Privacy Policy

LEVANTE AFFILIATES

PRIVACY POLICY

Last updated : December 27, 2024

Navigating this Policy

Welcome to Levante Affiliates´s Privacy Policy.

  1. INTRODUCTION AND SCOPE OF THIS PRIVACY POLICY
  2. WHO WE ARE AND HOW TO CONTACT US
  3. THE DATA WE COLLECT ABOUT YOU
  4. HOW YOUR PERSONAL DATA IS COLLECTED
  5. HOW WE USE YOUR PERSONAL DATA
  6. DISCLOSURE OF YOUR PERSONAL DATA
  7. INTERNATIONAL TRANSFERS
  8. AUTOMATED DECISION MAKING (INCLUDING PROFILING)
  9. DATA SECURITY
  10. DATA RETENTION
  11. YOUR RIGHTS AS A DATA SUBJECT
  12. EXERCISING YOUR RIGHTS
  13. YOUR DUTY TO INFORM US OF CHANGES
  14. CHANGES TO THIS PRIVACY POLICY
  15. ADDITIONAL TERMS
    1. INTRODUCTION AND SCOPE OF THIS PRIVACY POLICY
    1. Levante Affiliates respects your privacy and is committed to protecting your personal data. This Privacy Policy informs you about how we handle your personal data when you visit our website or use our app (regardless of where you arrive or visit it) or interact with us or our services.
    1. This Privacy Policy aims to provide you with information about how Levante Affiliates collects, stores, and processes your personal data, along with details of your rights as a data subject. It is important that you read this Privacy Policy together with our Cookie Policy and any other privacy or fair processing notices we may provide on specific occasions when we are collecting or processing personal data, so that you are fully aware of how and why we are using your data.

     

    1. This Privacy Policy is directed to users of our website and our customers (account holders).
    2. In this Policy, “Personal Data” means any information relating to an identified or identifiable natural person. Certain jurisdictions may also use the term “Personal Information” (or another similar term) in a similar manner, in accordance with local laws; however, the underlying principles set forth in this Policy apply to the collection, use, and/or retention of such data. For the avoidance of doubt, Personal Data does not include data from which you cannot be identified (which is referred to simply as data, non-personal data, or anonymous/anonymous data).
    1. In this Policy, “processing” means any operation or set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination of Data, or the restriction, erasure or destruction thereof. Likewise, “processing” shall be interpreted accordingly.
    1. References to “sensitive data” or “special categories” of Personal Data mean Personal Data relating to natural persons:

     

    1. racial or ethnic origin;
    2. political opinions;
    3. religious or philosophical beliefs;
    4. union membership;
    5. genetic data;
    6. biometric data;
    7. Health; or
    8. sex life or sexual orientation
    1. References to Personal Data relating to “criminal convictions and offences” include the alleged commission of offences, processing in relation to such offences or the disposition of such processing, including sentences.
    1. If and when we, Levante Affiliates, determine the purposes and means of processing your personal data, then we are a “controller,” and anyone acting on our instructions in relation to such processing is a “processor.” There may be times when we act as both a controller and a processor.

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    1. WHO WE ARE AND HOW TO CONTACT US
    1. Levante Affiliates is comprised of several legal entities, including LEVANTE AFFILIATES LTDA. This Privacy Policy is issued on behalf of the Levante Affiliates Group (which includes Levante Affiliates Servicos de Intermediacao LTDA, its parent company, and subsidiaries). Therefore, when we mention “Levante Affiliates,” “we,” “us,” or “our” in this Privacy Policy, we are referring to the relevant Levante Affiliates Group company responsible for processing your data. The data controller of your personal data is Levante Affiliates Holdings Ltd, a private company limited by shares incorporated in Gibraltar and governed by Gibraltar law, with its registered office at Av. dos Autonomistas, nº 2561, Salas 09 e 10, Bairro Centro, Osasco – SP, CEP 06090-020.
    1. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing matters related to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights as a data subject (as detailed in this Privacy Policy), please contact the DPO using the details set out below.

