This document is a legally binding agreement. By accessing and using our Services, you consent to the terms outlined in this Privacy Notice. We encourage you to read it carefully to understand our commitment to protecting your data and your rights concerning your information.

Our Identity and Regulatory Status

The Cityviews group of companies is committed to providing a secure and regulated gaming environment. Our operations are conducted by the following licensed and registered entities, which act as the data controllers for the information collected under this notice.

• Baytree Interactive Limited (69691): A company registered in Guernsey, located at Ground Floor, Kingsway House, Havilland Street, St Peter Port, Guernsey. It is licensed by the Kahnawake Gaming Commission under license number 00892, issued on 16 February 2022.
• Baytree (Alderney) Limited (No. 2012): A company registered in Alderney, located at La Corvee House, La Corvee, Alderney, GY93TQ. It is licensed by the Alderney Gambling Control Commission (AGCC) under license number 155 C1, issued on 15 December 2020.

Our Policy Towards Minors

Our Services are strictly intended for individuals who are 18 years of age or older, or the legal age of consent for engaging in gambling services in their jurisdiction, whichever is higher (“Legally of Age”). We do not knowingly solicit or collect Personal Information from anyone who is not Legally of Age.

If you are not Legally of Age, you must not use the Services or provide any of your Personal Information to us. We reserve the right to perform age verification checks and may discard any information we discover has been shared by an individual who is not Legally of Age. If you have reason to believe that a minor has shared information with us, please contact our support team immediately.

The Information We Collect

We collect two primary types of information from our users to provide and improve our Services: Personal Information and Non-Personal Information.

Category of Data	Examples	Primary Purpose
Identity & Contact	Name, date of birth, address, email, phone number, government ID	Account creation, identity verification, legal compliance (KYC)
Financial	Credit card number, bank account details	Processing payments, deposits, and withdrawals
Technical & Device	IP address, browser type, device identifiers, geo-location	Service optimisation, fraud prevention, security
Usage & Gameplay	Click-stream data, bets, deposits, session duration	Service improvement, analytics, providing a personalised experience
Communications	Emails, chat transcripts, call recordings	Customer support, quality assurance, dispute resolution

The specifics of what we collect are detailed below.

Personal Information

This category includes any information that can be used to identify you as an individual. We collect this data when you register, use our services, and communicate with us.

• Registration and Identity Details: When you create an account, you provide us with your first and last name, email address, date of birth, gender, physical address, phone number, username, password, country, ID number, and occupation. To comply with regulatory requirements, we may also request copies of government-issued IDs and proof of address for verification.
• Payment Information: To process deposits and withdrawals, we collect payment details such as credit card numbers, bank account information, and other relevant financial data.
• Device Identifiers: We collect information from your device, including IP address, geo-location data, and unique device identifiers like UDID, IMEI, and MAC address.
• Communications: We may record and monitor communications you have with us, including emails, live chats, and telephone calls, for training, quality assurance, and security purposes.
• Voluntary Information: This includes any information you choose to provide while using the Services, such as in chat rooms or when responding to surveys.
• Third-Party Information: We may receive information from third-party service providers, such as credit history from credit agencies, or basic profile information if you register using a social network account.

Non-Personal Information

This category includes un-identified and non-identifiable technical and usage data that is gathered automatically when you interact with our Services.

• Technical Data: This includes your operating system, browser type and version, screen resolution, and keyboard language.
• Usage and Gameplay Data: We record your activities on the Services, including click-stream data, visit duration, pages viewed, deposits, bets, bonuses, session times, and high scores.
• Analytics Information: We collect data about your use of the Services through log files and analytics tools, which helps us troubleshoot errors and conduct research to improve our platform.
• Aggregated Data: We may anonymize or de-identify collected information so it can no longer be used to identify you. This aggregated data may be used for marketing or analytics without restriction.

How We Use Your Information

We use the Personal Information we collect for a range of purposes, all of which are essential for operating our Services effectively, securely, and in compliance with legal obligations.

• To set up, manage, and maintain your account.
• To provide and operate the Services, including processing bets and financial transactions.
• To communicate important service updates, technical notices, and administrative messages.
• To conduct analytics and research for improving and customising the user experience.
• To provide customer support and troubleshoot issues.
• To promote a responsible gaming environment.
• To detect and prevent fraudulent, illegal, or unauthorised activities.
• To enforce our User Agreement and other policies.
• To comply with legal and regulatory obligations, such as Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements.
• To process your requests related to your data rights.

Our Marketing Communications

We may use your Personal Information, such as your name, email address, and phone number, to send you promotional materials about our Services and related products. These communications may come from us, other companies within the Group, or our designated marketing partners.

You have full control over your marketing preferences. You can opt-out of receiving marketing offers at any time by contacting our Customer Service team via Live Chat or by using the “unsubscribe” link in any promotional email. Please note that even if you unsubscribe from marketing, we will continue to send essential service-related communications about your account.

How We Share Your Information

We do not rent or sell your Personal Information. We only share it with specific third parties (“Recipients”) when necessary for the purposes outlined in this notice. We share Personal Information with:

• Companies within the Group and other affiliated companies.
• Third-party service providers who assist in our operations, such as payment processors, cloud storage providers, marketing affiliates, and identity verification services.
• Credit reporting agencies for credit checks and risk management.
• Governmental authorities, police, and regulatory bodies as required by law or to investigate illegal activities.
• Auditors, contractors, or advisers involved in our business processes.
• Potential purchasers or investors in the event of a corporate transaction like a sale or merger.

International Data Transfers

As we operate globally, it may be necessary to transfer your Personal Information to countries outside of New Zealand. The data protection laws in these countries may differ from those in your jurisdiction.

When we transfer your data internationally, we take all reasonable steps to ensure that it is protected in accordance with this Privacy Notice. We achieve this through contractual means, such as using approved standard contractual clauses, and by ensuring that the recipients of the data adhere to strict security and confidentiality standards.

Your Rights Over Your Information

You have several rights concerning your Personal Information. You may contact us at any time to exercise these rights.

• Right to Access: You can request a copy of the Personal Information we hold about you.
• Right to Rectification: You can request to change or update any inaccurate or incomplete Personal Information.
• Right to Erasure: You can request the deletion of your Personal Information, subject to our legal and regulatory retention obligations.
• Right to Restrict Processing: You can request that we limit the use of your Personal Information in certain circumstances.
• Right to Data Portability: You can request to receive your Personal Information in a structured, machine-readable format.

We will make all reasonable efforts to accommodate your request, though certain legal requirements may prevent us from immediately complying.

Changes to this Privacy Notice

We reserve the right to amend this Privacy Notice at any time. We recommend you revisit this page frequently to stay informed of any updates. For substantial changes, we will notify you through the Services or via email.

Substantial changes will take effect seven (7) days after notice is provided. All other changes are effective as of the “Last Revised” date. Your continued use of the Services after this date constitutes your acceptance of the changes.