Updated August 2020:
This policy explains how Legalbet.co.ke uses your personal data, whether you're an occasional visitor to our website or mobile app, or if you have signed into your account. There is a lot of information here so we have broken it down into bite-size sections.
Our Privacy Promise
We know that your personal information is important to you. For that reason we make the following promise to you:
Legalbet.co.ke is committed to protecting your privacy. We will only use any personal information to make things better for you. We will always keep your personal information secure. We'll be clear when we obtain your data on why we do so and how we use it. Where you have choices to make in relation to this we will explain them to you.
Our Data Protection Officer
If you have any concerns about how Legalbet handles your personal information, you can contact our Data Protection Officer by emailing [email protected].
If you wish to submit a subject access request or a request to exercise any of your rights here, please E-mail [email protected] to do so.
Collecting information about you
We may collect personal information about you whenever you use the Legalbet.co.ke website and associated products and services. Some of it is information you give us directly if you sign up or register for an account, and other information is collected as you interact with us by using our website or App or if you contact us with a query.
Information we get from you
You can browse Legalbet.co.ke a website without being required to give us any personal information, although, as we explain below we may collect some information from the device you are using. If you sign up on the site we will ask you for your email address. It is possible if you interact with the website and our staff that we ask for your name as well as e-mail address. If you contact us with a query or complaint we will, of course, record your contact information and details of your query.
Information we get from your device
We may collect information from the devices you use to access Legalbet.co.ke. This includes the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version, software, user agent, device information, preferred language, serial numbers, device motion information, mobile network information and location data.
We may collect Web server log files, which may include information such as dates and times of access, the features or pages you view, app or site crashes and other system activity, the third-party site or service you were using immediately before you came to our site, and the URL you go to immediately after leaving our site.
Information we get via Cookies
'Cookies' are small text files stored in your web browser that enable us to recognise your computer when you visit our website or our mobile app. Cookies are essential to keep certain parts of our website functioning correctly and securely. We also use them to make things quicker, easier and more personal to you, and to help us understand how our websites are used. They can also be used to present you with more tailored content or advertising.
Most cookies we use are "session cookies," which are automatically deleted at the end of a browsing session, but we also use "persistent" cookies. These stay on your hard drive and we use it to automatically recognise you as the same visitor when you return to our site or app. The cookie itself contains no personally identifiable information about you but it does pass an ID to our server which allows us to tie the cookie to you so we can update the homepage to let you know what has changed since your last visit.
The cookies we use fall into the following categories:
Strictly Necessary Cookies: Making Our Websites and Apps Work
These Cookies are essential so that you can move around our sites and log in to the secure areas. They also enable us to deliver content to you in a way that works for your device.
Without these cookies you would be unable to access your account, so if you opt-out of receiving them parts of our site will not work correctly and may not work at all. A few examples of the ways in which we use strictly necessary cookies:
Allowing you to navigate smoothly around our site;
Showing content in the best format for your device and positioning it for your screen;
keeping you logged in so that you don't have to log in each time you visit;
enabling you to stream content without having to repeatedly adjust volume and viewing settings;
Functionality cookies: Enabling the Features of the website
These cookies allow our websites to remember choices you have made, such as your user name, your preferred odds format, your marketing preferences and your region. They help us keep you logged into your account as you navigate around our websites, and enable you to use features such as resetting your user name. We also use them to personalise your experience by, for example, showing different content to regular site users and first-time visitors, giving you access to information provided by social media websites such as Twitter, or to show you 'related article' links relevant to the information you're looking at.
Without these cookies, you will still be able to use the site but might experience difficulty in using certain features, and will need to keep logging in as you navigate around our sites. You may find that the content you see on the site is not as relevant to you.
A few examples of the ways we use functionality cookies:
Remembering your preferred bookie ordering.
Remembering if you've filled in a survey, so we don't ask you to do it again.
Restricting the number of times you're shown a particular advertisement. (Sometimes called 'frequency capping'.)
Analytical Cookies - Monitoring the performance of our websites:
These cookies collect information about how people use our websites and how the sites are performing, e.g. how many people visit, which pages are most popular and whether and where people see error messages. They also ensure we can pay our commercial partners correctly for users they refer to us.
