1.	This Privacy Notice sets out what personal information we collect from you when you use, access or interact with the SuperPicks Mobile App or www.SuperPicks.com Website including all games available on the same platform (or any other electronic platforms) (together the “SuperPicks Platform”), how we collect your personal information, why we collect it and how we use it, and related matters.

2.	Please read this Privacy Notice carefully to understand Our views and practices regarding your personal information and how we will treat it and contact Us if you need any clarity or assistance, using the contact details set out at the end of this notice.

3.	This Privacy Notice is applicable to:

3.1 SuperSport International (Pty) Limited, a company incorporated in the Republic of South Africa with company number 1997/004108/07 and its principal place of business at MultiChoice City, 144 Bram Fischer Drive, Ferndale Randburg, Republic of South Africa (“SuperSport”) (and their affiliated group companies); and

3.2 Betagy Limited, a company incorporated and registered in Malta company number C81758 whose registered office is at Pendergardens Business Centre, 51, Level 5, Pendergardens, St. Andrew’s Road, St. Julians, Malta, STJ 9023 (“Kingmakers”)
(together referred to as “We” or “Us” or “Our”)

4.	This Privacy Notice should be read in conjunction with the End User License Agreement [www.superpicks.com/terms-and-conditions] and the applicable game rules for use of the SuperPicks Platform and must be applied with due consideration and compliance with South Africa privacy, protection and other consumer laws including the Protection of Personal Information Act 4 of 2013 as applicable or such other applicable data protection and privacy laws in any relevant territory.

5.	Both SuperSport and Kingmakers are the joint data controllers for the games on the following Platforms:
www.SuperPicks.com SuperPicks Mobile App
or such other related SuperPicks website or platform that may be offered by Us from time to time. 


Introduction

1.	Overview: We may receive and collect personal data about you in several ways, including when you access or register or sign up to the SuperPicks Website, and / or download and / or register or sign up to on the SuperPicks Mobile App on your device; you access or make use of, interact with any SuperPicks Platform or participate in any Contest or interact with any Content on the SuperPicks service (including when you decide on the selection of Content or participate in any promotional or sport related predictor or fantasy game or enter into any promotional competition (“Contest”) on either the SuperPicks Mobile App or the SuperPicks Website), you contact our support center, you participate in any marketing or promotional activity or you submit your personal data to us for any other reason related to the SuperPicks Platform including but not limited to prize fulfilment (if applicable) and verification purposes. We may also receive personal data from third parties that have obtained it from you and that are permitted to share it with us.

2.	Categories of personal data when you are signed into the SuperPicks Platform: The categories of personal data of signed in users that we collect include:

•	2.1 Basic Account and Contact Information:  You may be required to provide your name, date of birth, mobile telephone number, an email address, alias or avatar name and password to create a SuperPicks Account. You may also be required to provide KYC verification documents, your postal address and certain bank account information as a part of receiving a Contest prize (if applicable). We may also receive basic account information from third party sites, such as when you choose to sign in via a social network account;

•	2.2 Preferences, user profile and other information: We also collect and process certain information on your activity on the SuperPicks Platform, such as for example selections, sport predictions and picks in relation to a Contest, viewing history, and information about your SuperPicks Account (including information that you provide using your My Account section), settings data and certain data inferred on their basis, in particular taste preferences based on your participation in a Contest;

•	2.3 Events: We collect certain information about your activities observed when you are accessing and using the SuperPicks Website or SuperPicks App or when you react to our marketing communications, including details of how, when and for how long you have accessed, viewed or used any of our platforms as well as details regarding site traffic and usage information (for example search queries, navigation behaviour and viewing time and duration and selections, sport predictions and picks related to any Contest);

•	2.4 Support services information: We collect certain details of your interactions with the SuperPicks support center (in case we can attribute the conversation to you), such as the date, time and reason for contacting SuperPicks, transcripts of chat, email or other conversations;

•	2.5 Cookies: We may also store certain information collected via the use of cookies, web beacons, advertising IDs and other technologies, including ad data. For more information on cookies please refer to the Cookies section in clause 8 of this Privacy Notice;

•	2.6 Device and Browser Information: When you access the SuperPicks Website or the SuperPicks App, we may also collect information about the device or browser accessing any of these SuperPicks Platforms, such as unique device identifiers, IP address, type, model, settings, operating system, system activity and crash reports for your device and browser, such as unique device identifiers, IP addresses, the type of device used to access the SuperPicks Website, SuperSport Mobile App and your SuperPicks Account, hardware model and settings, operating system, browser type, language, system activity, and crash reports;

•	2.7 Location Information: When you access the SuperPicks Website or the SuperPicks Mobile App based on your IP address, we may determine the geographical location of a device used to access SuperPicks Platform based on your IP address or third party geolocation services;

•	2.8 We may also collect personal information from you to verify and prove your identity and the accuracy of the information you provided on the registration form for the SuperPicks Platform, and may pass your information on to third party verification service providers, including but not limited to a scanned image of your passport or other government-issued ID document; and/or a recent utility bill or bank statement clearly showing your first name and surname, full postal address; and bank account details for the purposes of prize fulfilment (if applicable).

