Situs23 Privacy Policy – Member Personal Data Protection

Situs23 understands that your trust is invaluable. When you entrust us with your personal information — from your name and email address to your financial data — we take full responsibility for safeguarding it to the highest standard.

This Privacy Policy is written in clear, easy-to-understand language because we believe you have the right to know exactly what happens to your data. No intentionally obscured clauses, no hidden terms — everything is stated here as it is.

We comply with international data protection principles, including requirements to collect only the data we truly need, retain it only for as long as necessary, and give you control over your own data.

Situs23 only collects data that is strictly necessary to operate the service safely and effectively. The following are the categories of data we collect:

Identity Data

• Full name as shown on your official ID (national ID/passport)
• Date of birth
• Photo or scanned copy of identity document for KYC verification

Contact Data

• Active email address
• Phone number
• Residential address (optional, for specific purposes)

Financial Data

• Bank account number or digital wallet for deposit and withdrawal purposes
• History of deposit, withdrawal, and win transactions on the platform

Technical and Behavioral Data

• IP address and device information when accessing the platform
• Browsing session data and in-platform preferences
• Betting history and game activity (used for security and fraud detection)

Data collection occurs through several fully transparent channels:

• Directly from you — when registering an account, filling out profile forms, making deposits or withdrawals, contacting the support team, or participating in promotional programs.
• Automatically — when you use the platform, our systems automatically log technical data such as your IP address, browser type, device used, and session activity. This data is used for security and service improvement.
• Cookies and similar technologies — used to keep login sessions active, save display preferences, and analyze platform usage in aggregate.
• Authorised third parties — during the KYC verification process, we work with trusted identity verification service providers. Data received from them is used solely for verification purposes.

Every piece of data we collect is used for a specific, accountable purpose. These purposes are as follows:

• Account operations — creating, verifying, and managing member accounts, and securely processing all financial transactions.
• Fulfilment of legal obligations — including KYC/AML (Anti-Money Laundering) procedures required by regulators to ensure the platform is not misused for illegal activities.
• Platform Security — detecting and preventing fraudulent activity, unauthorized access, or account misuse.
• Service improvement — analyzing usage patterns in aggregate (not individually) to improve product quality and user experience.
• Service communications — sending important notifications regarding your account, policy updates, or security information. This differs from marketing communications and cannot be disabled as it is operational in nature.
• Promotional communications — with your consent, sending information about bonuses, promotions, and exclusive offers. You can unsubscribe at any time via the notification settings in your account.

Situs23 does not sell, rent, or trade your personal data to any third party. However, in the course of operating our service, we work with trusted partners who may receive limited access to certain data:

• Payment service providers — the banks and digital wallets you use for deposits and withdrawals. They only receive the data necessary to process transactions.
• Identity verification providers (KYC) — independent verification agencies that help us confirm member identities. Data is shared solely for verification purposes and is not retained by them longer than necessary.
• Platform technology providers — cloud infrastructure and security partners that help operate the platform. They are bound by strict confidentiality agreements and may not access or use data for their own purposes.
• Legal authorities — if required by applicable law or court order, we may be asked to share data with the relevant authorities. We will always endeavor to limit the scope of information shared to only what is necessary.

All third-party partners working with situs23 are required to sign a data processing agreement that upholds the same security and confidentiality standards we apply ourselves.

Situs23 employs a layered security system to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL encryption for all data transmitted between your device and our servers.
• Data encryption at rest (at-rest encryption) for sensitive data such as financial account details and identity documents.
• Role-based access control (RBAC) — situs23 employees can only access data relevant to their role. No single employee has access to all member data.
• Real-time anomaly monitoring — our systems detect unusual access patterns and automatically block suspicious activity.
• Penetration testing periodically conducted by independent third parties to identify and patch security vulnerabilities before they can be exploited.

Situs23 uses cookies and similar tracking technologies to deliver a better experience on the platform. The following are the types of cookies we use:

• Essential cookies — strictly required for core platform functions such as keeping login sessions active and remembering language preferences. These cookies cannot be disabled without affecting platform functionality.
• Analytics cookies — used to understand how members use the platform in aggregate, not individually. This data helps us identify areas for improvement.
• Preference cookies — storing personal settings such as display preferences and favorite filters so you don't need to reconfigure them each time you visit the platform.

You can manage your cookie preferences through your browser settings. Please note, however, that disabling essential cookies will affect your ability to use key platform features.

We retain your personal data only for as long as needed to fulfil the purpose for which it was collected, or as required by applicable regulations.

• Active account data — retained for as long as your account remains active on the platform.
• Financial data and transaction history — retained for a minimum of 5 years in compliance with financial regulatory and audit obligations.
• Identity verification data (KYC) — retained for a minimum of 5 years after account closure, in accordance with international anti-money laundering regulations.
• Security log data — retained for 12 months for investigation purposes if required.
• Inactive (dormant) account — account data inactive for more than 3 years will go through a review process and be deleted after notifying the account holder.

Once the retention period ends, data is permanently deleted using secure erasure methods that ensure it cannot be recovered.

As a situs23 member, you hold the following rights over your personal data. situs23 is committed to processing all requests related to these rights within 30 calendar days.

Situs23 is a platform intended exclusively for users aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18.

If we find that someone under the age of 18 has registered an account or provided us with personal data, we will immediately close that account, delete all associated data, and void any transactions that may have occurred.

If you have information or suspect that a minor has used our platform, please contact our support team immediately so we can take the necessary action.

In the course of its operations, Situs23 may store and process your data on servers located in various countries. These cross-border data transfers are carried out with safeguards that ensure your data remains secure and is handled to a standard equal to or higher than this privacy policy.

The protective measures we apply for international data transfers include:

• Standard data transfer agreements compliant with international data protection regulations
• Selecting data storage partners that operate in jurisdictions with strong data protection laws
• Full encryption throughout the transfer process

Situs23 may update this Privacy Policy from time to time to reflect changes in our operational practices, regulatory requirements, or security standard improvements. Any changes will be published on this page with the latest update date shown at the top.

For material changes — those that significantly affect how we process or use your data — we will notify you via email or in-app notification at least 14 days before the changes take effect.

Continuing to use the platform after the effective date of any changes constitutes your acceptance of the updated policy. If you disagree with the changes made, you have the right to close your account and request deletion of your data in accordance with the procedure described in Section 9.