     

    Jonathan Cabedo

    Email:  [email protected]

     

    1. See more information in section 11 of this Privacy Policy about your rights as a data subject.
    1. THE DATA WE COLLECT ABOUT YOU
    1. We may collect, process, store and transfer different types of personal data about you, which we have grouped into “categories” of Personal Data as follows:
    1. Identity Data includes: first name, last name, username or similar identifier, title, date of birth, gender, nationality, tax identification numbers, employment/occupation or business activity details (which may include employment history).
    2. Contact Data includes: address, email address and telephone numbers.
    3. Financial Data includes: bank account, payment card details, alternative payment methods, and in limited cases may also include salary and employer/source of income/funds and/or accessibility information.
    4. Transaction Data includes: details about payments to and from you and other details of bets placed, games played and products purchased from us.
    5. Technical Data includes: internet protocol (IP) address, your login data, unique device identifiers, browser type and version (including search engine and keywords used to find the website(s)), operating system and/or platform used, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access our products and games. This information may be required by us in the event of attacks on our information technology systems, but is generally anonymized or de-identified and therefore will not constitute your Personal Data unless you can be identified from it. More information about the Technical Data collected is found in our Cookie Policy.
    6. Profile Data includes your username and password (the latter encrypted and securely stored), purchases or orders made by you, your interests, preferences, feedback and survey responses.
    7. Usage Data includes information about how you use our website/app, bets placed, products and games played.
    8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    1. We also collect, use, and share Aggregated Data, such as statistical or demographic data. Aggregated Data may be derived from your personal data, but it is not considered personal data because it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
    1. We may also ask you to provide evidence of your identity, such as a copy of your passport, driver’s license, proof of residence or income, or any relevant national identification card or ID. We are required to request this information to comply with anti-money laundering and sanctions laws, legislation such as Law No. 9,613/1998 and Law No. 13,810/2019, and applicable legal and regulatory guidance, to comply with relevant requirements, and/or to ensure we protect ourselves and report any suspicious activity in Brazil.
    1. Generally, we will not process any “sensitive” data unless required to do so by law or in compliance with our legal and/or regulatory obligations or where you have provided your explicit consent or where we are legally permitted to do so without your consent (including, for example, personal data that is manifestly made public by you).

     

    1. Generally, we will not process Personal Data relating to criminal convictions and offences unless required by law (for example, in the context of our AML obligations where we carry out background checks and identify previous convictions from the media/open sources or from background checks carried out by us or using third party providers/services).

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    1. HOW YOUR PERSONAL DATA IS COLLECTED
    1. We use different methods to collect data from and about you, including the following.

    Direct interactions

     

    1. You may provide us with your Identity Data, Contact Data, and Financial Data by filling out forms or corresponding with us by mail, phone, email, chat, or otherwise. This includes Personal Data you provide when:
    1. place a bet with us or play a game;
    2. create an account with us;
    3. request that marketing be sent to you;
    4. participate in a competition, promotion or survey; or
    5. give us some feedback; or
    6. make a complaint.

     

    Automated technologies or interactions

     

    1. As you interact with our website/app, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this information using cookies and other similar technologies (such as Google Analytics). We may also receive Technical Data about you if you visit other websites that use our cookies. More information about the use of cookies and similar technologies can be found in our Cookie Policy. We may also use automated technologies that utilize artificial intelligence, more information about which is contained in section 8 of this Privacy Policy.

    Third parties or publicly available sources

     

    1. We may also receive Personal Data about you from various third parties (including regulatory or statutory bodies, self-exclusion schemes, crime prevention agencies, credit or identity checking services and/or publicly available sources) and use this information to carry out further identification and/or integrity checks to minimise the risks of fraud, cheating or money laundering to the business.

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    1. HOW WE USE YOUR PERSONAL DATA
    1. We will only use your personal data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
    1. when we need to provide services under the contract we are about to enter into or have entered into with you;
    2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
    3. when we need to comply with a legal or regulatory obligation; or
    4. with your consent.
      1. Where we use the legal basis of consent in accordance with applicable law, you have the right to withdraw consent to marketing at any time by contacting us at [email protected]  or by changing your marketing preferences in the My Account section of your account or by clicking the “unsubscribe” option in the marketing in question.

