Data Protection and Privacy Policy

Introduction

This Privacy Notice sets out what personal information we collect from you when you use, access or interact with our Website, including any mobile application and other service channels, how we collect your personal information, why we collect it and how we use it, and related matters.

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

Interpretation Of Terms

a."anonymisation" means the removal of personal identifiers from personal data so that the data subject is no longer identifiable;

b."consent" means any manifestation of express, unequivocal, free, specific and informed indication of the data subject's wishes by a statement or by a clear affirmative action, signifying agreement to the processing of personal data relating to the data subject;

c.“data” means information which:-

I.is processed by means of equipment operating automatically in response to instructions given for that purpose;

II.is recorded with intention that it should be processed by means of such equipment;

III.is recorded as part of a relevant filing system;

IV.where it does not fall under paragraphs [I], [II] or [III], forms part of an accessible record; or

V.is recorded information which is held by a public entity and does not fall within any of paragraphs [I] to [V].

d.“Data Commissioner” means the person appointed under Section 6 of the Data Protection Act, 2019.

e.“data controller” means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purpose and means of processing of personal data;

f.“data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller;

g.“data subject” means an identified or identifiable natural person who is the subject of personal data;

h.“encryption” means the process of converting the content of any readable data using technical means into coded form;

i.“person” has the meaning assigned to it under Article 260 of the Constitution;

j.“personal data” means any information relating to an identified or identifiable natural person;

k.“personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

l.“processing” means any operation or sets of operations which is performed on personal data or on sets of personal data whether or not by automated means, such as;

I.collection, recording, organization, structuring;

II.storage, adaptation or alteration;

III.retrieval, consultation or use;

IV.disclosure by transmission, dissemination, or otherwise making available; or

V.Alignment or combination, restriction, erasure or destruction.

m."restriction of processing" means the marking of stored personal data with the aim of limiting their processing in the future;

n."Third Party" means natural or legal person, public authority, agency or other body, other than the data subject, data controller, data processor or persons who, under the direct authority of the data controller or data processor, are authorized to process personal data.

Scope Of Application Of This Data Protection And Privacy Notice:

1.1All platforms, games and services offered by ZuriBet Kenya Limited (“ZuriBet”, “We”, “Us”, “Our”). A company duly incorporated under the laws of Kenya.

1.2This Privacy Policy should be read in conjunction with the General Terms and Conditions and must be applied with due consideration and compliance with the Data Protection and Privacy Laws in Kenya, including but not limited to the Constitution of Kenya 2010, the Data Protection Act, 2019, the Gambling Control Act, 2025, Consumer Protection Act, 2012 and the Anti-Money Laundering and Combating of Terrorism Financing Act, 2025.

1.3ZuriBet is the Data controller and Processor for the Website, Platform, including any mobile application and other service channels available to you from time to time.

WHAT PERSONAL DATA DO WE COLLECT?

Overview

We may receive and collect personal data about you in several ways, including when you access or register or sign up to our service; you access or make use of, interact with any of our websites, Platform or applications or participate in or interact with any of Our products or services on Our Website or other service channels, 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 Our operations.

1.4We may also receive personal data from third parties that have obtained it from you and that are permitted by the operation of the Law to share it with us.

1.5We may also, automatically collect some technical information when you visit our Website or other service channels, such as your IP address, and information about your visit, such as the pages that you viewed. This information helps us understand customer interests and helps us improve our services. By visiting and using our services, you agree to our use of cookies in line with ZuriBet’s policies. For more details about Cookies, please read our Cookies Policy.

Information we collect

The information and data about you which we may collect, use and process may include, but is not limited to, the following:

Personal information.

a)When you register for or use our services, this information may include your full name, National Identity Number, age, mobile number, address, date of birth, email address, gender, username, password, social media profiles, personal preferences collected in surveys and recordings.

b)Information that you provide to us by filling in the forms on the website or any other information you submit to us via the website or email.

Technical information

This includes the type of mobile device you use, unique device identifiers such as internet protocol [IP] address of your computer or smart phone, or your device's IMEI or serial number or SIM card number of your non-smart phone or feature phone, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about the SIM card used by your device, service provider and mobile network information.

