FRONTÓN PRIVACY POLICY

Last revised: 25/08/2021

The Frontón group companies, which includes all of the entities specified below under “The Group” section, including its affiliates (collectively, the "Frontón"), offers online gambling services which is powered by Bayton limited, such as www.spincasino.mx both through websites, mobile apps and other online properties (collectively, the “Services”).

Frontón is deeply committed to safeguard the privacy expectations of its users (“User(s)”, “you” or “your”). Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.

In this Privacy Policy, you can learn about:

• THE GROUP
• WHAT INFORMATION WE COLLECT?
• MINORS
• HOW WE USE THE COLLECTED INFORMATION?
• MARKETING
• WITH WHOM WE SHARE INFORMATION?
• INTERNATIONAL TRANSFER OF INFORMATION
• THIRD PARTY TRACKING TECHNOLOGIES
• THIRD PARTY SERVICES
• RETENTION OF PERSONAL INFORMATION
• YOUR RIGHTS
• HOW WE KEEP YOUR INFORMATION SECURED
• CHANGES TO THE PRIVACY POLICY
• HOW TO CONTACT US

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By visiting Frontón group’s websites (powered by Bayton limited), mobile apps or other online properties, or by creating an account through our Services, you hereby agree to the Privacy Policy.

If you have any questions (or comments) concerning your information, or this Privacy Policy, you are welcome to contact our Data Protection Officer at:
FORM

Frontón group includes the following companies:

• “Espectáculos Deportivos Frontón México S.A. de C.V.”, which address is Plaza de la Republica No. 17, Col. Tabacalera, Alcaldía Cuauhtémoc, C.P. 06030, CDMX, with permit SEGOB 4184, together with its operator “FM Operadora Profesional en Apuestas SAPI de CV”, which address is Plaza de la Republica No. 17, Col. Tabacalera, Alcaldía Cuauhtémoc, C.P. 06030, CDMX, and with permit SEGOB DGJS/045/2017. Spincasino.mx is a brand managed by Bayton Limited (C41970), a company registered in Malta, which address is Villa Seminia, 8, Sir Temi Zammit Avenue, Ta’XBiex XBX 1011.

We collect two types of information from our Users:

The first type of information is information that identifies or may reasonably identify an individual with reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:

• Registration details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth data, physical address, ID number, phone number, occupation, etc.
• Governmental-issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
• Payment information: In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information will be collected from you, such as your credit card number and bank account details.
• Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.
• Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
• Telephone calls: We record or monitor telephone calls for customer support, training and/or security purposes.
• Social networks: When you register through your social network account (such as your Facebook account), to use the Services or connect your player account with such account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends' list, as well as information you made publicly available on such account.
• In addition, when using the Services, you may be able via your social network to "Invite a Friend" to use the Services. Should the person accept your invitation, we may obtain Personal Information from him/her such as: name, email address, phone number and date of birth. We will use the Personal Information for the purposes set out herein and disclose such information only to third parties as detailed in this Privacy Policy.
• Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).

Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

Types of Non-personal Information we collect from or about you:

• Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
• Gameplay information: We record game play information including, amongst other things, your deposits, bets, bonuses, game session duration and your high scores. We may also share and publish such information through any of our Platforms.
• Device and connection information: If you download the Software to your device, we may collect information from the particular device you are using, for security and fraud detection and prevention purposes. For example, we may gather information with regard to other software which is running simultaneously with the Software for detecting if you are using software which is associated with fraudulent activity (e.g. robots, malware, etc.) or checking if the connection you are using is via a VPN or proxy.
• Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
• Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us.

We use your Personal Information for the purposes listed below:

• To set up, manage and update your account;
• To provide and operate the Services (such as for betting and payment processing);
• To communicate with you and to keep you informed of our latest updates to our Services and special offers;
• To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
• To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
• For Customer Relationship Management purposes, and to support and troubleshoot the Services and to respond to your queries;
• To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
• To provide you with a responsible gaming environment;
• To communicate with your and to process any of your requests to exercise your User Rights;
• To identify and authenticate your access to certain features of the Services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
• To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
• To investigate and resolve disputes in connection with your use of the Services; and
• As required by law or regulation (such as Know Your Customer ("KYC") and Anti-Money Laundering regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.

The Group will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) White Label Brands; or (iii) Group's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.

We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.

