EFFECTIVE DATE: June 29, 2025

DATE OF LATEST UPDATE: June 29, 2025

 

INTRODUCTION

 GUYBET LLC, a domestic limited liability company organized pursuant to the laws of the State of New York, owns, manages and operates the present website (referred to as the “Platform”). The Platform functions as a digital e-commerce service providing its users the ability to purchase digital products consisting of gift cards and mobile game top-ups. 

The Platform is designed to facilitate the purchase, sale and transfer of such digital products.

1. DEFINITIONS

In this Privacy Policy, the following capitalized terms shall have the meanings provided, unless the context requires otherwise:

“Affiliate” shall refer to any third-party affiliate of GUYBET who requires access to Personal Information for purposes listed in this Privacy Policy. Affiliates may consist of GUYBET’s contractors, consultants, or third-party service providers.

 “GUYBET” shall refer to GUYBET LLC, a domestic limited liability company with its registered address is located in the State of New York (United States). For reference purposes, GUYBET owns, manages and operates the Platform.

 “Order” shall refer to a request to purchase one (1) or more Products placed by a Buyer on the Platform.

 “Personal Information” shall refer to personal information relating to an identified or identifiable natural person, also known and as a data subject. Personal Information can be used to identify an individual person. For reference purposes, Personal Information may include, without limitation, the User’s name, location, online identification number and other data relating to identity.

 “Privacy Policy” shall refer to the latest version of this Privacy Policy, as may be amended or updated by GUYBET from time to time.

 “Products” shall refer to all digital products listed as available for purchase on the Platform. Products may include, without limitation, gift cards, mobile game credits and top-ups.

“Users” shall refer to all users of the Platform, including Buyers, and “User” shall refer to an individual user of the Platform. For interpretation purposes, all references to Users shall be deemed to include Buyers.

2. APPLICABILITY

This Privacy Policy sets forth the terms and policy applicable to GUYBET’s collection, protection, usage, and disclosure of Personal Information provided by Users on the Platform. This Privacy Policy shall also provide the terms applicable to the submission of Personal Information by Users on the Platform, and the rights granted to Users in connection with their Personal Information.

The collection, handling, retention, protection and usage of Personal Information collected by GUYBET shall be governed by this Privacy Policy. Further, the provision or submission of Personal Information by Users on the Platform shall be subject to the terms of this Privacy Policy.

Users shall be deemed to have read and agreed to the terms of this Privacy Policy, in full and without condition, upon their initial use of the Platform. Accordingly, any access or use of the Platform by Users shall signify their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, even in part, the User’s sole recourse shall be to refrain from using the Platform.

3. APPLICABLE LEGISLATION

The present Privacy Policy has been drafted in compliance with data protection laws applicable in North America as well as in consideration of the General Data Protection Regulation (GDPR), which is applicable to organizations that handle and process the Personal Information of individuals within the European Union (EU) and the European Economic Area (EEA). The GDPR provides guidance relating to data processing, including the collection, use, storage, maintenance and deletion of Personal Information.

4. MINOR USERS

• Minimum Age to Use the Platform

The Platform is not intended for minors who are below the age of eighteen (18) years. Any Users below the age of eighteen (18) shall be required to use the Platform with the knowledge, approval and consent of their parent or legal guardian. The minor User’s parent or legal guardian shall be responsible for supervising the minor User’s usage of the Platform.

• Parent or Legal Guardian’s Responsibility

The minor User’s parent or guardian shall assume responsibility for supervising and ensuring the minor User complies with all the policies applicable to the Platform. As such, the minor User’s parent or guardian shall oversee the minor User’s use of the Platform, and purchase of Products, as applicable. Any Orders placed by the minor User shall be handled and managed by the minor User’s parent or legal guardian.

5. PERSONAL INFORMATION PROVISION

• Personal Information to Create an Account

Users shall submit Personal Information to create their accounts on the Platform. Users shall be required to provide the following Personal Information to create an account on the Platform: (i) First name, (ii) Last name, (iii) Email address, (iv) Phone number, (v) Residential address, (vi) Government-issued identification (ID), such as a passport, driver’s license or national ID, (vii) Selfie image for verification purposes and (viii) Payment information, such as  credit card details, debit card details or wallet transaction logs.

