Legal

Privacy Policy

Last Updated: [DATE]

1. Introduction

Welcome to VerifiedGamblers ("VerifiedGamblers", "VG", "we", "us", or "our"). This Privacy Policy explains how VerifiedGamblers collects, uses, stores, discloses, and protects personal information when you access or use our website, platform, services, and related communications (collectively, the "Services"). VerifiedGamblers operates an online intermediary and information platform that facilitates connections between eligible players and streamers in connection with affiliate-based account registrations with third-party operators. We are committed to handling personal information responsibly and transparently. This Privacy Policy applies to information processed through the VerifiedGamblers platform and related Services. It does not govern the privacy practices of third-party casinos, gaming operators, affiliate platforms, payment providers, blockchain networks, or other third parties that operate independently from VerifiedGamblers.

2. Data Controller

The data controller responsible for processing your personal information is:

[FULL LEGAL COMPANY NAME]

[LEGAL FORM]

[REGISTERED ADDRESS]

[CITY, STATE/COUNTRY, ZIP]

[REGISTRATION NUMBER, IF APPLICABLE]

Email: [PRIVACY EMAIL ADDRESS]

Telephone: [PHONE NUMBER, IF APPLICABLE]

For privacy-related questions or requests, please contact us using the contact information above.

Data Protection Officer: [TO BE COMPLETED IF APPLICABLE]

If required under applicable data-protection law, VerifiedGamblers will identify an applicable representative or data-protection contact for users in relevant jurisdictions.

3. Who Can Use the Platform

VerifiedGamblers supports different categories of users, including:

Players — Players may register on the platform, provide information relating to their gaming activity and account registrations, participate in matching with eligible streamers, and receive cashback where applicable.

Streamers — Streamers may register, undergo platform verification, provide information regarding their streaming channels and affiliate relationships, purchase or use platform Credits, and enter into agreements with players.

Administrators — VerifiedGamblers administrators have internal access to information necessary for platform administration, verification, contractual administration, compliance, support, accounting, security, and payout-related functions.

4. Personal Information We Collect

The categories of information we collect depend on how you use the Services.

4.1 Information Provided by Players

Depending on your use of the platform, we may collect:

Email address;
Gaming-account or account name used with a third-party operator;
Information concerning self-reported wagering categories, such as Slots, Sports, Live, Table, House, Dice, or similar categories;
Self-reported wagering or qualifying volume;
Current casino or other third-party operator;
Preferred third-party sites or operators;
Screenshots, documents, or other proof uploads relating to registration or qualifying activity;
Public cryptocurrency wallet receiving address;
Cryptocurrency, blockchain network, and, where applicable, destination tag or memo;
A short "About Me" profile description;
Referral information, including referral codes and referred users;
Contractual information;
Agreed and delivered volume;
Cashback amounts and related accounting information;
Communications and messages sent through the platform;
Support requests and other information you voluntarily provide.

Proof uploads may potentially contain additional information, including account balances, names, payment information, or other information visible in the submitted material. Users should avoid submitting unnecessary personal information.

4.2 Information Provided by Streamers

Depending on your use of the platform, we may collect:

Email address;
Streaming-platform or channel URL;
Information concerning affiliate relationships and deals;
Third-party operator information;
Affiliate codes and referral links;
Public cryptocurrency wallet receiving address;
Cryptocurrency and blockchain network;
Credit purchase or top-up information;
Amount and currency of Credit purchases;
Blockchain transaction hash;
Verification status and verification records;
Information concerning verification dates and verification personnel;
Contractual information;
Agreed volumes;
Reserved and consumed platform Credits;
Communications and support requests.

4.3 Technical and Account Information

We may also process information necessary to operate and secure the platform, including:

Password hashes;
Login attempts;
Password-reset tokens;
Consent records;
Platform messages and chats;
Administrative audit logs;
Timestamps;
Administrative actions and relevant before/after values;
Support tickets and support communications.

We do not store users' private cryptocurrency keys or seed phrases.