A few examples of the ways in which we use Analytical cookies:
to identify trends about how people navigate around our websites;
to help us keep our content relevant and up to date;
to count the number of times a page or email has been viewed and help us measure the effectiveness of our content and communication; and
to improve the functioning of our applications and websites.
Without these cookies, you will still be able to use and enjoy all the online features of our websites
Web Beacons ('tracking pixels')
Our websites and some of the emails we send also contain small invisible images known as 'web beacons' or 'tracking pixels'. These are used to count the number of times the page or email has been viewed and help us measure the effectiveness of our marketing. The web beacons are anonymous and do not contain or collect any information that identifies you as an individual.
Targeting Cookies - Marketing & advertising:
These cookies are used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. The Cookies remember that you have visited a website, and we share this information with a third party organisation, OptinMonster, for advertising purposes. We also use them to test and improve our products and services by, for example, trying out different product experiences with different groups of customers to see which is most popular
Without these cookies: You will be able to use and enjoy all the features of our websites but the adverts you see will not be tailored to your interests
Tracking Cookies: Online Behavioural Advertising
We sell space on some of our websites to advertisers, and the resulting adverts often contain cookies. We also place cookies to collect non-personal information about visitors to the site that we then sell to advertisers. The information allows us and them to identify you as the same online visitor, even though it does not tell them who you are. They may then use this to restrict the number of times you see the same advert and to show you adverts that are more likely to be relevant to you, based on your online activity, both on our site and on third-party websites you may visit.
Controlling my cookies
All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise, you should use the 'Help' option in your browser for more details. You may also find the links below helpful:
org (contains information about cookies on a wide variety of desktop browsers.)
Information we get from external companies
We will only work with reputable organisations that obtain their data legally in accordance with data protection law. Occasionally, we obtain lists of potential customers from companies that collate these details and make them commercially available for marketing purposes. We only deal with reputable companies that take privacy as seriously as we do and have obtained your consent to share this data with us or with companies in our sector for marketing, and you will always be able to opt-out of receiving further marketing from us.
Information we get from social media
If you raise a query or a complaint through the Legalbet.co.ke Facebook or Twitter pages, we will, of course, have a record of your user name and will use this to talk to you to resolve the matter you've raised and keep accurate records of how it was resolved.
We may use information posted publicly on social media sites to help us understand how our customers interact with us. For example, we might look at which groups of customers are more likely to contact us via social media or to use social media to talk about our products and services. We do this in a way that does not identify individual customers.
How and why we use your personal information
We use the information we hold about you in a range of different ways, which fall into these broad categories:
Things we need to do in order to provide you with the products or services you've requested
Things we need to do to meet legal or regulatory obligations
Things that enable us to run our business effectively and efficiently, and
Things we do with your consent for marketing purposes
This section explains more about each category, the rights it gives you, how to exercise them and what that means in practice.
Providing our products and services
As you would expect, we use your personal information to provide you with our products and services; respond to queries and provide you with the best possible level of customer service. We use technical information about your device, such as operating system, browser version and location to present you with the correct version of our website or app and keep it functioning securely and correctly.
To the question “Can I opt-out of having any of my data used in this way?” In short, “No”. If you don't want your data used in this way your option is to not use our services and to close your account
Running our business effectively and efficiently
There are some things we do to help us operate as a commercial organisation. We have a legitimate interest in carrying out these activities, and where they involve using your personal information, we are careful to carry them out in a way that minimises any impact on your privacy.
Data protection law gives you the right of objection to the activities in this category if your right to privacy outweighs our legitimate business interest in doing them. You always have the option to exercise this right but, as we explain in more detail below, the activities in this category are central to our business.
We carry out basic analytics to help us understand, how, when, where and why our customers use our services, and how our business is performing. This helps us monitor and plan everything from the effectiveness of our advertising through to ensuring we have enough staff available to handle queries at peak times. It also gives us a much clearer picture of our customers generally, the broad demographic groups they fit into (e.g. age group, gender, location, etc.) and the products and services they use, which in turn helps us to develop better and more relevant features, products and services. We do this analysis in a way that does not identify individual customers so there is no impact on the privacy of anyone.
