Privacy Policy

Effective Date: 24 November 2025

SilverFern Sports ("we", "us", or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our sports betting services. We adhere strictly to the Privacy Act 2020 (New Zealand) and other applicable data protection laws.

1. Who We Are

SilverFern Sports is the data controller responsible for your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out in the "Contact Us" section below.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data: First name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
• Contact Data: Billing address, residential address, email address, and telephone numbers.
• Financial Data: Bank account details and payment card details (note: full card numbers are tokenized and stored by our PCI-DSS compliant payment processors, not directly by us).
• Transaction Data: Details about payments to and from you and details of the bets you have placed, including stakes, wins, and losses.
• Technical Data: Internet Protocol (IP) address, your 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: Your username and password, wagers made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: Information about how you use our website, products, and services.
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

3. How We Collect Your Data

We use different methods to collect data from and about you including through:

• Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you create an account, verify your identity, request marketing, or give us feedback.
• Automated Technologies: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
• Third Parties: We may receive personal data about you from various third parties, including technical data from analytics providers (such as Google), identity and verification services (to perform KYC checks), and credit reference agencies.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.1. Performance of Contract

To process your registration, manage your account, process your bets, and handle financial transactions.

4.2. Legal Obligation

To comply with our regulatory obligations under the Gambling Act 2003 and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. This includes age verification, identity checks, and reporting suspicious transactions.

4.3. Legitimate Interests

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes:

• Detecting and preventing fraud and sports integrity issues (match-fixing).
• Keeping our website updated and relevant.
• Studying how customers use our products/services to develop them and grow our business.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in Section 4:

• Service Providers: IT and system administration services, identity verification providers (e.g., CloudCheck), and payment service providers.
• Professional Advisers: Lawyers, bankers, auditors, and insurers.
• Regulators: The Department of Internal Affairs (DIA), the New Zealand Police, and the Privacy Commissioner, where reporting is required by law.
• Sports Governing Bodies: In specific cases of suspected betting integrity breaches.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International Transfers

Some of our external third parties (such as cloud hosting providers) may be based outside New Zealand. Whenever we transfer your personal data out of New Zealand, we ensure a similar degree of protection is afforded to it by ensuring comparable privacy safeguards are in place.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers.

9. Your Legal Rights

Under strict circumstances, you have rights under the Privacy Act 2020 in relation to your personal data:

• Request access: You can ask for a copy of the personal information we hold about you.
• Request correction: You can ask us to correct any data we hold about you that is inaccurate.
• Request deletion: You can ask us to delete your data where there is no good reason for us continuing to process it (subject to our legal retention obligations).
• Object to processing: You can object to the processing of your data for direct marketing purposes.

If you wish to exercise any of the rights set out above, please contact our Privacy Officer.

10. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact us at:

SilverFern Sports
Email: [email protected]
Attention: The Privacy Officer
Address: Level 4, Tech Plaza, Wellington, New Zealand (Fictional Address)