Privacy Policy

This Privacy Policy explains how Batery, the Canadian-facing version of the Batery online gaming service available via the domain baterywin-ca.com ("we", "us", "our"), collects, uses, discloses, and protects personal information of players, registered account holders, and other visitors to our website. It applies to all use of baterywin-ca.com from Canada and from any other location where our services are accessible.

This Privacy Policy is intended to meet the requirements of applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act ("PIPEDA"), as well as comparable international standards such as the EU/EEA General Data Protection Regulation ("GDPR") where those laws apply to us. By using baterywin-ca.com, you acknowledge that you have read and understood this Privacy Policy.

Effective date: 1 January 2026

Who We Are

Batery is a project associated with the online gaming brand Batery, operated through the website baterywin-ca.com. The service is operated by the following legal entity, which is responsible for the processing of personal information in connection with baterywin-ca.com:

Operator / Controller: YouGmedia B.V.
Legal form: Private limited liability company (B.V.)
Registration number: 153269
Registered address: Dr. M.J. Hugenholtzweg 25, Curacao
Gaming licence: Online gambling sublicense under Gaming Curacao master licence 365/JAZ (status reported as active as of May 2024)

Payments for baterywin-ca.com may be processed on our behalf by payment agents, including:

Payment agent: Woola Tech Ltd, Cyprus (payment processing partner for Batery)

For privacy and data protection matters, YouGmedia B.V. acts as the organization accountable for your personal information collected via baterywin-ca.com and Batery.

Data Protection Contact

We have designated a data protection function (Data Protection Officer or equivalent) to oversee compliance with this Privacy Policy and applicable privacy laws.

Data Protection Contact: Data Protection Officer, YouGmedia B.V.
Contact method: via the dedicated privacy/contact channels made available on https://baterywin-ca.com (for example, the "Contact Us" or "Support" sections, or internal messaging in your account).

If you cannot locate the relevant privacy contact details, you may contact our customer support through your account on baterywin-ca.com and indicate that your query concerns "privacy" or "personal data"; your request will then be redirected to the appropriate team.

What Personal Data We Collect

We collect only the personal information that is reasonably necessary for clearly identified purposes related to the operation of Batery and baterywin-ca.com. The categories below cover the main types of information we may collect and process.

1. Identification and Contact Data

Full name, date of birth, and proof of age.
Residential address and country of residence.
Email address and telephone number(s).
Copies of identification documents (e.g., passport, national ID, driver's licence) and, where required, proof of address (e.g., utility bill, bank statement).

2. Account and Gaming Data

Username, password (stored using secure hashing), security questions and answers.
Account settings and preferences (language, currency, responsible gambling limits).
Gameplay and betting history, including games played, stakes, wins/losses, session duration, and responsible gambling interactions.
Loyalty and bonus program participation, including accumulated points, bonus usage and wagering progress.

3. Payment and Financial Data

Payment method details (e.g., masked card numbers, payment wallet identifiers, partial IBAN or account numbers, where applicable).
Deposit and withdrawal history, including amounts, timestamps, payment provider, and transaction identifiers.
Financial verification information and documents required for anti-money laundering ("AML") and know-your-customer ("KYC") checks.

4. Technical and Device Data

IP address, approximate geolocation derived from the IP address, and related network identifiers.
Device identifiers, device type, operating system, browser type and version, language settings, and screen resolution.
Log data such as access timestamps, pages viewed, referral URLs, clickstream data, error logs, and performance metrics.

5. Behavioural and Usage Data

Interactions with our website, including clicks, page views, navigation paths, and time spent on different sections.
Responsible gambling behaviour (e.g., self-exclusion requests, time-out periods, limit changes, and interaction history with our responsible gambling tools).
Marketing interaction data (e.g., email opens and clicks, responses to promotions, opt-in/opt-out decisions).

6. Communications and Support Data

Records of your communications with us, including emails, web forms, in-account messages, chat sessions, and call notes (where applicable).
Feedback, complaints, and dispute-related correspondence.

7. Cookies and Similar Technologies

Cookies, web beacons, pixels, SDKs, and other tracking technologies that store or access information on your device to support functionality, security, analytics, and advertising.
Identifiers associated with these technologies (e.g., cookie IDs, advertising IDs, session IDs) that may be linked to your account or device.

We do not intentionally collect information from individuals under the legal gambling age in their jurisdiction (in most Canadian provinces, including Ontario, this is 19 years of age). If we become aware that we have collected such information contrary to our eligibility rules, we will take steps to delete it and close any related account.

