Privacy Policy

Privacy Notice last updated: 15 April 2025

IDENTITY AND DOMICILE OF THE RESPONSIBLE PARTY

In accordance with the Federal Law for the Protection of Personal Data in Possession of Individuals (hereinafter, the “Law”), its regulations and other current and related legislation (hereinafter, the "PD Legislation"), by means of this Privacy Notice (the “Privacy Notice”), we inform you about the treatment of your personal data (“Personal Data”).

This Privacy Notice is brought to you (the “Data Subject”) by Unocapali La Paz Operadora, S.A. de C.V., an authorized operator by the Secretaría de Gobernación under that certain gaming permit granted to Producciones Móviles, S.A. de C.V. (hereinafter referred to as “we”, “our”, “us” or the “Company”) which carries out the services to you by means of website jugabet.mx.

The Data Controller of your personal data is the Company.

The Company is committed to protecting your privacy and handling your Personal Data in an open and transparent manner, in compliance with the PD Legislation.

This Privacy Notice provides an overview on how we collect, use and otherwise process your Personal Data as Data Controller when you use our products and services or use/or access our websites (hereinafter referred to as “Websites”) and our mobile apps (hereinafter referred to as “Apps”) (hereinafter collectively referred to as “Services”).

This Privacy Notice applies to any person which is (i) a potential customer, a current customer or a former customer registered on our gambling platform available on our Websites/Apps (hereinafter referred to as “Customers”) or (ii) is accessing and using our Websites/Apps as a simple user/visitor, without registering on and using our gambling platform (hereinafter referred to as ”Website Visitors”). The information of the data holders mentioned is part of our ‘Website / Application Users’ database.

WHAT PERSONAL DATA DO WE PROCESS?

In compliance with the PD Legislation, we process various categories of Personal Data depending on how you interact with us or use the Services. Such data may be provided by you, inferred by us based on your interaction, or obtained from third parties as permitted by applicable regulations, including:

Identification data: Includes username, name, surname, email, phone number, password, date of birth, nationality, place of birth, address, unique identification number (CURP or equivalent), tax identification number (RFC or equivalent), occupation, and other official identification documents (e.g., copy of IDs, passports, residence permit, INE), as well as biometric data such as fingerprints, iris images and, in general, any other part of the body that, according to the advances of science, allow you to be identified. This data is collected to enable full use of our Services, including bet placement, game participation, viewing bet history, financial account transactions (deposits and withdrawals), and account security settings.

Other data: Includes data required to verify identity and ensure compliance with anti-money laundering (AML) regulations in Mexico, such as information required to verify the authenticity of data provided during the registration process on our gambling platform (e.g. utility bills, bank statement, lease contract, internet/TV/phone subscription bills), information required to prove the source of funds (e.g. bank statements, tax returns, payslips etc.) information whether you may be a politically exposed person, a close affiliate of such person and relevant information in this respect, data related to potential international sanctions, data related to ultimate beneficial owners regarding the transactions with us, your image (from photographs) which may be required by us to verify the authenticity of your data; any other data for the purposes of verifying the source of wealth to validate the customer’s transactions;

Contact and communications data: phone number, e-mail address, name, birth data, country, saved phone calls and text live chats for the purpose of communication with us and providing Customer support;

Financial transactions data: the payment method used; bank account number, payment card number, and other payment details (amount, payer identity and other transaction data), account financial history (deposits and withdrawals), information regarding the taxes retained and paid on behalf of the Customers;

Data related to illegal or fraudulent activities: information whether you may be included on a list of fraudulent or undesired players, data related to criminal investigations or sanctions imposed to the Customers/potential Customers following any fraudulent or illegal activities;

Geolocation data: the country, the city and the ISP from which the gambling platform is accessed (based on client IP address);

Online identifiers: cookie identifiers and other similar identifiers;

Device and connection data: type of device accessing our Websites/Apps, browser used, IP address;

Online activity data: include the data collected via the cookies and tracking technologies implemented on our Websites/ Apps. For more information on how we use such technologies, please see our Cookie Section below;

Preferences data: include the data concerning your permissions given to process Personal Data requiring an additional consent (e.g. for marketing activities, for placing and using non-essential cookies and other tracking technologies).

WHERE DO WE GET YOUR DATA FROM?