Financial information.

a)Your transaction information when you withdraw from or deposit into your account, information we obtain from fraud prevention agencies, Anti-Money Laundering agencies and any other statutory regulator; Details of the transactions you carry out with us via the website, telephone or other channels.

b)Location information. Including information on where you have logged in from/ your log in location

Information about your visit

The full Uniform Resource Locators [URL] clickstream to, through and from our App, system and network [including date and time]; services or products you viewed or searched for or requested; page response times, download errors, length of visits to certain pages, page interaction information and any phone number used to request a service or call our customer service number;

Purposes For Collecting Personal Data

Overview

We may collect, use, and store your personal data for the purposes of providing, promoting, maintaining, personalizing and improving our products and services including the offering of various products and services for your participation, to develop new products and services, and to protect Us, including partners and our users from fraudulent or unlawful activities.

Purposes

Specific purposes for which we process your data are;

a)Processing personal data necessary for the purposes of conclusion and performance of the interaction with you, including:

b)To establish, personalize and maintain your account, and to authenticate your identity when accessing your account, including full compliance with our Terms and Conditions, and marketing activities to notify you about changes to our products and services, keeping you informed about new products and services;

c)To provide customer support services and to communicate with you, including to inform you about the changes to our products and services;

d)Processing of personal data in order to fulfil obligations resulting from the provisions of the Data Protection Act, 2019, Gambling Control Act, 2025, Anti-Money Laundering and the Combating of Terrorism Financing [Amendment] act, 2025, and other relevant law as may be amended or enacted from time to time;

e)To fulfil any contractual obligations with our business partners for the purpose of offering our products and services, which is our lawful legitimate interest for processing personal data;

f)We may use your personal data for the purposes of marketing our products and services, our affiliate products and services, including through advertising tailored for individual or group needs and preferences, for example online advertising, in fulfillment of our legitimate interest for processing personal data

g)Processing for the purposes of research, analytics, development, improvement [including user experience improvement], administration, maintenance, technical support and security of our products and services, Website in alignment with our lawful interest for processing personal data; and

h)Processing for the intents 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 including industry and sporting trade bodies, which is our legitimate interest for processing personal data.

Who Are The Recipients Of Personal Data?

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

ZuriBet and its affiliates.

Which includes our holding companies, subsidiaries and entities that control or are under common control with ZuriBet, when necessary for the ongoing maintenance and continued provision of the services to you, who will process it on behalf of ZuriBet 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];

Service providers

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 products and services, 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 bonus/ product and/or service, independent auditors to assess and ensure compliance with the rules of products and/or services.

1.6Marketing services providers, supporting us in promoting our products and services, including marketing agencies, email distribution and other marketing tools providers, social media marketing services providers including Meta ads and Google, as well as analytics services providers.

1.7Partners who may offer access to our products and services on our behalf and/or partners with whom we co-operate with respect to hosting and placing our products and services on their platforms.

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.

1.8Third parties in relation to betting and gambling sports integrity and compliance monitoring activities and prevention; and/or

1.9Third parties in relation to reorganization of the ZuriBet group, 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.

Lawful Basis For Processing Your Information

1.10This policy is not intended to prevent the processing of Personal Data but to ensure that it is done lawfully and without adversely affecting your rights.

1.11ZuriBet ensures that Personal Data is processed lawfully, this is achieved by enforcing the principles of good practice and processing Data in strict adherence to the Data Protection Act, 2019 Laws of Kenya, in line with the below principles:

a)Data is collected and processed legitimately and lawfully;

b)Data is processed with the consent of the data subject;

c)Data is processed for limited purposes and in an appropriate way;

d)Data is processed for legitimate purposes in line with the consent of the Data Subject;

e)Data processed is accurate;

f)Data is not kept longer than necessary for the purpose;

g)Data is processed in compliance with Data Subjects' rights;

h)Data is secured against foreseeable hazards, breaches such as theft, cyber-attack, viral attack, dissemination, manipulations of any kinds, and damage by rain, fire or exposure to other natural elements;

i)Data is not transferred to people or organizations situated in other jurisdictions without adequate protection better than or similar to the Data Protection Act, 2019 Laws of Kenya;

j)Anyone who is entrusted with the Personal Data of a Data Subject or who is in possession of the Personal Data of a Data Subject shall be accountable for his acts and omissions in respect of data processing and in accordance with the principles contained in this Policy.

