End User Privacy Policy

Privacy and security are very important to us at BookSync. This End User Privacy Policy (“Policy”) is meant to help you (the “end user”) understand how we at BookSync collect, use, and share end user information in our possession to operate, improve, develop, and protect our services, and as otherwise outlined in this Policy. Please take some time to read this Policy carefully.

A quick note about BookSync

Our mission is to give freedom to the betting consumer – after all it’s your data, we just want to make it seamless for you to retrieve it. Our technology allows you to connect your betting accounts to software applications that can help you do things like track, record, analyze, and share your betting activity. These software applications are built and provided by our business customers (we’ll call them “developers” here), and powered by BookSync. By delivery access to high-quality, usable betting data that we’ve translated and standardized, we enable developers to build the next generation of betting products and services.

About this Policy

Our goal with this Policy is to provide a simple and straightforward explanation of what information BookSync collects from and about end users (“End User Information”), and how we use and share that information. We value transparency and want to provide you with a clear and concise description of how we treat your End User Information.

Please note that this Policy only covers the information that BookSync collects, uses, and shares. It does not explain what developers do with any End User Information we provide to them (or any other information they may collect about you separately from BookSync). This Policy also does not cover any websites, products, or services provided by others. We encourage you to review the privacy policies or notices of developers or those third parties for information about their practices.

Our Data Practices

Generally, what types of information do we collect? BookSync does not store your login credentials. In fact, your login credentials remain on your BookSync enabled device. Additionally, no third-party developer will have access to your login information. As explained in greater detail below, BookSync has collected identifiers, location information, commercial information, electronic network activity information, professional information, inferences, and other types of End User Information.

Information we collect from your betting accounts.

The information Booksync receives from the betting product and service providers that maintain your betting accounts varies depends on a number of factors, including the specific BookSync services developers use, as well as the information made available by those providers. But, in general, we collect the following types of identifiers, commercial information, and other personal information from your betting product and service providers:

  • Account information, including betting institution name, account name, etc.;

  • Information about your account balance, including current and available balance;

  • Information about your betting transaction history;

  • Identifiers and information about the account owner, including name, email address, phone number, date of birth, and address information;

  • The data collected from your betting accounts includes information from all accounts (e.g., different states) accessible through a single set of account credentials.

Information we receive from your devices.

When you use your device to connect to our services through a developer’s application, we receive identifiers and electronic network activity information about that device, including internet protocol (IP) address, timezone setting and location, device location, hardware model, operating system, which features within our services you access, browser data, and other technical information about the device. We also use cookies or similar tracking technologies to collect usage statistics and to help us provide and improve our services. You can find more information about how we use cookies and your related choices in our Cookie Policy.

Information you give us.

Part of our service involves enabling you to connect your betting accounts with a developer application or otherwise connect your betting accounts through BookSync. Where applicable, you will be prompted to enter the login information required by the provider of your account, such as your username and password, or a security token. You may also asked to provide a phone number, email address, security questions and answers, and one-time password (OTP) to help verify your identity before connecting your betting accounts. This information will never be stored by BookSync. The information you provide during this process will be transferred securely between your device and your selected institution.

In providing this information, you grant the developer and BookSync the authority to act on your behalf to access and transmit your End User Information from the relevant institution or other entity that provides your betting accounts (we’ll call them “betting product and service providers” in this Policy). You may also provide us with identifiers and other information, including your name, email address, and phone number, when you contact us or enter any such information on our websites.

How do we use your information?

We use your End User Information for a number of business and commercial purposes, including to operate, improve, and protect the services we provide, and to develop new services. More specifically, we use your End User Information:

  • To operate, provide, and maintain our services;

  • To improve, enhance, modify, add to, and further develop our services;

  • To protect you, developers, our partners, BookSync, and others from fraud, malicious activity, and other privacy and security-related concerns;

  • To develop new services;

  • To provide customer support to you or to developers, including to help respond to your inquiries related to our service or developers’ applications;

  • To investigate any misuse of our service or developers’ applications, including violations of our Developer Policy, criminal activity, or other unauthorized access to our services;

  • To comply with contractual and legal obligations under applicable law; and

  • For other notified purposes with your consent.

Our Lawful Bases for Processing (EEA and UK End Users Only)

For individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”), our legal basis for processing your End User Information will depend on the information concerned and the context in which we collected or processed it. Generally, however, we will normally only collect and process End User Information where:

  • we need to fulfill our responsibilities and obligations in any contract or agreement with you (for example, to comply with our end user services agreements);

  • to comply with our legal obligations under applicable law;

  • the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to safeguard our services; to communicate with you; or to provide or update our services); and you have given your consent to do so.

  • To the extent we rely on consent to collect and process End User Information, you have the right to withdraw your consent at any time per the instructions provided in this Policy.

How We Share Your Information

We share your End User Information for a number of business purposes:

  • With the developer of the application you are using and as directed by that developer (such as with another third party if directed by you);

  • To enforce any contract with you;

  • With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or developers;

  • With your connected betting institution(s) to help establish or maintain a connection you’ve chosen to make;

  • If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);

  • In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);

  • Between and among BookSync and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;

  • As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, developers, our partners, BookSync, and others; or

  • For any other notified purpose with your consent

We may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

Our Retention Practices

We retain End User Information for no longer than necessary to fulfill the purposes for which it was collected and used, as described in this Policy, unless a longer retention period is required or permitted under applicable law. As permitted under applicable law, even after you stop using an application or terminate your account with one or more developer, we may still retain your information (for example, if you still have an account with another developer). However, your information will only be processed as required by law or in accordance with this Policy.

Please refer to the “Your Data Protection Rights” section for options that may be available to you, including the right to request deletion of End User Information. You can also contact us about our data retention practices using the contact information below.

Your Data Protection Rights

Under applicable law, and subject to limitations and exceptions provided by law, if you are located in the EEA or UK, and in certain other jurisdictions, you may have certain rights in relation to the End User Information collected about you and how it is used, including the right to:

  • Access End User Information collected about you

  • Request that we rectify or update your End User Information that is inaccurate or incomplete;

  • Object to our processing of your End User Information under certain conditions provided by law;

  • Where processing of your End User Information is based on consent, withdraw that consent;

  • Request that we provide End User Information collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible; andt;

  • File a complaint regarding our data protection practices with a supervisory authority (if you are in the EEA or UK, please refer to the following link for contact details: EEA - https://edpb.europa.eu/about-edpb/board/members_en and UK - www.ico.org.uk).

  • Under the California Consumer Privacy Act (“CCPA”), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to End User Information we have collected about you that constitutes personal information under the CCPA:

  • To request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes);

  • To request deletion of your personal information;

  • To opt-out of any “sales” of your personal information, if a business is selling your information; and

  • To not be discriminated against for exercising these rights

  • To exercise your access or deletion rights, where applicable, you can submit a request by emailing contact@booksync.com. You can also contact us as described in the “Contacting BookSync” section below to exercise any of your data protection rights, where applicable. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

We will consider all such requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.

Changes To This Policy

We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on BookSync’s website at legal website url and update the effective date at the top of this Policy. We will also notify developers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify their end users about such changes to this Policy, as appropriate.

Contacting BookSync

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at contact@booksync.com or by mail at:

BookSync, LLC

188 Grand Street, Unit #381 New York, NY 10013

Effective Date: July 6,2022