Pinnacle (otherwise referred to herein as "we" or "us") adheres to the EU Electronic Communications Privacy Directive (EC Directive/2002/58/EC as amended by the Directive 2009/136/EC) and the EU General Data Protection Regulation (GDPR). This Privacy Policy is issued on behalf of the Pinnacle Group of companies, which includes the URL www.pinnacle.se (“Website”).

The data controller for this website is PinBet (Sverige) Limited, Level 4, The Penthouse, Suite 2, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR9034 Malta.

This Privacy Policy aims to provide you with information on how we collect and process your personal information through our website, including any data you may provide through our website or when you interact with us. We may change this Privacy Policy at any time and if we do, we will publish changes on our website as well as the date the changes take effect.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is imperative that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This Privacy Policy applies to the services offered by Pinbet (Sverige) Limited, which includes the website available at www.pinnacle.se. We will share your personal information in accordance with this Privacy Policy.

By using our website, you acknowledge that we will process your personal information in accordance with this Privacy Policy, including the purpose set out in Paragraph three below (The Purpose for Which We Collect Your Personal Information). If you do not wish to provide your personal information on the basis set out in this Privacy Policy, you should not enter your personal information on the website or otherwise provide us your personal information. However if you do not provide us your personal information, we may not be able to provide support regarding your queries about our service.

We adhere to the General Data Protection Regulation (EU) 2016/679 (and any national legislation implementing it) or in each case as amended, consolidated, re-enacted or replaced from time to time and the EU Electronic Communications Privacy Directive (EC Directive 2002/58/EC as amended by directive 2009/136/EC).

This version was last updated on November 16, 2023.

It is imperative that the personal information we hold about you is accurate. While we use reasonable efforts to ensure that your personal information is accurate, we ask that you update your information via your account whenever your information is incomplete, out of date or otherwise changes. Please refer to section eight “Your Rights” for more information about how to request changes to your personal information in our custody.

If you have any concerns or questions regarding this Privacy Policy, you should contact our Customer Service Department via email at customerservice@pinnacle.se.

You have a right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement. You have a right to make a complaint at any time to the Swedish Data Protection Authority (SDPA) imy@imy.se. We would, however, appreciate the chance to deal with your concern before you approach the SDPA, so please contact us in the first instance.

We use your personal information in the following circumstances:

• Where you have provided your consent.
• Where we need to comply with a legal or regulatory obligation.
• Where it is necessary to our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

By providing your personal information and registering with us or logging in when you use our website, you understand and agree that we will collect, use, disclose and otherwise process your personal information in the manner set out in this Privacy Policy, or as otherwise provided in accordance with our Terms and Conditions.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal information is information about an identifiable individual, including any information that constitutes personal information within the meaning of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and any national legislation implementing it) or in each case amended, consolidated, re-enacted or replaced from time to time.

We may collect different kinds of personal information about you, which we have grouped together as follows:

• Identity Data: includes first name, middle name, last name, username or similar identifier, descriptive occupation (i.e. job position and industry), date of birth and gender.

  We will collect some of the above personal information, and if provided by you, your country of residence, business telephone number, employer’s name, employer’s address, citizenship and alias/preferred name for the purposes of complying with our anti-money laundering obligations under applicable law.

  If you attest that you are a Politically Exposed Person (“PEP”) the Head of an International Organization (“HIO”), or a family member or a close associate of a PEP or HIO as those terms are defined in our Terms and Conditions, you will be required to provide additional information, such as your source of funds, your source of wealth, the nature of your connection to the PEP or HIO if you are a family member or close associate of a PEP or HIO, the office or position of the PEP/HIO, the PEP or HIO’s organization/institution name and, if you have a relationship with someone who is a family member or close associate of a PEP or HIO, the nature of the relationship between you and the family member/close associate of the PEP or HIO.

• Contact Data: includes billing address, delivery address, email address and telephone number(s).
• Financial Data: includes bank account and payment card details.
• Transaction Data: includes details about payments to and from you, and other details of products and services you have engaged us for.
• Technical Data: includes internet protocol (IP) address, PC tag, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, correspondence feedback and survey responses.
• Usage Data: includes information about how you use our website, products and services.
• Marketing and Communications Data: if you sign up to receive marketing communications, we will ask you about your preferences for receiving marketing from us and our third parties and your communication preferences. We will collect your email address as well as other information on an optional basis to help us tailor our communications to you.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information that will be used in accordance with this Privacy Policy.

Where we need to collect personal information by law, under the terms of a contract we have with you or to provide our service, and you fail to provide that data when requested, we may not be able to perform the contract we have or provide you with the service requested.

Please note that any information that you transmit to us by email is not encrypted and is transmitted at your own risk.

We have set out below, in a table format, a description of the ways we plan to use your personal information and which legal bases we rely on to do so.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at customerservice@pinnacle.se if you need details about the specific legal purpose we are relying upon to process your personal information where more than one purpose has been set out in the table below.

We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

a. For anti-money laundering, fraud detection and/or control purposes, Pinnacle may share your personal information with third parties, including but not limited to third-party suppliers, the police, financial integrity units, banks, ID and address verification service providers, payment service providers and financial institutions; however, only where we have assurance that they are meeting the same standards on the processing of data and security. We encourage you to read the privacy policies of our third-party suppliers.

b. Furthermore, we reserve the right to disclose your personal information to relevant third parties, such as other Pinnacle group companies, our regulators or financial integrity units, notably when Pinnacle has reasonable grounds to suspect irregularities involving your account.

c. Your personal information will also be shared for regular operational purposes with entities providing services such as cloud services, data centers, payment services providers, banking, ID verification tools, customer communication tools, game suppliers, etc.

d. We are entitled to share the information we hold on you, which includes personal information and/or betting history with sporting bodies in order to investigate fraud, money laundering or sports integrity issues and to comply with our regulatory duties.

e. We and our service providers may process personal information outside of the country of your residence, including in the U.S. or other foreign jurisdictions. In such cases, we and our service providers will provide the equivalent security and coverage as required for personal information processing under GDPR and/or any equivalent national legislation.

f. We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

g. We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Pinnacle or as part of a corporate reorganization or other change in corporate control.

h. We will take all reasonable steps to ensure that your personal information is treated securely by ourselves and any third parties, and is processed with appropriate care and protection and in line with applicable legal requirements.

We will retain your personal information for no longer than necessary for the purposes set out herein, or in order to comply with our legal, financial, regulatory and business requirements. In such cases, we will maintain your personal information for the minimum length of time required to meet those requirements. After the minimum amount of time for maintaining your personal information has elapsed and provided we do not have any other legitimate reason for maintaining your data, your data will be securely deleted or anonymized.

In the event that you withdraw your consent, your personal information will be anonymized. Once anonymized it is no longer recognized as personal information.

If there has been no Account Activity (as defined in our Terms and Conditions) and we have maintained your personal information for the minimum time required to meet our legal and regulatory requirements, your account will be closed and your personal information will be securely deleted or anonymized.

Accounts where there has been an instance of fraud, a notification of gambling addiction, and/or permanent Self-Exclusion, will not be anonymized so that we may continue to monitor these customers in adherence to our legal and regulatory requirements.

If you sign up to receive marketing communications, we will send you offers, competitions and exclusive content through our various marketing channels. Your data will not be sold or given to any third parties not affiliated with Pinnacle for marketing purposes without your prior consent.

You can change your marketing preference settings by logging in to your Pinnacle account and going to the “Preferences” page.

You can unsubscribe from marketing communications at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt out of receiving email marketing communications by contacting us via the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.

a. Pinnacle assures you that your personal information is:

• Processed in accordance with your rights;
• Processed fairly and lawfully;
• Obtained only for the above purposes;
• Adequate, relevant and not excessive for its purpose;
• Kept in a secure manner;
• Not kept longer than is necessary for its purposes.

b. Pinnacle shall take all reasonable steps to ensure that your information is kept secure and protected. In this regard, we maintain appropriate physical, administrative, technical and organizational measures to protect your data against unauthorized or unlawful processing.

c. We recommend that you send all personal documents to us using our secured upload tool. To do so, please copy and paste the following link into your browser (followed by your Client ID):

https://cashier.pinnacle.com/VerifyUpload.asp?customerId=

d. Passwords must contain at least one letter, one number and one special character, and must be at least eight characters long. It is your responsibility to keep your account details (including your password) secure, and failure to do shall be at your sole risk and expense. If you believe that your account has been compromised in any way, you must notify us immediately at customerservice@pinnacle.se using your registered email address. We will immediately suspend your account once we are made aware of such an incident.

