1.1. Who We Are

1.2. Purpose

1.3. Scope

1.4. Review and Changes

We collect and process the following categories of personal data:

• Identity Data: full name, date of birth, government-issued ID (passport, driving licence).
• Contact Data: email, phone number, home address.
• Financial Data: payment details, deposit and withdrawal history, source of funds/wealth.
• Account & Usage Data: username, login credentials, betting and gaming history, session logs, IP addresses.
• Compliance & KYC Data: AML checks, sanctions/PEP screening, self-exclusion data (GamStop).
• Technical Data: device type, browser, OS, cookies, and tracking identifiers.
• Special Category Data: information about self-exclusion, affordability, or problem gambling behaviours where necessary to meet regulatory obligations.
• Communications Data: emails, live chats, call recordings (for compliance, training, and dispute resolution).

We may share your personal data with:

• Regulatory authorities: Gambling Commission, HMRC, NCA, law enforcement.
• Verification providers: identity, AML, sanctions screening.
• Payment service providers: banks, card processors, e-wallets.
• Responsible gambling schemes: GamStop, GAMCARE, or blocking tools.
• Alternative dispute resolution services: ProMediate Ltd
• Technology partners: IT hosting, cloud storage, cybersecurity monitoring.
• Marketing partners: Only where explicit consent is given.
• Data Sharing for Sports Integrity: UKGC, Sporting National Governing Bodies or Betting Integrity Associations

All third parties are bound by Article 28 GDPR data processing agreements.

If your data is transferred outside the UK, we ensure safeguards are in place, including:

• UK Addendum to EU Standard Contractual Clauses (SCCs)
• Adequacy regulations recognised by the UK Government
• Technical and organisational controls to ensure equivalent protection.

We retain personal data only as long as necessary for regulatory, legal, and contractual purposes:

• Customer account & betting data: 5 years after account closure (UKGC LCCP).
• AML/CTF data: 5 years after end of business relationship (MLR 2017).
• Self-exclusion data: Minimum 7 years.
• Financial records: 5 years for audit and tax.
• Complaints/disputes: Minimum 5 years from resolution.
• Marketing data: until consent is withdrawn.

We use cookies and similar tracking technologies:

• Essential cookies: Required for account security and service operation.
• Analytics cookies: To improve our services (with consent).
• Marketing cookies: Only if you opt-in.

We comply with the Privacy and Electronic Communications Regulations (PECR). See our Cookie Policy for details.

We use automated tools to:

• Detect fraud and suspicious activity
• Identify underage or self-excluded customers
• Monitor responsible gambling behaviours

All automated processes are subject to human oversight, and you have the right not to be subject to solely automated decisions (Article 22 UK GDPR).

We do not knowingly collect data from anyone under 18. If such data is inadvertently processed, it will be deleted immediately.

We maintain an ISO 27001:2022 certified ISMS and comply with UKGC RTS 4: Information Security.

Controls include:

• Data encryption in transit and at rest
• Multi-factor authentication (MFA)
• Role-based access controls
• Continuous monitoring and logging
• Regular penetration testing and security audits.

You have the right to:

• Access your data (Art. 15 GDPR)
• Rectify inaccuracies (Art. 16)
• Erasure where lawful (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)
• Withdraw marketing consent at any time
• Not be subject to decisions based solely on automated processing (Art. 22)

Some rights may be restricted where required by UKGC or AML regulations.

If you are unhappy with how we process your data, you can contact our DPO at dpo@reelmoney.bet.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: www.ico.org.uk
• Phone: 0303 123 1113

Kairos Edge Limited

Sussex Innovation Centre Science Park Square, Falmer, Brighton, England, BN1 9SB

Email: support@updates.reelmoney.bet