Datenschutzrichtlinie

EFFECTIVE FROM AND LAST UPDATED 01.09.2025

1.​ GENERAL INFORMATION

The Company, UNOCOMPAÑIA S.R.L. (hereinafter “MENACE”) a company incorporated under the laws of Costa Rica, having its address at: Costa Rica, Province 01 San José, Canton 15 Montes de Oca, San Pedro, Barrio Dent, Alvmar, Office 101, 37th Street, 3rd Avenue is committed to the protection of players’ personal data. This Privacy Policy describes the way in which UNOCOMPAÑIA S.R.L. processes personal data and informs players about their rights. Personal data means any information relating to an identified or identifiable individual. The processing of players’ data complies with all applicable data protection regulations.

By accepting this Privacy Policy, the player confirms his (hereinafter referred to as a neutral term and applicable to both sexes) consent to the use of his personal data as set out in this Privacy Policy.

1.1.​ Data Controller

UNOCOMPAÑIA S.R.L. acts as a data controller

Costa Rica, Province 01 San José, Canton 15 Montes de Oca, San Pedro, Barrio Dent,Alvmar, Office 101, 37th Street, 3rd Avenue

Registration Number 3-102-927059

1.2.​ Data Protection Officer

For any privacy issues or for further information on MENACE data processing activities please contact the data protection officer of UNOCOMPAÑIA S.R.L.:

UNOCOMPAÑIA S.R.L.

Costa Rica, Province 01 San José, Canton 15 Montes de Oca, San Pedro, Barrio Dent,Alvmar, Office 101, 37th Street, 3rd Avenue

E-Mail [email protected]

2.​ HOW MENACE PROCESSES PERSONAL DATA

2.1.​ General Information

In the following it is described how MENACE processes personal data and how such processing is justified. MENACE only processes personal data:

2.1.1.​ when the player has given consent with such processing,

2.1.2.​ when processing is necessary for the performance of the services provided by MENACE,

2.1.3.​ when processing is necessary for compliance with a legal obligation to which MENACE is subject, or

2.1.4.​ when processing is necessary for the purposes of the legitimate interests pursued by MENACE or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the player.

2.2. ​Not providing personal data may mean that MENACE is unable to provide services to the player.

2.3.​ Data Collected when visiting the Website.

During the visit of the website menace.com our system automatically collects information which is generated by the browser of the visitor of our Website and stores the data in log files on a temporary basis including but not limited to:

2.3.1.​ the IP address of the requesting computer,

2.3.2.​ the date and the time,

2.3.3.​ the operating system,

2.3.4.​ the browser used by the player.

2.4.​ The log files may contain IP addresses which allow identification of a player.

2.5.​ Such collection is necessary for the performance of the services provided and for the purpose of our legitimate interests in order to enable the use of the site by the visitor, to optimize the website and in order to identify dysfunctions and abuse of MENACE services.

2.6. ​Data Collected upon Registration

MENACE collects players’ personal data during registration process (and during ongoing KYC monitoring at a later stage in time) including but not limited to:

2.6.1.​ first name and last name

2.6.2.​ gender

2.6.3.​ complete address

2.6.4.​ date of birth

2.6.5.​ a verifiable email address

2.6.6.​ mobile phone number

2.6.7.​ username and password

2.6.8.​ in certain countries id-card or social security number

2.7.​ Players will be requested - at any given time and in line with applicable laws and regulations, particularly the current regulations to prevent money laundering and the financing of terrorism - to submit further documents to verify their identity and to enable security identity checks, such as a copy of a valid ID issued by the competent authority, e.g., passport, personal identity card, driver’s license, a utility bill (e.g. for gas, electricity or a lease contract).

2.8.​ Every player is to update his personal data without delay once information provided to MENACE is no longer correct or is incomplete.

2.9. ​MENACE may also collect information from third party databases.

2.10.​ The collection of such data is required for us to provide our services to the player. The verification of the players’ age and identity is necessary for complying with legal obligations. It may also be necessary for enforcing our contractual agreements and is therefore in our legitimate interest.

2.11.​ Data collected for Payment Services

If players deposit funds into the MENACE account by credit card, the processing of particularly the following additional personal data is required:

2.11.1.​ first name and last name of cardholder

2.11.2. name of credit card company

2.11.3. credit card number

2.11.4.​ expiry date of credit card, CVC code and password

2.12. For a transfer of winnings into the player’s bank account, particularly the following personal data has to be collected:

2.12.1. name and surname of account holder

2.12.2. name of bank

2.12.3.​ IBAN

2.12.4.​ SWIFT code

Such data may be transmitted to payment providers. The collection of this data is necessary for performing payment services.

