Privacy Policy

Effective Date: 31/03/2025

1. Introduction

1. This Privacy Policy, last updated on 31/03/2025, outlines the data processing practices of tugabet.com, operated by Titanzenith Ventures Limitada. At Tugabet, we prioritize simplicity and transparency in handling your personal data. This policy details what information we collect, how we use it, and why, ensuring clarity about your privacy rights.
2. This policy applies whether you are visiting our website, making a deposit, or playing our games. It explains your data privacy rights, circumstances under which we share or obtain your information, and how we personalize marketing communications. Please read all sections carefully.
3. Significant updates to this policy will be communicated to you.
4. All Tugabet employees receive regular training on information security and are bound by confidentiality obligations and internal policies when handling your data.
5. For any questions or concerns regarding data protection, contact our Data Protection Officer at [email protected].

2. Privacy Commitment

1. Tugabet is dedicated to safeguarding the privacy of every customer. Your trust is paramount, and we pledge to:
2. Protect your personal information and keep it secure.
3. Be transparent about why we collect your data and how it is used.
4. Explain and respect your choices and rights regarding your personal information.
5. We aim to enhance your experience by using your data responsibly to deliver better services.
6. To comply with anti-money laundering regulations, players must wager active deposited amounts at least once before making a withdrawal.
7. Tugabet reserves the right to conduct Know Your Customer (KYC) verification for deposits, which may include submitting a selfie with identification documents or other forms of ID. For account verification, we require documents (e.g., ID, payment methods, utility bills) in Latin or Cyrillic alphabets. If you cannot provide documents in these alphabets, we may request video verification showing you with your documents.
8. Tugabet may contact you via the phone number provided in your account as part of the KYC process. No payouts will be processed until your account is fully verified.

3. What Personal Information We Collect and When

3.1. During Account Registration

We collect:

1. Personal details (e.g., name, email address, postal address, phone number, gender, date of birth)
2. Identification documents (e.g., passport, proof of address) for due diligence
3. Banking and financial details to verify the source of funds
4. Account login credentials (e.g., username, email)

3.2. During Use of Our Services

We gather:

1. Data on your interactions with our products
2. Online browsing behavior on tugabet.com (see our Cookies Policy for details)
3. Device information (e.g., model, operating system, IP address, browser type, mobile device identifier)
4. Recordings of phone calls with you, which we may use to verify instructions, resolve issues, comply with regulations, improve service quality, train staff, or detect/prevent fraud
5. Information you voluntarily share or make public (e.g., social media profiles)

3.3. Special Categories of Data

We may collect “special categories of data,” such as health-related information (e.g., for responsible gambling purposes). Additional safeguards are in place to protect the confidentiality of such data (see Section 8).

4. Why We Collect Your Personal Data and Legal Basis

We collect your data to provide the services you expect, enhance your experience, and comply with legal obligations. Tugabet relies on specific legal bases under data protection laws for processing your information, depending on the activity.

4.1. Contractual Necessity

We process your data to fulfill our contract with you, as outlined in our Terms and Conditions, for:

1. Providing gaming, betting, and online content, and handling your requests or inquiries
2. Administering services (e.g., password reminders, service notifications, site maintenance, updates to policies, or account dormancy notices)
3. Processing your transactions

4.2. Legitimate Interests

We process your data for legitimate business interests, provided they do not override your rights or freedoms. We assess factors such as your expectations, the nature of the data, and the impact of processing. These purposes include:

1. Personalizing Your Experience: Using your playing history to offer tailored recommendations or services. If you prefer not to receive personalized services, you can opt out by contacting [email protected] or unsubscribing from marketing offers.
2. Improving Services and Products: Enhancing user navigation, analyzing data for research, testing systems, evaluating marketing effectiveness, and conducting customer modeling or trend analysis to develop better products.
3. Contacting and Interacting with You: Reaching out via phone, email, post, or social media; managing promotions or competitions; inviting you to participate in surveys or market research (participation is optional and does not affect service access); and addressing your queries or complaints.
4. Ensuring Safe and Enjoyable Gaming: Detecting third-party software in peer-to-peer gambling, preventing breaches of our Terms and Conditions, and performing affordability checks to ensure you have sufficient funds.

4.3. Special Categories of Data

We process special categories of data only when:

1. You provide explicit consent
2. The data is publicly available (e.g., shared by you)
3. It is necessary to establish, exercise, or defend legal claims
4. It is required for substantial public interest under applicable laws

5. When We Share Your Personal Information

Tugabet generally does not share your personal data with third parties outside our company group for marketing purposes. However, we may share your data in the following circumstances:

1. When required by regulatory bodies or legal provisions under Costa Rican law
2. To authorize financial institutions holding your account to disclose information as requested by regulators
3. To establish, exercise, or defend our legal rights
4. For verification, affordability checks, or fraud detection, we may share data with third parties
5. With service providers (e.g., technology, data storage, payment processing, or advertising companies) to deliver our services
6. With external auditors conducting independent checks for accreditations
7. To a buyer or transferee in case of a business sale or merger, ensuring your data is used in accordance with this policy
8. To successors in title of our business
9. With regulators regarding self-exclusion matters
10. We ensure that any shared data is used only for the purposes outlined in this Privacy Policy.

