Privacy Policy

This Privacy Policy explains how personal data is collected, used, stored and shared when you visit or use the Duelbits version of the Duelbits-branded services made available via the website located at duelbit.bet (the "Website"). It applies to visitors, registered users, and other individuals whose data we process in connection with our online gambling and betting services, even though players from the United Kingdom are not allowed to open or use real-money accounts. This Privacy Policy is effective and was last updated on 6 November 2025.

By accessing or using the Website, you acknowledge that you have read this Privacy Policy and understand how and why we process your personal data, as described below.

Who We Are

Data controller. For the purposes of data protection laws (including the UK GDPR and, where applicable, the EU GDPR and other local laws), the primary controller of personal data associated with the Duelbits-branded services offered via duelbit.bet (including the Duelbits version of the site) is:

Liquid Gaming N.V.
Zuikertuintjeweg Z/N (Zuikertuin Tower)
Willemstad, Curaçao
(operating company responsible for the Duelbits-branded online gaming services)

Payment processing entity. Certain payment and financial processing activities are handled on our behalf by:

Ghost Operations LTD
3 Griva Digeni Street, Patsalos House, 3rd floor, office 301
6030 Larnaca, Cyprus

Regulatory and licensing context. The Website and related services are operated under a Curaçao online gaming sub-license:

Master Licence: 365/JAZ (Government of Curaçao)
Sub-licence: GLH-OCCHKTW0706212022 held by Liquid Gaming N.V.

Duelbits-branded services available on duelbit.bet are not licensed by the UK Gambling Commission, and players located in the United Kingdom are not permitted to open or use real-money accounts. This Privacy Policy is provided for transparency to visitors from the UK and other jurisdictions.

Data protection contact. If you have any questions about this Privacy Policy or our handling of personal data, you can contact our data protection contact (Data Protection Officer / privacy team) by writing to Liquid Gaming N.V. at the address above, clearly marked "Data Protection Officer", and/or by using the contact or support options available on the Website at https://duelbit.bet or the legacy domain https://duelbits.com. The most up-to-date contact channels (including email and live chat details, where available) are published on the Website.

What Personal Data We Collect

We only collect personal data that is relevant and necessary for providing, securing and improving the Duelbits-branded services on duelbit.bet, including the Duelbits version of the site. Depending on how you use the Website, we may process the following categories of data:

Identification and contact data

Account information: full name, username, password (stored in hashed form), country of residence, preferred language.
Contact details: email address, telephone number, communication preferences, and records of communications with our support team.
Verification data (KYC): date of birth, age verification data, government-issued identification details, proof of address, and other documents required for identity verification and compliance checks.

Technical and usage data

Technical identifiers: IP address, approximate location derived from IP, device identifiers, browser type and version, operating system, time zone setting and language settings.
Log and activity data: access dates and times, pages viewed, referral URLs, clickstream data, session identifiers, login history, and security logs used to detect unusual or suspicious activity.

Payment and transactional data

Payment details: limited payment instrument information processed through our payment partners (for example, masked card details or wallet identifiers), deposit and withdrawal records, transaction amounts, timestamps and currencies.
Financial monitoring data: information linked to anti-money laundering (AML) and counter-terrorist financing (CTF) monitoring, such as source-of-funds information or enhanced due diligence notes where required by law or internal policies.

Gaming and behavioural data

Gameplay history: betting and wagering records, game rounds played, wins and losses, bonuses used, tournament participation and achievements.
Behavioural analytics: interaction patterns with the Website (such as navigation paths, clicks, time spent on pages), responsible gambling indicators (e.g. self-imposed limits, time-outs, self-exclusions), and responses to surveys or promotions.

Cookies and similar technologies

Cookies: small text files placed on your device to enable core site functionality, remember your preferences, perform analytics and support marketing where permitted.
Similar technologies: web beacons, pixels, SDKs and local storage used to recognise your device, measure campaign performance and prevent fraud.

Where we need to collect personal data by law or under a contract with you and you fail to provide that data when requested, we may be unable to provide part or all of the services (for example, if you do not complete mandatory KYC checks, we cannot allow withdrawals).

Legal Basis for Processing

We process personal data in accordance with applicable data protection laws, including the UK GDPR (for individuals in the UK), the EU GDPR (for individuals in the EEA), and, where relevant, other national laws such as Mexican data protection legislation. Our main legal bases are:

Performance of a contract

Account creation and management: processing necessary to set up and manage your Duelbits user account on duelbit.bet, including authentication, password management and user preferences.
Provision of services: enabling you to place bets, participate in games, receive winnings, use bonuses and interact with our platform and customer support.
Payments and withdrawals: processing deposits, withdrawals, refunds and account balance adjustments, in cooperation with Ghost Operations LTD and other payment providers.

Compliance with legal obligations

KYC/AML requirements: verifying your identity, age and residency; monitoring and reporting suspicious transactions; complying with anti-money laundering, fraud and gambling regulations under Curaçao laws and other applicable regimes.
Regulatory and tax reporting: responding to lawful requests from regulators or law enforcement, and maintaining records as required by law.
Responsible gambling obligations: supporting self-exclusion schemes, limits and other player-protection tools where required or recommended by regulators or industry standards.

Legitimate interests

Service security and integrity: protecting our systems, games and users from fraud, abuse, unauthorised access and other harmful activities, including device fingerprinting and risk profiling.
Service improvement and analytics: analysing how the Website is used to improve performance, develop new features, and optimise user experience, provided such processing does not override your fundamental rights.
Resolving disputes and enforcing terms: investigating and handling complaints or disputes, enforcing our Terms of Service and protecting our legal rights.

Consent

Marketing communications: sending you email, SMS or push marketing messages about Duelbits-branded services at duelbit.bet, where you have given us your explicit consent or where we are otherwise permitted to do so and you have not opted out.
Non-essential cookies and tracking: using analytics, advertising or personalisation cookies and similar technologies, as indicated in our cookie banner and cookie settings on the Website.

Where we rely on consent, you may withdraw it at any time using the mechanisms described below, without affecting the lawfulness of processing based on consent before its withdrawal.

Purpose of Processing

We use personal data for clear and specific purposes aligned with our obligations as an online gambling operator and with the expectations of users of the Duelbits version of the site on duelbit.bet. These purposes include:

Providing and operating the services: creating and maintaining user accounts, enabling gameplay and betting, processing payments, calculating and paying out winnings, and offering customer support.
Compliance and risk management: performing identity and age checks, monitoring transactions for AML/CTF purposes, enforcing limits and self-exclusions, detecting fraud or bonus abuse, and fulfilling regulatory reporting duties.
Improving our platform: analysing technical and behavioural data to fix errors, optimise performance, design new features, and tailor the Website to the needs of our user base, including where we geo-block certain jurisdictions such as the United Kingdom for regulatory reasons.
Marketing and personalisation: sending you offers, promotions, newsletters and tailored content related to the Duelbits brand on duelbit.bet, based on your preferences and where allowed by law; measuring the effectiveness of such campaigns.
Analytics and statistics: generating aggregated and anonymised statistics about Website usage, financial performance and security indicators, which do not identify individual users.
Protecting our legal interests: investigating and responding to legal claims or disputes, enforcing our Terms of Service and other policies, and cooperating with competent authorities.

Disclosure & Sharing

We treat your personal data confidentially and only share it with third parties when necessary and lawful. Categories of recipients may include:

Group and related companies: Liquid Gaming N.V. and Ghost Operations LTD, as well as any future affiliated entities that help to operate or support the Duelbits version of the Duelbits-branded services on duelbit.bet.
Payment and financial service providers: banks, card schemes, payment gateways, e-wallet providers, crypto payment processors and other financial institutions that process your deposits, withdrawals and refunds.
Technical and operational service providers: hosting providers, IT and security providers, analytics vendors, customer support platforms, marketing tools and other suppliers who process data on our behalf under written data processing agreements.
Regulators, authorities and dispute bodies: the Curaçao Gaming Control Board and other competent regulators, law enforcement agencies, tax authorities and courts where required by law or necessary to defend our rights. For gambling-related disputes, players may be referred to the Curaçao Gaming Control Board's complaints portal at https://gamingcontrolcuracao.org/complaints-form.
Advertising networks and partners: where you have consented to marketing cookies or similar technologies, we may share limited pseudonymised data with advertising and affiliate partners so they can measure campaign performance and avoid fraud.
Professional advisers: lawyers, auditors, accountants and consultants who need access to data to provide professional services to us and are subject to confidentiality obligations.

We do not sell your personal data to third parties. Where we share data with processors, they may only process it on our documented instructions and must implement appropriate security measures.

International Transfers

Due to the international nature of online gambling operations, your personal data may be transferred to, stored in or accessed from countries outside your place of residence, including outside the United Kingdom and the European Economic Area (EEA). This may include transfers to:

Curaçao: where Liquid Gaming N.V. is established and where core gaming operations and records are maintained.
Cyprus: where Ghost Operations LTD and certain payment or support services are located.
Other countries: where some of our technical service providers, support teams or business partners are based, which may include jurisdictions that do not offer the same level of data protection as the UK or EEA.