     

    Purposes for which we will use your Personal Data

     

    1. Below, in table format, we describe the main ways we may use your Personal Data and the legal bases we rely on to do so. We have also identified our legitimate interests, where appropriate. Please note that we may process your Personal Data for more than one legal basis, depending on the specific purpose for which we use your data:
    Purpose/Activity Data type Purpose/Activity

    To register you as a new customer and manage and administer our relationship with you.

    To verify your age and ensure you are not playing in a restricted country.
    • Identity
    • Contact

    Performance of a contract with you

    Necessary to fulfill a legal obligation

    Necessary for our legitimate interests

    To process your bet and allow you to play, including:

    (a) manage your payments and pay out your winnings

    (b) collect and recover money owed to us, including any fees and charges
    • Identity
    • Contact
    • Financial
    • Transaction
    • Marketing and Communication

    Performance of a contract with you

    Necessary for our legitimate interests (to recover debts owed to us)

    To manage our relationship with you, which will include:

    (a) notify you about changes to our terms and conditions or privacy policy;

    (b) ask you to leave a comment or respond to a survey; or

    (c) to allow you to interact with our Customer Service team via email, phone and live chat.
    • Identity
    • Contact
    • Profile
    • Marketing and Communication

    Performance of a contract with you

    Necessary to fulfill a legal obligation

    Necessary for our legitimate interests (keeping our records up to date and studying how customers use our products/services)
    To allow you to enter a prize draw, competition or respond to a survey
    • Identity
    • Contact
    • Profile
    • Use
    • Marketing and Communication

    Performance of a contract with you

    Necessary for our legitimate interests (studying how customers use our products/services, developing them and growing our business)
    To administer and protect our business and the security of our website(s)/app(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting)
    • Identity
    • Contact
    • Technical

    Necessary for our legitimate interests (to administer our business, provide administrative and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

    Necessary to fulfill a legal obligation
    To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
    • Identity
    • Contact
    • Profile
    • Use
    • Marketing and Communication
    • Technical
    		 Necessary for our legitimate interests (studying how customers use our products/services, developing them, growing our business and informing our marketing strategy)
    To use data analytics to improve our website/app, products/services, marketing, customer relationships and experiences
    • Technical
    • Use
    		 Necessary for our legitimate interests (defining customer types for our products and services, keeping our website/app updated and relevant, developing our business and informing our marketing strategy)
    To make suggestions and recommendations about our products and offers or promotions that may be of interest to you and to carry out direct marketing
    • Identity
    • Contact
    • Technical
    • Use
    • Profile
    • Marketing and Communication
    		 Necessary for our legitimate interests (to develop our products/services and grow our business)

    Promotional and marketing offers from us

     

    1. We strive to provide you with options relevant to your interests and a personalized online experience, so you can receive offers or products relevant to you, in line with your marketing preferences. We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. We then tailor our promotions or marketing materials and contact you directly to offer them to you. This is known as “Direct Marketing.” You will receive our direct marketing communications if you have opened an account with us, placed a bet, or played a game, or if you provided us with your data when entering a competition or signing up for a promotion. In each case, you have not opted out of receiving marketing communications or opted out of playing with an industry scheme. See section 11 of this Privacy Policy for more information about your rights regarding direct marketing and more information about Opting Out .

     

    Third-party marketing

     

    1. Third parties (i.e., companies and/or service providers outside the Levante Affiliates Group) may wish to market their services to you. We will obtain your explicit consent (i.e., we will ask you to opt-in) before sharing your Personal Data with any company outside the Levante Affiliates Group for their marketing purposes. Any marketing you subsequently receive from them is/will be subject to that third party’s privacy policy.

     

    If you do not provide Personal Data

     

    1. Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to close your account or cancel a bet you have placed with us.