Subject to certain limitations on certain rights, you have the following rights in relation to your information. You can exercise any of these rights by contacting customerservice@pinnacle.se naming the right you are exercising along with the reason for your request, if applicable.

Right of Access: you have the right to request access to your personal data and supplementary information.

Right to Rectification: you have the right to request that inaccurate personal data be rectified or completed if incomplete.

Right to Erasure: you have the right to request erasure of your information where there is no longer a good reason for us to continue processing it. Please ensure that you withdraw your Account Balance prior to sending us the request. The rules enacted under the section 8 of our Terms and Conditions relating to the withdrawal of funds apply. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. It should be noted that this right is not absolute and may be subject to our compelling reasons to maintain that information such as our adherence to legal and regulatory obligations. Please see the section “How Long We Keep Your Information” above. In the event that we are unable to comply with this request you will be notified.

Right to Restrict Processing: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful (i.e. where it does not fall under a legal reason for processing as outlined under section 3. or your information has otherwise been obtained illegally by a third party) but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that this right is not absolute.

Right to Data Portability: you have the right to request the personal data you have provided to us. You may make a data portability request by contacting customerservice@pinnacle.se.

Right to Object: you have the right to object to our processing of your data. It should be noted that this right is not absolute and may be subject to any reasons we have to maintain that information, such as our adherence to legal and regulatory obligations. If you wish to object to direct marketing please contact us at customerservice@pinnacle.se requesting that you no longer wish to receive marketing materials.

It should be noted that the ability to perform our services relies on the processing of certain information. Therefore, exercising certain rights may result in a loss of the service or part of it.

You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

It should be noted that the ability to perform our services relies on the processing of certain information. Therefore, exercising certain rights or choices may result in a loss of the service or part of it.

We may request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. In the event that you did not provide all of your verification information upon registering with us, this information may be requested to complete your profile. We may also contact you to ask you for further information in relation to your request to speed up our response. Please remember to keep your password confidential.

We try to respond to all legitimate requests within 30 days. Occasionally, it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

It is your responsibility to ensure that your personal information held by us is up to date and accurate.

Pinnacle’s websites (including those optimized for mobile devices) and mobile applications use cookies and similar technologies to manage login sessions, provide personalized web pages and tailor content to reflect your specific needs and interests. Once you “Accept” our banner on cookies, you agree to the use of cookies and similar technologies for the purposes we describe in this policy.

Cookies are text files containing a small amount of information that are downloaded to your device when you visit a website. They are generally used by most websites to improve your online experience and to ensure that content and functions are delivered and used more effectively. Other similar files such as clear GIFs, web beacons and pixel tags work in the same way, and we use the word ‘cookie’ in this policy to refer to all files that collect information in this way.

Cookies perform various different functions. For example, some cookies are downloaded to your device temporarily for the period that you browse a particular website. These cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Other cookies can be used to help websites remember you as a returning visitor or ensure that the online advertising you receive is more relevant to your specific needs and interests.

You can amend your browser settings to block some or all cookies. To do this, follow the instructions provided by your browser provider. Please be aware that if you block cookies from Pinnacle’s website some or all of the website's functions may not perform as intended.

For example, you may not actually be able to place any bets. If you would like to amend your browser settings, see “Manage Your Cookies”. If you would like more information about cookies, see “Further Information”.

The types of cookies Pinnacle uses are:

Essential Cookies

Performance Cookies

Functionality Cookies

Targeting Cookies

Essential Cookies are cookies that are necessary in order for a website to function correctly; they enable you to navigate our website and allow you to perform specific functions, such as accessing secure areas, placing bets, depositing funds and managing your account. Without these cookies, it would not be possible to provide our specific online services and functions.

We use Essential Cookies to:

• Maintain your Bet Slip selections as you navigate around the site;
• Identify you as being logged in to Pinnacle.se;

Cookies we have defined as Essential Cookies will not be used to:

• Gather information that could be used to advertise products or services to you;
• Remember your preferences or username beyond your current visit.