•	2.9 Categories of data when you are not signed in to SuperPicks Platform: The categories of personal data of that we may collect when you are browsing the SuperPicks Website or the SuperPicks App without signing in include data referred to in the following sections: on Events (2.3), Cookies (2.5), Device and Browser Information (2.6) and Location Information (2.7).

•	2.10 Children’s’ data: You must be at least 18 years of age or older to create a SuperPicks Account or use the SuperPicks Platform. You must not provide us with any personal data relating to persons under 18 years of age.

•	2.11 Voluntary provision of data:  The provision of your personal data is voluntary and in some cases, necessary to use some of the services offered by SuperPicks Platform. Refusal to provide some of your personal data will make it impossible to use the SuperPicks Platform or some of their functionalities, for example its websites, Applications, products, platforms and services to browse or to access content, and will prevent Us from offering and performing such services.


What personal data do we collect?

1.	Overview: We collect, use and store your personal data for the purpose of providing, promoting, maintaining, personalizing and improving our services including the offering of various Contests for your participation, to develop new services, and to protect Us, our SuperPicks Platforms, content partners and our users from fraudulent or illegal activity.

2.	Purposes: Specific purposes for which we process your data include:

•	2.1 processing personal data necessary for the purposes of conclusion and performance of the agreement with you, including:

•	2.2 to establish, personalize and maintain your SuperPicks Platform Account, and to authenticate your identity when accessing your SuperPicks Account, including ensuring full compliance with the End User License Agreement, to provide you with access to Contests, content or details of your participation in any Contests, (promotions, competitions or sport predictor or fantasy games) including your predictions and selections;

•	2.3 to provide you with unique selection of titles and Contests in specific sporting categories or leagues tailored exclusively for you in a form of recommendations resulting from automated analysis of your predictions and choices and other actions made by you while using the SuperPicks Platform;

•	2.4 to provide customer support services and to communicate with you, including to inform you about any changes to SuperPicks products, Contests, prizes and SuperPicks Platforms;

•	2.5 processing of personal data in order to fulfil obligations resulting from provisions of Applicable laws;

•	2.6 to fulfil any contractual obligations with our business partners for the purpose of offering the SuperPicks Platforms, which is our legitimate interest for processing personal data;

•	2.7 Where you give consent, we may use your personal data for the purposes of marketing of the SuperPicks Platform and each of Our affiliate group company products and services (including but not limited to BetKing Nigeria (SV Gaming Limited)), including through advertising tailored for individual or group needs and preferences, for example online advertising, which is our legitimate interest for processing personal data;

•	2.8 processing for the purposes of research, analytics, development, improvement (including user experience improvement), administration, maintenance, technical support and security of the SuperPicks Platform, SuperPicks Website and SuperPicks App which is our legitimate interest for processing personal data; and

•	2.9 processing for the purposes of establishment, exercise and defense of legal claims, enforcing or investigating potential violations of our terms of use or any other actual or alleged fraudulent activities, protecting rights, property or safety of Us, our affiliate group companies, our customers, employees and other third parties, which is our legitimate interest for processing personal data.


For what purposes do we process personal data? 

1.	Your personal data may be disclosed to the following categories of recipients:

•	1.1 SuperSport and its affiliates, which includes our holding companies, subsidiaries and entities that control or are under common control with SuperSport for the following purposes: (a) processing for the purposes of customer preferences, analytics and research, and subject to your consent the marketing of SuperSport and its affiliates’ products and services; and (b) processing it on behalf of SuperSport for various operational purposes when necessary (such as website hosting, maintenance, email communication services and get all information required for the computation and tabulation of points);

•	1.2 Kingmakers and its affiliates, which includes our holding companies, subsidiaries and entities that control or are under common control with Kingmakers (including but not limited to SV Gaming Limited (BetKing Nigeria) for the following purposes: (a) processing for the purposes of customer preferences, analytics and research, and subject to your consent the marketing of Kingmaker and its affiliates’ products and services including but not limited to BetKing Nigeria; and (b) processing it on behalf of Kingmakers for various operational purposes when necessary (such as website hosting, maintenance, email communication services and get all information required for the computation and tabulation of points);

