The controller of personal data is Admiral Bet S.r.l., with registered office at Via Giulio Vincenzo Bona n. 110, 00156 – Rome, Italy, Tax Code 04236330405 and Group VAT No. 17305131009.

For any information regarding the processing of personal data or to exercise the rights provided for under applicable law, the data subject may contact the Controller at the contact details set out in Section 14 of this Policy.

In the context of use of the Site, Admiral Bet may process various categories of personal data depending on the user’s interaction with the Site and its related services.

2.1 Browsing data

The computer systems and software procedures used to operate the Site automatically collect, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This category includes, by way of example, the IP addresses or domain names of devices used by users, the URIs (Uniform Resource Identifiers) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code relating to the server response status, and other parameters relating to the user’s operating system and computing environment.

2.2 Data voluntarily provided through the “Contacts” section form

When the user completes the form in the “Contacts” section of the Site, Admiral Bet may collect the personal data requested in the form, such as first name, last name, email address, telephone number, and any further information spontaneously entered by the user in the message field.

2.3 Data provided through the Programme application form

When the user completes the Programme application form, Admiral Bet processes the personal data necessary to manage the application or membership request, including identification data, contact details, professional information, and any other information required by the form or subsequently necessary to assess the potential establishment of a contractual relationship.

Depending on the structure of the form and any documentation that may be requested, the data processed may also include information relating to the data subject’s professional or business activity, tax or corporate details, and data of their representatives, partners or contact persons where relevant to the membership application. Where necessary, information obtained from publicly available sources or legitimately accessible commercial databases for the purpose of assessing commercial reliability may also be processed.

2.4 Data contained in subsequent communications

Admiral Bet may also process data contained in communications sent voluntarily by the data subject, including after the initial contact or application request, for example via email or other contact channels indicated on the Site, where such communications are relevant to managing the request, the pre-contractual phase, or any contractual relationship.

2.5 Data processed in the context of KYC and AML checks

In compliance with Legislative Decree No. 231/2007 and subsequent amendments, as well as the Programme Terms and Conditions and the Online Affiliation Agreement, Admiral Bet may process personal data in the context of customer due diligence checks (Know Your Customer – KYC) and anti-money laundering checks (Anti-Money Laundering – AML). Such data may include identity documents, information on beneficial ownership, financial data, and any further information necessary to fulfil legal obligations.

Personal data are processed for the following purposes.

3.1 Enabling browsing and the correct functioning of the Site

Browsing data are processed to enable the technical operation of the Site, ensure its security, carry out technical checks, obtain aggregate statistical information on Site usage, and establish any liability in the event of unlawful conduct or cyberattacks.

3.2 Managing requests submitted through the “Contacts” section form

Data provided by the user through the contact form are processed to respond to requests for information, clarification or assistance submitted by the data subject, and to carry out all activities strictly connected with the management of such requests.

3.3 Managing the Programme application

Data entered in the application form are processed to receive, analyse, and manage the data subject’s application, to follow up with the applicant, to carry out the necessary preliminary checks, and to take pre-contractual measures at the data subject’s request.

3.4 Performance of the contractual relationship

Where, following the assessment and pre-contractual phase, a relationship is established with the data subject through the execution of the Online Affiliation Agreement, personal data may be processed for the management, execution, and administration of the relevant contractual relationship, including invoicing activities, commission reporting, and management of the dedicated Portal.

3.5 Compliance with legal obligations

Personal data may be processed to comply with obligations imposed by law, regulations, national or EU legislation, as well as orders or requests from competent authorities, including obligations relating to tax matters, anti-money laundering (Legislative Decree No. 231/2007), public gaming regulations (Legislative Decree No. 41/2024), and measures issued by ADM (Agenzia delle Dogane e dei Monopoli).

3.6 Assessment of commercial reliability and risk mitigation

Prior to entering into the contractual relationship and, where appropriate, also during its performance, Admiral Bet may process the data subject’s personal data to assess their commercial reliability, solvency, and suitability with respect to the potential establishment or continuation of the commercial relationship.