Users recognize however that by not supplying the required Personal Information, Users may not create an account on the Platform. Users may not be able to place Orders and proceed with purchases of Products without inputting Personal Information.

 

6. PERSONAL INFORMATION COLLECTION

 For purposes of safeguarding Personal Information from unauthorized disclosure, GUYBET agrees to collect only Personal Information that has been voluntarily provided by Users on the Platform.

• Personal information Provided on Accounts

GUYBET may collect Personal Information voluntarily provided by Users upon creating their accounts on the Platform. All Personal Information submitted by Users shall be deemed voluntarily provided.

 

• Personal Information for Identity Verification

 Users may be required to submit certain Personal Information, including a government-issued identification document, a recent selfie and proof of address, for the purpose of completing identity verification in accordance with Know Your Customer (KYC) and Anti-Money Laundering (AML) principles. GUYBET shall use such information solely for internal verification and fraud prevention purposes. The identity verification process shall be required in order for approved Users to place Orders.

The Personal Information provided for KYC verification is for internal purposes and shall not be shared with any third parties, except where such disclosure is required by law, including requests from law enforcement or regulatory authorities.

 

• Personal Information for Payment Purposes

Considering Users may purchase Products on the Platform, Users may need to input their payment information. Users’ payment information may be maintained and stored by GUYBET’s  secure third-party payment processing company.

 

• Personal Information from Third Party Logins

Users shall be granted the ability to log into the Platform through their Facebook account or Google account.

Upon accessing the Platform through a third-party service login, such as Facebook or Google, GUYBET may collect information from the third-party service provider. Such information may include Users’ login credentials and any public information available on their account with the third-party service.

 

• Non-Personal Information

Non-personal information, also known as indirect identifiers, is anonymous and does not allow for the identification of Users.

GUYBET may collect non-personal information when Users use the Platform. GUYBET shall not use IP addresses to track individual Users, but may collect them for general analytics or security purposes.

 

7. PERSONAL INFORMATION PROTECTION

• Security Measures

In compliance with applicable legislation, GUYBET shall protect and safeguard Personal Information according to the standards required. Accordingly, GUYBET established certain protection measures to safeguard Users’ Personal Information in accordance with industry standards. To this effect, GUYBET protects Personal Information collected from the Platform through the use of SSL encryption for data in transit, secure cloud storage with firewall protection, access restrictions limited solely to authorized personnel, regular security audits and data backups, and two-factor authentication (2FA) for administrative-level access.

• Limited Disclosures

Personal Information shall not be shared, communicated or disclosed by GUYBET, except in accordance with this Privacy Policy.

To this effect, GUYBET shall disclose Personal Information on a need-to-know basis, and exclusively to any Affiliate requiring such information for legitimate purposes. Accordingly, GUYBET may share Personal Information with its Affiliates to allow: (i) the fulfillment of Orders placed on the Platform, and (ii) the processing of payments.

• Disclaimer

GUYBET implemented measures to safeguard Personal Information. Nonetheless, despite GUYBET’s best efforts, Users understand that the transmission of Personal Information over any internet-dependent platform is never fully secure. There are risks associated with the provision and transmission of Personal Information.

Consequently, GUYBET is unable to guarantee that Personal Information shall be safe and secure on the Platform at all times. Users’ provision of Personal Information on the Platform shall be at their sole risk, subject to any requirements imposed by applicable laws and regulations. GUYBET shall not be responsible for any unauthorized access to Personal Information, except to the extent required by applicable legislation, including the GDPR.

8. USE OF PERSONAL INFORMATION

GUYBET shall use Personal Information solely for the purposes specified in this Privacy Policy. Any usage of Personal Information by GUYBET shall be limited to the extent required by GUYBET’s operations activities and legitimate interests, and in accordance with applicable laws and regulations.

GUYBET does not share Personal Information with third parties for marketing and commercial purposes. Instead, Personal Information is used strictly for internal operations, identity verification, Order processing and fraud prevention. GUYBET may disclose Personal Information if required by law or for any purpose set out in this Section.

• Usage for Legal Purposes

GUYBET may disclose Personal Information if required to do so by an applicable law or a valid court order. In such cases, GUYBET may not be able or permitted to notify the affected User of the disclosure in advance.

Further, GUYBET may use Personal Information to determine if a User has breached or attempted to breach any applicable laws and/or policies in effect, including but not limited to the Terms and Conditions.

Moreover, in accordance with applicable laws, GUYBET shall be authorized to use Personal Information for reasons of public interest.

• Order Fulfillment

GUYBET may use and communicate Personal Information to fulfill Orders placed on the Platform and deliver the Products ordered and purchased.

• Marketing and Promotional Purposes

GUYBET reserves the right to send Users promotional newsletters and content by email and on the Platform. GUYBET may also use Personal Information for marketing and promotional purposes. Each such promotional newsletter shall include an unsubscribe link, allowing Users to opt out of future communications. Users may also request to be removed from GUYBET’s mailing list by contacting GUYBET’s support team using the contact information provided in this Privacy Policy.

• Analytical and Statistical Purposes

GUYBET may use Personal Information for statistical and analytical purposes, including Platform usage, transaction volumes, User activity, geolocation and related metrics. As such, GUYBET may collect and process anonymized or aggregated data, such as geolocation derived from IP addresses and other non-personal information. This information shall be used by GUYBET solely to improve the Platform’s functionality, enhance User experiences and develop service offerings. Personal Information shall not be included in statistical or analytical reporting.

• Third Party Providers

GUYBET shall not sell, trade, rent or otherwise share Personal Information with third parties without Users’ prior consent. Notwithstanding the foregoing, GUYBET may share Personal Information with third-party providers who perform services for GUYBET with respect to the Platform. The third-party providers GUYBET uses shall only collect, use and disclose Personal Information to the extent necessary to allow them to perform the services they provide for the Platform.

GUYBET reserves the right to share Personal Information with authorized third-party providers to allow such authorized third-party providers to:

• Perform identity verifications, background checks, and other related investigations;
• Perform duties that GUYBET delegated or subcontracted to them, including processing payments;
• Protect the Platform against fraud, cyberattacks or other malicious activity;
• Provide analytics and services relating to Orders, usage and compliance with legal standards. 

• Pursuant to a Consent

Users may consent to GUYBET using their Personal Information for purposes extending beyond those set forth in this Privacy Policy. GUYBET may use Personal Information in compliance with any consent provided by the Users. GUYBET’s usage thereof shall be limited to the extent and according to the consent provided. To be valid, the consent shall be in writing, specifying the scope and duration thereof.

Any consents provided by Users with respect to their Personal Information may be withdrawn at any time. To withdraw a consent, Users shall email GUYBET at support@guybet.com.

In accordance with the GDPR’s obligation to minimize use of Personal Information, GUYBET shall ensure its usage of Personal Information is limited to the purpose for which it was collected.

 

9. PLATFORM MAINTENANCE

GUYBET handles the maintenance of the Platform internally. GUYBET may obtain support regarding the maintenance of the Platform from trusted third partners. GUYBET shall ensure that each partner providing maintenance support is subject to strict confidentiality obligations that are as stringent as those contained in this Privacy Policy.

 

10. USER RIGHTS

As data subjects, Users shall benefit from certain rights in connection with their Personal Information. GUYBET shall grant Users of the Platform the following rights set forth in the GDPR.

 

• Right to be Informed

Users have the right to be informed of GUYBET’s collection and use of their Personal Information. Users may request a copy of the data GUYBET has collected about them. To exercise this right, Users shall email GUYBET’s support team. GUYBET shall process all such requests in accordance with applicable data protection regulations.

• Right to Access

Users shall have the right to obtain information regarding the transmission of their Personal Information outside of where GUYBET’s servers are located. To exercise this right to access, Users may send a request by email. Any such requests shall indicate the reasons for which the Users are seeking information regarding the transmission of Personal Information.

 

• Right to Rectification

GUYBET may, at its discretion and without obligation, verify the accuracy and validity of Personal Information submitted by Users. If Users find that the Personal Information held and stored on the Platform is incorrect, Users may request the correction thereof. If Users determine that their Personal Information stored on the Platform is incomplete, Users may request that GUYBET make all required additions or supplements.

Any requests to correct, add or supplement Personal Information shall be submitted by email.

Additionally, Users may be able to make changes to their Personal Information directly on the Platform through their accounts.

• Right to be Forgotten

Users have the right to request the deletion of their Personal Information from GUYBET’s servers.

 

Users may also request that GUYBET delete their Personal Information from the Platform. Any such requests shall be sent by email, and shall include justification. GUYBET’s support team shall then proceed with the deletion unless such information is required by law for fraud prevention or compliance. However once Users’ Personal information is deleted, Users shall no longer be able to place Orders as their KYC information is no longer available and identity verification is required for all transactions.

 

Notwithstanding the foregoing, Users may not request the deletion of their accounts until at least thirty (30) days have lapsed since the completion or cancellation of the last Order placed. This delay has been instituted to ensure GUYBET can effectively manage cancellation and refund requests that may be provided following the completion of an Order. Accordingly, GUYBET reserves the right to refuse to delete Personal Information if the delay specified herein has not yet lapsed.

Right to Data Portability

Users may request a copy of their Personal Information as stored on the Platform in a structured, commonly used and machine-readable format.

• Right to Revoke Consent

Users may revoke any consent granted to GUYBET to use their Personal Information for purposes beyond those listed in this Privacy Policy. This right granted may be exercised by Users at any time at their convenience. Any revocation shall be submitted to GUYBET in writing.

• California Users

 California Users have the rights granted to them by the California Consumer Privacy Act (CCPA). Accordingly, California Users shall have the right to request the deletion of their Personal Information, as well as information regarding the collection and the categories of Personal Information collected. California Users have the right to opt out of having Personal Information sold to third parties for direct marketing purposes.

As per the California Privacy Rights Act (CPRA), California residents may request that GUYBET restrict its usage of their Personal Information to that use which is needed to fulfill Orders and provide Products ordered.

• Nevada Users

Users residing in the State of Nevada have the right to prohibit the sale or licensing of their Personal Information to or by third parties.

 

• Canadian Users

Users residing in Canada benefit from the rights granted by the Personal Information Protection and Electronic Documents Act (PIPEDA). Such rights shall include the right to remain anonymous, where applicable. Canadian Users also have the right to access information, provide and revoke specific consents, correct any inaccurate Personal Information, and be informed of the purposes of GUYBET’s collection of Personal Information.

• Brazilian Users

Brazilian Users benefit from the protections provided in the Brazilian General Data Protection Law (LGPD), which contains protections similar to those in the GDPR. Brazilian Users shall be entitled to obtain information that GUYBET collects about them, and how GUYBET processes Personal Information.

• Users in Other Countries and Regions

Users located in the People’s Republic of China benefit from rights granted by the Personal Information Protection Law (PIPL). The PIPL grants its data subjects the right to access their Personal Information, request corrections and/or deletion, and to limit GUYBET’s processing thereof.

The Personal Data Protection Act (PDPA) applies to Users located in the Republic of Singapore. This Act grants Users based in the Republic of Singapore the same rights as those granted by the GDPR, with adjustments.

11. PERSONAL INFORMATION STORAGE AND MAINTENANCE

Personal Information shall be stored in GUYBET’s secure third-party cloud servers with industry standard encryption and access control measures.

GUYBET shall retain Personal Information on its servers for as long as is necessary to fulfill the purpose for which the information was collected, including fraud prevention, purchase history and compliance requirements.