We may obtain your Personal Data:

Directly from you: (i) when you provide the information directly to us, either in writing (e.g., by e-mail or live chat or by respective form at Website) or verbally (e.g., following a telephone conversation with you) or (ii) by observing the interaction we have with you. For example, we will obtain your Personal Data when you: (i) register on our Websites/Apps or use any of our Services, (ii) express your preferences to receive commercial communications (including personalized marketing communications) or other offers and information from us, (iii) contact us through various channels; (vi) simply visit or browse our Websites/Apps.

From third parties: the external sources from which we may obtain your data include:

Public sources providing information on international sanctions list;
Private third parties providing fraud prevention and background verification services as long as we have your prior authorization);
Our services providers whose services are integrated into our gambling platforms (e.g. payment services providers);
Public authorities or institutions, for example in the context of judicial investigations, court requests, requests related to complaints submitted by you.
From our Customers, whenever such data relates to a person which is in a relevant relationship with the Customer (e.g. close relative of a publicly exposed person).

WHETHER YOU HAVE AN OBLIGATION TO PROVIDE US WITH YOUR PERSONAL DATA

In order for us to be able to proceed with a business relationship with you, you must provide certain Personal Data to us which are necessary for the required commencement and execution of a business relationship.

Kindly note that if you do not provide us with the required data, then we will not be allowed to commence or continue our business relationship.

WHY WE NEED YOUR PERSONAL DATA AND WHAT IS THE LEGAL BASIS FOR PROCESSING

We will use your Personal Data for the following purposes in compliance with the PD Legislation:

Registration of the game account, account management, and provision of the Services

Creating and managing your game account within our gambling platform available on our Websites/Apps.
Providing gambling Services, including processing deposits, placing bets, managing stakes, and processing payments of winnings.
Verifying compliance with gaming regulations in Mexico, ensuring that access is granted only to eligible persons.
Analyzing and settling the results of your participation in gambling activities.
Sending functional messages related to changes in our Services, including updates to terms and conditions, account interruptions, suspensions, or contract terminations.
Processing self-exclusion requests and deposit limits for responsible gaming purposes.
Enforcing the terms and conditions of our Services.

Identity verification, verification of transactions and regulatory reporting

identity verification when entering into the contract with us and throughout the contract performance;

Customer support and management | Complaints handling

We collect and process some Personal Data to provide support services to our Customers and handling of the complaints. We will also process Personal Data of Website Visitors and of any other persons contacting us through the available channels seeking answers to their requests.

As part of our customer support service, the telephone conversation with our agents may be recorded. If you continue the call, we will assume that we have your consent to record the call. If you do not wish this, please end the call and contact us through other available communication channels.

Management of Company's claims | Dispute Resolution and Litigation

We may process your Personal Data in order to defend our rights and interest in litigation and/or administrative proceedings, including to collect and recover any debts you may owe us under the contract with us.

Functioning of the IT systems, Security and Abusive use of our systems

When you use or access the Websites/Apps, our systems automatically collect certain Device and connection data (such as, the IP address, the date and time of accessing / logging in to the system, the operating system used, the type of browser used) which are used to prevent and investigate potential abuses/ frauds in using our IT systems / services provided by us, as well as to ensure the long-term viability of our IT systems.

Prevention of abusive use of Services | Prevention, management and reporting of frauds and illegal activities

We will process your Personal Data to detect and protect against fraudulent, improper or abusive use of Services, including analysis, investigation and reporting of frauds, money laundering and other illegal gambling schemes.

Compliance with other regulatory requirements

reporting of data from the gambling activities to the national gambling authority (e.g. we are required to grant national gambling authority access to all data related to your participation in gambling activities, we are also required to report to the gambling authority certain information about you, for example if we suspend a transaction for breach of terms of Services or breach of law, or in case your account becomes dormant and we are unable to return to your account the balance);
to keep a register of self-excluded players, or of the persons which required a suspension or interruption of access to the games;
to monitor your time spent on the gambling platform and to send you notifications within the time intervals provided by the law;
to comply with the tax payment and tax reporting obligations in relation to your wins;
to ensure the access of the gambling platform is granted only to the eligible persons;
to disclose any information, we may hold about you to the competent public authorities with the observance of the laws.