6. How Long We Retain Your Data

1. We retain your personal information only as long as necessary to fulfill the purposes for which it was collected.
2. While you are a customer, we retain your data to meet legal and contractual obligations. After you cease using Tugabet’s services, we may retain your data for a period to:
3. Comply with legal requirements (e.g., anti-money laundering or licensing regulations)
4. Establish or defend legal claims (e.g., negligence claims)
5. Fulfill contractual obligations
6. Support our legitimate interests, based on balancing tests
7. Adhere to data protection authority guidelines

7. Your Rights and Choices

1. Under data protection laws, you have rights regarding your personal information, subject to certain conditions. To exercise these rights, contact our Data Protection Officer at [email protected]. These rights include:
2. Accessing, amending, or erasing your data
3. Objecting to data processing
4. Withdrawing consent
5. Requesting data portability
6. Complaining to your data protection authority if you are concerned about our data processing
7. Rights related to automated decision-making and profiling
8. Registration requires mandatory personal information to process your account, contact you, and comply with gambling and financial laws. If you do not provide this information, you cannot use our services.
9. Right to Access and Rectify: You can request a copy of your data (data subject access request) or update incorrect/outdated information free of charge by contacting [email protected].
10. Right to Erase (Right to Be Forgotten): You may request deletion of your data when:
11. It is no longer needed for its original purpose
12. You withdraw consent, and no other legal basis applies
13. We rely on legitimate interests, but cannot justify continued processing
14. There is no lawful basis for processing
15. Erasure is required by law
16. This right is subject to mandatory retention periods under applicable laws.
17. Right to Restrict Processing: You can request that we restrict processing (e.g., store but not use your data) when:
18. You dispute the data’s accuracy (while we verify)
19. Processing is unlawful, and you prefer restriction over erasure
20. We no longer need the data, but you require it for legal claims
21. You object to processing based on our legitimate interests, pending verification
22. We maintain lists of restricted data to ensure compliance.
23. Right to Data Portability: You can receive your data in a commonly used, machine-readable format for use with other services, when processing is based on consent or contract and is automated.
24. Right to Object: You can object to processing based on our legitimate interests or for research/statistical purposes, or to direct marketing (including profiling).
25. Right to Withdraw Consent: For processing based on consent (e.g., marketing), you can withdraw consent at any time via the “unsubscribe” option in communications or by contacting [email protected].
26. Automated Decision-Making and Profiling: We may use automated systems to make decisions (e.g., tailoring services, detecting fraud, assessing account eligibility, or evaluating betting risks). You have the right not to be subject to automated decisions with significant effects, unless they are necessary for a contract, authorized by law, or based on your explicit consent. Contact [email protected] to address related requests.
27. We will respond to your requests within one month, extendable by one additional month for complex or numerous requests, with prior notice. If your request is rejected, we will provide justification. If your request does not meet data protection requirements, we may charge a reasonable fee or reject it.

8. Security and Confidentiality of Your Data

1. Tugabet is committed to protecting your personal information using robust procedures and technologies to prevent unauthorized access or misuse, in line with this Privacy Policy and strict data protection standards.
2. Our payment providers use encryption to secure your credit card details. We collaborate only with trusted payment providers to safeguard your confidential information.
3. Our systems and applications undergo regular security testing by third-party experts. An Intrusion Detection System monitors network traffic 24/7 for potential attacks or intrusions.
4. Our dedicated fraud department employs advanced systems to detect and prevent suspicious activity, ensuring a secure gaming environment.
5. If you notice unrecognized transactions or unexpected balance changes, contact us immediately at [email protected].
6. Tugabet uses SSL encryption to ensure the confidentiality of data during transmission. We do not collect, store, or transfer your card data; payment operations are handled entirely through secure payment gateway servers.

9. Complaints

1. To raise a complaint about how we handle your personal data, contact our Data Protection Officer at [email protected] for investigation.
2. If you are unsatisfied with our response or believe we are processing your data unlawfully, you may complain to your national data protection authority.

10. Changes to the Privacy Policy

1. We may update this Privacy Policy to reflect changes in our operations or regulatory requirements. The most recent revision date will be displayed on this page. Check it regularly, especially before submitting personal information.
2. If you disagree with changes, do not continue submitting personal information or using our services. Continued use indicates acceptance of the updated policy.
3. Significant changes (e.g., affecting how we use your data) will be communicated prominently, including via email for certain services. You must expressly accept such changes to continue using our services, and they will apply immediately upon acceptance.
4. You may delete your Tugabet account at any time.

11. Your Obligations

1. By using tugabet.com and providing personal data, you agree to submit accurate, complete, and current information as requested. You must notify us of any changes to keep your data up to date.
2. If we suspect or find that your provided information is false, incomplete, or violates data protection laws or this Privacy Policy, we may reject your registration, suspend, or terminate your account without notice. In such cases, you are not entitled to compensation for rejection, suspension, or termination.