Privacy Policy

1. Introduction

The information in this Privacy Policy describes how we, SAAGE Labs Limited, a company registered in England (Company number 13783501) whose registered address is Cannon Place, 78 Cannon Place, London, United Kingdom, EC4N 6AF, use the personal data you provide us when you use the SIX SIGMA SPORTS application (“SIX SIGMA SPORTS”), any of the services provided by us which are accessible through SIX SIGMA SPORTS (“Services”), the website (https://sixsigmasports.io/#) or any other sites of ours (“Sites”) and through any communications with us in connection with SIX SIGMA SPORTS (“Communications”).

SIX SIGMA SPORTS, the Services and Sites are delivered to you in partnership with our online gaming licensor, SunSeven N.V. (a company incorporated under the laws of Curacao, company number 100554, and having its registered office at Heelsumstraat 51, E-Commerce Park, Curacao). When you engage with SunSeven N.V. in connection with the provision of SIX SIGMA SPORTS, the Services, and the Sites, SunSeven N.V. is acting as a processor on our behalf. When we refer to information collected by us throughout this policy, this includes information collected by SunSeven N.V. on our behalf and under our instructions.

We respect your privacy and protecting your information is paramount. We want you to be informed and empowered with respect to your privacy when you use SIX SIGMA SPORTS and the Services, Sites, and during any Communications with us, so please read this Privacy Policy carefully. This Privacy Policy sets out our practices regarding your personal data, how we collect, process, and treat it, and the rights you have in relation to the protection of your personal data.

2. Important information and who we are

SAAGE Labs Limited is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

· Full name of legal entity: SAAGE Labs Limited

· Attention: Data Privacy Manager

· Email address: [e-mail]

· Postal address: Cannon Place, 78 Cannon Place, London, United Kingdom, EC4N 6AF

3. Complaints

If you have a complaint relating to the processing of your personal data, please use the contact details above to contact us.

We would appreciate the opportunity to address any concerns or complaints you may have with respect to SIX SIGMA SPORTS, the Services, Sites and Communications and our data processing practices. However, you have the right to make a complaint at any time to the Supervisory Authority (that is, the regulator for data protection issues). In the UK, this is the Information Commissioner’s Office (ICO) (https://ico.org.uk/make-a-complaint/).

4. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

5. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

· Communications Data: details regarding the communications made between us.

· Identity Data: first name, last name, username, e-mail address or similar identifier, title, date of birth.

· Contact Data: address and email address.

· Financial Data: digital wallet address.

· Transaction Data: details about transactions to and from you.

· Device Data: IP Address.

· Usage Data: includes details of your use of SIX SIGMA SPORTS, the Services and Sites including, but not limited to, traffic data, and other communication data, whether this is required for our own purposes or otherwise and the resources that you access (including but not limited to the digital wallet(s) used).

· Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

· Location Data: Geo-Location IP.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

6. How is your personal data collected?

We will collect and process the following data about you:

· Information you give us. This is information (including Identity, Contact and Marketing and Communications Data) you consent to giving us about you by filling in forms on SIX SIGMA SPORTS or on our Sites, or through Communications with us (for example, by email or chat). It includes information you provide when you register to use SIX SIGMA SPORTS or subscribe to any of our Services and when you report a problem with SIX SIGMA SPORTS or our Services or our Sites. If you contact us, we will keep a record of that correspondence.

· Information we collect about you and your device. Each time you visit one of our Sites or use SIX SIGMA SPORTS we will automatically collect personal data including device and usage Data. We collect this data using cookies and other similar technologies.

· Location Data. We also use geo-location IP to determine your current location. It is necessary for us to determine your location to provide you with access to and use of SIX SIGMA SPORTS and the Services in compliance with our legal and regulatory obligations. If you wish to register to use SIX SIGMA SPORTS and the Services, you will be asked to consent to your data being used for this purpose. You can withdraw your consent to your data being used for this purpose at any time by requesting the deletion of your SIX SIGMA SPORTS account.

· Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

o Device Data from the following parties:

§ analytics providers including but not limited to Meta, Google Analytics and other third party affiliate networks;

§ advertising networks including but not limited to Meta and Google; and

§ search information providers including but not limited to Google Index, Bing and Yahoo.

o Identity and Contact Data from data brokers, data aggregators or third party service providers.

7. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

· Where you have consented before the processing.

· Where we need to perform a contract, we are about to enter or have entered with you.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. When we rely on our legitimate interests, you have the right to object at any time. For example, we may process your personal data to:

o Keep our records up to date.

o Provide you with our Services, including for the purpose of quality control and analysis.

o Develop and improve our Services.

o Communicate and manage our relationship with you.

· Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email, Progressive Web App (PWA) notification or native in-app notification if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We will never sell your personal data.

Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new SIX SIGMA SPORTS user	Identity Contact Location	Your consent Necessary to comply with legal obligations
To manage our relationship with you including notifying you of changes to SIX SIGMA SPORTS or any of the Services and managing any requests or complaints received from you	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and SIX SIGMA SPORTS including troubleshooting, data analysis and system testing	Identity Contact Device Usage Location	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To monitor trends so we can improve SIX SIGMA SPORTS	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)

8. Disclosures of your personal data

We may need to disclose your personal data to others to facilitate the provision to you of SIX SIGMA SPORTS. Disclosure of your personal information to a third party will only be made where they agree to keep your information confidential and will only be used for the specific purpose for which we provide it to them. Your data may be disclosed to the other persons or entities as described below.

· Third parties who supply services to us, such as our online gaming licensor (SunSeven N.V., as referred to above) and our KYC service provider.

· Our professional advisors, such as our legal advisors where they require information in order to provide advice to us in relation to SIX SIGMA SPORTS, our Services, Sites or Communications.

· Any regulatory authority we may be subject to for the purpose of demonstrating compliance with applicable laws and regulations.

· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

· Such third parties as we reasonably consider necessary in order to prevent crime, e.g., the police.

9. International transfers

Your personal data may be stored and processed outside the UK in countries that may have different data protection rules than our own. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards have been put in place.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

10. Data security

All information you provide to us is stored on our secure servers. Information we pass to third parties will be stored on their secure servers.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

11. Use of Cookies

SIX SIGMA SPORTS, the Services and our Sites use “cookies” and similar technologies to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Depending on their purpose, the cookies may last only the length of a single browsing session, but in some cases, may last longer to ensure their purpose is fulfilled. Cookies help us recognise you as a unique visitor when you return to SIX SIGMA SPORTS and our Sites and help us to better understand how visitors use SIX SIGMA SPORTS and our Sites. This helps us to provide you with a good experience when you use SIX SIGMA SPORTS and our Sites and also allows us to improve SIX SIGMA SPORTS, our Sites and the Services. We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

Broadly, SIX SIGMA SPORTS and our Sites use cookies and similar technologies for the following purposes:

· Strictly necessary cookies. These are cookies that are required for the operation of SIX SIGMA SPORTS, the Services and our Sites. They include, for example, cookies that enable you to log into secure areas of SIX SIGMA SPORTS and our Sites.

· Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around SIX SIGMA SPORTS and our Sites when they are using them. This helps us to improve the way SIX SIGMA SPORTS and our Sites work, for example, by ensuring that users are finding what they are looking for easily.

· Tracking cookies. These cookies record your visit to SIX SIGMA SPORTS and our Sites, the pages you have visited and the links you have followed. We will use this information to make SIX SIGMA SPORTS and our Sites, and the advertising displayed on them more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title Cookie Type Cookie Name	Purpose	Expiry
Name: App Session Cookie Category: Strictly Necessary Type: Persistent Cookies	Application feature in use Application state Time Zone Device type	Expires 7 days from visit
Name: User Session Cookie Category: Strictly Necessary Type: Session Cookies	Wallet Address Wallet Balance Wallet Type Track Login/Logout of SIX SIGMA SPORTS and our Sites	End of session / Expires on Logout of our Site

Please note that the following third parties may also use cookies when you access SIX SIGMA SPORTS, our Services or our Sites, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

· Google Analytics

· Facebook Pixel

· Instagram Pixel

· Elfsight

· Youtube

You can choose whether to allow analytical and tracking cookies by clicking on the button(s):

· Analytical or Tracking cookies ON/OFF

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of SIX SIGMA SPORTS, our Sites or our Services.

12. Data retention

We will only keep your personal data for as long as necessary to carry out the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations, following which we will securely destroy your personal information. We will provide you with more detail regarding the storage periods for the different types of personal data as and when you request.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

We are committed to delivering the rights that data protection law provides. Please be aware that these rights are often not absolute, and exemptions may apply.

You have the right to:

· Be informed: and to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.

· Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o if you want us to establish the data’s accuracy;

o where our use of the data is unlawful, but you do not want us to erase it;

o where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

o you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or Services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting us using the contact details set out at the top of this Privacy Policy.

14. How we Protect Your Information

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss, or damage.

15. Links to Third Party Websites

SIX SIGMA SPORTS may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

16. Changes

We keep our privacy policy under regular review. This version was last updated on 1 December 2023.

We may make changes to this Privacy Policy in future to reflect changes in the functionality of SIX SIGMA SPORTS or otherwise changes in the way that we process your personal information. Any changes we may make to our SIX SIGMA SPORTS Privacy Policy will be posted [https://six-sigma-sports.gitbook.io/docs/privacy-policy] and, where the changes are material or we decide it is appropriate, notified to you in any manner we deem appropriate. Please check back frequently to see any updates or changes. Please note that from time to time, we may require you to read and acknowledge such updates or changes.