SECONDARY PURPOSES

Different purposes that do not result in the legal relationship between you and the Data Controller, but that are extremely useful for us to provide you with a better service and to develop our legitimate business interests:

Marketing, advertising, promotion, commercial prospecting, reference processes, the development, evaluation and analysis of the users' profiles for the development and offering of new products and services, conducting surveys unrelated to our products or services, analytical and statistical purposes, all related to the services of the Data Controller, its affiliates, subsidiaries, allies and other third parties.
To provide you with information regarding promotions.
To be in contact by mail, email or telephone to share newsletters with you and to conduct surveys regarding the quality of the Services provided by the Data Controller.
Conduct satisfaction surveys: Use the data of the Data Subject to conduct satisfaction surveys in order to obtain feedback on the quality of products or services, and improve the experience of the Data Subject.
Inform and/or offer you products, services and promotions, either our own or from third parties.
Invite you to events organized by the Data Controller for its clients.
Reinforcement of our brands, being able to select and use comments that you post on social networks in relation to the Data Controller.
Allow you to participate in contests and/or raffle organized by us.
Have photographic or video evidence of the events carried out by the Data Controller.

WHO RECEIVES YOUR PERSONAL DATA

In compliance with the PD Legislation, we may disclose your Personal Data to third parties strictly for the purposes outlined in this Privacy Notice. We ensure that any disclosure is conducted in accordance with the principles of legality, consent, information, quality, purpose, loyalty, proportionality, and accountability as required by Mexican data protection laws.

We disclose your Personal Data to:

Persons authorized by us to process Personal Data (i.e., entities we contract to carry out various Personal Data processing operations on our behalf, acting as data processors). These third parties are required to comply with strict confidentiality obligations and security measures.
Third-party entities acting as data controllers, when required by law or when there is a valid legal basis for doing so. These entities process data for their own purposes, ensuring compliance with applicable legal requirements.

We may share Personal Data with third-party service providers and partners, who assist us under contractual agreements, including but not limited to:

Payment processors and financial institutions handling deposits and withdrawals.
IT service providers ensuring the security and functionality of our systems.
Customer support services.

We may disclose your Personal Data to Mexican regulatory authorities, judicial entities, and law enforcement agencies, as long as they have the legal authority to request such information. This may include:

The Servicio de Administración Tributaria (SAT) for tax reporting and compliance.
The Unidad de Inteligencia Financiera (UIF) for anti-money laundering (AML) investigations.
The Secretaría de Gobernación (SEGOB) in connection with gambling and gaming regulations.

TRANSFER OF YOUR PERSONAL DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANIZATION

For the compliance of the primary and secondary purposes stated in this Privacy Notice, your Personal Data may be transferred within the national territory or abroad, in accordance with the following:

To authorities, agencies or governmental entities, in compliance with or in relation to the obligations established in the applicable legislation to the Data Controller, its subsidiaries and/or affiliates, as well as in compliance with the requirements made to the same.
To authorities, agencies or governmental entities, when the transfer is officially required and/or necessary for the recognition, exercise or defense of a right of the Data Controller, its subsidiaries and/or affiliates in a court proceeding.
To third party acquirers, resulting from a corporate restructuring of the Data Controller, including, merger, consolidation, sale, liquidation or transfer of assets, when the transfer is necessary for the maintenance or fulfillment of a relationship between such Data Controller and the Data Subject.
To affiliated companies, treasury agents and their agents and vendors or subsidiaries of the Data Controller, inside or outside the national territory, that are part of the same group, that operate under our same processes and internal policies, in order to provide you with a better service and comply with our internal regulations.
When the transfer is needed by virtue of a contract executed or to be executed in the interest of the Data Subject, by the Data Controller and a third party;
When the transfer is required for the maintenance or performance of our contractual relationship with you.
According to the other assumptions established in the PD Legislation, which do not require your consent.

According to the PD Legislation, the aforementioned transfers do not require your consent.

