or unlawful activity, including but not limited to game manipulation, payment fraud, use of stolen payment methods, chargebacks, or any activity related to money laundering, we reserve the right to disclose relevant Personal Data, including your identity and associated information, to:

  • Other licensed gaming operators;
  • Payment service providers, banks, and financial institutions;
  • Fraud prevention agencies and monitoring systems;
  • Relevant regulatory authorities and licensing bodies;
  • Law enforcement agencies.

Such disclosures may be made for the purposes of fraud prevention, risk management, regulatory compliance, and the protection of the integrity of the gaming industry.

For research and analysis purposes related to the prevention of gambling addiction and responsible gaming, anonymized and aggregated data may be shared with relevant institutions. Such data will not contain information that can identify you personally.

Your Rights and Access to Personal Data

You have the right to opt out of receiving marketing communications from us at any time. You may exercise this right by:

  • Adjusting your preferences within your Account settings;
  • Following the unsubscribe instructions included in any marketing communication;
  • Contacting our Customer Support.

You may also contact us at any time to exercise your rights in relation to your Personal Data, including:

  • Requesting access to the Personal Data we hold about you;
  • Requesting correction or updating of inaccurate or incomplete Personal Data;
  • Requesting restriction of processing, where applicable;
  • Objecting to certain types of processing, including direct marketing.

We may require you to verify your identity before processing any such requests in order to protect your Personal Data.

Where you request correction or updating of your Personal Data, we will take reasonable steps to amend such data, provided that sufficient evidence is supplied to support the requested changes.

Please note that, notwithstanding the above, we may retain and process your Personal Data where required to comply with legal, regulatory, or licensing obligations, including obligations related to anti-money laundering, fraud prevention, and responsible gaming.

Cookies

We use cookies and similar tracking technologies to collect and store information when you access or use our Website and Services. Cookies are small text files placed on your device that enable us to recognize your device and store certain information about your preferences or past actions.

Cookies help us ensure the proper functioning of the Website, enhance your user experience, analyze traffic, and support our security and fraud prevention measures.

Strictly Necessary Cookies

These cookies are essential for the operation of the Website and enable you to access secure areas, use your Account, and perform financial transactions. Without these cookies, the Services cannot be provided properly.

Functional Cookies

These cookies allow us to remember your preferences (such as language, region, or login details) and provide enhanced, more personalized features.

Analytical Cookies

These cookies allow us to recognize and count visitors and understand how users interact with the Website. This helps us improve the performance and functionality of our Services.

Marketing and Advertising Cookies

These cookies are used to deliver relevant advertisements and promotional content based on your interests and interactions with our Services. They may also be set by third-party advertising partners.

Session and Persistent Cookies

  • Session Cookies are temporary and are deleted when you close your browser. They are used to enable core functionality during your visit.
  • Persistent Cookies remain on your device for a defined period or until manually deleted. They help us recognize you on subsequent visits and remember your preferences.

Third-Party Cookies

We may allow third-party service providers, such as analytics providers and advertising partners, to place cookies on your device. These third parties may process your data in accordance with their own privacy policies.

Managing Cookies

Most web browsers automatically accept cookies. However, you can modify your browser settings to refuse cookies or to notify you when cookies are being used. Please note that disabling or rejecting certain cookies may affect the functionality of the Website and limit your ability to use certain features of the Services. For more detailed information about cookies and how to manage them, please refer to your browser's help settings.

Use of Payment Service Providers

In order to access and use real money gaming and betting Services, you will be required to deposit and withdraw funds through your Account. We engage third-party payment service providers to process such financial transactions.

By using our Services, you acknowledge and agree that certain Personal Data necessary for the processing of deposits, withdrawals, and related financial transactions may be shared with such payment service providers. This may include the transfer of your Personal Data to jurisdictions outside your country of residence, where required for the provision of payment services.

All payment service providers engaged by us are subject to contractual and regulatory obligations, including data protection, security, and anti-money laundering requirements. We take appropriate measures to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy.

Security and Verification Checks

We reserve the right to conduct security and verification checks at any time to validate the information provided by you during registration, as well as to monitor your use of the Services and financial transactions for compliance with our Terms and Conditions and applicable laws and regulations.

By using our Services, you acknowledge and agree that we may process your Personal Data and disclose it to authorized third parties for the purposes of identity verification, fraud prevention, anti-money laundering (AML) compliance, and risk management. This may include the transfer of your Personal Data to jurisdictions outside your country of residence where necessary for such purposes.

Verification checks may include, but are not limited to:

  • Verification of identity and personal details through third-party databases;
  • Requests for documentation (such as identification documents and proof of address);
  • Review of transaction history and payment methods;
  • Fraud and risk assessments conducted through external providers.