Legal Basis for Processing

Our processing of personal information in connection with Batery and baterywin-ca.com is based on the following legal grounds, depending on your location and the context of the processing.

1. Consent

Under Canadian privacy law (including PIPEDA), we rely on your meaningful consent for most of our collection, use, and disclosure of personal information, except where an exception applies.
You provide consent by registering an account, accepting our Privacy Policy and Terms and Conditions, adjusting your account settings, or otherwise clearly indicating your agreement (for example, by selecting cookie or marketing preferences).
For EU/EEA or UK users, where GDPR or UK GDPR applies, we also rely on your consent for certain uses (e.g., some marketing and non-essential cookies), in line with Articles 6(1)(a) and 7 GDPR.

2. Contractual Necessity

We process your personal information when it is necessary to enter into and perform our contract with you, including:
- Creating and managing your gaming account on baterywin-ca.com.
- Processing deposits, wagers, bonuses, and withdrawals.
- Providing customer support and resolving operational issues.
For GDPR purposes, this corresponds to Article 6(1)(b) GDPR ("performance of a contract").

3. Legal and Regulatory Obligations

We are required to process certain information to comply with legal obligations, including:
- Age verification, identity checks, and AML/KYC requirements.
- Record-keeping obligations under applicable gambling, financial crime, and tax laws in Curacao and any other relevant jurisdiction.
- Responding to lawful requests from regulators and law enforcement authorities.
For GDPR purposes, this corresponds to Article 6(1)(c) GDPR ("compliance with a legal obligation").

4. Legitimate Interests / Reasonable Purposes

We process personal information for our legitimate business interests or, under Canadian law, for purposes that a reasonable person would consider appropriate in the circumstances, including:
- Securing our systems, preventing fraud, and protecting the integrity of games.
- Analyzing service usage, improving our products, and enhancing user experience.
- Defending and exercising legal claims and managing our business operations.
Where GDPR applies, we ensure that these legitimate interests (Article 6(1)(f) GDPR) are not overridden by your rights and freedoms by conducting appropriate balancing assessments.

5. Vital Interests and Public Interest (Exceptional Cases)

In rare emergency situations, we may process or disclose data if necessary to protect the vital interests of an individual or if required for substantial public interest (e.g., responding to serious criminal activity, threats to life, or public safety), in accordance with applicable laws.

Purpose of Processing

We use the personal information collected via Batery and baterywin-ca.com for the following purposes. Each use is limited to what is reasonably necessary to achieve a clearly identified purpose.

1. Provision and Management of Casino Services

Creating, verifying, and managing user accounts, ensuring eligibility (age and jurisdiction) for online gambling.
Operating games, processing bets, awarding winnings, and managing bonuses and promotions.
Processing deposits and withdrawals through our payment agents and financial institutions.
Providing customer support, including troubleshooting, responding to questions, and handling complaints.

2. Compliance, Risk Management, and Fraud Prevention

Conducting identity, age, and AML/KYC checks and maintaining appropriate records.
Monitoring transactions and gameplay patterns to detect, investigate, and prevent fraud, abuse of bonuses, money laundering, and other prohibited behaviours.
Ensuring responsible gambling, including enforcing self-exclusion, limits, and other harm-minimization tools.
Cooperating with regulators and law enforcement where legally required.

3. Service Improvement and Analytics

Analyzing aggregated and pseudonymized data to improve site performance, game portfolio, user interface, and customer experience.
Conducting statistical and business analysis, including measuring the effectiveness of promotions and features.
Testing and deploying new functionalities and security enhancements.

4. Marketing and Personalization

Sending service-related communications, such as transactional emails and important account or policy notifications.
Providing marketing communications (e.g., offers, bonuses, newsletters) where permitted by law and in accordance with your preferences.
Customizing content, promotions, and recommendations based on your account data and gameplay history, subject to your consent where required.

5. Legal Obligations and Business Operations

Maintaining records required for auditing, regulatory reporting, tax compliance, and dispute management.
Protecting our legal rights and those of our users, affiliates, and partners.
Supporting corporate transactions, such as restructurings or transfers of business, in which case appropriate safeguards will apply.

Disclosure & Sharing

We do not sell your personal information. We only disclose personal information to third parties as reasonably necessary for the purposes described in this Privacy Policy or as required by law, applying contractual and technical safeguards wherever appropriate.

1. Group Entities and Payment Agents

We may share data with other entities within the YouGmedia B.V. business structure (if any) for operational, risk management, and compliance purposes.
We share relevant information with payment agents and financial institutions, such as Woola Tech Ltd (Cyprus), in order to process deposits, withdrawals, chargebacks, and related financial operations.

