PRIVACY POLICY – Ambos Marcan

I. Who is responsible for processing your data?

AmbosMarcan.com is operated by Ambos Marcan Ecuador Pronósticos Deportivos, with registered domicile in Ecuador, it is a company authorized and regulated under Ecuadorian law.

For the purposes of this Privacy Policy, “User” shall mean any natural person interested in the products and services that Ambos Marcan offers through its websites, apps, social media, other third-party online platforms, and in person. Ambos Marcan will process your personal data as joint controller. The purpose of Ambos Marcan’s Privacy Policy is to provide transparency on how we process your data, protect information on the Internet, and safeguard any data the user may provide on the website.

The User may contact the Ambos Marcan Compliance and Legal Office via [email protected] for any questions or needs related to data protection.

II. For what purposes do we process your personal data?

The User is informed that Ambos Marcan may process the personal data provided through online forms or during the registration process to benefit from any of Ambos Marcan’s products or services, for the purposes indicated below, to the extent there is a legal basis for each processing activity as explained here:

(a) Provision of gambling and casino services, both online and in person, including but not limited to making deposits to your user account, participating in Casino games, placing bets, hospitality services, promotions, and customer service.

(b) Management of all your information requests and claims.

Casinos operated by Ambos Marcan comply with applicable legislation requiring, among other things, accreditation and confirmation of compliance with security and gaming regulation standards, including age verification, as well as legal requirements and procedures for fair gaming.

(d) During your digital registration as a User, verifying your identity remotely through computer-based identification, verification, analysis, and cross-checking of your identity documentation and the photograph or video of yourself provided for that purpose.

(e) Informing you, by any means including commercial communications via electronic channels of your choice and that you provide us, about products and services, as well as Ambos Marcan bonuses and promotional offers similar to those you have already acquired.

(f) Preparing a “commercial profile” derived from a set of automated decisions based on the information provided by you, in order to offer products and services tailored to your interests and improve your customer experience.

(g) Pseudonymization of your personal data for statistical and analytical purposes.

(h) Cross-referencing and processing your data with other information held by the Joint Controllers or Public Authorities, in order to comply with visitor admission restrictions under applicable gambling and betting laws, anti-money laundering obligations, and possible disclosures to law enforcement, tax authorities, and other competent regulatory bodies.

III. What is the legal basis for processing your personal data?

The legal basis for processing data for purposes (a), (b), and (c) is the execution of the service contract and/or acquisition of the relevant products.

The legal basis for processing data for purpose (d) is Ambos Marcan’s legal obligation to process your personal data for remote identity verification through IT systems, pursuant to the regulations governing gaming activities. In any case, Ambos Marcan carries out this processing proportionately to its objective and has established adequate measures to protect your fundamental rights and interests.

The legal basis for processing data for purpose (e) is both the User’s consent (when requested and granted) and Ambos Marcan’s legitimate interest in informing you about products or services similar to those previously acquired. The legal basis for purposes (f) and (g) is Ambos Marcan’s legitimate interest in optimizing its services and business performance, offering products and services tailored to your interests, and enhancing your customer experience.

The legal basis for processing data for purpose (h) is compliance with applicable legal obligations of the joint controllers.

The User understands and accepts that failing to provide certain personal data will prevent Ambos Marcan from offering services linked to such data. Under no circumstances will Ambos Marcan transfer, exploit, or use the data for any purpose other than expressly indicated here. During registration, the User will be informed which data collection is optional for Ambos Marcan services. Where the legal basis is the User’s consent, such consent may be withdrawn at any time without affecting the legality of prior processing. Ambos Marcan may continue processing User data insofar as permitted by applicable law.

Where legitimate interest is the legal basis, Ambos Marcan ensures it has previously balanced such interest against your fundamental rights and freedoms regarding personal data protection. In any case, the User may object to such processing at any time.

The User may exercise these rights by following the instructions in Section VI of this Policy.

IV. How long do we retain your personal data?

We will retain Users’ personal data for 2 years from their last interaction with a Group casino, or for a longer period if the User has provided specific consent or another legitimate basis for processing exists, such as legal obligations. This is without prejudice to retention necessary for the formulation, exercise, or defense of potential claims and/or as permitted by applicable law.