5. How We Use Personal Information

We process personal information for purposes including:

Account creation and authentication — We use information to create and maintain user accounts, authenticate users, provide verification codes, and facilitate password recovery.

Platform operation — We use information to provide the Services, operate user profiles, facilitate eligible player/streamer matching, and enable platform functionality.

Verification — We may review information and proof submitted by users to verify eligibility, registrations, qualifying activity, platform participation, and other requirements applicable to the Services.

Contract administration — We process information necessary to establish, administer, perform, and document agreements between users and/or between users and VerifiedGamblers.

Cashback and Credits — We process contractual, accounting, wallet, transaction, and related information to administer player cashback, streamer Credit purchases, and applicable refunds or other payments.

Communication — We use email addresses and other contact information to send verification messages, account notifications, status updates, rejection notices, support responses, and other service-related communications.

Security and fraud prevention — We process technical and account information to protect the platform, detect misuse, investigate suspicious activity, maintain account security, and prevent unauthorized access.

Compliance — We may process information to comply with applicable legal obligations, regulatory requirements, court orders, governmental requests, sanctions requirements, age-related requirements, anti-money-laundering obligations where applicable, and other compliance requirements.

Record keeping and auditing — We maintain appropriate records concerning platform activity, consents, administrative actions, contractual relationships, and other activities where necessary for legal, security, accounting, compliance, or evidentiary purposes.

Customer support — We use information submitted through support requests to respond to questions, investigate issues, and provide customer service.

6. Legal Bases for Processing

Where the General Data Protection Regulation ("GDPR") or similar data-protection legislation applies, VerifiedGamblers will process personal information on an applicable legal basis, including where appropriate:

performance of a contract or taking steps at the user's request before entering into a contract;
compliance with a legal obligation;
legitimate interests of VerifiedGamblers or a third party, provided those interests are not overridden by applicable rights and freedoms;
consent, where consent is required or relied upon; and
other lawful bases available under applicable law.

The specific legal basis may differ depending on the category of information and the purpose for which it is processed. Where processing is based on consent, you may withdraw your consent at any time, subject to applicable legal limitations and the consequences of withdrawal.

[LEGAL COUNSEL TO COMPLETE/CONFIRM SPECIFIC ART. 6 LEGAL BASES FOR EACH PROCESSING PURPOSE.]

7. Chat and Communications

VerifiedGamblers provides communication functionality between users whose interaction has been enabled through the platform. Platform chats may be accessible to VerifiedGamblers administrators. This access exists for purposes including:

platform administration;
dispute resolution;
security;
abuse prevention;
contractual administration;
compliance;
investigation of suspected misuse; and
protection of VerifiedGamblers and its users.

Users should therefore not assume that platform chats are private or confidential from VerifiedGamblers. VerifiedGamblers may use automated filtering and masking mechanisms to detect and mask certain personal information in chats and profile text, including certain email addresses, links, telephone numbers, and specified name information.

8. Information We Receive From Third Parties

Where applicable, VerifiedGamblers may receive or process information connected to third-party operators, affiliate relationships, payment or blockchain infrastructure, verification services, or other service providers. Third-party operators operate independently of VerifiedGamblers. Their own privacy policies govern their processing of personal information on their respective websites and platforms. If you register with or interact with a third-party casino, gaming operator, affiliate platform, or other external service, that third party may independently collect and process information about you. VerifiedGamblers does not control the privacy practices of such third parties.

9. Cryptocurrency and Blockchain Information

VerifiedGamblers may use cryptocurrency-related infrastructure in connection with platform Credits, cashback, refunds, or other permitted transactions. We may process:

public cryptocurrency wallet addresses;
cryptocurrency type;
blockchain network;
transaction amounts;
transaction hashes;
applicable destination tags or memos; and
related transaction records.

