Privacy Policy

Updated: December 2024

С (hereinafter referred to as “С”, “Us”, “We”, and “Our”) is committed to respecting and protecting your privacy. We take this seriously, so if you have any questions, don’t hesitate to ask.

In our work, we strive to comply with all applicable laws to protect the privacy and security of personal information.

This Privacy Policy (“Policy”) explains how С collects, uses and discloses your personal information.

The Policy sets out our data protection practices and describes the types of information we may process when you use our website (“our Web-site”). This policy applies to all users who access our Web-site (“Users”).

By accessing or using our web-site, you acknowledge that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

In this Policy, you may be referred to as “you” or the “User”.

By using our Web-site, you agree to this Privacy Policy. If you do not agree, do not use our Web-site.


The terms we can use in this Privacy Policy:

“С”, “Us”, “We”, and “Our” – those who are authorized to manage the our Web-site, who organize and/or process Personal Data, and also determine the purposes of processing Personal Data, the composition of Personal Data. The actions to be processed (operations) performed with Personal Data. 

“Personal data” – any information of any kind relating directly or indirectly to a specific or identifiable subject of personal data (individual) who can be identified directly or indirectly, in particular by reference to such data. This is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social status (“User”).

“Personal data processing” – any action (operation) or a set of actions (operations) took with or without the use of automation tools with Personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal data.

“Confidentiality of Personal data” – a mandatory requirement not to allow the disclosure of Personal Data without the consent of the Users or the existence of other legal requirements.

“User” is a person who has an access to the Website via the Internet and / or uses the Services.

“IP-address” — Internet Protocol address, that is a series of numbers that identifies any device on a network.

“Device” – means any internet-connected device, such as a phone, tablet, computer, or any other device that can be used to access our Web-site.

“Third Party Services” – refers to advertisers, advertising and marketing partners, and providers of  analytics, email, SMS, push notification providers and others who provide our content or whose products or services, in our opinion, may be of interest to you.


The User’s use of our Web-site constitutes acceptance of this Privacy Policy and the terms of processing of the User’s Personal Data.

If Users do not agree to the terms of the Policy, they must immediately stop using our Web-site.

This Policy applies only to our Web-site. С does not control and is not responsible for third party sites that the User may access via links that may be available as a result of using our Webs site.

We do not check and are not responsible for the accuracy of the Personal Data provided by the User, but we assume that the User provides reliable and sufficient Personal Data and also keeps this information up to date.


С may acquire, store, process, use and disclose Personal Data provided by the User when using our Web-site as defined in this Policy. The User grants С the right to receive, store, process, use and disclose the Subject’s Personal Data in accordance with the terms of this Policy. С collects, stores, processes and uses the User’s Personal Data to allow Users to use our Web-site, as well as to protect the rights and legitimate interests of the User of Personal Data established by law.

Personal data provided for processing under this Policy is provided by the User by filling out special forms in our Web-site and includes the following information:

  • Contact Data – includes email address.
  • Profile Data” includes your username and password (encrypted), login and logout times.
  • Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties, your communication preferences and any correspondence we had with you. This category also includes content you submit, such as, posts, comments, personal preferences, opinions, complaints, chats.
  • Technical Data” includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, your internet service provider (ISP), your device, your location, your operating system and platform, header of your requests and other online identifiers.
  • Usage Data” includes information about how you use our Website, including the full Uniform Resource Locators (URL) and page interaction information.
  • 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 information 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.

We may use the User’s Personal Data for the following purposes:

  • To register you as a new user;
  • To manage our relationship with you which will include notifying you about changes to our Terms of Use or Privacy Policy and maintain a User Account with us;
  • To send you promotional information and newsletters;
  • To administer and protect our business and out Web-site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  • To use data analytics to improve our website, products, marketing, customer relationships and experiences;
  • To make suggestions and recommendations to you about products that may be of interest to you.


We may use third-party automatic data processing technologies, such as advertising or analytics tools, to analyze certain information sent by your device through our Web-site. Some of these integrated tools may perform automated processing of your personal data, including profiling. Profiling includes any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects relating to your personal preferences, interests, behaviour, location or movements. 

To improve the performance of our Web-site, we may process information about your device and user behavior based on our legitimate interests. This data is generally non-personal information, meaning it cannot be directly associated with any specific individual, and we only access it in aggregate form.