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    1. DISCLOSURE OF https://www.levanteaffiliates.com.br/privacidade#topYOUR PERSONAL DATA
    1. We may have to share your personal data with the following recipients or categories of recipients set out below for the purposes set out in the table in section 5 of this Privacy Policy:

     

    1. Other companies within the Levante Affiliates Group act as joint controllers or operators and provide customer services, IT systems administration services and undertake leadership reporting.
    2. Identity verification agencies and fraud prevention agencies used to provide customer due diligence, including anti-money laundering, fraud, and sanctions checks in the context of our AML or responsible gaming obligations.
    3. External third parties to provide promotional and marketing services on our behalf.
    4. Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. If a change occurs to our business, the new owners may use your personal data in the same manner set out in this Privacy Policy.
    5. Service providers that provide IT services and systems administration.
    6. Professional advisors, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to Levante Affiliates.
    7. Regulators and other authorities that require reporting of processing activities in certain circumstances.
    1. We require all third parties to respect the security of your Personal Data and treat it in accordance with the law. We do not permit our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions, such as our processors (defined above). However, in limited circumstances and with your explicit consent, we may share your Personal Data with specific third parties, as notified to you from time to time, who may wish to market their services to you.

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    1. INTERNATIONAL TRANSFERS
    1. We share your personal data within the Levante Affiliates Group with third-party companies and service providers. This may involve transferring your data outside of Brazil, known as a third-country transfer or “restricted transfer.” For the purposes of the LGPD, a “third country” means a country or territory outside of Brazil.
    1. We will only share your Personal Data with third parties or international organizations outside of Brazil when we have a legal basis to do so, such as to provide our services or because we ourselves use service providers (operators) outside of Brazil to operate our business.
    1. Whenever we transfer your personal data outside of Brazil to a third country or international organization, we ensure that a similar degree of protection is afforded to it by ensuring that at least one or more of the following applies:

     

    Transfers to suitable territories

     

    We may transfer your Personal Data to territories that have been deemed to provide an adequate level of protection for personal data by the National Data Protection Authority (ANPD).

    Transfers subject to appropriate safeguards

    We may transfer your Personal Data when we implement “adequate safeguards” as set out in ANPD Resolution CD/ANPD No. 19. This may include the following:

    1. Binding corporate rules implemented within the Levante Affiliates Group (if any)
    2. Standard Contractual Clauses specified in ANPD Resolution CD/ANPD No. 19;
    3. Specific Contractual Clauses

    Restricted transfers based on derogations

     

    In certain limited cases, where we cannot, for whatever reason, apply appropriate safeguards and the transfers are not to an appropriate territory or international organization, we may rely on certain exemptions provided for in the LGPD and in situations where transfers may be necessary for a defined set of reasons. These reasons include:

    1. where you have given your explicit consent to the proposed transfer, after having been informed of the possible risks of such transfers for you as the data subject due to the absence of an adequacy decision and appropriate safeguards;
    2. the transfer is necessary for the performance of a contract between you and Levante Affiliates or the implementation of pre-contractual measures taken at your request;
    3. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between Levante Affiliates and another natural or legal person (e.g. overseas lottery agents/authorities)
    4. The transfer is necessary for the establishment, exercise or defense of legal claims.

    Furthermore, we may carry out restricted transfers in certain  specific  or limited cases if the transfer is not repetitive, concerns only a limited number of data subjects, is necessary for the purposes of compelling legitimate interests pursued by Levante Affiliates which are not overridden by your interests or rights and freedoms, and Levante Affiliates has assessed all the circumstances surrounding the data transfer and, based on that assessment, has provided appropriate safeguards with regard to the protection of Personal Data.

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    1. AUTOMATED DECISION MAKING (INCLUDING PROFILING) AND USE OF ARTIFICIAL INTELLIGENCE (AI)
    1. “Automated decision-making” is the processing of a decision by automated means without any human involvement. A decision is therefore automated only if there is no significant contribution from a human being in the final decision made about a person. In most cases, we do not use automated decision-making when processing Personal Data, as decisions will usually involve human involvement. If this changes, we will confirm this to you and provide you with meaningful information about the logic involved, as well as its significance and the anticipated consequences for you. However, certain third parties (e.g., credit reference agencies) may use certain automated decision-making tools or software, including artificial intelligence (see below). We are not responsible for any automated decision-making by third parties (see section 14 of this Privacy Policy), but we may take reasonable steps to draw your attention to such automated decision-making.
    1. “Profiling” means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. The context of our profiling activities is generally limited to assigning risk profiles to our clients based on AML obligations, but we may use artificial intelligence in certain cases to analyze and predict trends related to gaming behavior (particularly in the context of our responsible gaming obligations). Relevant exemptions from the LGPD allow us to carry out such activity without the need to provide you with further information if it is in the context of assigning risk profiles and reducing financial crimes, as this may infringe trade or industrial secrets. We reserve the right to refuse to do business with any client, and our non-acceptance or discontinuation of services may or may not be related to a profiling decision and/or legal obligation(s) imposed on us.

    Artificial Intelligence (AI)

     

    1. Artificial intelligence (“AI”) refers to when a machine can demonstrate intelligence (i.e., learning, reasoning, understanding concepts and pattern recognition, etc.) through the analysis of input data and information. This allows the use of  machine learning to synthesize, make inferences, and even solve problems. Generative AI typically uses large language models (LLMs), and some applications create generative pre-trained transformers (GPTs). While generative AI transforms machine learning inputs into content, predictive AI uses machine learning to attempt to predict the future and prevent bad outcomes by using data to identify early warning signs.
    1. When AI makes decisions and there is no human involvement (beyond the input stage), this is considered fully automated decision-making, as defined above. However, when the final decision is subject to human intervention or involvement, this is not considered automated decision-making.
    1. From time to time, we may make use of these automated technologies by implementing processing that uses AI to analyze and predict trends and recognize patterns. In most cases, we will use Aggregated Data as input for the use of AI technology, and AI will not be used as a method of collecting Personal Data. However, we will leverage the benefits of AI in our decision-making processes and, therefore, we will use AI in our processing of Personal Data to fulfill certain processing purposes and needs, such as complying with our AML and responsible gaming obligations, or to generate relevant marketing content, promotions, or strategies. To this end, Levante Affiliates may make decisions about the desired output of the AI models (i.e., what is being predicted or classified) or about which features will be used in such models, and in these cases, it will remain a controller. In other cases, Levante Affiliates may be a joint controller with the third party providing the AI system and will provide further information through separate privacy notices explaining the joint controller arrangement to data subjects.
    1. As explained in more detail in Section 11 of this Privacy Policy, you have the right not to be subject to a decision based solely on automated processing, including profiling (i.e., without human intervention). This means that you can request a human review of a decision made about you using automated processing, including through the use of AI. Levante Affiliates monitors the use of AI to ensure that your privacy rights are protected and conducts data protection impact assessments (“DPIAs”) where appropriate. Furthermore, while Levante Affiliates takes all reasonable steps to ensure that the output of AI systems is not incorrect or misleading as to any matter of fact, the accuracy of AI systems is not guaranteed, as errors may occur at the input stage (e.g., human error) and/or at the processing stage (e.g., errors in specific algorithms or LLMs, or in the reading of illegible or difficult-to-read text). These errors may result in accuracy issues and incorrect inferences from the input data. To mitigate this, Levante Affiliates will implement reasonable measures, including but not limited to:
    1. carrying out DPIAs and other due diligence on AI systems and providers;
    2. ensure that any incorrect results from AI systems can be quickly identified and corrected;
    3. consider the impact of potentially incorrect inferences on decisions to be made about data subjects;
    4. consider potential biases in how variables are measured, labeled, or aggregated, including the potential for discrimination by developers and/or users of AI systems; and
    5. striving to use AI in decision support in most cases, with limited use of AI in automated decision making .

     

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    1. DATA SECURITY
    1. The unauthorized, accidental, or unlawful destruction, loss, alteration, disclosure, or access to Personal Data is known as a “data breach.” We implement appropriate physical, technical, and administrative security measures to prevent and address data breaches when they occur. These measures include internal policies regarding data breach prevention and internal/external reporting (as necessary), as well as physical and IT security measures to monitor and restrict processing. Additionally, we limit access to your Personal Data to employees, agents, contractors, and other third parties who have a business need to know. These individuals will only process your Personal Data in accordance with our instructions and are subject to duties of confidentiality and compliance with our data protection procedures.

     

    1. We undertake to inform you, to the extent we are obliged to do so, if your personal data is compromised and, as a result, there is a high risk to your rights and freedoms.

     

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    1. DATA RETENTION
    1. We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including:
    1. maintain business records for the purpose of satisfying any legal, accounting or reporting requirements;
    2. comply with record retention requirements under relevant laws
    3. exercise, establish or defend legal claims; or
    4. Handling complaints about our services

     

    1. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

     

    1. By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least five years after they cease to be customers in the context of our AML obligations.