VerifiedGamblers does not collect or store private cryptocurrency keys or seed phrases. Cryptocurrency transactions may be recorded on public blockchains. Blockchain transactions may be permanent and may be accessible to third parties independently of VerifiedGamblers. A blockchain wallet address may be capable of being associated with an identifiable person under certain circumstances. Accordingly, VerifiedGamblers may treat wallet-related information as personal information where applicable law requires. Before applicable payouts, VerifiedGamblers may conduct sanctions or wallet screening through an appropriate third-party service.

[LEGAL COUNSEL / COMPLIANCE PROVIDER TO CONFIRM APPLICABLE CRYPTOCURRENCY AND SANCTIONS PROCESSING REQUIREMENTS.]

10. Sharing Personal Information

VerifiedGamblers may disclose personal information to third parties where necessary for the operation of the Services, legal compliance, contractual administration, or other lawful purposes. Potential categories of recipients include:

Service Providers — Service providers supporting: hosting; databases; file storage; email delivery; security; verification; cryptocurrency infrastructure; wallet or sanctions screening; customer support; and other technical or administrative functions. Such providers may process information on behalf of VerifiedGamblers where applicable.

Cryptocurrency and Wallet Infrastructure — Where required to process transactions, relevant public wallet information, transaction information, and amounts may be shared with cryptocurrency infrastructure providers.

Sanctions / Wallet Screening Providers — Where implemented, recipient wallet addresses may be submitted to a sanctions or blockchain/wallet screening provider before a payout. [PROVIDER TO BE IDENTIFIED BEFORE LAUNCH.]

Third-Party Operators — VerifiedGamblers facilitates interactions involving third-party casino, gaming, or affiliate operators. Where applicable, information may be transmitted to or collected by such third parties in connection with registration or affiliate activities. The exact information shared with each operator depends on the applicable integration and business arrangement. [LEGAL COUNSEL TO CONFIRM THE EXACT ROLE OF VERIFIEDGAMBLERS AND THE DATA SHARING ARRANGEMENTS WITH THIRD-PARTY OPERATORS.]

Professional Advisers and Authorities — We may disclose information to lawyers, accountants, auditors, compliance professionals, governmental authorities, courts, regulators, or law-enforcement authorities where reasonably necessary or legally required.

11. Service Providers and Data Processing

VerifiedGamblers may use third-party service providers to operate its infrastructure. These may include providers responsible for: database hosting; application hosting; file storage; email delivery; security; blockchain infrastructure; wallet screening; and other technical services. Where required by applicable law, VerifiedGamblers will enter into appropriate data-processing agreements with processors. Current infrastructure includes structured database storage and a file-storage environment for uploaded proof files. [FINAL DATABASE PROVIDER, HOSTING PROVIDER, EMAIL PROVIDER, AND OTHER PROCESSORS TO BE INSERTED BEFORE PUBLICATION.]

12. International Data Transfers

VerifiedGamblers may operate across multiple jurisdictions and may use service providers located outside the country in which a user resides. Where the GDPR or another law governing international transfers applies, VerifiedGamblers will implement an appropriate legal mechanism for transferring personal information to a third country, where required. Depending on the circumstances, this may include:

an adequacy decision;
Standard Contractual Clauses;
appropriate contractual safeguards;
another legally recognized transfer mechanism; or
an applicable exception under law.

[LEGAL COUNSEL TO CONFIRM ALL INTERNATIONAL TRANSFER MECHANISMS, INCLUDING ANY EU/US OR OTHER THIRD-COUNTRY TRANSFERS.]

13. Data Retention

VerifiedGamblers retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. Retention periods may depend on:

the type of information;
the purpose for which it was collected;
whether an account or contractual relationship remains active;
legal and regulatory obligations;
accounting requirements;
dispute resolution;
fraud prevention;
security requirements; and
the establishment, exercise, or defense of legal claims.

Certain records, including consent records and administrative/audit records, may need to be retained for evidentiary, compliance, security, or legal purposes even after other account information has been deleted. [LEGAL COUNSEL TO INSERT SPECIFIC RETENTION PERIODS.]

