Privacy

Introduction

Bigbat (the “Company”, “we”, “our”) processes personal data in connection with its online gambling services. This Privacy Policy explains what personal data we collect, the purposes for processing, the legal bases we rely on, how data is shared and protected, and the rights you may exercise. The policy applies to customers, site visitors and any individuals whose data we process in relation to Bigbat’s services, including via websites and mobile apps. We comply with applicable data protection laws, including GDPR where those laws apply.

Scope and Application

This Privacy Policy covers personal data that you provide to us, data generated through use of our services, and data collected from other sources as described herein. It governs how we collect, store, use, disclose and retain your information as the data controller responsible for your personal data.

Privacy Principles

• Lawfulness, fairness and transparency: we identify lawful grounds for processing and communicate clearly how we use your data.
• Purpose limitation: we process data only for identified purposes and as long as needed.
• Data minimisation: we collect only data that is adequate and relevant to the purposes pursued.
• Accuracy: we take reasonable steps to ensure data is correct and up to date.
• Storage limitation: we retain data in accordance with legal and regulatory requirements.
• Integrity and confidentiality: we implement appropriate technical and organizational measures to protect data.
• Accountability: we maintain records demonstrating compliance with this Policy.

The Data We Collect

Registration and Account Information

When you create an account with Bigbat, we collect: full name, date of birth, residential address, email address, phone number, username and password, and other contact details. Some data may be mandatory to complete the account opening and to enable age and identity verification. We may also collect details relevant to your gaming account, such as self-exclusion status and betting limits.

Identity Verification and Compliance Data

To comply with licensing, anti‑money laundering (AML) and responsible gaming obligations, we collect and may verify documents such as government-issued identification and proof of address. We may obtain information from third-party verification providers and may perform background checks to confirm identity and age, assess source of funds and detect potential risks.

Usage and Technical Data

We automatically collect data about your use of our services, including IP address, device identifiers, browser type, language, time and date of access, pages viewed, and how you interact with the platform. We also record login times, betting activity, navigation paths, and preferences to maintain security and improve the service.

Financial and Transaction Data

We process data related to deposits, withdrawals, payment methods, transaction history, and related account details. We may tokenize payment data and rely on trusted payment service providers to process transactions securely. We also record balance changes, wagering activity and bonus-related transactions.

Communications and Support

We keep records of communications with our customer support team, including requests, responses and feedback, to manage the relationship and improve service quality.

Other Data

We may collect information from surveys, promotions, or interactions you undertake within our platforms, and data derived from automated systems such as analytics or risk assessments.

How We Use Personal Data

• To provide, operate and maintain Bigbat’s services, including executing bets and processing transactions.
• To verify identity and age and to comply with AML/CFT and licensing obligations.
• To detect and prevent fraud, money laundering, and other prohibited activities; to manage risk and ensure game integrity.
• To protect the security of our systems and users, including monitoring for unusual or unlawful activity.
• To communicate with you about your account, transactions, updates, and regulatory notices.
• To personalise your gaming experience and improve services through analytics and research.
• To support responsible gaming initiatives, including self‑exclusion and limits management.
• To provide marketing communications where you have consent or where permitted by law; you may opt out at any time.

Legal Bases for Processing

• Contractual necessity: processing required to provide and administer the service you request.
• Legal obligation: processing to comply with licensing, AML/CFT, anti-fraud and consumer protection laws.
• Consent: where required for direct marketing or certain processing activities.
• Legitimate interests: for security, fraud prevention, service improvement, and risk management, provided that these interests do not override your rights and freedoms.

Data Sharing and International Transfers

We may disclose personal data to service providers (e.g., payment processors, identity verification services, IT support, analytics, and security providers), auditors, legal counsel, and regulatory bodies as required. We may share information within the Bigbat corporate group for the purposes described in this Policy. We may also disclose data to law enforcement or regulators where legally required or to protect rights and safety. When data is transferred internationally, we implement appropriate safeguards, including the use of Standard Contractual Clauses and other lawful transfer mechanisms to protect your information. Some recipients may be located outside your jurisdiction; in such cases we ensure equivalent privacy protections are in place as required by applicable law.

Data Retention

We retain personal data for as long as necessary to provide services and for legitimate business purposes, including regulatory obligations. In general, data related to your account, transactions, and identity verifications is retained for up to five to ten years after account closure, in accordance with applicable laws. Certain data may be retained longer where required by law or for dispute resolution and fraud prevention; health-related data is retained only as long as necessary for regulatory obligations and is deleted when no longer needed.

Your Rights

• Access: you may request access to your personal data held by Bigbat.
• Rectification: you may request correction of inaccurate or incomplete data.
• Erasure: you may request deletion of data where there is no legal basis for its continued processing.
• Restriction: you may request limitation of processing under certain circumstances.
• Portability: you may request a portable copy of your data in a structured, commonly used format.
• Objection and automated processing: you may object to processing based on legitimate interests or withdraw consent where applicable; you may request human review for automated decisions where consent or rights are affected.
• Marketing choices: you may opt out of marketing communications at any time.
• Rights enforcement: you may lodge a complaint with a supervisory authority if you believe your rights are violated.

Cookies and Tracking Technologies

We use cookies, local storage and similar technologies to operate, analyse and improve our services. We classify cookies as strictly necessary, functionality, performance/analytics, and targeting/advertising. You may manage cookie preferences in your browser, or through our settings where available; note that disabling cookies may limit certain features.

Electronic Communications and Consent

By using our services, you consent to processing of data for the purposes described in this Policy. We may send essential service communications regardless of marketing preferences. Where we rely on consent for marketing, you may withdraw it at any time by adjusting your preferences or contacting us.

Security of Data

We implement technical and organizational safeguards appropriate to the data and risk, including encryption in transit and at rest, access controls, secure storage, and routine security assessments. We require third-party providers to maintain equivalent protections and to process data only for the purposes specified by Bigbat.

Protection of Minors

Bigbat services are not intended for individuals under the applicable legal age. We implement age verification and will delete or restrict data if a minor attempts to access the services or submits information inappropriately.

Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or applicable law. Material changes will be communicated clearly and, where required, with notice or consent. Continued use of the services after changes constitutes acceptance of the revised policy.

Contact Information

For questions, concerns or to exercise your rights, contact our privacy officer at [email protected]. You may also reach out to us via the securities and compliance contacts in your jurisdiction as required by applicable law.