Again if you don't want your data used in this way your option is to not use our services and close your account.
Giving you a more personal experience
Whichever products or services you use, wherever and however you interact with us, we want to give you the same great level of service and make it personal to you. We will tailor your experience, personalising the layout and content of our sites according to what we know about you, your preferences and how you like to use our services. For example, we will present you with features we know you have used or think you are likely to use, and personalise search results to show more relevant results first.
We also look at aggregated (non-identifiable) data showing the products and features our customers use and based on that we suggest products and features we think you'll enjoy because they are popular with other people who use the same products and features as you.
We believe this personalised experience makes betting and gaming better and we want to give you the best customer experience we can. Using your personal data in this way enables us to do that, and does not have an impact on your privacy.
Please note that some aspects of your customer experience are provided via cookies. If you have enabled cookies in your browser, we will personalise certain aspects of our site.
If you don't want your data used in this way your option is to not use our services and to close your account
Protecting our commercial interests
If you don't want your data used in this way your option is to not use our services and to close your account
We will occasionally invite you to give feedback on services you have used or to take part in customer surveys, questionnaires or focus groups. Taking part in research is always voluntary, and where we use a third party we do not pass over any details (other than your contact details so they can send you the initial request or invitation) unless and until we have your consent to do so.Privacy Rights: Can I opt-out of this?
It's really important for any business to find out what its customers think. As we are careful to limit the number and frequency of contacts we make if you don't want your data used in this way your option is to not use our services and to close your account
Things we do with your consent: Marketing
We will send you offers and information only if you have given your consent for us to do so, in which case we will contact you via email, post, SMS or online about any of our group products and services. We never share your data with companies outside our group for them to use for their own marketing. From time to time, we may team up with a third party to bring you details of a product or service we think may interest you, but where we do this the contact will come from us - we will never pass your details to the third party without your prior consent.
Keeping it Relevant
We want to make betting and gaming better for you, so we want to be able to tell you about products, services and features that you will find exciting and relevant and we tailor the offers and information we send to suit you. To do this, we look at what we know about you across our group, such as your age, location and gender, your browsing history, social media usage and how you interact with us and build up a picture of you that helps us decide what you're most likely to want to hear about. (This is sometimes known as 'Profiling'). We also combine this with information we've obtained from publicly or commercially available sources about what things people with similar characteristics to you (in terms of age, gender, location etc.) tend to be interested in, so we can fine-tune the offers we present to you.
Putting You in Control
We firmly believe our customers prefer offers and information that are relevant to them and their interests over general adverts, so we tailor all our marketing using this picture we've built up of you. We think this makes our marketing better both for you and for us. However, data protection law gives you the right to opt-out of having your personal data used to build up this type of picture and predict what you might be interested in, so you can opt-out at any time. As we explain above, all our marketing is tailored to you in this way, so to opt-out of this type of personalisation, you will need to opt-out of receiving all direct marketing from us.
You can do this when you sign up by not ticking the box to opt into marketing. We won't then send you offers and information by post, email or SMS but we will continue to personalise your online experience based on the picture we've built up of you. This means you'll continue to benefit from a more personalised look and feel on our websites and apps, and will still see the following:
Targeted pop-ups telling you about products, services and offers we think you'll like
Bespoke offers relevant to you, communicated through pop-ups or other on-site content
Targeted messages on social media platforms such as Facebook or Twitter (which you can control easily through your privacy settings on each individual platform) and in other places on the internet that support targeted advertising.
We think this strikes the best balance: it lets you opt-out of receiving marketing through offline channels (email) while still enjoying the best online experience, and without having to miss out on benefits. However, if you prefer not to receive any personalised messages or offers online you can opt-out in your online account.
Please also note the following:
Where applicable, we will still make onsite recommendations for products you might enjoy. We base these on how our customers as a whole tend to use our sites and features, not on information about you as an individual.
Some personalised banner adverts on our sites are controlled separately through cookies, so you will also need to adjust your browser's cookie settings or you will continue to see them.
You may still see our adverts on other websites or social media platforms you visit, but these will not be targeted at you.