14. Deletion of Information

VerifiedGamblers maintains mechanisms that allow applicable account and content information to be deleted. Uploaded proof files are stored in an environment capable of hard deletion, allowing applicable files to be physically removed from the storage system. When an account or its content is deleted, certain administrative, security, audit, consent, accounting, or legally required records may remain where retention is required or permitted by applicable law. Deletion therefore does not necessarily mean that every record associated with a user can immediately be erased.

15. Your Privacy Rights

Depending on your location and applicable law, you may have rights including:

the right to request access to your personal information;
the right to request correction of inaccurate information;
the right to request deletion of personal information;
the right to request restriction of processing;
the right to object to certain processing;
the right to data portability;
the right to withdraw consent where processing is based on consent; and
the right to lodge a complaint with a competent data-protection supervisory authority.

These rights are subject to applicable legal limitations and exceptions. To exercise a privacy right, contact: [PRIVACY EMAIL ADDRESS]. We may need to verify your identity before fulfilling certain requests in order to protect user accounts and personal information. [LEGAL COUNSEL TO INSERT PROCEDURE AND APPLICABLE RESPONSE DEADLINES.]

16. Children's Privacy

VerifiedGamblers is intended only for users who are legally permitted to use the Services in their jurisdiction. The platform is not intended for persons below the applicable minimum legal age. The applicable minimum age may differ depending on the user's jurisdiction and the underlying activity. Users must provide truthful information concerning their eligibility and age where requested. The current platform uses email verification. A separate comprehensive KYC-based age-verification system may not be implemented in all circumstances. Users who do not satisfy the applicable age or eligibility requirements must not use the Services. [LEGAL COUNSEL TO CONFIRM THE APPLICABLE AGE REQUIREMENTS AND WHETHER ADDITIONAL AGE/KYC VERIFICATION IS REQUIRED.]

17. Responsible Use

VerifiedGamblers operates in a gambling-related environment but does not itself provide gambling services. Third-party operators are independently responsible for their own services, licensing, age requirements, responsible-gambling procedures, and compliance obligations. Users should review the applicable terms, privacy policies, responsible-gambling information, and legal requirements of any third-party operator before registering or participating. Where applicable, responsible-gambling information may be provided through the VerifiedGamblers website.

18. Cookies and Similar Technologies

VerifiedGamblers may use cookies and similar technologies that are necessary for the operation, security, authentication, and functionality of the website. If VerifiedGamblers uses analytics, advertising, tracking, or other non-essential technologies, additional information and, where required, consent mechanisms will be provided. [TO BE COMPLETED: CONFIRM WHETHER GOOGLE ANALYTICS, META PIXEL, ADVERTISING TECHNOLOGIES, SESSION RECORDING, OR OTHER TRACKING TECHNOLOGIES ARE USED.]

19. Data Security

VerifiedGamblers uses reasonable technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, destruction, or loss. Security measures may include:

authentication controls;
password hashing;
access controls;
administrative audit logs;
secure infrastructure;
restricted administrative access;
file-storage controls;
automated masking of certain personal information; and
security monitoring.

No internet-based service can guarantee absolute security. Users are responsible for maintaining the confidentiality of their login credentials and must notify VerifiedGamblers if they suspect unauthorized access to their account.

20. Data Breaches

If VerifiedGamblers becomes aware of a personal-data breach, we will assess the incident and take steps required by applicable law, including notifying affected users or relevant authorities where legally required.

21. Third-Party Websites and Services

The VerifiedGamblers website may contain links to third-party websites, operators, streaming platforms, affiliate services, or other external services. Once you leave VerifiedGamblers or interact directly with a third party, that third party's privacy policy and terms may apply. VerifiedGamblers is not responsible for the privacy practices, security, content, or data-processing activities of third-party websites and services.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our Services, technology, legal requirements, or business practices. When we make material changes, we may provide additional notice where required by applicable law. The "Last Updated" date at the beginning of this Privacy Policy indicates when this Privacy Policy was most recently revised.

23. Contact

If you have questions about this Privacy Policy or wish to exercise a privacy right, please contact us: