1. Introduction

1.1 Who We Are

Valorbet is an online gaming and wagering platform accessible at valorbet‑download.com. We provide sports betting, casino games, live dealer tables, and related interactive entertainment to registered users. Your privacy is of paramount importance to us, and we are committed to handling your personal data with integrity, transparency, and in accordance with applicable legal obligations.

1.2 Applicable Legal Framework

Our data processing activities are governed by the following primary legal instruments applicable to users in India:

• The Digital Personal Data Protection Act, 2023 ("DPDPA") as notified by the Government of India;
• The Digital Personal Data Protection Rules, 2025 ("DPDPR") issued thereunder;
• The Information Technology Act, 2000 ("IT Act") and related Rules;
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (as amended);
• Any other applicable sector-specific laws, regulatory guidelines, or court directions in force from time to time.

Under the DPDPA framework, Valorbet acts as a Data Fiduciary — an entity that determines the purpose and means of processing your personal data. You, as the individual whose data is processed, are referred to as the Data Principal.

1.3 Scope of This Policy

This Policy applies to all personal data collected when you:

• Register for an account or access our Services;
• Make deposits, withdrawals, or engage in financial transactions;
• Use our website, mobile application, or customer support channels;
• Respond to surveys, promotions, or marketing communications;
• Simply browse our website as a visitor without registering.

This Policy does not apply to third-party websites or services that may be linked to from our Platform. We encourage you to review the privacy policies of any third-party services you access independently.

2. Data We Collect

2.1 Personal Identification Data

When you register an account or complete our Know Your Customer ("KYC") verification process, we collect:

• Full legal name, date of birth, and gender;
• Government-issued identification numbers (e.g., Aadhaar, PAN card, passport, or voter ID);
• Email address and mobile phone number;
• Residential address and postcode;
• Photographs or scanned copies of identity documents as required for identity verification.

2.2 Financial & Transaction Data

To process your deposits and withdrawals, we collect:

• Payment method details (e.g., UPI Virtual Payment Address, masked card numbers, e-wallet identifiers);
• Bank account details provided for net banking or IMPS transfers;
• Transaction history including amounts, dates, and processing status;
• Details of bonus claims, wagering activity, and win/loss records.

We accept the following payment methods for Indian users: UPI (Google Pay, PhonePe, Paytm, BHIM), Visa, Mastercard, RuPay, Net Banking / IMPS, Paytm Wallet, Skrill, Neteller, AstroPay, and Bitcoin / Cryptocurrency.

2.3 Technical & Usage Data

When you access our Services, our systems automatically collect:

• IP address, browser type and version, operating system;
• Device identifiers and mobile device information;
• Pages visited, session duration, clickstream data;
• Search queries, game selections, betting preferences;
• Log data including error reports and timestamps;
• Geolocation data (country and region level).

2.4 Communications Data

We retain records of:

• Customer support interactions via live chat, email, or telephone;
• Your responses to surveys, feedback forms, or promotional activities;
• Emails and messages you send to us;
• Social media interactions where you communicate with us directly.

2.5 Responsible Gaming Data

In accordance with our Responsible Gaming Policy, we may record self-exclusion requests, deposit limit elections, cooling-off period applications, and any self-assessment data you voluntarily provide to us relating to your gaming behaviour.

2.6 Data We Do Not Collect

We do not intentionally collect special category data (such as racial origin, religious beliefs, health data, or political opinions) unless you voluntarily disclose such information during a support interaction. Where inadvertently received, such data will be deleted without processing.

3. How We Use Your Data

We process your personal data strictly for the purposes set out below. We will not repurpose your data in a manner incompatible with these stated purposes without obtaining fresh consent or establishing a new lawful basis.

3.1 Marketing Communications

We will only send you promotional emails, SMS, or push notifications if you have given us your explicit, informed consent at the point of registration or through your account settings. You may withdraw marketing consent at any time by clicking "Unsubscribe" in any marketing email, by adjusting your notification preferences within your account, or by contacting us at support@valorbet-download.com. Withdrawal of marketing consent does not affect the lawfulness of prior processing.

3.2 Profiling & Automated Decision-Making

We may use automated tools to analyse usage patterns for the purposes of fraud detection, responsible gaming interventions, and personalising your experience. Where an automated decision significantly affects your account (e.g., account suspension), you have the right to request human review. Please contact us via the details in Section 13 to exercise this right.

4. Legal Bases for Processing

Under India's Digital Personal Data Protection Act, 2023, we process personal data on the following lawful grounds:

4.1 Consent

Where required, we obtain your free, specific, informed, and unambiguous consent prior to processing. This applies particularly to marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing based on consent.