Furthermore, the identification and contact Personal Data may be transferred to the following legal entities, in which cases we do require your consent:

To third parties that display and market services through our Websites/Apps, commercial allies and other strategic allies of the Data Controller, for marketing, advertising or commercial prospecting purposes.
Companies with commercial activities, with the purpose of commercial prospecting and sale of their own products or services or those of such companies.
Companies with promotional, marketing and advertising activities, with the purpose of conducting studies, market surveys, disseminate advertising and make known promotions in travel, destinations and tickets.
Companies with financial activities, with the purpose of offering you products and services of such companies or co-branded products and services.
Companies with tourism activities, with the purpose of promoting their hosting and broadcasting services in national and international destinations.

If the Data Subject does not express its refusal for us to carry out these transfers, or any of them, we will understand that consent has been granted. The refusal for the transfer of Personal Data can be made as of this moment by sending an e-mail to the personal data department of the Data Controller to the following e-mail address marketing@infinitumssolutions.com.

In any of the cases mentioned above, we will communicate this Privacy Notice to the third party recipients in order to ensure that your information is used in accordance with the terms of this Privacy Notice.

PROCESSING OF PERSONAL DATA OF CHILDREN

Our Services are restricted to users who are 18 years of age or older. We do not permit Customers under the age of 18 to have registered accounts on our Websites/Apps and we do not intent or knowingly collect personal information from anyone under the age of 18.

We will delete any Personal Data and implement any applicable measures, in accordance with our obligations as gambling providers, in case we find that persons under age of 18 have registered/used Websites/Apps in breach of our terms & conditions and the applicable laws.

USE OF COOKIES, WEB BEACONS AND OTHER SIMILAR TECHNOLOGIES

Cookies are small pieces of information that are sent by a website to your browser and stored on your computer's hard drive and are used to determine your preferences when you log on to the services of our Websites/Apps, as well as to trace certain behaviors or activities carried out by the Data Subject within our Websites/Apps.

In some sections of our Websites/Apps we require the Data Subject to enable cookies as some of the functionalities require cookies to function. Cookies allow us to: a) recognize the user when entering our Websites/Apps and offer a personalized experience, b) know the personal configuration of the site specified by the user, for example, cookies allow us to detect the bandwidth that the user has selected when entering the home page of our Websites/Apps so that we know what kind of information it is advisable to download, c) calculate the size of our audience and measure some traffic parameters, as each user who accesses our Websites/Apps acquires a cookie that is used to determine the frequency of use and the sections of the visited Websites/Apps, reflecting their habits and preferences, information that is useful for us to improve the content, headlines and promotions for users, not all functions of the v require the enablement of cookies.

Cookies also help us to track some activities, for example, in some of the surveys we launch online, we may use cookies to detect if the Data Subject has already filled out the survey and avoid displaying it again, in case it has been filled out. However, cookies will allow you to take advantage of the most beneficial features we offer, which is why we recommend that you keep them enabled. The use of cookies will not be used to identify users, with the exception of cases where possible fraudulent activities are being investigated.

In this regard, we inform you that the Website makes use of cookies and other technologies, through which it is possible to automatically monitor your behavior, provide our services and to offer you an optimal and personalized experience during the use of the same, as well as to offer you new services based on your preferences. The Personal Data collected through these technologies are: IP address, Websites/Apps and sections thereof that the Data Subject visits from the Websites/Apps, before the Websites/Apps or on pages related to the Websites/Apps, browser characteristics, device characteristics, operating system, language preferences, URLs referred to, information about behaviors and actions performed on the Site, dates and times of visits to the Websites/Apps, sections or content consulted on the Websites/Apps and location data and location of the User.

These technologies may be disabled by accessing the Privacy and/or Security option(s) located in the section(s) of Options, Tools, Internet Preferences or similar functions of the Internet browser you are using; however, when disabling them you should be aware that such action may result in you not being able to obtain the full functionality that the Site may offer you.

We inform you that the Data Controller does not collect Personal Data from our users and Customers through the use of cookies, web beacons and other similar technologies.

PERSONAL DATA DEPARTMENT

Our personal data department will be in charge of processing requests for the exercise of rights and to promote the protection of Personal Data, said department may be contacted at that address or by e-mail marketing@infinitumssolutions.com.

MEANS TO EXERCISE YOUR RIGHTS

In all legally admissible cases, the Data Subject may, at any time and through the procedure set forth in this section, exercise the following rights regarding its Personal Data: (i) rights of Access, Rectification, Cancellation and Opposition ("ARCO Rights"); (ii) revoke the consent given to each of the Data Controllers for the processing of your personal data; (iii) limit the use or disclosure of your Personal Data; and (iv) express your refusal for the processing of your Personal Data with respect to the secondary and accessory purposes or for certain transfers previously mentioned in this Privacy Notice.