Marketing: Keeping it relevant and putting you in control - At a Glance:
All our marketing is tailored to be more relevant and interesting to you so if you're:
Happy to receive personalised offers and information by email and online - Make sure you opt in to direct marketing.
Happy to see personalised offers and information when you're online but don't want to receive them by email- you need to opt-out of direct marketing.
Not happy to see personalised offers and information online or by e-mail - be sure to opt-out of personalised marketing and adjust your cookie settings to avoid receiving banner adverts.
Remember, you can change your mind at any time by updating your preferences in your account settings.
Online Banner Adverts: Cookies
If you have enabled cookies in your browser you may receive banner adverts on our homepage, as these are cookie-based and not tailored using other information we hold about you. As they are cookie-based you may receive them even if you have opted out of other personalised marketing but you can control them easily via your browser settings
Advertising on social media
If you have given your consent to marketing, we may work with social media companies such as Facebook and Twitter to provide you with information about our products and services via their platforms. If you do not wish to see these adverts, you can control this easily by disabling preference-based marketing in the privacy settings on each individual platform.
Even if you have withdrawn your consent to personalised marketing by us, you may still occasionally see general adverts for our group products and services on your social media feeds. These will not be specifically targeted to you, and again, you can control this via the privacy settings on each platform.
Online Behavioural Advertising
Sharing your information
Companies that provide services on our behalf
We share your personal information with external organisations that carry out a range of services on our behalf for the purposes in this policy. The main functions that are, or maybe, carried out fully or in part by third parties are listed below:
Management and execution of marketing campaigns
Checks to help us detect unfair use of our products and services
Web hosting, online content services and data storage
Management of competitions, contests and offers
Data analytics and data cleansing
Market research and collecting or analysing customer feedback
IT services and support
Audit-, legal- and compliance-related services
We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.
Other Circumstances in which we may share your personal data
Apart from the functions set out above, we do not share your personal information with third parties except where we are compelled or permitted by law to do so. These circumstances are rare but may require us to share information with the police, courts or other law enforcement agencies, statutory bodies (in relation to matters such as taxation) and sporting bodies (in connection with sporting integrity issues), in any of the countries in which we operate.
Where necessary to protect or defend our rights and interests, resolve disputes or enforce our agreements, we will share personal data with our regulators, external legal advisors and debt recovery and tracing agencies, although again these circumstances are rare.
If the ownership of all or part of our business changes or we undergo a reorganisation or restructure, we will transfer your personal information to the new owner or successor company so we or they can continue to provide the services you have requested.
Whenever we share personal information, and whatever the circumstances, we will always do so legally and with due regard to your privacy.
How long do we keep your information?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary depending on why we originally obtained them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors and requirements including gambling regulation, anti-money laundering rules, tax rules, payment industry requirements, complaint handling standards, the need to prevent or detect crime or other misuses of our services, and audit requirements.
To fulfil our various requirements and obligations, some of your personal data will need to be retained for a period of time after you cease to be a customer.
Staying in control of your personal information: your privacy rights
The Right to access the data we hold about you
If you would like a copy of the personal information Legalbet.co.ke holds about you, you should request it by emailing [email protected]. We will ask you to complete and return a form, which is not compulsory but helps us to help you by providing the information you are looking for. Before we respond to your request, we will ask you for a valid proof of identity and once we've received it we will provide our response within one month. If your request is unusually complex and likely to take longer than a month we will let you know as soon as we can and tell you how long we think it will take.
We will fulfil requests wherever possible, but there are occasional situations in which local data protection law requires or permits us to withhold some information (such as where it would involve disclosing information about another person or information which is commercially sensitive), or allows us to make a small charge. If either of these applies, we will tell you why.
Links to third party sites
Keeping your data secure
Your privacy and shared computers
If you log in to one of our websites from a shared computer, cookies may cause your e-mail address or user name to display in the login field to anyone who uses the site on that computer after you. You can avoid this by clearing the Cookies stored by the web browser. The option to do this is normally in the 'Tools' dropdown menu at the top of the browser window. If you have opted to stay logged in, remember that another person using the same device could access your account unless you log out.
Passwords and PINs
Remember to keep your passwords and PINs secret, choose complex passwords, change them periodically and never use the same password or PIN on multiple websites.