To this end, Admiral Bet may also obtain information from databases or specialist providers offering information on the commercial reliability of business owners and managers, limited to data that are relevant and necessary for the purpose pursued, as well as from publicly accessible sources. Data extracted from such databases may belong to the following categories: financial and economic data; reputational data; data necessary for the purposes of asset investigations.

During the performance of the contractual relationship, Admiral Bet may process the data subject’s personal data, including data obtained from the commercial information systems referred to above, to assess the Partner’s contractual diligence and commercial performance, in order to determine whether and under what conditions to continue the relationship. In any case, no decisions based solely on automated processing will be made by the Controller.

3.7 Prevention of fraud, abuse, and protection of Programme integrity

Personal data may be processed to prevent and combat fraudulent activities, artificial traffic, Programme abuse, and unlawful use of the Site, in accordance with the Programme Terms and Conditions and the Online Affiliation Agreement.

3.8 Establishment, exercise, or defence of a legal claim

Personal data may be processed where necessary to establish, exercise, or defend a legal claim of the Controller, whether in judicial or out-of-court proceedings.

The processing of personal data is carried out in compliance with the lawfulness conditions provided for in Article 6 of Regulation (EU) 2016/679 and is based on the following legal grounds, in relation to the specific purposes referred to in Section 3 of this Policy.

In particular:

• the processing of data provided through the “Contacts” form, for the management and handling of requests (purpose referred to in Section 3.2), is based on the data subject’s consent pursuant to Article 6(1)(a) of the Regulation. The provision of consent is optional; however, failure to provide it will make it impossible to process the request;
• the processing of data relating to the Programme application and the potential subsequent establishment of a contractual relationship, as well as invoicing and reporting activities (purposes referred to in Sections 3.3 and 3.4), is based on the performance of pre-contractual measures taken at the data subject’s request and, where applicable, on the performance of a contract, pursuant to Article 6(1)(b) of the Regulation;
• the processing carried out to comply with legal obligations, including those relating to tax matters, anti-money laundering, and public gaming regulations (purpose referred to in Section 3.5), is based on Article 6(1)(c) of the Regulation;
• the processing of personal data for purposes connected to the technical operation and security of the Site (Section 3.1), the assessment of commercial reliability and risk mitigation (Section 3.6), the prevention of fraud and Programme abuse (Section 3.7), as well as the establishment, exercise, or defence of a legal claim (Section 3.8), is based on the legitimate interest of the Controller pursuant to Article 6(1)(f) of the Regulation.

It is understood that, in cases where processing is based on legitimate interest, the Controller has carried out a balancing assessment between its own interests and the fundamental rights and freedoms of the data subjects, concluding that such interests are compatible with the data subjects’ reasonable expectations in relation to their interactions with the Site and the Programme.

The provision of browsing data is necessary for the operation of Internet protocols and the Site.

The provision of data requested in the forms on the Site is optional but necessary to enable Admiral Bet to respond to the data subject’s request or to manage their Programme application. Failure to provide data marked as mandatory may result in the inability to respond to the request or to initiate or complete the pre-contractual assessment and membership procedure.

The provision of data required in the context of KYC and AML checks is mandatory under applicable law; refusal to provide such data will result in the inability to proceed with membership of the Programme and execution of the Online Affiliation Agreement.

Personal data are processed by electronic, digital and, where necessary, paper-based means, in ways strictly related to the purposes set out in this Policy and in compliance with the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity, and confidentiality. The Controller implements appropriate technical and organisational measures to protect personal data against loss, destruction, unauthorised access, unlawful or improper use, and any other form of unauthorised processing.

Personal data may be accessed by employees and collaborators of the Controller who are expressly authorised to process them, within the limits of their respective duties and in connection with the purposes described above, and who are duly instructed and bound by confidentiality obligations – for example, for activities relating to Site management, customer support, compliance, administration, contract management, and operational support.

Personal data may also be processed, as data processors pursuant to Article 28 of the Regulation, by third-party providers that supply the Controller with services instrumental to its activities, such as IT service providers, hosting providers, management and administrative service providers, external consultants, professionals, group companies providing intra-group services, and other parties whose involvement is necessary for the technical, organisational, or legal management of the relationship.