2. Service Providers and Technical Partners

We use reputable third-party providers for:
- IT infrastructure, web hosting, and content delivery.
- Customer support tools and communication platforms.
- Identity verification and AML/KYC checks.
- Analytics, anti-fraud tools, and security monitoring.
- Email delivery and, where allowed, marketing and personalization services.
These providers act as "processors" or equivalent under applicable law and are contractually bound to use the data only on our instructions, to implement appropriate safeguards, and to maintain confidentiality.

3. Regulators, Law Enforcement, and Legal Obligations

We may disclose data to:
- Gaming regulators and authorities (for example, authorities in Curacao) to comply with licensing and reporting obligations.
- Law enforcement, courts, and other governmental bodies in any country where we operate or store data, when we are legally required or permitted to do so.
- External advisers (lawyers, auditors) where necessary to protect our legal rights, defend claims, or conduct audits.

4. Affiliates and Marketing Partners

Where you arrive at baterywin-ca.com via an affiliate or advertising partner, we may share limited performance and tracking information (e.g., registration and deposit confirmation, bonus usage) with that partner for attribution and commission purposes.
Where local law requires your consent for sharing data with advertising networks or third-party marketing services, we will only do so after obtaining such consent and providing you with clear opt-out options.

5. Business Transfers

In the event of a merger, acquisition, sale of assets, restructuring, or insolvency involving YouGmedia B.V. or the Batery brand, user information may be transferred as part of the transaction, subject to confidentiality obligations and, where required, your consent or notification in line with applicable law.

6. Aggregated and De-Identified Information

We may share aggregated or de-identified information (which cannot reasonably be used to identify you) with partners, advertisers, or the public for research, analytics, or promotional purposes.

International Transfers

Batery and baterywin-ca.com are operated by a company established in Curacao and supported by partners in various countries. As a result, your personal information may be transferred to, stored in, or accessed from countries outside your province, territory, or country of residence, including:

Curacao - where YouGmedia B.V. is registered and where core gaming operations and records may be maintained.
Cyprus - where Woola Tech Ltd and potentially other payment or service providers are located.
European Economic Area (EEA), United Kingdom, and other jurisdictions - where certain hosting, support, analytics, and verification providers may process data.
Other countries - where specific technical vendors (for example, cloud infrastructure or security providers) may be based.

When personal information is transferred internationally, the laws of the receiving country may be different from those in your home jurisdiction and may provide a different level of protection. In such cases, we take steps designed to ensure that an adequate level of protection is in place, including:

Using appropriate contractual safeguards, such as the European Commission's Standard Contractual Clauses or equivalent agreements, where applicable.
Imposing strict confidentiality and security requirements on our service providers and partners.
Limiting transfers to what is reasonably necessary for the operation of our services and legal compliance.

By using baterywin-ca.com, you acknowledge that your information may be transferred to and processed in countries outside your province or country, including Curacao and Cyprus, as described above.

Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to meet legal and regulatory requirements, to resolve disputes, and to enforce our agreements. Retention periods vary depending on the type of data and the context of processing.

1. Core Account and Identification Data

Basic account details (name, contact information, account history) and verified identity data are generally retained for up to five (5) years after account closure, unless a longer period is required by law or necessary to resolve ongoing disputes or investigations.
KYC/AML documentation and records may be retained for longer periods (for example, up to seven (7) years) where required by applicable anti-money laundering or gambling regulations.

2. Transaction and Payment Data

Transaction records (deposits, wagers, wins/losses, withdrawals) are retained for at least five (5) years from the date of the transaction, and longer where necessary for accounting, tax, regulatory, or legal reasons.

3. Technical Logs and Security Data

Technical logs, IP logs, device identifiers, and security-related records are typically retained for 12 - 24 months from collection, unless a longer retention is required to investigate security incidents or fraud.

4. Marketing and Communication Data

Marketing preference data is maintained as long as you remain subscribed and for a short period thereafter to demonstrate compliance with your choices.
Where you unsubscribe from marketing, we maintain a record of your opt-out to ensure your choice is respected in the future.

5. Cookies and Similar Technologies

Session cookies generally expire when you close your browser or log out.
Persistent cookies remain on your device for periods ranging from a few days to several months, depending on their purpose; expiry periods are indicated in our cookie management tools where feasible.

6. Deletion Criteria

Data is securely deleted, anonymized, or aggregated when:
- It is no longer reasonably required for the purposes set out in this Privacy Policy.
- The applicable retention period has expired.
- Deletion is required to comply with a legal obligation or a valid rights request, subject to legal limitations.