•	1.3 trusted service providers retained by us to enhance or provide services to you, acting at our instruction, including hosting services providers, cloud storage providers, sponsors platform development software providers and the developers of our Contests, support and security services providers, analytics tools and services providers, customer support services providers, banking, payment and reconciliation services providers, couriers for the delivery and fulfilment of prizes arising in respect of any Contest (if applicable), independent auditors to assess and ensure compliance with the rules of any Contest;

•	1.4 marketing services providers supporting us in promoting the SuperPicks Platform, including marketing agencies, email distribution and other marketing tools providers, social media marketing services providers including Facebook and Google, as well as analytics services providers;

•	1.5 partners who may offer access to the SuperPicks Platform on our behalf and/or partners with whom We co-operate with respect to hosting and placing the SuperPicks App and SuperPicks Mobile Apps on their platforms;

•	1.6 third parties, including governmental bodies, courts or bodies of similar nature, when it is required in order to comply with Applicable laws, to enforce or investigate potential violations of our terms of use or any other contract between you and us, to protect our rights, property or safety or that of our customers, employees, and other third parties; and/or

•	1.7 third party in relation to reorganization of the SuperSport or Kingmakers groups, in particular a third party that acquires (or proposes to acquire) ownership or control of our assets, shares or management, or that of our affiliates by any means, or a third party from whom we acquire, ownership or control of assets, shares or management.

•	1.8 Please note that We offer services in jurisdictions located outside the European Economic Area and some of the data recipients referred to in clause 1 may be located outside the European Economic Area, in countries with respect to which the European Commission has not issued an adequacy decision (“Third Country”).

2.	Where personal data is transferred to a Third Country, SuperSport and Kingmakers take legally required steps consistent with Applicable European data protection legislation to ensure that the personal data is adequately protected in each such jurisdiction in particular by basing agreements with the relevant data recipients on the standard data protection clauses adopted by the European Commission or adopted by a supervisory authority and approved by the European Commission.


Who are the recipients of personal data? 

1.	Your data subject rights  You have the following rights with respect to your personal data processed by Us:

•	1.1 Right to Access: You have the right to access your personal data;

•	1.2  Right to Rectification: You can ask us to have inaccurate personal data amended.

•	1.3  Right to be forgotten: You can ask us to erase personal data. Note that we will keep only personal data that are necessary where such data is under an investigation or under a subsisting contract which may require further processing or where the data relates to criminal records; or for us to comply with financial and tax regulations and for the establishment, exercise or defense of legal claims;

•	1.4  Right to Object to processing (marketing): You can object to processing your personal data for marketing purposes; You can object to processing of your personal data based on Our legitimate unless We have a valid ground to continue processing the data;

•	1.5  Right to Data Portability: You can ask us to receive your personal data that you provided to SuperPicks in machine-readable format or have such data transmitted to a third party; and

•	1.6  Right to Restriction of processing: We may be required to have your data restricted for processing in certain circumstances as defined in article 19 of the GDPR and per the Protection of Personal Information Act 4 of 2013.

Exercise of your rights.

2.	You can exercise your rights and lodge requests to Us by contacting the Data Protection Officers of either of Us at dpo@multichoice.co.za or dpo@kingmakers.com

3.	Withdrawal of consent: In some situations when we may seek your consent for processing. In such case, you will have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

4.	Support center: Should you have any difficulties with exercising any of the rights referred to above using your SuperPicks Platform Account, you may contact us at the customer support email address help-za@superpicks.com for assistance (in such case, for security reasons you may be asked to confirm your request by logging into your SuperPicks Account and upon such confirmation your request will be considered to be validly filed).

5.	Complaints: You can raise a complaint about our processing with the data protection regulator in your jurisdiction. If you find it difficult to contact the data protection regulator, we will help you.


What are your rights?

1.	Data Retention Principles: We process your personal data for the duration of your registration and holding of a SuperPicks Account on the relevant SuperPicks Platform and following the end of such registration or holding of the SuperPicks Account to the extent that the data is necessary for the purposes with respect to which we are permitted and/or required to process data, in any event no longer than for the period of expiry of claims, including for the following purposes:

•	1.1 compliance with obligations resulting from Applicable laws to which We are subject;

•	1.2 establishment, exercise or defense of legal claims as well as for the purposes any other legal proceedings or compliance with any judgments and/or decisions issued by public authorities;
•	1.3 research and analytics;

•	1.4 marketing of Our products and services; and

•	1.5 maintaining the SuperPicks Account in accordance with clause 2.

