Privacy Notice

Overview

This Privacy Policy outlines how Clear Play Analysis processes your personal data, along with the rights you have under applicable data protection laws. We strongly encourage all users to review this policy carefully.

We understand that your time is valuable, so here’s a quick summary of how your data is handled. Please note, however, that this is a simplified overview and does not replace the full details set out below.

• Service Delivery: To provide access to our platform and betting tools, we require you to register for an account. This includes submitting personal information such as contact details and, in some cases, bank details for secure deposit handling.
• Legal Compliance: As a licensed betting platform, we are obligated to monitor transactions and user behavior to ensure responsible gambling practices, prevent fraud, and verify age and identity.

Introduction

This Privacy Policy applies to all websites, applications, services, and features operated by Clear Play Analysis that refer to or display this policy. Its purpose is to inform you how we collect, use, and protect your personal data.

We may update this policy periodically to reflect changes in legal requirements, technology, or our services. In the case of material updates, we will notify users prominently via our website or other appropriate channels.

Who Is the Data Controller?

The data controller responsible for your personal information is Clear Play Analysis Pty Ltd, registered and operating in Australia. In this Privacy Policy, references to “we”, “our”, or “us” mean Clear Play Analysis Pty Ltd.

Who Is the Data Protection Officer (DPO)?

We have appointed a Data Protection Officer (DPO) to oversee our compliance with applicable privacy and data protection laws. If you have any questions or concerns regarding how we handle your personal data, you can reach our DPO at:

[email protected]

While the DPO can assist with all privacy-related matters, our Customer Support team remains your first point of contact for exercising your rights (see the “Your Rights” section below).

Is Clear Play Analysis Part of a Corporate Group?

At this time, Clear Play Analysis operates as an independent entity and is not part of a broader corporate group. Should this change in the future, and if your data is ever processed by affiliated entities, we will update this policy and ensure all necessary protections and disclosures are in place.

How We Collect Your Personal Data

In order to provide you with access to the features and services offered by Clear Play Analysis, we collect personal data directly from you, from your activity on our platform, and from third-party sources.

• Account Registration: When you create a user account, we collect personal data including your full name, age, residential address, email address, and other necessary identity verification details.
• Payment and Transactions: To enable deposits and withdrawals, we collect payment information such as bank card details. We also record your transaction history, including betting activity and wallet movements.
• Usage Data: We automatically collect data about your interactions with our website and mobile applications, including your session activity, device type, IP address, browser type, and referring pages.
• Communications: If you contact us via email, chat, or other support channels, we will retain any personal data included in your communications for customer support and recordkeeping purposes.
• Surveys and Research: We may request your participation in voluntary surveys, which may involve collecting demographic or opinion data, either directly or through approved third-party research providers.
• Third-Party Sources: Where legally permitted, we may obtain information from trusted third-party providers such as identity verification services, credit reference agencies, and fraud prevention databases.
• Cookies and Tracking Technologies: Our website uses cookies and similar technologies to enhance user experience and collect analytical data. This includes your IP address, browser behavior, and device identifiers. More details can be found in our Cookie Policy.

How We Use Your Personal Data

In compliance with applicable data protection laws, Clear Play Analysis will only process your personal data where we have a lawful basis to do so. We will process your personal data if one or more of the following conditions apply:

• Contractual Necessity: Processing is required to fulfill our obligations to you under the terms of service, including providing account access, managing transactions, and delivering platform features.
• Legal or Regulatory Obligation: We are required to process certain personal data to comply with applicable laws, licensing requirements, anti-money laundering obligations, and responsible gambling regulations.
• Consent: In situations where your consent is necessary—for example, for marketing communications or the use of non-essential cookies—we will obtain and honor your consent, which can be withdrawn at any time.
• Legitimate Interests: We may process your data where it is in our legitimate interests to do so, provided these interests are not overridden by your rights and freedoms. This includes activities like fraud prevention, product optimization, and platform security.

We do not process any special categories of personal data—such as information relating to your health, race or ethnicity, religious beliefs, political opinions, trade union membership, sexual orientation, or biometric data—unless in very limited and specific circumstances where: you have provided explicit consent, or the processing is necessary for legal reasons or public interest as outlined under relevant data protection laws.

Below is a summary of the purposes for which we process your data, and the lawful bases that apply:

• To manage your user account: Contractual necessity
• To verify your identity and age: Legal obligation
• To process deposits and withdrawals: Contractual necessity
• To monitor betting activity for fairness and responsible play: Legal obligation and legitimate interests
• To prevent fraud and ensure platform security: Legitimate interests
• To improve services and conduct analytics: Legitimate interests (with data anonymization where possible)
• To send marketing communications (where applicable): Consent
• To respond to your support requests and inquiries: Contractual necessity or legitimate interests

Purposes for Processing Your Personal Data

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this Privacy Policy accordingly, when we do this.