Your Rights

You have a number of rights in relation to your personal information, subject to applicable Canadian privacy laws (including PIPEDA and substantially similar provincial laws) and, where relevant, the GDPR or UK GDPR. We will not discriminate against you for exercising your rights, although certain consequences (such as limits on our ability to provide services) may follow where data is essential for service delivery or legal compliance.

1. Access to Your Personal Information

You have the right to request confirmation of whether we hold personal information about you and to obtain access to that information, subject to limited exceptions (for example, information that would reveal another person's data or that is protected by legal privilege).
Upon request, we will provide you with a summary or copy of your personal information in a clear format.

2. Correction (Rectification)

You have the right to request correction of inaccurate, incomplete, or outdated personal information that we hold about you.
Where appropriate, you may update certain information directly through your account settings on baterywin-ca.com.

3. Deletion (Erasure) and De-Indexing

You may request deletion of your personal information where:
- The information is no longer necessary for the purposes for which it was collected.
- You withdraw consent and we have no other legal ground to continue processing.
- Processing is unlawful under applicable law.
We may not be able to delete certain data where retention is required by law (for example, AML, gambling, and tax obligations) or where it is needed to establish, exercise, or defend legal claims. In such cases, we will explain the basis for continued retention.

4. Restriction and Objection

You may request that we restrict processing of your personal information in certain cases (for example, while we verify its accuracy or assess an objection).
Where processing is based on our legitimate interests, you may object to such processing on grounds relating to your particular situation. We will stop processing unless we demonstrate compelling legitimate grounds or the processing is required for legal claims.

5. Data Portability (Where Applicable)

Where the GDPR or similar laws apply and processing is based on consent or contract and carried out by automated means, you may request a copy of your personal information in a commonly used, machine-readable format and, where technically feasible, have it transmitted to another service provider.

6. Withdrawal of Consent

You may withdraw your consent to processing where consent is the legal basis, including for marketing communications and certain cookie categories. Withdrawal will not affect the lawfulness of processing prior to withdrawal.
You can withdraw marketing consent by:
- Using the "unsubscribe" link in marketing emails; or
- Changing your preferences in your account settings, where available.

7. How to Exercise Your Rights

Submit your request via the privacy or contact channels available on baterywin-ca.com, or through your account support section, clearly stating that your request concerns your privacy rights.
We may need to verify your identity before fulfilling your request, for example by asking you to log in to your account or provide certain identifying details.
We aim to respond to all valid requests within 30 days of receipt. If we need more time due to complexity or volume, we will inform you of the extension and reasons.
We will generally handle your requests free of charge. However, where permitted by law, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive (for example, repetitive requests), in which case we will explain our decision.

Cookies & Tracking Technologies

We use cookies and similar technologies on baterywin-ca.com to ensure the website functions properly, to secure your account, to analyze usage, and to personalize content and offers where permitted. Some cookies are essential to the site's operation, while others are optional and subject to your consent where required.

1. Types of Cookies

Session cookies: Temporary cookies that are stored on your device only while your browser session is active and are deleted when you close your browser or log out.
Persistent cookies: Cookies stored on your device for a defined period after your session ends, used to remember your preferences, recognize you on subsequent visits, and support long-term analytics.
First-party cookies: Cookies set directly by baterywin-ca.com.
Third-party cookies: Cookies set by third-party service providers (e.g., analytics firms, advertising networks, or payment providers) used in connection with our services.

2. Purposes of Cookies

Strictly necessary / functional cookies: Required for core functionality such as secure log-in, account management, transaction processing, language settings, and maintaining session security. These cookies cannot be disabled via our systems without affecting service functionality.
Performance and analytics cookies: Help us understand how visitors use baterywin-ca.com, which pages are most visited, and how users move around the site, so we can improve usability and performance. Data is often aggregated or pseudonymized.
Advertising and personalization cookies: Used (where permitted) to deliver more relevant offers and promotions, to measure campaign effectiveness, and to limit the frequency of certain messages.

3. Managing Cookies

You can manage or disable cookies through:
- Your browser settings, where you can normally block or delete cookies from all or specific sites; and
- Any cookie consent or preference management tools we provide on baterywin-ca.com, which may allow you to choose or adjust cookie categories (where technically available).
Please be aware that disabling certain cookies, particularly strictly necessary ones, may impact the functionality, security, or performance of the site and may prevent you from using some features.

Data Security

We take the security of your personal information seriously and implement a combination of technical, organizational, and physical safeguards designed to protect it against unauthorized access, use, alteration, and disclosure.