     

    1. We may retain your Personal Data for longer periods when such retention is necessary for compliance with a legal obligation to which we are subject or when another legal basis applies. For example, when Personal Data is collected pursuant to a contract or before the creation of a contract, we may retain it for a period of 6 years after the termination of the contract, in accordance with our legitimate interests in defending any legal claims that may be brought against us, or that we may wish to bring.

     

    1. After the relevant period we have determined is appropriate for retaining your Personal Data, we will delete or anonymize such Personal Data. If, for technical reasons, we are unable to delete or anonymize such Personal Data (partially or fully), we will implement appropriate measures to prevent further processing, discontinuing such data and  /or implementing pseudonymization where possible.

     

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    1. YOUR RIGHTS AS A DATA SUBJECT

    General

    1. You have certain rights under the LGPD, which are explained in this section.

     

    1. Confirmation that your personal data is being processed
      1. You have the right to receive confirmation about the processing of your Personal Data (and, if you have not provided it to us, information about the source) and this Privacy Policy aims to provide you with the necessary information.
    1. Data access
      1. You also have the right to access the information we hold about you (commonly known as a “data subject access request”). We are happy to provide you with details of your Personal Data that we hold or process, provided this does not adversely affect the rights of others or reveal your Personal Data (unless they consent). It is important to note that this right does not provide the right to access documents, but only a copy of your Personal Data and certain  supplementary information , most of which is already contained in this Policy.
    1. Correction of incomplete, inaccurate or outdated data
      1. You have the right to have any inaccurate Personal Data about you rectified and to have any incomplete Personal Data about you completed.
    1. The accuracy of your information is important to us. Please see Section 13 of this Privacy Policy for your duty to inform us of changes. We may need to verify the accuracy of the new data you provide.
    1. Deletion of personal data
      1. You have a general right to request the deletion of your Personal Data in the following circumstances:
    1. the Personal Data is no longer necessary for the purpose for which it was collected;
    2. you withdraw your consent to processing based on consent and no other legal justification for the processing applies; or
    3. Deletion is necessary to comply with a legal obligation that applies to us
    1. We will continue to comply with a deletion request without delay and to the extent we are able to do so. However, please note that your right to deletion is a qualified right and does not apply when continued retention is necessary to:
    1. comply with a legal obligation under Brazilian law or other law to which we may be subject; or
    2. the establishment, exercise or defense of legal claims.
      1. Additionally, we may not always be able to comply with your deletion request for specific legal or operational reasons which will be notified to you, if applicable, at the time of your request.
    1. Right to restriction of processing 
      1. You have the right to ask us to restrict the processing of your Personal Data in the following situations:
    1. you contest the accuracy of the Personal Data;
    2. where the processing is unlawful, you may request, instead of requesting erasure, that we restrict the use of the unlawfully processed personal information;
    3. We no longer need to process your personal information, but we need to retain your information for the establishment, exercise or defense of legal claims.
    4. You have exercised your right to object (see below) and are awaiting the verification whether our legitimate grounds (or those of a third party) override your interests, rights and freedoms.
    1. If you exercise this right, we may only store the Personal Data and may not further process it without your consent, unless the processing is for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest. We will also need to inform you before a processing restriction is lifted.
    1. Right to data portability

     

    1. Where the legal basis for our processing is your consent, or the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have the right to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
    1. Right of opposition 
    1. Right to freedom from direct marketing (opting-out):

    You have the right to opt out of receiving our direct marketing, also known as “ opting out .” You can exercise this right at any time by contacting us. You can ask us to stop sending you marketing messages at any time by following the unsubscribe or “ unsubscribe ” links in any electronic marketing messages/materials sent to you or SMS you receive from us, or by changing your marketing preferences in the My Account section of your account. When you opt out of marketing , we may need to retain your data to ensure we no longer send you marketing. Exercising your right to opt out does not affect our ability to contact you other than for direct marketing purposes (e.g., to notify you of changes to our terms of service, any problems with your account, or to request any information we may require to comply with our AML obligations).