When transferring personal data internationally, we take steps to ensure an adequate level of protection as required by applicable laws:

Standard contractual clauses / IDTA: for transfers from the UK or EEA to countries without an adequacy decision, we rely on the UK International Data Transfer Agreement (IDTA) and/or the European Commission's Standard Contractual Clauses, as applicable.
Additional safeguards: we conduct risk assessments and, where necessary, implement additional technical and organisational measures (such as encryption and strict access controls).
Service provider selection: we choose reputable partners and require them to handle personal data in compliance with contractual obligations and security standards.

You may contact us using the details in the "Who We Are" section if you would like more information about international transfers and the safeguards in place, including copies of relevant contractual protections where legally permitted.

Data Retention

We only keep personal data for as long as necessary for the purposes for which it was collected, including satisfying any legal, accounting or reporting requirements, and in line with industry standards for online gambling. When determining retention periods, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, and the purposes of processing.

Category of data	Typical retention period
Account and identification data (e.g. name, contact details, KYC documents)	For the lifetime of the account and normally up to 5 years after account closure, or longer where required by AML or other laws.
Transaction and payment data	Generally at least 5 years from the date of the transaction, and up to 10 years where required for tax, regulatory or legal purposes.
Gameplay and betting history	For the account lifetime and typically up to 5 years after closure to deal with disputes, regulatory inquiries and responsible gambling obligations.
Customer support communications	Usually up to 3 years following resolution of the inquiry or complaint, longer if related to ongoing disputes or legal matters.
Marketing data and preferences	Until you opt out of marketing, plus a short period to record your opt-out; anonymised or aggregated data may be kept longer.
Cookies and analytics identifiers	Typically between a single session and 24 months, depending on the cookie type and purpose, as detailed in our cookie tools.

When data is no longer required, we will either securely delete or anonymise it. We may retain anonymised or aggregated data indefinitely, as it no longer identifies individuals. If you request deletion of your data, we may still need to retain certain information where we have a legal obligation or overriding legitimate interest to do so (for example, for AML or dispute purposes).

Your Rights

Depending on your location and subject to applicable law, you may have various rights in relation to your personal data. These rights arise under the UK GDPR, the EU GDPR and, where applicable, Mexican data protection law (including the Federal Law on Protection of Personal Data Held by Private Parties).

Core data protection rights

Right of access: to obtain confirmation as to whether we process your personal data and receive a copy of that data, together with information about how we use it.
Right to rectification: to have inaccurate or incomplete personal data corrected or updated (for example, updating your contact details).
Right to erasure: to request deletion of your personal data in certain circumstances, for example where it is no longer necessary for the purposes for which it was collected and we have no legal obligation to keep it.
Right to restriction: to request that we suspend processing of your personal data in certain situations (such as when you contest the accuracy of the data or object to our processing).
Right to object: to object to processing based on our legitimate interests, including profiling, and to object at any time to the use of your data for direct marketing.
Right to data portability: to receive personal data you have provided to us in a structured, commonly used and machine-readable format, and to request that we transmit it to another controller where technically feasible.

Consent and marketing preferences

Withdrawal of consent: where we rely on your consent (for example, for marketing or certain cookies), you can withdraw it at any time through your account settings, via unsubscribe links in emails, via cookie management tools on the Website, or by contacting us.
Marketing opt-out: you can opt out of receiving direct marketing communications at any time; we will still send service or transactional messages necessary for your account.

Mexican privacy law alignment

Where Mexican data protection law applies, you may exercise ARCO rights (Acceso, Rectificación, Cancelación y Oposición), which broadly correspond to access, rectification, cancellation (erasure) and objection rights.
We handle such requests in line with applicable deadlines and procedures under Mexican law and will provide information about our response and reasons for any refusal, where permitted by law.

How to exercise your rights and response times

Submission: you may exercise your rights by contacting us using the details set out in the "Who We Are" section, via the support or contact tools available on duelbit.bet, or, where relevant, via any data rights interfaces we provide on the Website.
Verification: we may request additional information to verify your identity before acting on your request, particularly for access, erasure or portability requests.
Timeframe: we aim to respond to all valid requests within one month (30 days) of receipt. This period may be extended by up to two further months for complex or multiple requests, in which case we will inform you of the extension and reasons.
Fees: we generally handle requests free of charge. We may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, particularly if they are repetitive.

Cookies & Tracking Technologies

We use cookies and similar technologies on the Duelbits version of the Website to ensure functionality, personalise your experience, analyse usage and, where permitted, deliver targeted advertising.

Types of cookies

Strictly necessary (session) cookies: required for the Website to function, for example to maintain logged-in sessions, secure areas, and basic game operation. These are typically session cookies that expire when you close your browser.
Functional (persistent) cookies: used to remember your choices and preferences (such as language, region, or display settings) and may remain on your device for a longer period.
Analytics cookies: first-party or third-party cookies that help us understand how visitors use the Website, which pages are most viewed and how features perform, so we can improve the service.
Advertising and affiliate cookies: used to measure the effectiveness of our marketing and affiliate campaigns, prevent promotional abuse and, where allowed, tailor promotions or adverts to your interests.