Personal data may be disclosed to third parties where permitted or required by law, and in particular:

• to banks or payment institutions, where necessary in connection with the contractual relationship and the payment of commissions;
• to administrative, tax, judicial or public security authorities, including the Customs and Monopolies Agency (ADM), to the extent required by law or by orders from competent authorities;
• to lawyers, consultants, and other professionals, where disclosure is necessary for compliance with legal obligations or for the protection of the Controller’s rights;
• to companies belonging to the same corporate group as the Controller, for internal administrative and organisational purposes.

Personal data will not be subject to dissemination.

Personal data are processed within the European Economic Area (“EEA”).

In the event of a transfer of personal data to countries outside the EEA, such transfer will take place in compliance with Articles 45 et seq. of the Regulation, by means of appropriate safeguards, such as adequacy decisions of the European Commission or standard contractual clauses.

Personal data are retained for a period no longer than necessary for the purposes for which they were collected and processed. In particular:

• data collected through the “Contacts” form are retained for the time necessary to manage the request and, in any event, within the period necessary to protect the Controller’s rights;
• data collected through the Programme application form are retained for the time necessary to manage the assessment and pre-contractual phase;
• if, following the assessment, Admiral Bet decides not to proceed with the execution of the Online Affiliation Agreement, data may be retained for 30 days, consistent with the provisions set out in the contractual notice for a negative outcome of the pre-contractual assessment procedure;
• in the event of establishment of a contractual relationship, data will be retained for the duration of the relationship and, thereafter, for 10 years from its termination, for the fulfilment of legal obligations and the protection of the Controller’s rights, unless extended by events interrupting the applicable limitation period;
• where it is necessary to manage disputes, complaints, or authority requests, data may be retained for the additional time needed to resolve the relevant procedure.

The Site may use technical cookies and other tracking tools and, where applicable, further categories of cookies in accordance with the cookie policy made available through the Site.

For detailed information on the cookies used, their purposes, retention periods, and how to manage preferences, users should refer to the specific cookie policy.

The assessment of a Programme application may also involve the analysis of relevant commercial information; however, Admiral Bet will not make decisions based solely on automated processing that produce legal effects or similarly significant effects on the data subject, and human intervention in the decision-making process will always remain possible.

Pursuant to Articles 15–22 of the GDPR, the data subject has the right to:

• access: obtain from the Controller, where applicable, confirmation as to whether or not personal data relating to the data subject are being processed, and if so, to obtain access to those data and a copy thereof, as well as the information referred to in Article 15 of the Regulation;
• rectification: obtain the rectification of inaccurate data or the completion of incomplete data;
• erasure (“right to be forgotten”): obtain the erasure of data relating to the data subject where one of the grounds set out in Article 17 of the Regulation applies;
• restriction of processing: obtain, in the cases indicated in Article 18 of the Regulation, the marking of stored data with a view to limiting their processing in the future;
• data portability: receive, in the cases indicated in Article 20 of the Regulation, data in a structured, commonly used, and machine-readable format, and to transmit them to another controller without hindrance;
• objection: object at any time, on grounds relating to the data subject’s particular situation, to the processing of data based on the legitimate interest of the Controller, including profiling;
• withdrawal of consent: withdraw consent at any time, without prejudice to the lawfulness of processing based on consent before its withdrawal.

The data subject also retains the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali – www.garanteprivacy.it) or with the supervisory authority of the EU Member State in which the data subject resides or works.

Requests to exercise rights may be sent to the Controller at the contact details set out below, including by using the forms made available by the Italian Data Protection Authority at: https://www.garanteprivacy.it/home/modulistica-e-servizi-online.

Admiral Bet S.r.l.
Via Giulio Vincenzo Bona 110
00156 Roma
Attn.: Compliance Office
Email: privacy@admiralsport.it

Admiral Bet has appointed a Data Protection Officer (DPO) who may be contacted:

• by email at: dpo@greentube.com
• by certified email (PEC) at: dpoadmiralsport@pec.it
• by recorded delivery post to: Admiral Bet S.r.l. – Via Giulio Vincenzo Bona 110, 00156 Rome, Italy, Attn.: Compliance Office.

This Policy may be subject to amendments or updates, including as a result of changes in applicable law, organizational developments, or modifications to the services offered through the Site.

Users are therefore encouraged to consult this page periodically.