What are your rights?

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

1.12Right to Access. You have the right to access your personal data.

1.13Right to Rectification. You can request us to have inaccurate personal data amended.

1.14Right of erasure. 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.

1.15Right 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 grounds unless we have a lawful ground to continue processing the data.

1.16Right to Data Portability. You can ask to receive your personal data that you provided to ZuriBet in machine-readable format or have such data transmitted to a third party; and

1.17Right to Restriction of processing. We may be required to have your data restricted for processing in certain circumstances.

Exercise of your rights

You can exercise your rights and lodge requests to Our Data Protection Officer who can be contacted at dpo@zuribets.com

1.18Withdrawal of consent. In some situations, 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.

1.19Customer Support center. Should you have any difficulties with exercising any of the rights referred to above using your Account, you may contact us at the customer support email address zuri@zuribets.com for assistance [in such case, for security reasons you may be asked to confirm your request by logging into your Account and upon such confirmation your request will be considered to be validly filed].

Obtaining Your Consent

You consent to the processing of your Personal Data when you access our platforms, or use our services, content, features, technologies or functions offered on our website or other digital Platforms.

Your Data Rights

We will process all Personal Data in line with Data Subjects' rights, your rights are to:

a)Request access to any data held about you.

b)Prevent the processing of your data for direct marketing purposes.

c)Request to have inaccurate data amended.

d)Prevent processing that is likely to cause damage or distress to yourself or anyone else.

e)Withdraw your consent at any time, provided that the withdrawal of your consent shall not affect the lawfulness of processing based on consent prior to the withdrawal.

How long do we store data?

Data Retention Principles.

We process your personal data for the duration of your registration and holding of a ZuriBet account and following the end of such registration or holding of the 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:

a)compliance with obligations resulting from regulatory authorities to which We are subject;

b)establishment, exercise or defense of legal claims as well as for the purposes of any other legal proceedings or compliance with any judgments and/or decisions issued by public authorities;

c)research and analytics;

d)marketing of Our products and services; and

e)Maintaining the Account in accordance with the termination provision below.

Access to your Account after termination

Following the cancellation or termination of your Account, your 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 the Data Protection Act.

Data retention Principles with respect to consent

a)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.

b)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 measures.

Safeguarding and Protection of Information

a)We take all reasonable measures to ensure that your information is secured and protected. ZuriBet has put in place technical and operational measures to protect your information from unauthorized access, accidental loss, or destruction.

b)Your Personal Data is stored with utmost confidentiality, and we make every effort to keep your Personal Data secure, including restricting access to your Personal Data with us on a need-to-know basis. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate security standards to protect your Personal Data.

Foreign Jurisdiction Data Transfers

a)From time to time, we may need to transfer your personal information outside Kenya in accordance with our use of Your Personal Data set out above.

b)Where we send your information outside of Kenya, we ensure that your information is adequately protected in accordance with the Data Protection Act, 2019.

Non-Compliance with this statement

ZuriBet shall have the right to terminate any agreement with you for failure to comply with the provisions of this Privacy Policy and its other Terms and Conditions and reject any application for information contrary to this Privacy Policy.

Amendments to this Notice

Due to constant dynamics in technology and regulatory requirements, we may need to change our privacy policies or update this policy from time to time. You will always be able to find the most recent version of our updated privacy policy on this site.

In the instance of discrepancy between this document and the Terms and Conditions the provisions of this Privacy Notice will prevail.

Contact and Complaints

If you would like further information on this policy, like to request your data, or lodge a complaint you may contact our Data Protection Officer by emailing directly: dpo@zuribets.com

You also have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection; the Office of the Data Protection Commissioner [ODPC].