Managing cookies

Cookie banner and settings: on your first visit (and periodically thereafter), you will see a cookie banner giving you the option to accept or reject non-essential cookies and to access detailed cookie settings.
Browser controls: most web browsers allow you to block or delete cookies via their settings. However, blocking certain cookies may affect the functionality of the Website and your ability to log in or play games.
Do Not Track: we may not respond to "Do Not Track" signals, as there is currently no agreed standard for these signals. You can manage tracking preferences through our cookie settings and your browser tools.

Data Security

We implement technical and organisational measures designed to protect personal data processed in connection with the Duelbits version of the Duelbits-branded services on duelbit.bet against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Encryption: data transmitted between your browser and our servers is protected using industry-standard Transport Layer Security (TLS 1.2+), and sensitive data is encrypted at rest where appropriate.
Access controls: access to systems containing personal data is restricted to authorised personnel only, based on role and "need-to-know" principles, using strong authentication mechanisms and, where feasible, multi-factor authentication.
Network and application security: we employ firewalls, intrusion detection and prevention systems, and other security technologies to protect our infrastructure and applications.
Security testing and audits: we conduct regular internal reviews, vulnerability assessments and other checks to maintain and improve our security posture.
Staff training: employees and contractors with access to personal data receive training on confidentiality obligations, data protection principles and secure handling of information.
Incident response: we maintain procedures to detect, investigate and respond to potential data breaches, including notifying affected individuals and relevant authorities where required by law.

We strive to align our security practices with recognised international standards such as ISO 27001 and SOC 2 where appropriate for our operations, although the Duelbits service is not represented here as formally certified under these standards unless expressly stated on the Website. No system can be guaranteed as completely secure, but we continuously work to mitigate risks and improve protections.

Complaints & Contacts

If you have concerns about how your personal data is handled in connection with the Duelbits version of the Duelbits-branded services on duelbit.bet, you have several options for raising questions or complaints.

Contacting us

Postal contact: write to the Data Protection Officer / privacy team at Liquid Gaming N.V., Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curaçao, clearly indicating that your correspondence concerns "Privacy" or "Data Protection".
Online contact: use the support or contact forms, live chat or other communication tools provided on the Website at https://duelbit.bet or on the legacy domain https://duelbits.com. These channels are the fastest way to reach us.

Complaint handling procedure

Submission: submit your complaint or query, describing the issue and, where relevant, the data or transactions involved.
Acknowledgement: we will acknowledge receipt of your complaint through the same channel you used, where feasible.
Review and investigation: our privacy and/or compliance team will investigate the matter, which may require requesting additional information from you.
Response: we aim to provide a substantive response within 30 days. For more complex issues, we may extend this timeframe, but we will keep you informed of any delay and the reasons.
Escalation: if you are not satisfied with our response, you may request further review or escalate the matter to a supervisory authority as described below.

Escalation to supervisory authorities

United Kingdom (UK GDPR): if you are in the UK, you may lodge a complaint with the Information Commissioner's Office (ICO) at https://www.ico.org.uk or by using the contact details provided on that website.
European Economic Area (EU GDPR): if you are in the EEA, you may lodge a complaint with your local data protection authority. Contact details are available via the European Data Protection Board website.
Mexico: if Mexican data protection law applies to you, you may submit a complaint to the Mexican data protection authority (INAI - Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales) via its official website.
Curaçao gambling disputes: for disputes relating to the provision of gambling services (rather than data protection), you may submit a complaint to the Curaçao Gaming Control Board using the official complaints form at https://gamingcontrolcuracao.org/complaints-form.

We encourage you to contact us first so that we have an opportunity to resolve your concerns directly, but you are not required to do so before contacting a supervisory authority.

Updates

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, industry best practices or technical developments affecting the Duelbits version of the Duelbits-branded services on duelbit.bet.

Notification of changes: where we make material changes, we will provide appropriate notice, which may include email notifications, in-account messages, prominent banners on the Website, or other reasonable means.
Advance notice: where changes materially affect your rights or the way we use your data, we will, where practicable, provide at least 30 days' advance notice before the new terms take effect.
Version control: each version of this Privacy Policy will be identified by an effective date and/or version number. The current version is marked as "Last updated: 6 November 2025".
Your options: if you do not agree with a material change to this Privacy Policy, you may close your account (if applicable) and stop using the Website. Continued use after the effective date of the updated policy will constitute acceptance of the changes.

We recommend that you review this Privacy Policy periodically to stay informed about how we process personal data in connection with the Duelbits version of our services on duelbit.bet.