Privacy Policy — Betamigos

Last updated: July 5, 2026 · Effective date: July 5, 2026

This Privacy Policy describes how FRIZZO TECH SOLUTIONS INOVA SIMPLES (I.S.), registered under CNPJ No. 67.804.372/0001-41 ("Betamigos", "we", "us" or "our"), collects, uses, shares and protects your personal data when you use the Betamigos platform (the "Service"), available at https://betamigos.io.

We take your privacy seriously and process your data in accordance with applicable law, including Brazil's General Data Protection Law (LGPD — Law No. 13,709/2018) and, where applicable, the European Union's General Data Protection Regulation (GDPR).

By using the Service, you acknowledge this Policy. This Policy supplements and should be read together with our Terms and Conditions of Use.

1. Who is the data controller

The controller responsible for processing your personal data is FRIZZO TECH SOLUTIONS INOVA SIMPLES (I.S.), registered under CNPJ No. 67.804.372/0001-41. For privacy matters, to exercise your rights, or to contact our Data Protection Officer (DPO), use: [email protected].

2. What data we collect

2.1. Data you provide to us

• Registration and profile data: name, email address, country and, where applicable, CPF (required only for users in Brazil), phone number, display currency and time zone.
• Service preferences: odds display method (de-vig), bankroll and staking settings (bankroll, flat/Kelly method, limits) and alert settings.
• Bet-tracker data: the bets, odds, stakes, results, wallets, balances, deposits and withdrawals that you yourself record. This data is entered by you and represents a personal record — we do not hold money or operate bets (see Terms).
• Communications: messages you send us (support, contact) and your communication preferences.

2.2. Data collected automatically (usage data)

When you access the Service, we automatically collect certain technical data, such as: IP address, browser type and version, language, device type and operating system, pages and features accessed, date and time of access, session identifiers and diagnostic/log data.

2.3. Data received from third parties

• Sign in with Google (OIDC): if you sign in with Google, we receive your name, email and an account identifier from Google, according to the permissions granted.
• Payment processor: when you subscribe to a plan, we receive the payment status and minimal transaction data from the processor. We do not receive or store full card or cryptocurrency-wallet details.
• Telegram: if you link your account to Telegram to receive alerts, we receive your chat identifier to deliver the notifications.

3. Cookies and similar technologies

We use cookies and similar technologies to operate and improve the Service:

• Essential: required for authentication, security and session maintenance. Without them the Service will not work.
• Preference/functionality: remember choices such as language and display preferences.
• Analytics/performance: where used, help us understand usage and improve the Service.

You can manage or block cookies in your browser settings. Blocking essential cookies may prevent the Service from working.

4. How we use your data and on what legal basis

We process your personal data for the following purposes, supported by the legal bases of the LGPD (art. 7) and, where applicable, the GDPR (art. 6):

• Provide and maintain the Service, create and manage your account and enable its features — performance of a contract.
• Process subscriptions and payments and manage your plan — performance of a contract and compliance with legal obligations (e.g., tax).
• Send notifications and alerts that you configured (in-app, by email or Telegram) — performance of a contract / consent.
• Ensure security, prevent fraud and abuse and protect the Service and its users — legitimate interest / compliance with legal obligations.
• Improve and develop the Service (aggregate analytics, bug fixing) — legitimate interest.
• Comply with legal and regulatory obligations and respond to competent authorities — legal obligation.
• Marketing communications, where applicable, only with your consent, with an opt-out available at any time.

Automated decisions. The Service computes indicators (EV, CLV, stake suggestions) automatically, but these calculations are purely informational and do not produce decisions with legal effects or a significant impact on you.

5. Who we share your data with

We do not sell or rent your personal data. We share data only with:

• Processors (sub-processors) that provide services on our behalf, such as: the odds-data provider, hosting and infrastructure providers, the payment processor (payments, including in cryptocurrency), Telegram (alert delivery), Google (authentication) and, where applicable, analytics/monitoring providers. Each processes data under its own policies and our instructions.
• Authorities and third parties, where required by law, court order, or to protect the rights, safety and integrity of the Service, its users or third parties.
• In the context of a corporate reorganization (merger, acquisition, asset sale), in which case data may be transferred to the successor, subject to this Policy.

6. International data transfers

Some of our providers may be located outside your country of residence. Where an international data transfer occurs, we will apply the safeguards required by applicable law (LGPD/GDPR) to ensure an adequate level of protection.

7. How long we keep your data

We retain your personal data only for as long as necessary for the purposes described in this Policy, while your account is active and, after closure, for the period necessary to comply with legal, regulatory or accounting obligations or to exercise rights. After that period, the data is deleted or anonymized.

8. How we protect your data

We adopt reasonable technical and organizational measures to protect your data against unauthorized access, loss, alteration or improper disclosure (including encryption in transit via HTTPS/TLS and secure storage of credentials). No method of transmission over the internet or of electronic storage is 100% secure, and therefore we cannot guarantee absolute security.

9. Your rights

Under the LGPD and, where applicable, the GDPR, you have the right, among others, to:

• confirm the existence of processing and access your data;
• correct incomplete, inaccurate or outdated data;
• request the anonymization, blocking or deletion of unnecessary data or data processed in non-compliance;
• request data portability;
• obtain information about the entities with which we share your data;
• withdraw consent and be informed of the consequences of refusal;
• object to processing based on legitimate interest; and
• lodge a complaint with the competent data protection authority (in Brazil, the ANPD).

To exercise your rights, contact [email protected]. We may request information to confirm your identity before fulfilling the request. Many of these rights can be exercised directly in your account settings (e.g., edit profile, close account).

10. Children's and minors' data

The Service is intended solely for persons 18 years of age or older and is not directed at minors. We do not knowingly collect data from minors. If we become aware that we have collected a minor's data, we will take steps to delete it.

11. Links to third-party sites

The Service may contain links to third-party sites and services (including bookmakers). We do not control and are not responsible for the privacy practices of those third parties. We recommend reviewing the privacy policy of every site you visit.

12. Changes to this Policy

We may update this Policy from time to time. The updated version will be posted within the Service with a new effective date and, in the case of material changes, may be communicated by reasonable means. Continued use of the Service after the changes take effect constitutes awareness of them.

13. Contact

For questions, requests or to exercise rights regarding this Policy, contact our Data Protection Officer (DPO) at [email protected].