4.2 Contractual Necessity

Processing your data is necessary to enter into or perform the contract constituted by our Terms & Conditions when you create an account and use our Services. This includes account creation, facilitating gameplay, and processing financial transactions.

4.3 Compliance with Legal Obligations

We process certain personal data to comply with our obligations under applicable laws, including but not limited to identity verification requirements, record-keeping mandates, and reporting obligations to competent authorities.

4.4 Legitimate Interests

We may process your data where we have a legitimate interest that is not overridden by your rights and interests. Our legitimate interests include: maintaining the security of our platform, preventing fraud and money laundering, improving our Services, and enforcing our legal rights. We conduct a balancing test before relying on this basis and will provide details on request.

5. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data in the limited circumstances described below.

5.1 Service Providers & Data Processors

We engage trusted third-party companies to provide services on our behalf. These include:

• Payment Processors: To facilitate deposits and withdrawals (e.g., UPI gateways, card networks, e-wallet providers);
• KYC & Identity Verification Providers: To verify your identity and comply with age-verification obligations;
• Fraud Prevention & Security Vendors: To detect and prevent suspicious activity;
• Cloud Hosting & Infrastructure Providers: To store data and operate our platform;
• Analytics Providers: To measure and improve platform performance;
• Customer Support Platforms: To manage support tickets and live chat;
• Marketing Platforms: To manage consented communications and campaigns.

All third-party processors are required to handle your data in accordance with our instructions, maintain appropriate security measures, and comply with applicable data protection legislation. We conduct due diligence before engaging any processor.

5.2 Legal & Regulatory Disclosures

We may disclose your personal data to competent governmental authorities, law enforcement agencies, regulatory bodies, or courts where we are required to do so by law, court order, or lawful governmental request. We will notify you of any such disclosure to the extent permitted by law.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. We will notify you of any such transfer as required by applicable law.

5.4 Responsible Gaming Partners

With your knowledge and where legally required or permitted, we may share limited data with responsible gaming support organisations and self-exclusion registers to give effect to your self-exclusion or responsible gaming requests made under our Responsible Gaming Policy.

6. Cookies & Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files placed on your device when you visit our website. We also use similar technologies including web beacons, pixel tags, local storage objects, and session tokens. These tools help us operate the platform, remember your preferences, and understand how you interact with our Services.

6.2 Types of Cookies We Use

6.3 Managing Your Cookie Preferences

On your first visit to our website, you will be presented with a Cookie Consent Banner that allows you to accept all, reject non-essential, or customise your cookie preferences. You may update your preferences at any time via the "Cookie Settings" link in the footer of our website.

You may also manage cookies through your browser settings. Please note that disabling certain cookies may impair the functionality of the Platform. For more information on managing cookies, visit www.allaboutcookies.org.

6.4 Third-Party Cookies

Some of our third-party partners (such as analytics and advertising providers) may place their own cookies on your device when you use our Services. These are governed by the respective third parties' privacy policies. We endeavour to list all active third-party cookie providers in our Cookie Settings panel.

7. Data Security

7.1 Technical Safeguards

We implement industry-standard technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, loss, or destruction. Our security measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers;
• AES-256 encryption for sensitive data stored in our databases;
• Multi-Factor Authentication (MFA) for administrative access and optional for user accounts;
• Firewalls, intrusion detection systems (IDS), and continuous network monitoring;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• Data access controls based on the principle of least privilege — staff only access data necessary for their role;
• Pseudonymisation and anonymisation of data used for analytical purposes where feasible.

7.2 Organisational Safeguards

Our team members who have access to personal data are bound by confidentiality obligations and receive regular training on data protection principles and procedures. We maintain written information security policies and conduct periodic internal reviews.

7.3 Data Breach Response

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the relevant competent authority without undue delay and in accordance with applicable legal timeframes;
• Notify affected Users directly where the breach is likely to result in high risk, providing details of the nature of the breach, likely consequences, and measures taken;
• Maintain an internal breach register documenting all incidents regardless of reporting thresholds.

8. Data Retention

8.1 General Retention Principles

We retain your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. When data is no longer needed, it is securely deleted or anonymised.

8.2 Specific Retention Periods

8.3 Regulatory Retention Requirements

Consistent with the obligations under the Digital Personal Data Protection Rules, 2025, we maintain personal data of users for a minimum period as prescribed, including a minimum one-year retention of traffic data and processing logs for all online service providers. For platforms with significant user bases, we apply the three-year retention period from the date of the user's last interaction as directed under applicable rules.

8.4 Deletion & Anonymisation

Upon expiry of the applicable retention period, personal data is securely deleted from our active systems. Where complete deletion is not technically feasible (e.g., data within backup archives), the data is isolated from further processing and deleted as soon as practicable during the next scheduled backup cycle.