These cookies collect information about how visitors use a website, for instance, which pages they go to most often or if they get error messages from web pages. It is only used to improve a website's performance.

We use Performance Cookies to:

• Provide statistics on how our website is used;
• See how effective our promotions are;
• Collect statistics on which markets customers are betting on;
• Help us improve the website by measuring any errors that occur;
• Test different designs of our website;
• Identify the browser or device you are using to access the site.

Cookies we have defined as Performance Cookies will not be used to:

• Gather information that could be used to advertise products or services to you on other websites;
• Remember your preferences or username beyond your current visit;
• Target promotions to you on any other website;
• Allow third parties to use the cookies for any purpose other than those listed above.

We use third-party cookies (such as Google Analytics and Silverpop Web Analytics) to gather information on customer interactions with the site so we can develop and improve your customer journey and provide you with an optimized service. To opt out of performance cookies, please see below.

Please be aware that opting out of our performance cookies won’t keep you from using our website; however, it will limit us from learning from your experience and may limit our ability to make accurate decisions to improve our website. However, if you wish to opt out of the web analytics that Pinnacle uses, please use the link below:

GoogleAnalytics

http://tools.google.com/dlpage/gaoptout

These cookies allow the website to remember choices you make (such as your username, language or the region you are in) and provide enhanced, personalized features. They may also embed functionality from third-party services. For instance, a website may be able to provide you with local weather reports or traffic news by using cookies to store information about the region in which you are located, or may integrate useful services provided by third-party providers into the website, e.g. social media features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have requested, such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

We use Functionality cookies to:

• Remember settings you've applied, such as layout, preferences, colors and showing/hiding features;
• Remember that you have seen certain content;
• Provide proactive live chat sessions to offer you support.

Cookies we have defined as Functionality Cookies will not be used to:

• Target you with advertising on other websites;
• Allow third parties to use the cookies for any purpose other than those listed above.

These cookies are used to deliver content, such as advertising, that is more relevant to you and your interests. They may also be used to limit the number of times you see an advert or measure the effectiveness of the advertising campaign. These tend to be set by third-party advertising agencies with Pinnacle's permission, on our website and other websites and apps, and we may share information about websites that you have visited with other organizations, such as advertisers.

We work with third parties such as advertising networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our website and other websites and apps in order to provide you with tailored advertisements across the internet. This is a common marketing practice referred to as interest-based or online behavioral advertising. These companies may collect information about your activity across your different devices on our website and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications), and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate our online advertising campaigns.

We use Targeting Cookies to:

• See what pages you are interested in and feed this back to our email tool so that we only target customers with information that is relevant to them.
• Provide promotions to you if you have registered an account with us, whether the account is funded or not.
• Provide cross-product promotions to you based on what markets you have viewed or the value of the bets you have placed.
• Provide suggested third parties with information about your visit so that they can present you with adverts that you may be interested in.

We recommend that you don't change your cookie settings as it may limit your user experience and the performance of the site.

If you do want to change your cookie settings, you can do this through your browser. Different web browsers may use different ways of controlling cookies, so you'll need to use your browser's help section to find out how to do this or you can visit one of the following browser providers’ sites directly.

• Firefox
• Google Chrome
• Microsoft Edge
• Safari

Alternatively, you may wish to visit http://www.allaboutcookies.org/, which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer, as well as more general information about cookies. Please note that, as the allaboutcookies.org website is not owned or operated by us, we are not responsible for any of the content it contains.

To opt out of interest-based advertising, see “Interest-Based Advertising/Targeting Cookies”.

You can find more information about cookies at https://en.wikipedia.org/wiki/HTTP_cookie. For a video about cookies, please visit https://policies.google.com/technologies/cookies.

Any changes to our Privacy Policy shall be posted on this page and any such changes will become effective upon posting the revised Privacy Policy. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavors to inform you by email, a notice on our website or other agreed upon communications channels. If we plan to use your personal information for a new purpose, we will update our Privacy Policy and communicate the changes to you before starting any new processing.

If you have any questions about this Privacy Policy, please contact customerservice@pinnacle.se.