Where required, we may request additional information or documentation from you in order to complete such checks. Failure to provide requested information may result in restrictions, suspension, or closure of your Account in accordance with our Terms and Conditions.

Security

We recognize the importance of protecting your Personal Data and implement appropriate technical and organizational measures to safeguard it against unauthorized access, loss, misuse, alteration, or disclosure.

All Personal Data provided by you is stored within secure systems protected by encryption, access controls, and firewall technologies. We use industry-standard security protocols, including Transport Layer Security (TLS), to ensure that data transmitted between your device and our systems remains protected.

Access to Personal Data is restricted to authorized personnel and service providers who require such access for the performance of their duties and are subject to confidentiality obligations.

We also take reasonable steps to ensure that our affiliates, service providers, and partners implement appropriate security measures to protect your Personal Data in accordance with applicable data protection standards.

While we take all reasonable precautions to protect your Personal Data, no system or transmission over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of your data.

Protection of Minors

Our Services are strictly intended for individuals who are at least eighteen (18) years of age, or the minimum legal age required for gambling in their respective jurisdiction, whichever is higher.

By accessing or using our Services, you confirm that you meet the applicable legal age requirement. We do not knowingly collect or process Personal Data from individuals who do not meet this requirement.

We implement measures to detect and prevent access to our Services by minors, including identity verification (KYC) procedures and security checks. Where we have reason to believe that an individual is under the legal age, we reserve the right to:

  • Suspend or terminate the Account;
  • Void any transactions, bets, or winnings;
  • Request verification documentation.

If we become aware that Personal Data has been submitted by a minor, we will take all reasonable steps to delete such data from our records, in accordance with applicable legal and regulatory obligations.

International Transfers

Your Personal Data may be transferred to, stored, and processed in jurisdictions outside your country of residence, including countries in which we, our affiliates, or our service providers maintain operations.

By using our Services, you acknowledge and agree that such transfers may take place, including to jurisdictions that may not provide the same level of data protection as your country of residence.

Where Personal Data is transferred internationally, we implement appropriate safeguards to ensure that it is protected in accordance with this Privacy Policy and applicable data protection standards. Such safeguards may include contractual obligations, data protection agreements, and other appropriate technical and organizational measures.

We take reasonable steps to ensure that our affiliates and third-party service providers process Personal Data securely and in a manner consistent with our data protection requirements, regardless of their location.

Third-Party Practices

Our Services may contain links to third-party websites or services that are not owned or controlled by us. Please note that we do not have control over, and are not responsible for, the privacy practices, policies, or content of such third-party websites.

Any Personal Data you provide to third-party websites or services, including those operated by affiliates, partners, or third-party programs, is processed in accordance with their respective privacy policies. We strongly recommend that you review the privacy policies of any third-party website or service before providing any Personal Data.

We accept no responsibility or liability for the protection, processing, or use of your Personal Data by third parties that operate independently of our Services.

The Services are provided on an "AS IS" and "AS AVAILABLE" basis, without any warranties, express or implied, to the fullest extent permitted by applicable law.

While we implement appropriate technical and organizational measures to protect your Personal Data, we do not warrant or guarantee that the Services will be uninterrupted, error-free, or completely secure at all times.

We shall not be liable for any failure or delay in performance arising from circumstances beyond our reasonable control, including but not limited to technical failures, third-party service disruptions, or force majeure events.

To the maximum extent permitted by applicable law, we shall not be liable for any indirect, incidental, consequential, or punitive damages arising out of or in connection with the use, processing, or disclosure of Personal Data.

Acceptance of This Privacy Policy

By accessing or using our Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

This Privacy Policy constitutes the entire and exclusive statement regarding the processing of your Personal Data and supersedes any prior versions. It should be read in conjunction with our Terms and Conditions and any additional applicable terms made available on the Website.

We reserve the right to amend this Privacy Policy at any time to reflect changes in legal, regulatory, or operational requirements. Any updated version will be published on the Website, and the revised terms shall take effect upon publication. Your continued use of the Services following such changes constitutes your acceptance of the updated Privacy Policy.

Where applicable, you may have the right to lodge a complaint with a competent data protection authority regarding the processing of your Personal Data, in accordance with relevant data protection laws, including Article 77 of the General Data Protection Regulation (GDPR).

Other Websites

The Website may contain links to third-party websites or services that are not owned or controlled by us. Such websites operate independently and are not subject to this Privacy Policy.

If you access any third-party website through links provided on our Website, any Personal Data you provide will be processed in accordance with the privacy policy of that third party, which may differ from ours. We recommend that you review the privacy policies of such websites before providing any Personal Data.

We do not accept any responsibility or liability for the content, functionality, security, or privacy practices of third-party websites. The operators of such websites are solely responsible for their respective services and any issues arising from their use.