1. Technical Safeguards

Encryption in transit: Data transmitted between your device and baterywin-ca.com is protected using industry-standard encryption protocols (such as TLS 1.2 or higher).
Encryption at rest: Sensitive data (including passwords, which are stored using strong cryptographic hashing) is protected using appropriate encryption or other forms of protection where feasible.
Access controls: Systems are designed with role-based access controls so that only authorized personnel with a business need can access relevant information.
Secure development and testing: We apply security-oriented development practices and may use regular vulnerability assessments and security testing to identify and address potential weaknesses.

2. Organizational and Operational Measures

Security policies: Internal policies govern how employees and contractors handle personal information and access systems.
Staff training: Personnel with access to personal information receive training on data protection, privacy, and information security principles relevant to their roles.
Vendor due diligence: We select service providers that implement appropriate security measures and require them to safeguard personal information they process on our behalf.

3. Monitoring and Incident Response

We monitor systems for suspicious activity, potential fraud, and security incidents using technical and procedural controls.
If we become aware of a data breach affecting your personal information, we will investigate promptly, take reasonable steps to mitigate harm, and notify affected individuals and relevant authorities as required by applicable law.

While we strive to protect your information, no security measure can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for using unique, strong passwords and secure devices when accessing baterywin-ca.com.

Complaints & Contacts

If you have questions, concerns, or complaints regarding this Privacy Policy or our handling of your personal information in connection with Batery and baterywin-ca.com, you have several options.

1. Contacting Us

Primary contact: Data Protection Officer (or equivalent), YouGmedia B.V.
How to reach us:
- Use the contact, support, or privacy request channels provided on https://baterywin-ca.com (for example, via "Contact Us", live chat, or in-account messaging); and
- Clearly indicate that your request relates to "Privacy" or "Personal data".

2. Internal Complaint Procedure

Submit your complaint: Provide a clear description of your concern, including relevant dates, account identifiers (if any), and supporting documentation.
Acknowledgment: We aim to acknowledge receipt of your complaint within a reasonable period, typically within 5 business days.
Investigation: We will review your complaint, gather any necessary information, and, where appropriate, consult with relevant internal teams (e.g., compliance, security, support).
Response: We will provide a substantive response within 30 days of receiving your complaint, explaining our findings and any steps taken or planned. If we cannot respond within this period, we will inform you of the delay and provide a new expected timeline.
Further steps: If you are not satisfied with our response, you may escalate your complaint to the appropriate privacy regulator as described below.

3. Supervisory Authorities

If you believe that your privacy rights have been violated and we have not provided a satisfactory response, you may lodge a complaint with the competent data protection authority.

Canada (federal private-sector law):
Office of the Privacy Commissioner of Canada (OPC)
30 Victoria Street
Gatineau, Quebec K1A 1H3
Canada
Website: https://www.priv.gc.ca
Telephone (Canada and U.S.): 1-800-282-1376
Provincial authorities: If your complaint relates to a province with its own private-sector privacy legislation (e.g., Quebec, British Columbia, Alberta), you may also have the option to contact the relevant provincial privacy commissioner. Details are available on their official websites.
EU/EEA or UK data subjects: Where the GDPR or UK GDPR applies, you have the right to lodge a complaint with your local data protection authority in the EU/EEA or with the UK Information Commissioner's Office (ICO). Contact details are available on the European Data Protection Board website and at https://ico.org.uk.

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors affecting the processing of personal information related to Batery and baterywin-ca.com.

1. How We Notify You of Changes

Website notice: We will post the updated Privacy Policy on https://baterywin-ca.com with a revised "Last updated" date.
Email or account notifications: For material changes that significantly affect your rights or how we process your personal information, we will provide additional notice through means such as:
- Email to the address associated with your account; and/or
- In-account notifications or banners displayed when you log in.

2. Advance Notice and Your Choices

Where required by law or where changes are significant, we will provide you with at least 30 days' notice before the updated Privacy Policy becomes effective, unless a shorter period is necessary due to legal or security reasons.
Continued use of your account or of baterywin-ca.com after the effective date of the updated Privacy Policy will constitute your acceptance of the changes, to the extent permitted by law.
If you do not agree to the changes, you may:
- Adjust your privacy or marketing preferences where possible; and/or
- Request closure of your account, subject to our need to retain certain information for legal and regulatory purposes as described in this Privacy Policy.

3. Version Control

The current version of this Privacy Policy applies to all processing of personal information in connection with Batery and baterywin-ca.com as of the effective date below.
Last updated: January 2026

We encourage you to review this Privacy Policy periodically to stay informed about how we protect and use your personal information.