Please note that we do not control the information automatically provided to advertising or analytics tools and therefore cannot accept responsibility for the processing of such information. It is important to know that some services engage in personal data profiling and may obtain information related to your identity or device through technologies for which we are not responsible. If your user ID is associated with your Facebook account, Facebook may use information about your device along with classified data already recorded in its databases, such as your age, gender or other demographics. We do not control or guarantee how third parties process your personal data that may be collected through means other than our Wed-site. If you have any questions regarding the disclosure of your personal information, please direct them to us at


The User‘s Personal data is treated in compliance with generally accepted international law and the rules that apply to you, including but not limited to:

  • If you live in the European Union (EU), you have privacy rights and all Personal Data processing is governed by regulations and rules that follow Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, also known as the General Data Protection Regulation (“GDPR”).
  • If you are located in the United Kingdom, all Personal Data processing is carried out in compliance with the Data Protection Act 2018 (“DPA 2018”) and the UK General Data Protection Regulation (“UK GDPR”).
  • If you are based in Australia, all Personal Data processing is done in line with the Privacy Act 1988‘s norms and rules.
  • If you are located in Canada, all Personal Data processing is carried out in compliance with the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
  • If you live in New Zealand, all Personal Data processing is done in compliance with the Privacy Act 2020‘s regulations and procedures.
  • If you live in California, all Personal Data processing is done in accordance with the California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq. (“CCPA”) standards and procedures.
  • If you are located in Brazil, all Personal Data processing is done in line with the Lei Geral de Proteço de Dados (“LGPD”) legislation and rules.
  • Protection of Children, Our Web-site is an online gambling information portal and as such none of its marketing content, products, services or promotions are appropriate for, or targeted at, children and visitors under the age of 18 years of age (or the equivalent minimum age in the relevant jurisdiction). Our Web-site does not knowingly solicit or collect personal data from children below the age of 18. If we discover that our Web-site has accidentally collected personal data from a child below 18, it will remove that child’s personal data from its records as soon as reasonably possible. We bear no responsibility for the actions taken by children or visitors under the age of 18 (or the equivalent minimum age in the relevant jurisdiction) based on the content found on our Web-site, or any of its sub-domains and pages, nor our outbound marketing campaigns (including but not limited to our email newsletter). In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at


To protect your Personal Data, С follows the following principles based on applicable international laws regarding the processing of personal data.

The principle of purpose limitation means that С collects Personal Data only for specific, explicit and lawful purposes, and С does not process it in ways that are incompatible with those purposes.

Data accuracy is a principle that С follows to ensure that Personal Data is accurate and, where appropriate, up to date. С takes all reasonable precautions to ensure that erroneous Personal Data is promptly destroyed or corrected, taking into account the reasons for which it is collected.

Principles of legality, fairness and transparency. С processes the Personal Data of the data subject in a lawful, fair and transparent manner.

The data minimization principle states that С collects only as much Personal Data as is necessary for the purposes for which С processes the Personal Data.

Principle of storage limitation. С stores Personal Data in a form that allows the identification of data subjects for no longer than is necessary for the purposes for which the Personal Data is processed.

С processes Personal Data in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful processing, as well as against accidental loss, destruction or damage, by applying appropriate technical or organizational measures.


The user is obliged:

  • Provide Personal Data necessary for us to provide the Services.
  • Do not disclose the information required to log into your С personal account, and do not transfer access to your personal account to third parties.
  • Do not use any automated means to collect data on our Web-site.

С is obliged:

  • Use Personal Data solely for the purposes specified in this Policy.
  • Ensure that Personal Data is kept secret and does not sell, exchange, publish or disclose in any other possible way the User’s Personal Data transferred, except for the conditions set forth in this Policy.
  • The provision of User information to third parties is carried out only in accordance with his instructions or if necessary in order to provide the User with a certain Service, or for other reasons in accordance with current legislation.
  • Take reasonable and necessary precautions to protect the User’s Personal Data.
  • Block Personal data relating to the relevant User from the moment of application by the User or his legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification, in the event of detection of false personal data or unlawful actions.

