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Privacy Policy

1. General Applications

1.1. These Rules are an official document of Global Business Ltd. with the address at: 60 Market Square, P.O. Box 364, Belize City (hereinafter the Service Administration) and determine the method of processing and protecting information on the individuals using Surebets App (hereinafter the Service) and its services (hereinafter the Users).

1.2. The purpose of these Rules is to ensure due protection of the user information, including personal data, from unauthorized access and disclosure.

1.3. The relations connected with the collection, storage, distribution and protection of the Service Users information are governed by these Rules, other official documents of the Service Administration and current Russian legislation.

1.4. The current version of the Rules, which are a public document, is available to any Internet user by clicking http://100surebets.com/privacy.php. The Service Administration has the right to modify these Rules. In case changes are made to these Rules, the Service Administration shall notify the users by posting the new version of the Rules on the Service permanently at http://100surebets.com/privacy.php no later than 10 days before such changes become effective. The previous versions of the Rules are stored in the Service Administration’s documentation archive.

1.5. These Rules have been developed and are used in accordance with the Service User Rules available at http://100surebets.com/agreement.php. In case of contradictions between these Rules and other official documents of the Service Administration, these Rules will prevail.


1.6. By registering and using the Service, the User agrees with the conditions of these Rules


1.7. In case the User disagrees with the conditions of these Rules, the use of the Service and its applications must be stopped immediately.


2. Terms and conditions

2.1. By making available the Service and its applications (hereinafter the Service Applications), the Service Administration, acting reasonably and in conscientiously believes that the User:

has all necessary rights to register on and use this Service;

provides true information about himself (herself) to the extent necessary for use of the Service Applications;

understands that the personal information posted by the User may become available to other Service Users and Internet users and this information may be copied and disseminated by such users;

understands that some types of information transferred by him / her to other Users cannot be deleted by the User himself / herself;

is aware of and accepts these Rules and assumes the rights and obligations provided by these Rules.

2.2. The Service Administration does not check the user information received (collected), except where such check is necessary in order for the Service Administration to fulfill its obligations to the User.

3. Purposes of information processing

The Service Administration processes information on the Users, including their personal data, in order to fulfill the Service Administration’s obligations to the Users regarding the use of the Service and its applications.

4. User information

4.1. Users’ personal data

The Users’ personal data include:

4.1.1. data that are provided by the Users and minimally necessary data for registering on the Service: name, surname, gender, mobile phone number and/or e-mail;

4.1.2. data that are provided by the Users additionally at the Service Administration’s request to enable the Service Administration to fulfill its obligations to the Users under the Service Application contract (e.g., in case the User requests restoration of his / her page that is not linked to a mobile phone number). Among other things, the Servcie Administration has the right to request that the User produce a copy of the identity document or another document containing the User’s name, surname, photograph as well as other additional information which, at the discretion of the Service Administration, is necessary and sufficient to identify such User and prevent abuses and infringements of third parties’ rights.

4.2. Other User information processed by the Service Administration

The Service Administration also processes other User information including:

4.2.1. standard data that are automatically received by the http-server when the User accesses the Service and takes further actions (IP-address of the host, type of the user’s operational system, Service pages visited by the User).

4.2.2. . information that is automatically received at the time of access to the Service with the use of bookmarks (cookies);

5. Processing of the user information

5.1. The personal data are processed according to the following principles: a) lawful purposes and methods of personal data processing;

b) conscientiousness ;

c) the purposes of personal data processing meet the purposes determined in advance and declared at the time of personal data collection as well as to the Service Administration’s powers;

d) the scope and nature of the personal data being processed and the methods of personal data processing meet the purposes of personal data processing;

e) it is unacceptable to unify personal data bases created for incompatible purposes.

5.1.1. Conditions and purposes of personal data processing

The Service Administration processes the User’s personal data for the purpose of performance of the contract between the Service Administration and the User for the Service Applications. By virtue of Article 6 of Federal Law “On Personal Data” No. 152-FZ of July 27, 2006, no separate consent of the User for the processing of his / her personal data is required. By virtue of sub-clause 2, clause 2, Article 22 of this Law, the Site Administration has the right to process personal data without notifying the authorized body in charge of personal data protection.