You may update your marketing preferences at any time through Customer Services (where available). When you choose to download Software pursuant to our Services, notification software may also be downloaded onto your device. This allows us to send notifications to you about our Services directly to your device, for example to inform you about new features, updates, service communications, offers and promotions.

By downloading such Software, You consent to receiving notifications. If You would prefer not to receive these notifications, You will need to manually uninstall the notification software from your device (for example by clicking the "what's this" link on a notification you receive and following the 'how to remove' instructions, or by following the applicable "Settings" and "Notification Centre" uninstall instructions on Your Access Device).

You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to [email protected]. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

We share Personal Information with any of the following recipients:

• White Label Brands, including any replacement service provider that the White Label Brand may engage to operate the White Label Brands (if applicable);
• Companies within the Group and other affiliated companies;
• Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
• Credit reporting agencies;
• Payment service providers, payment processors and banks;
• To any third parties who provide services in relation to the operation or promotion of the applicable In House Brand or the White Label Brands (if applicable);
• To any third parties who organize offline events or tournaments on behalf of or in conjunction with any companies within the Group;
• To hotels and flight companies (such as in the context of offline events and promotions);
• Auditors, contractors or advisers of any of the Group’s business processes;
• To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
• Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
• Potential purchasers or investors in any of the companies within the Group or While Label Brand (if applicable), or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Group (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy).

• Storing such information on our behalf, for example by using cloud computing service providers;
• Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
• Performing research, technical diagnostics or analytics;
• Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see below, under "Marketing"); and
• Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our User Agreement and Privacy Policy), protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.

We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at [email protected].

When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").

The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.

We also allow third parties to collect information about you through Tracking Technologies. To learn more please visit our Cookie Policy.

While using the Services you may encounter links to third party websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.

Please be advised that such third party websites, services or applications are independent from the Group. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.

You should always review their privacy practices carefully before providing Personal Information to such third parties.

You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.

If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations.

In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping.

If for any reason you wish to delete your Personal Information, please send us an e-mail to [email protected], and we will make reasonable efforts to address your request.

You may contact us at any time by email, and request:

1. To access or delete any Personal Information relating to you.
2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
3. That we will restrict or cease any further use of your Personal Information;
4. That we will provide the Personal Information you volunteered to us in a machine-readable format.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

• Secure network topology, which includes intrusion prevention and Firewall systems;
• Encrypted communication;
• Authentication and Access Control;
• External and Internal audit tests; etc.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Services and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email or via the form below.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.

Revised at: 25/08/2021

When you visit or access our Services (such as websites or applications operated by us, or when you interact or engage with our content), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other tracking technologies ("Tracking Technologies").

The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.

We also allow third parties to collect information about you through Tracking Technologies.

Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.

We store Tracking Technologies when you visit or access our Services (for example when you are visiting our websites) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies".

Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

There are five main types of Tracking Technologies:

• Strictly necessary Tracking Technologies – These Tracking Technologies are essential to enable you to login, navigate around and use the features of our Services, or to provide a service requested by you (such as your username). We do not need to obtain your consent in order to use these Tracking Technologies. These Tracking Technologies can be used for security and integrity reasons - for example to detect violation of our policies and for support or security features.
• Functionality Tracking Technologies – These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.
• Performance Tracking Technologies – These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
• Marketing or Advertising Tracking Technologies – These Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.
• Social media Tracking Technologies – Our website includes social media features, such as the Facebook "Like" or "Share" buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.

Tracking Technologies	Type	Purpose
Analytics Cookies	First party Tracking Technology	Performance Tracking Technologies These Tracking Technologies are used to collect information regarding how you interact with the content on our Services, attribution purposes (for example, the referral URL), etc. We use the information to compile reports, calculate the revenues due to us and, help us improve the Services and to offer personalized products and content.
Other cookies	First and Third party Tracking Technology	Strictly necessary Tracking Technologies - these unlisted cookies might be in use on internal sections of the Services, in order to customize and simplify the user experience on the site by remembering choices you made and your log in credentials.

Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including "Do Not Track" requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively. Should you wish to update your preferences at any time,click here.

• Turning off cookies via your web browser
  Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
• Information about cookies is usually found in the "Help" section of the web browser. Below are some links to some commonly used web browsers:
  • Chrome
  • Chrome for mobile
  • Internet Explorer and Microsoft Edge
  • Mozilla Firefox
  • Safari
• Turning off third party cookies
  You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.