In case of disclosure of Personal Data, we are not responsible if this information:

  • Became publicly known before being lost or revealed.
  • It was received from a third party before we received it.
  • Was disclosed with the consent of the User.

In case of violation of any of the obligations specified in this section, the User’s personal account may be blocked forever without the possibility of unblocking and refunding funds for the Services provided.


When integrating external services, we carefully select third-party providers to ensure that appropriate technical and organizational measures are in place to protect your personal data. However, we cannot guarantee the security of any information transmitted to such third-party providers. We are not responsible for any accidental loss or unauthorized access of your personal data due to the actions of third-party providers.

We do not rent or sell your personal information to third parties, but we may share information from tools such as cookies, log files, device identifiers and location data with third parties that provide automatic data processing technologies for our Web-site. We do not control these third parties’ tracking technologies or their use.

Please note that when integrating external services, we select third parties who can guarantee the use of all necessary technical and organizational measures to protect users’ personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for accidental loss or unauthorized access to your personal data due to the fault of third parties.

We may also share certain information, such as cookie data, with third party advertising partners. This information allows third-party advertising networks to deliver targeted advertisements that they believe will be of most interest to you.

We may disclose your personal information in the following cases:

  • When required by law;
  • When we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via a prominent notice of changes in ownership or use of your personal information, as well as the choices you have regarding your personal information.


Our activities cover cross-border areas, providing our Web-site to users around the world.

We and our selected third-party providers who provide automated data processing technologies for our application, as well as our advertising partners, may transfer processed information outside the country from which the transfer occurs to other countries or jurisdictions.

If you are located in the European Union or other regions with different data processing laws than the United States, please be aware that information, including personal data, may be transferred to a country or jurisdiction where the applicable data protection rules may differ from those of are valid in your region.

This means that your personal information may end up in a third country, a specific territory or one or more specified sectors within that country, or an international organization where the level of data protection and privacy may not meet your local regulations.

We are committed to ensuring that the recipient of your personal data provides appropriate protection in accordance with applicable data protection laws. By using the application, you consent to the transfer of your personal data to any third country, territory or designated sector in that country, as well as to international organizations.

To store data, we use the services of hosting organizations. We place great importance on your privacy and, where possible, encrypt your personal information before storing it. Please note that we only work with hosting organizations that have successfully passed our security and reliability checks.


Your personal information will be retained for as long as necessary to ensure the functionality of our Web-site and to comply with our legal obligations. If you decide that you do not want us to continue to use your information that we actively process and maintain, you may request that we delete your personal information and close your account.

However, certain data may be retained for a limited period (but no longer than necessary) if such retention is required by law (for example, for tax, accounting or audit purposes) or for data security and backup purposes, to prevent fraud or other malicious activity.

Antivirus application. We have a periodically updated anti-virus application installed on all computers and servers of the information technology infrastructure.

Firewall. The data centers and disaster recovery centers where our servers are located are protected by periodically updated software firewalls; appropriate next-generation firewalls monitor Internet connections and provide protection against viruses and similar threats during this monitoring.

VPN. Suppliers can access ScaleUp servers or systems via SSL-VPN defined in firewalls. Separate SSL-VPN authentication is performed for each provider; Once identified, the supplier only grants access to those systems that it must use or is authorized to use.

Information security threats and event management. Events occurring on С servers and firewalls are transmitted to the Information Security Threat and Event Management system. This system alerts responsible personnel to a safety risk and allows immediate response to the hazard.

Encryption. Sensitive data is stored using cryptographic methods and, if necessary, transmitted through a cryptographically encrypted environment, and cryptographic keys are stored in secure and distinct environments.

Journaling. All transaction records and confidential data transfers are securely logged.

Two-factor authentication. Remote access to sensitive data is permitted with at least two-factor authentication.

Backup. We periodically create backup copies of stored data. We use backup tools provided by cloud infrastructure providers as our backup mechanism.

Details of payment. With respect to any credit card or other payment processing information you provide to us, we are committed to maintaining this confidential information in the most secure manner possible.

XI. Changes to our privacy policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy to accurately reflect our Service and policies. If we make any changes to this Privacy Policy, we will update it and post the revised version on this page and other appropriate places. If you do not want to agree to this or any updated Privacy Policy, you may delete your account.

XII. Connect with us

Feel free to contact us if you have any questions by email:

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