2.	Access to your SuperPicks Account after termination: Following the cancellation or termination of your SuperPicks Account, your SuperPicks Account, and your personal data and any related information will be deleted and not available should you re-subscribe. Data shall only be retained for a legitimate legal purpose as may be required by any relevant data laws.

3.	Data retention Principles with respect to consent: As outlined in clause above we might be processing your data based on consent. In such event we process data only as long as the consent is valid and to the extent that the data is necessary for the purposes with respect to which we are permitted and/or required to process data.

4.	Where appropriate we will encrypt, pseudonymize, anonymize and/or segregate information so that we may make use of it in a manner that avoids unnecessary identification, in the interest of protecting your privacy and enhancing security practices.


How long do we store data?

1.	Maintaining the security and integrity of your personal data is a high priority and we endeavour to maintain appropriate technical and organizational measures to secure the integrity of information, using accepted technological standards to prevent unauthorized access to or disclosure of your personal data and to protect them from misuse, loss, alteration or destruction.

Security

1.	In order to ensure that the SuperPicks Website, SuperPicks Mobile App work properly, to provide you with a personalised experience, we and certain of our third party service providers may set cookies or similar technologies (such as in particular web beacons, pixels and advertising identifiers) on your device, subject to your consent where relevant. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. It enables the website to remember your actions and preferences (such as session status, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

2.	The SuperPicks Website uses two basic cookie types: session cookies and persistent cookies. Session cookies are temporary files stored on the user’s end device until the user logs out, leaves the website or closes the software (web browser). Persistent cookies are stored on the user’s end device for the time specified in the parameters of the cookies or until deleted by the user.

3.	In many cases, the default settings of the web browsing software (web browser) enable cookie storage on the user’s end device. You can delete or block cookies from being set in your web browser settings or relevant software. Cookies set by Us will likely be labelled as first party cookies, and those set by our partners will be labelled third party cookies. Certain parts of the SuperPicks Website, or the SuperPicks Mobile App may not work properly if first party cookies are blocked or deleted.

4.	The types of cookies and the purposes for which they are used on the SuperPicks Website and the SuperPicks Mobile App include:

•	4.1 strictly necessary cookies, which enable use of the services available on the SuperPicks Website and SuperPicks Mobile App, including but not limited to cookies used for authentication of users, for making the SuperPicks Platform work (including the improvement of your experience) and cookies that ensure security;

•	4.2 performance cookies, which help us collect information about how the SuperPicks Website, the SuperPicks Platform and the SuperPicks Mobile App are used, so that we can perform analytics and improve their performance;

•	4.3 functionality cookies, which remember choices made by the user and personalise the interface and allow enhanced functionality and personalisation of the SuperPicks Website, the SuperPicks Platform and the SuperSport App;

•	4.4 targeting cookies and advertising IDs for delivering adverts more relevant to users and their interests, as well as ad conversion tracking; these cookies are mainly set by our advertising partners; and

•	4.5 Third party cookies: • Third party service providers providing chat functionality as We use third party cookies to power third party functionality such as chat windows and • Third parties that engage in online behavioral advertising, or that provide such services to us as service providers, may offer additional control over this practice via a self-regulatory body called the European Interactive Digital Advertising Alliance. For further details regarding the collection of information by third-party advertising companies or to exercise choices over online behavioral advertising practices, visit https://youronlinechoices.eu/.


Cookies

9.1 When you register on our platform you can choose to receive direct marketing from us. You may also manage it in your settlings on the SuperSportBet Platform. 
 
9.2	You may opt out of receiving direct marketing communications from us: 
 
9.2.1 at the time of registering on the SuperSportBet Platform by ticking the relevant “opt-out” box; and 
 
9.2.2 at any time by requesting us (in any manner, whether telephonically, electronically, in writing, including live chat) to desist from initiating any direct marketing to you. 

9.3 If you have opted out in accordance with the above, we will not send you any further direct marketing communications. 
 
9.4 You may (in terms of the Consumer Protection Act, 2008) register a pre-emptive block against direct marketing communications. If you do so, we will not send you direct marketing communications unless you have expressly consented to received direct marketing communications from us. 
 
9.5 We will not send you direct marketing communications at home at any period during which it is prohibited by law to do so unless you have expressly or implicitly requested or agreed otherwise. 


Direct Marketing

1.	We may change this Privacy Notice from time to time. If we do so, we will post the revised notice on the www.superpicks.com/privacy-policy page and the relevant page on the SuperPicks Mobile App and will inform users of such amendments and of their effective date.

2.	In case of discrepancy between this document and the SuperPicks End User Licence Agreement the provisions of this Privacy Notice will prevail.

3.	This version of this Privacy Notice applies from 2nd Sept 2024.