9. Your Rights

As a Data Principal under the Digital Personal Data Protection Act, 2023, you hold the following rights in respect of your personal data. You may exercise any of these rights by contacting us at privacy@valorbet-download.com. We will respond within the timeframes prescribed by applicable law (generally within 30 days, extendable in complex cases).

9.1 Right to Access & Summary

You have the right to obtain a summary of the personal data we hold about you and information about the processing activities we carry out in relation to your data.

9.2 Right to Correction

You have the right to request correction of inaccurate or incomplete personal data. Where technically feasible and reasonable, we will correct or complete the data promptly.

9.3 Right to Erasure

You have the right to request deletion of your personal data where: (a) the data is no longer necessary for the purpose it was collected; (b) you withdraw consent and there is no other legal basis for processing; or (c) the data has been unlawfully processed. Please note that this right is subject to overriding legal obligations that may require us to retain certain data.

9.4 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. To withdraw marketing consent, use the unsubscribe link in any marketing communication or update your preferences in your account settings.

9.5 Right to Data Portability

Where technically feasible and where processing is carried out by automated means on the basis of consent or contractual necessity, you may request a copy of your personal data in a structured, commonly used, machine-readable format.

9.6 Right to Grievance Redressal

You have the right to have your grievances addressed in a timely and effective manner. If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India once it becomes fully operational under the DPDPA framework.

9.7 Right to Nominate

Under the DPDPA, you have the right to nominate another individual who may exercise your data rights on your behalf in the event of your death or incapacity. Please contact our privacy team to register a nominee.

9.8 Identity Verification for Rights Requests

To protect against unauthorised requests, we will verify your identity before processing any data rights request. We may ask you to confirm account details or provide identification. We will not charge a fee for exercising your rights unless requests are manifestly unfounded or excessive.

10. International Data Transfers

10.1 Cross-Border Processing

As part of operating a global digital platform, your personal data may be transferred to, stored in, or processed in countries other than India, including countries where our hosting infrastructure or third-party service providers are located. Such transfers may include jurisdictions where data protection laws differ from those of India.

10.2 Safeguards for International Transfers

We ensure that any international transfer of personal data is subject to appropriate safeguards, including:

• Transfers to countries or international organisations notified by the Central Government as providing adequate protection under the DPDPA framework;
• Contractual obligations (Standard Contractual Clauses or equivalent) binding the recipient to data protection standards equivalent to those applicable under Indian law;
• Technical and organisational measures ensuring the security of data in transit and at rest;
• Binding corporate rules where data is shared within a corporate group.

10.3 Your Acknowledgement

By using our Services, you acknowledge that your data may be processed internationally as described in this section. If you have concerns about specific cross-border transfers, please contact our Privacy team using the details in Section 13.

11. Minors

11.1 Minimum Age Requirement

Our Services are intended exclusively for individuals who are 18 years of age or older. We do not knowingly collect, process, or retain personal data from individuals under the age of 18. Registration by minors is strictly prohibited under our Terms & Conditions and our Responsible Gaming Policy.

11.2 Age Verification

We carry out mandatory age verification as part of our KYC process prior to allowing any real-money activity. If we discover or have reasonable grounds to suspect that a user is under 18 years of age, we will:

• Immediately suspend or terminate the account;
• Refund any deposits made, where verifiable, net of any amounts required by applicable law;
• Permanently delete all personal data associated with the minor's account to the extent permitted by law and our record-keeping obligations.

11.3 Children's Online Privacy

We do not direct any advertising, content, or marketing toward individuals under the age of 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately at privacy@valorbet-download.com so that we can take appropriate action.

11.4 Support Organisations for Problem Gambling in India

If you or someone you know — including a young person — is experiencing difficulties related to gambling, the following organisations offer free and confidential support in India:

12. Changes to This Policy

12.1 Our Right to Update

We reserve the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory guidance, or our Services. The updated version will always be published on this page with a revised "Last Updated" date and version number.

12.2 Notification of Material Changes

Where a change is material — meaning it significantly affects how we process your personal data or your rights as a Data Principal — we will notify you in advance by:

• Displaying a prominent notice on the Platform;
• Sending an email to your registered email address at least 14 days before the change takes effect;
• Requiring your renewed consent where the change affects data processed on the basis of consent.

12.3 Continued Use

Your continued use of the Services following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with any modification, you must immediately cease using the Services and may request account closure pursuant to our Terms & Conditions.

12.4 Version History

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please reach out to us using the contact details below. We are committed to resolving all privacy-related enquiries promptly and transparently.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your concern to the Data Protection Board of India, established under the Digital Personal Data Protection Act, 2023, once it becomes fully operational.