    1. Except in cases of objection to direct marketing, where your right to refuse to receive marketing communications persists, and if you exercise your right to object, we will stop processing your Personal Data unless there are compelling legitimate grounds for the processing that override your interests, or we need to process your Personal Data to establish, exercise, or defend legal claims. Please note that exercising your right to object may affect the services we can provide, and we will explain this to you if you decide to exercise this right. If you still wish to exercise your right to object, we may have to close your account or cancel a bet you have placed with us, but we will notify you if this is the case at the time.
    1. Right to freedom from automated decision-making 

     

    1. You have the right not to be subject to a decision based solely on automated processing, including profiling (i.e. without human intervention), which produces legal effects concerning you or similarly significantly affects you.
    1. This provision does not apply if the decision:
    1. is necessary for the conclusion or performance of a contract between you and Levante Affiliates
    2. is required by Brazilian law; or
    3. is based on your explicit consent.
    1. Levante Affiliates will implement appropriate measures to protect your rights and freedoms and legitimate interests. These measures must include, at a minimum, the right to obtain human intervention and to express your point of view and contest the decision.
    1. Revocation of consent 

     

    1. Where the legal basis for processing your Personal Data is your consent, you have the right to withdraw that consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal) by contacting us using the details found in section 2 of this Privacy Policy.

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    1. EXERCISING YOUR RIGHTS

    Contact

    1. If you wish to exercise any of the rights set out above, please contact the DPO using the details set out in section 2 of this Privacy Policy.

     

     

    What we might need from you

     

    1. In certain cases (for example, when we don’t recognize an email address), we may need to request specific information from you to help us confirm your identity (or the authority of anyone purporting to act on your behalf). This is a security measure to ensure that Personal Data is not disclosed to anyone who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

    Deadline to respond

     

    1. We try to respond to all legitimate requests within 15 days. Occasionally, it may take longer than this if your request is particularly complex or if you have made multiple requests, and we may extend the timeframe for our response by an additional 15 days. In these cases, we will notify you of any extension within 10 days of receiving the request, along with the reasons for the delay, and keep you updated.

     

    Electronic form

     

    1. When you make your request electronically, our response will be provided by electronic means wherever possible, unless otherwise requested by you.

     

    Extent of our obligations to other recipients

     

    1. We will communicate the restriction, rectification, or erasure of Personal Data to each recipient to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate effort. In particular, for deletion requests , when we have made Personal Data public and intend to erase the Personal Data, we will take reasonable steps (taking into account available technology and the cost of implementation), including technical measures, to inform other controllers processing the Personal Data that you have requested https://www.levanteaffiliates.com.br/en/privacity-policy#topdeletion.

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    1. YOUR DUTY TO INFORM US OF CHANGES
    1. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If any of your personal data is or becomes incorrect, you can update it in the “My Account” section or contact our Customer Service team by email at [email protected].

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    1. CHANGES TO THIS PRIVACY POLICY
    1. We may update this Privacy Policy from time to time by posting a new version on our website or app. We may choose to notify you of significant changes to this Privacy Policy by email (if you are a customer or subscribed to our email lists), and we will also update the “ Last Updated ” field at the top of this Privacy Policy.
    1. The new version of the Privacy Policy will, however, come into effect immediately after its publication on our Website/App.

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    1. ADDITIONAL TERMS

    Third-party links

    1. This website or application may include links to third-party websites, plug-ins, and applications (e.g., Facebook, Twitter, etc.). Clicking on these links or enabling these connections may allow third parties to collect or share your Personal Data.
    1. We are not responsible for the privacy practices of third parties, and you are encouraged to familiarize yourself with the privacy practices of any third-party websites you visit or any third-party with whom you enter into any contracts. Likewise, we do not control third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policies/notices of every website you visit.

    No services for children

    1. Protecting children’s privacy is important to us. For this reason, we do not collect or maintain information on our website from people we actually know are under 18 (notwithstanding any legal definition of “child” or “children” or other legislation that establishes a lower age for a person to be considered a child). No part of our website is directed to attract anyone under 18. We request that all visitors to our website under the age of 18 not disclose or provide any personal information (including when attempting to open an account) and that they discontinue using our website.

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