Please note that the lawful bases set out above are those which will primarily apply although it is possible that a change in circumstance may result in a change in lawful basis – for example, if you close your user account with us we will no longer process your personal data to perform a contract with you but will continue to do so in order to comply with legal requirements.

Intra-Group Sharing

Clear Play Analysis is part of a wider group of affiliated companies (the “Group”), and in some cases, your personal data may be shared between group entities. This sharing is limited to circumstances that are necessary, lawful, and consistent with the purposes outlined in this Privacy Policy.

We may share your personal data with other members of our Group in the following situations:

• Responsible Gambling Enforcement: To apply responsible gambling measures such as self-exclusion across all Group platforms.
  Lawful basis: Legal or regulatory obligation
• Customer Identification & Compliance: To assist with account management, KYC (Know Your Customer) checks, age and identity verification, and compliance screenings.
  Lawful basis: Legal or regulatory obligation
• Data Accuracy: To ensure the accuracy and consistency of customer records across the Group.
  Lawful basis: Legal or regulatory obligation
• Fraud and Crime Prevention: To identify and mitigate fraud, money laundering, or other criminal activity across platforms.
  Lawful basis: Legal or regulatory obligation
• Breach Detection: To identify customers who have violated our terms of service or similar policies across the Group.
  Lawful basis: Legitimate interests
• Cross-Brand Marketing: To deliver relevant promotions and marketing communications from other Group brands, only where you have explicitly consented to receive such materials.
  Lawful basis: Consent
• Business Intelligence: To analyze service usage trends, customer behavior, and improve services across the Group.
  Lawful basis: Legitimate interests

We may also share personal data within the Group in the future for purposes that are closely related to and consistent with the lawful uses described above. Where legally required, we will share data within the Group for other regulatory purposes not explicitly listed here.

As our Group structure or regulatory obligations evolve, the nature of intra-group data sharing may change. We encourage you to review this Privacy Policy regularly for the most up-to-date information.

Disclosing Your Personal Data

In addition to the intra-group sharing outlined earlier, Clear Play Analysis may disclose your personal data to third-party service providers (“processors”) that assist us in operating our platform, processing payments, providing IT support, or conducting regulatory checks. Each of these processors is bound by a contract that ensures your personal data is processed securely and in compliance with applicable privacy laws.

We may also disclose your personal data under the following circumstances:

• Legal Compliance: Where required to do so by law or regulation, we may disclose your data to government agencies, regulators, or law enforcement authorities.
• Legal Proceedings: Where necessary to protect our legal rights, defend against legal claims, or comply with a judicial proceeding, court order, or legal process.
• Corporate Transactions: In the context of a business transfer such as a merger, acquisition, asset sale, or restructuring, your personal data may be shared with parties involved in the transaction under appropriate confidentiality protections.

Transferring Your Personal Data Outside of Australia

While Clear Play Analysis stores user data on servers located in Australia, certain services and group operations may involve the transfer of your personal data to countries outside your jurisdiction, including those without equivalent data protection laws.

In cases where personal data is accessed or processed outside of Australia (or the European Economic Area, where applicable), we ensure that such transfers are carried out with appropriate safeguards in place. These may include:

• Standard Contractual Clauses (SCCs) approved by data protection authorities
• Data Processing Agreements (DPAs) with international service providers
• Adequacy Decisions issued by the European Commission (if EEA-based)
• Binding Corporate Rules for intra-group transfers where applicable

These safeguards ensure that your personal data receives a level of protection that is substantially similar to that provided under local privacy laws. If you would like further information about international data transfers or copies of relevant safeguards, you may contact our Data Protection Officer at [email protected].

Security of Your Personal Data

Clear Play Analysis implements appropriate technical and organizational measures to safeguard your personal data from unauthorized access, loss, alteration, or disclosure. These measures include encryption, access controls, secure network architecture, and employee training on data protection best practices.

While we take all reasonable steps to protect your data, it is important to understand that no system can be guaranteed 100% secure. In the unlikely event of a data breach resulting from our negligence, we will comply with our legal obligations and notify you where required. However, to the extent permitted by law, we shall not be held liable for breaches beyond our control.

Marketing Communications

Where you have actively consented, Clear Play Analysis may contact you via email, SMS, or push notifications to provide information about our services or promotions. We may also send marketing on behalf of affiliated brands within our Group, provided you have opted in to receive such communications.

You can manage or withdraw your marketing preferences at any time through your account settings. Alternatively, every marketing communication we send includes a clear and accessible unsubscribe option.

Please note that it may take up to five (5) business days to fully process your opt-out request.