5.1.2. Personal data collection

The User’s personal data are collected on the Site at the time of registration and also subsequently as the User enters additional information about himself / herself on his / her own initiative, using the Service tools. The personal data mentioned in clause 4.1.1 hereof are provided by the User and are minimally necessary for registration.

5.1.3. Storage and use of personal data

The Users’ personal data are stored only on electronic media and are processed with the use of automated systems, except where a non-automated processing of personal data is necessary in connection with legal requirements.

5.1.4. Transfer of personal data

The Users’ personal data are not transferred to any third parties, except as expressly provided by these Rules. If instructed or agreed so by the User, the User’s personal data may be transferred to the Service Administration’s third-party contractors, provided that such contractors assume confidentiality obligations, in particular, regarding use of applications. The applications used by the Users on the Service are placed and supported by third parties (developers) which act independently and not on behalf of the Site Administration. The Users should familiarize themselves with the service rules and personal data protection policy of such third persons (developers) before beginning to use the applications. The actions of such third parties (developers) are subject to the official document of the Service Administration, the Application Placement Conditions. The Users’ personal data are provided on the request of government agencies (local self-government bodies) in such manner as provided by law.

5.1.5. Deletion of personal data

The User’s personal data are deleted in case:

– the User himself / herself removes data from his / her personal page;

– the User himself / herself removes his / her personal page;

– the Site Administration removes the information posted by the User as well as the User’s Page as provided by the Service Use Rules.

6. User’s rights and obligations

6.1. The User has the right to:

6.1.1. access their information without restrictions and free of charge by loading his / her personal page on the Service with the use of login and password;

6.1.2. independently make changes and corrections to his / her information on the User’s personal page on the Service, provided that such changes and corrections contain up-to-date and true information;

6.1.3. remove his / her information from his / her personal page on the Site;

6.1.4. request that the Service Administration update, block or delete his / her personal data, if such data are incomplete, outdated, untrue, unlawfully received or are not necessary for the declared purpose of processing or if the actions specified in sub-clauses 6.1.3 and 6.1.4 hereof cannot be implemented independently;

6.1.6. request information from the Service Administration regarding the processing of his / her personal data.

6.2.1. The service administration is not responsible for the disclosure of personal information by other users of the service who obtained access to such data in accordance with the user's privacy level.

6.2.2. When you delete personal data (other information) with personal user page or deleting the Service user's personal page, User Information copied or stored on other users pages is saved.

7. Users’ information protection measures

7.1. The Service Administration takes technical, organizational and legal measures to ensure that the User’s personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying, dissemination as well as from other unauthorized actions.

7.2. Access to the Service is authorized using the User’s login (e-mail address or mobile phone number) and password. The User is responsible for keeping this information confidential. The User may not transfer his / her login and password to third parties and is also obliged to take measures for keeping them confidential.

7.3. To improve the Users’ information protection, the Service Administration uses a system that links the page to the mobile phone number. To implement this system, the User must provide the Service Administration with his / her mobile phone number.

8. Limitation of the Rules applicability

These Rules do not apply to the actions and Internet resources of third parties.

The Service Administration bears no liability for the actions of third parties which as the result of using the Internet or the Service Applications obtained access to the User information in accordance with the confidentiality level selected by the User, for the consequences of use of the information which, due to the Service nature, is available to any Internet user. The Service Administration recommends that the Users take a responsible approach to the scope of their information posted on the Site.

9. Users’ inquiries

9.1. The Users have the right to send their inquiries to the Site Administration, including inquiries regarding the use of the personal data under clause 6.1.6 hereof, in the form of an electronic document bearing a qualified electronic signature in accordance with Russian legislation

9.2. The User’s inquiry must contain the following information:

number of the principal identity document of the User or his / her representative;

date of issue of the above document and the issuing authority;

information confirming the User’s participation in relations with the operator (in particular, the number of the User’s id);

signature of the User or his / her representative.

9.3. All correspondence received by the Service Administration from the Users (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without the User’s written consent. The personal data and other information on the User who sent the inquiry may not be used without the User’s special consent for any purpose other than for response to the inquiry, except as expressly provided by law.


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