GUYBET shall maintain and store Users’ Personal Information while Users have an active account on the Platform. As such, GUYBET shall retain Users’ Personal Information until their accounts become dormant. Following one (1) year of inactivity, GUYBET shall notify Users, by email or as a notice on the Platform, that their accounts are inactive and require a login to reactivate.

GUYBET shall retain and maintain Personal Information for a minimum period of five (5) years following the last recorded account activity, in compliance with KYC and AML practices. After this period, the Personal Information shall either be deleted or anonymized, in compliance with applicable laws and GUYBET’s data retention policies.

GUYBET may retain Users’ Personal Information for a longer period to comply with legal and financial obligations. In addition, GUYBET may hold Personal Information in its servers for payment purposes until all funds owed have been paid or to resolve disputes.

Further, GUYBET reserves the right to store and maintain Personal Information on file for a longer duration if permitted by applicable laws and regulations. Once GUYBET has removed Users’ Personal Information from its servers, GUYBET may maintain non-personal information in its servers, indefinitely, for statistical purposes.

12. DATA TRANSFERS

In compliance with applicable laws, GUYBET shall not transfer Personal Information outside of GUYBET’s servers, except to countries who adhere to data protection standards at least as protective as those in the GDPR.

Accordingly, GUYBET shall ensure that all Personal Information transfers are to countries that have been identified as secure by trusted governmental authorities. In addition, GUYBET shall not transfer Personal Information outside of its servers except for compelling and legitimate purposes.

13. COOKIE POLICY

GUYBET reserves the right to use cookies, including but not limited to essential and functional cookies. Non-personal information may be obtained through the use of cookies. Cookies may be sent to User browsers from GUYBET’s servers, and subsequently stored upon User devices. Cookies help GUYBET collect non-personal information about Users, allowing for the safeguard of preferences.

Essential cookies are designed to ensure the proper functioning of the Platform and support its core features, such as user login information, wallet functionality and secure sessions. Essential cookies allow Users to access secure parts of the Platform. These cookies are utilized when Users log in to Platform. It is possible to remove or disable session cookies, however, the disabling or removal thereof may result in portions of the Platform being inaccessible or unusable.

GUYBET reserves the right to use functional cookies, performance cookies and other cookies. Functional cookies are used to save User preferences and settings, allowing for the recognition of Users’ devices and safeguarding preferences, such as location and language.

Any non-essential types of cookies may require the consent of Users. Users may remove or disable cookies by adjusting browser settings or turning off cookies.

Users may delete the cookies stored on their devices, which could result in the loss of certain preferences. Users acknowledge that certain parts of the Platform may be unavailable or inaccessible if cookies are disabled or removed.

14. PRIVACY POLICY UPDATES

GUYBET may update this Privacy Policy at its discretion or to comply with evolving laws and regulations. The latest version of this Privacy Policy shall be published on the Platform.

This Privacy Policy shall specify the date of its latest update in the header. The latest version of this Privacy Policy shall be binding as of the date specified in the header. Any use of the Platform following the publication of the updated Privacy Policy shall be construed as the Users’ agreement to be subject to the updated Privacy Policy.

15. THIRD-PARTY SERVICES

This Privacy Policy applies solely to the Platform and Personal Information collected from the Platform. This Privacy Policy shall not apply to third-party services, such as payment processors, top-up agents and gift card providers. The links or mentions of third-party services on the Platform are for reference or convenience purposes only.

Any personal information submitted to a third-party service shall be governed by the third party’s privacy policy, and not by the present Privacy Policy. GUYBET shall not be responsible for the use and collection of Users’ Personal Information by the third-party services. The submission of Users’ Personal Information to such third-party services shall be at Users’ own risk.

 

16. QUESTIONS AND COMMENTS

GUYBET welcomes questions, feedback and comments about this Privacy Policy, and the privacy practices employed by GUYBET. Users may send their questions, feedback and comments to GUYBET by email to support@guybet.com or through the Platform. GUYBET shall strive to respond to inquiries and questions in a timely manner.