Social Media Advertising

We may use the information you provide us (such as email address or device identifiers) to show you tailored advertisements for our services on third-party social media platforms such as Facebook, Instagram, or X (formerly Twitter). This targeting is enabled through audience-matching tools provided by those platforms.

You can opt out of such advertising by adjusting your preferences directly within the social media platform settings. If you would prefer that Clear Play Analysis not share your information with social media platforms for this purpose, please contact us at [email protected].

Cookies and Similar Technologies

In this Privacy Policy, we use the term “cookie” to refer collectively to cookies and similar tracking technologies, such as web beacons, pixels, and local storage. A cookie is a small text file placed on your computer or mobile device by a website’s server when you visit. Each cookie is unique to your browser and typically contains anonymous data such as a session identifier, website name, and some alphanumeric characters.

Like most modern websites, Clear Play Analysis uses cookies to enhance your user experience. Cookies help our website remember your preferences, streamline navigation, and allow us to present you with relevant content or offers based on your usage patterns.

Cookies are generally categorized as follows:

• Session Cookies: Temporary cookies that expire when you close your browser. Used to maintain your session during navigation.
• Persistent Cookies: Stored on your device between visits to remember login information, settings, or personalization.
• First-Party Cookies: Set directly by the website you are visiting (e.g. safeclearplayanalysis.com).
• Third-Party Cookies: Set by external domains for analytics, social media, or advertising purposes.

Cookies serve several functions, including:

• Helping you navigate between pages efficiently
• Remembering your preferences and login details
• Analyzing website performance and user behavior
• Delivering targeted advertising based on your interests

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies, or to alert you when a cookie is set. Please be aware that disabling cookies may affect the functionality of certain features on our website.

For more information on cookies and how to manage them, please visit:
www.allaboutcookies.org

Advertising and Third-Party Cookies

We may use advertising cookies and third-party services (such as Google Ads or Facebook) to show you relevant content and promotions based on your activity on our website. These cookies help us measure campaign effectiveness and limit ad frequency.

You can learn more about ad personalization and opt out of third-party tracking via:
https://optout.aboutads.info

Retention of Your Personal Data

We retain your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for legal, regulatory, and legitimate business purposes. Unless stated otherwise, we will retain your personal data for up to six (6) years following the closure or inactivity of your user account.

Exceptions to this retention period include:

• Self-Exclusion: If you have self-excluded from using our services, we will retain this record indefinitely to ensure compliance with responsible gambling measures.
• Regulatory or Criminal Investigations: If your data is linked to an active investigation involving fraud, money laundering, or criminal activity, it may be retained beyond the standard period.
• Legal Disputes: If your data is relevant to a legal dispute, it will be retained for the duration of the dispute and for up to six (6) years after its conclusion.

Updating Your Personal Information

You may update certain personal details directly through your Clear Play Analysis account at any time. We encourage you to keep your information accurate and current to ensure uninterrupted service.

If you are unable to make changes via your user account, please contact our Support Team for assistance.

Your Rights

You have the following rights in relation to your personal data, subject to applicable laws:

• Right to Access: Request access to the personal data we hold about you (commonly known as a “data subject access request”).
• Right to Rectification: Request corrections to any inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data in certain circumstances, such as where it is no longer necessary for processing or where you withdraw consent.
• Right to Data Portability: Receive certain personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Withdraw your consent at any time where processing is based solely on consent.
• Right to Object: Object to the processing of your personal data where the basis is legitimate interest or for direct marketing.
• Right to Restriction: Request restriction of processing where there is a dispute about the accuracy or legal basis of the processing.
• Right in Relation to Automated Decision-Making: Request an explanation of automated decisions and object to certain profiling, particularly where it relates to marketing.

If you would like to exercise any of your rights, please contact us at [email protected] or through our Support team. We may request proof of identity to protect your data from unauthorized access.

We aim to respond to all legitimate requests within one (1) month of verifying your identity. If your request is complex or involves multiple inquiries, we may extend this period and will notify you accordingly. Please note, your rights are not absolute—there may be situations where we are unable to fully comply due to legal obligations or other lawful grounds.

If you believe we have not handled your data in accordance with applicable laws, you also have the right to lodge a complaint with your local data protection authority.

Supervisory Authorities

If you have concerns about the way we handle your personal data, you have the right to lodge a complaint with your local data protection authority. However, we strongly encourage you to contact us first so that we may address your concerns directly and promptly.

Your trust is important to us, and we are committed to resolving any issues transparently and in accordance with data protection laws.

Contact Us

If you have any questions about this Privacy Policy, your rights, or how we process your personal data, please contact our Support team as your first point of contact.

You may also reach out to our appointed Data Protection Officer (DPO) at:
[email protected]

Privacy Policy last updated: 12 April 2025