2.13.​ Additional Data collected when using MENACE Services

2.13.1.​ Profiles

MENACE processes information that is collected by cookies, log files, clear gifs, and/or by third parties’ support in order to create player profiles. A profile contains information on individual players including preferences concerning the activities of the player. This information is related to the players’ personal and identifiable data and used to provide and improve our services to the benefit of the player. Profiles are also used to design each player’s experience on the MENACE website individually and to provide specific marketing information.

2.13.2. ​Log files

2.13.2.1. MENACE uses log files. These include internet protocol (IP)addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyze trends for administration of the site, to track players’ movements on the site, and to gather usable comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.

2.13.2.2. The collection of such data is required for us to provide our services to the player. It is also necessary to protect our customers and ourselves from crime and to comply with legal obligations. It is also in our legitimate interest to improve and promote our services.

2.14. Communication with Players

2.14.1. MENACE stores communication with players including requests for information or customer support. This applies to communication via email, the website or other means of communication including telephone. Telephone calls are recorded for training and security purposes.

2.14.2.​ The collection of the player’s personal data is required for us to provide our services to the player and to comply with legal obligations. It may also be necessary for enforcing our contractual agreements and therefore, in our legitimate interest.

2.15.​ Marketing activities

2.15.1.​ Subject to the player’s account settings his personal data may be used by MENACE for marketing activities across various channels including mail, email, telephone call as well as electronic/instant messaging. The use of the player’s personal data for marketing activities may be cancelled or restricted to certain communication channels at any time.

2.15.2. Whenever a player has not consented to the use of his personal data for marketing purposes MENACE processes personal data for marketing purposes only as necessary for the purpose of our legitimate interests in promoting our services.

2.16.​ Cookies, third party Content and Trackers

A cookie is a piece of data saved on the player’s computer and linked to specific user information. For cookies, third party services, social media plugins and the use of trackers see section 4 below and the Cookie Policy.

2.17.​ Other Purposes

It may be necessary to process personal data for additional purposes. However, MENACE will only process personal data if and to the extent that one or more conditions set out in clause 2.1 are met.

3.​ DISCLOSURE OF PERSONAL DATA

3.1.​ General Information

3.1.1.​ Player’s personal data is treated as strictly confidential. Personal player data may be disclosed to third parties:

3.1.1.1. if the player has given consent with such disclosure,

3.1.1.2. if the player has chosen a forum and initiated the disclosure,

3.1.1.3. the disclosure is necessary for compliance with legal obligations to which MENACE is subject, or

3.1.1.4. when the disclosure is necessary for the purposes of the legitimate interests pursued by MENACE or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the player.

3.1.2. In the following clauses 3.2 to 3.7 it is described how MENACE shares personal data.

3.2. Sharing of personal data within the MENACE Group

Personal data may be transferred or disclosed to any company within the MENACE Group. Menace Group means all group companies and their related companies.

3.3. ​Sharing of personal data with Service Providers

3.3.1.​ MENACE may share personal data with other third-party service providers, when players request a service, which MENACE offers partly or fully through the third-party provider, such as casino games, virtual sports or eSports. For these products provided via the game provider websites’ additional provisions may apply.

3.3.2.​ MENACE makes also use of trusted third parties to process players’ personal data including but not limited to payment services, information technology, statistics and reporting, customer support, sales, marketing related services.Pursuant to applicable data protection regulations these third parties are contractually bound to MENACE and obliged to treat players’ data securely and confidentially. Their use of the said data is restricted to the extent required to fulfil the respective task.

3.4.​ Sharing of personal data for KYC, the Prevention of Fraud and Money Laundering

3.4.1.​ MENACE may share your personal data with authorized third-party service providers for the purposes of identity verification (KYC), fraud prevention, and compliance with applicable Anti-Money Laundering (AML) regulations. Such data processing is conducted in accordance with our internal security policies and applicable legal requirements. By using our services, you acknowledge and agree to such data sharing where necessary to ensure the integrity of our platform.

3.4.2.​ In order to complete players’ identity verification, to carry out security checks, to assess players’ compliance with our Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and the protection of minors, player data may be matched against third party databases of including but not limited to SumSub.

3.4.3.​ Upon any indication of transactions and/or activities that may raise suspicions of criminal activities, MENACE will report to the relevant parties in charge (e.g. police, sporting associations, private associations aiming at the prevention of criminal and fraudulent activities in sports betting and/or games of chance).

3.4.4.​ Furthermore, MENACE reserves the right to record telephone calls with players and forward recordings to law enforcement agencies if there is precise evidence of criminal offences.

3.4.5.​ With the acceptance of the General Terms and Conditions and this Privacy Policy, the player grants his explicit consent to these procedures including requests for credit information and the matching of data provided against databases of third parties.

3.4.6.​ The sharing of players’ data might also be necessary to protect players and MENACE from crime and to comply with legal obligations.

3.4.7.​ Within the framework of this contractual relationship, we transmit collected personal data for the purpose of requesting, implementing, and terminating this business relationship, as well as data regarding non-contractual conduct or fraudulent conduct to anti-money laundering prevention, fraud prevention and creditworthiness service providers.

3.5.​ Sharing of data with Regulatory and Enforcement Authorities

In order to comply with its legal obligations, MENACE may be required to transfer players’ registration details, identification documentation, financial transactions, gaming transactions and general information about player accounts to regulatory and enforcement authorities.

3.6.​ Sharing of anonymized Data

MENACE commitment to the protection of personal data notwithstanding, the company reserves the right to publish gaming data (e.g. achieved results), the player’s first name, the initial of the surname as well as the player’s country of residence on the MENACE website as long as the player remains, directly and indirectly, unidentifiable.

3.7.​ Sharing of personal data for other purposes

3.7.1.​ It may be necessary to share personal data for additional purposes. However, MENACE will only disclose personal data if and to the extent that one or more conditions set out in clause 3.1.1 are met.

3.7.2.​ MENACE may process and disclose personal data to a third party which a player has contacted for solving disputes, giving feedback on MENACE services or for any other purpose pursued by the player. MENACE processes and discloses player’s personal data in such cases in order to respond to any inquiries by such third parties that the player has reached out to. MENACE will not assume any liability for the accuracy, integrity and confidentiality of such data processing. Nor will MENACE assume any liability for the fulfilment of any other regulatory requirements in case a player has on its own motion and initiative contacted a third party concerning MENACE services. MENACE reserves the right to respond to all correspondence initiated by a player with a third party and to assume that the information presented by such third party chosen by the player is true and accurate.

3.8. ​Limitation of liability

3.8.1.​ MENACE does not control nor assume any responsibility for any third party websites that contain illegal or defamatory content and that might include a link to MENACE websites or URLs. MENACE does not accept any responsibility from third party websites that contain content such as, but not limited to:

3.8.1.1. Adult Entertainment;

3.8.1.2. Child Pornography;

3.8.1.3. Drug Paraphernalia;

3.8.1.4. Internet Gun Sales;

3.8.1.5. Unlicensed Forex brokers;

3.8.1.6. Sexual Encounter Firms;

3.8.1.7. Unlicensed Money Transmitters;

3.8.1.8. Ammunition Sales;

3.8.1.9. Escort Services;

3.8.1.10. Firearms/Fireworks Sales;

3.8.1.11. Government Grants;

3.8.1.12. Home Based Charities;

3.8.1.13. Loans or other financial services;

3.8.1.14. Pharmaceutical Sales;

3.8.1.15. Pornography;

3.8.1.16. Telemarketing;

3.8.1.17. Tobacco Sales.

4.​THIRD PARTY SERVICES AND TRACKERS

MENACE may use plugins and active script contents (including JavaScript)from third party services for the purpose of functionality of its websites or services, evaluating user behaviour and the improvement of its offers. MENACE reserves the right to use additional plugins and active script contents at any time.

5.​ RETENTION

Personal data is kept by MENACE as long as a player is a customer of MENACE. Whenever a player closes his MENACE account, the personal data saved in the system will remain stored for the minimum length of time required to comply with the purposes set out in this Privacy Policy and applicable legal obligations. Personal Data may also be stored longer if it cannot be deleted for technical and/or legal reasons.

6.​ DATA SECURITY

6.1.​ All data will be processed in an automated manner. MENACE takes all adequate technical and organizational measures to protect players’ data from access by unauthorized persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration, or damage. In particular payment information will always be encrypted when data is being processed.

6.2.​ Whereas sensitive information is protected online by SSL encryption, MENACE makes any reasonable effort to ensure the protection of players’ data in all other areas as well.

6.3.​ Only authorized employees of MENACE, or employees of third parties contractually bound to compliance with the principles of data protection, have access to players’ information. MENACE monitors the trustworthiness and reliability of all its employees. At regular intervals, all employees are given training on the applicable security and data protection standards. All relevant servers are located in a secure environment.

7.​ DATA ENCRYPTION

In order to protect players’ personal data during communication with the web browser, MENACE uses encryption technology. In addition, online transactions are shielded by the security system.

8.​ OTHER TECHNICAL SECURITY MEASURES

In addition, all player data is protected from unauthorized access by firewall and intrusion prevention systems.

9.​ PLAYER’S RIGHTS

If you want to exercise your rights regarding your personal data, please feel free to contact us at [email protected].

10.​ FILING A COMPLAINT

If the player is not satisfied with how we handle your personal data, the player is entitled to file a complaint to the competent data protection authority.

11.​ AMENDMENTS TO THIS DATA PROTECTION POLICY

This Privacy Policy is subject to change from time to time. Although players will always be informed about any changes, it is recommended to review this policy and potential amendments regularly.