V. Who has access to your personal data?

Optimal service provision through Ambos Marcan’s website may require third parties (e.g., marketing providers, IT service providers, consultants, among others) to access User personal data as data processors.

Additionally, in some cases and based on your prior and express consent, and to provide additional services (Wi-Fi, marketing, etc.), Ambos Marcan may obtain and/or share your data with other entities. In any case, all personal data obtained through any entity linked to Ambos Marcan will be processed under the terms described in this document.

Ambos Marcan may also disclose or communicate personal data to fulfill obligations with public authorities, as required under applicable law, and where necessary, to law enforcement agencies, tax authorities, and judicial bodies.

VI. What are the users’ rights?

Ambos Marcan informs the User of their rights to access, rectification, objection, erasure, portability, and restriction of processing, as well as to reject automated decision-making involving personal data collected by Ambos Marcan.

These rights may be exercised free of charge by the User, or their representative, via a written and signed request sent to the following address: Autovía A-6 km 29, 28250 Torrelodones, Madrid. The request must state “Data Protection” in the subject and include the following: User’s full name, address for notifications, a copy of the National ID or Passport, and a specific request. Representation must be proven with valid documentation. The User may also exercise these rights by emailing [email protected].

Ambos Marcan reminds the User of their right to lodge a complaint with the competent authority.

VII. Unsubscribing from commercial communications

As previously mentioned in this Policy, the User has the right to withdraw consent for receiving commercial communications at any time by notifying Ambos Marcan that they no longer wish to receive such communications. The User may either revoke consent as described in the previous section or simply click on the unsubscribe link included in each commercial communication, thus canceling further electronic commercial communications.

VIII. From what age and under what circumstances may Users access our products and services?

Ambos Marcan informs you that if you are under 18 years of age, have a disability, or are included in the General Registry of Gambling Access Prohibitions or in the Registry of Persons Linked to Gaming Operators, your entry and registration are prohibited both in physical casinos and in any online gaming activity offered by Ambos Marcan.

If you fall under any of these categories and therefore cannot play, please do not provide us with any information. We do not wish, nor are we permitted, to process the data of individuals not authorized to play or to promote our games among such individuals. If we become aware that you have registered under any of the above conditions by falsifying registration details, we will immediately take all possible measures to ensure your registration is deleted.

IX. What security measures have we implemented?

Ambos Marcan is committed to maintaining the confidentiality of personal data and fulfilling its duty to safeguard such data, adopting necessary measures to prevent alteration, loss, unauthorized processing, or access, in accordance with applicable law.

Ambos Marcan has implemented technical and organizational security measures necessary to ensure the safety of personal data and prevent alteration, loss, processing, and/or unauthorized access, taking into account the state of technology, the nature of stored data, and risks from human action, physical, or natural causes, in accordance with applicable regulations.

At Ambos Marcan, we understand that security is fundamental to online gaming. Therefore, in our online platform we aim to honor the trust gained throughout our extensive history by offering our clients and users the full security guarantee of our brand.

To achieve this, we use cutting-edge technologies and the most prestigious security protocols to ensure the robustness of our system. The Ambos Marcan platform is based on a multi-layered architecture that provides a high level of security by imposing several physical and logical controls, preventing fraudulent operations.

X. Use of cookies

Ambos Marcan may use “cookies” when the User navigates its websites. “Cookies” are files sent to a browser by a web server to maintain a browsing session, storing the computer’s IP address and other browsing data. “Beacons” are electronic images that allow a website to count visitors and users who have accessed a specific site and access certain “cookies.” Thanks to cookies, Ambos Marcan’s server can recognize the User’s computer browser. This facilitates navigation, improves the user experience, and helps measure audience and traffic parameters (via beacons), monitor progress and entries, while ensuring the information contained in cookies is used independently of any other personal data the User may provide.

XI. Links

The Ambos Marcan website may include hyperlinks to other sites not operated or controlled by Ambos Marcan. Therefore, Ambos Marcan does not guarantee and is not responsible for the legality, reliability, usefulness, truthfulness, or accuracy of the content on such websites or their privacy practices. Before providing personal information to these third-party websites, please note that their data protection compliance may differ from ours.

XII. Changes to the Privacy Policy

Ambos Marcan may amend this Privacy Policy in accordance with applicable legislation at any given time. In any case, any substantial modification to the Privacy Policy will be communicated to the User.