ARCO RIGHTS

In order to exercise such rights regarding your Personal Data, the Data Subject or its duly accredited legal representative, must submit the corresponding request through an e-mail to the following address marketing@infinitumssolutions.com addressed to our Personal Data Department, who will inform you about the procedure and requirements for the exercise of such rights, response periods, the way in which we will make your right effective, and will attend to any doubt, complaint or comment you may have in this regard.

The request for the exercise of the ARCO Rights must include a clear and precise description of the right you wish to exercise and the Personal Data in respect of which you seek to exercise it. The request can be submitted in writing and must be signed at the end and initialed at the bottom of each page, and must be accompanied by the following documentation, so that its authentication can be completed:

Identification data, as well as a copy of a valid official ID (valid official ID with photograph).
In the event that the exercise of the ARCO Rights is carried out through its legal representative, the official identification of the representative shall be provided, as well as the corresponding power of attorney notarized before a notary public that certifies the legal representation conferred by the Data Subject.
Address to receive our response and, if necessary, future communications and/or notifications, or your request for our response and/or future notifications or replies to be sent by e-mail, indicating the respective account.
When exercising the right of rectification, the documentation evidencing the requested change must be submitted in accordance with the Personal Data to be rectified, as well as mentioning the modifications to be made.
Any other element or document that facilitates the location of your Personal Data.

We will respond to any of your requests within 20 (twenty) business days after receipt.

In the event that your request is accepted, the same will be effective within 15 (fifteen) business days following the date on which we communicate our response to you, in accordance with the provisions of the PD Legislation.

These periods can be extended only once for an equal period, if justified by the circumstances of the case, which we will inform you by means of a notification.

If the request for the ARCO Rights exercise is regarding the exercise of the right of access, we will make your information or Personal Data available to you through simple copies and/or electronic documents.

As the Data Controller, we may deny the exercise of ARCO Rights in the cases permitted by the PD Legislation, therefore, you must be informed of the reason for such denial. The refusal may be partial, in which case we will carry out the access, rectification, cancellation or opposition in the appropriate part.

The Data Controller undertakes to comply with all the provisions of the PD Legislation and to observe at all times the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility contained therein.

The Data Controller will take reasonable organizational and technical security measures to prevent the loss, misuse, alteration or unlawful disclosure of your information and Personal Data, which we require to be complied with by the service providers we hire, including in the case of services provided by subsidiaries or affiliates of the Data Controller.

The Data Controller wishes to keep your Personal Data updated at all times. Therefore, we request your cooperation to inform us in a timely manner of any change that we should take into account, in order to incorporate it into our databases. The Data Subject guarantees and responds, in any case, for the truthfulness, accuracy, validity and authenticity of its Personal Data or those of any third party under its custody or legal representation.

OPTIONS TO REVOKE OR RESTRICT THE PROCESSING OF YOUR PERSONAL DATA.

You, as the Data Subject, may revoke or limit your consent for the processing of your Personal Data following the same procedure as for the exercise of your ARCO Rights, in the understanding that once your request is available to us, we will issue our response within a period no longer than 5 (five) business days. Please be reminded that not in all cases your request will be admissible or we will be able to conclude the use immediately, since it is possible that due to some legal obligation we may need to continue processing your Personal Data.

AMENDMENTS TO THE PRIVACY NOTICE

This Privacy Notice may be modified, changed or updated due to the Data Controller's own needs, as a result of the products or services we offer; our privacy practices; changes in our business model, or for other reasons; as well as due to updates in the applicable legislation.

The updated version will be available to the public through any of the following means:

• On our Websites/Apps, which we suggest visiting frequently.

• We will be able to send it to the last e-mail address you provided us.

IMPROPER PROCESSING OF YOUR PERSONAL DATA.

If you consider that your right to the protection of your Personal Data has been violated by any conduct or omission on our part, or presume any violation of the provisions of the Federal Law for the Protection of Personal Data in Possession of Individuals, its Regulations and other applicable laws, you may file a complaint with the marketing@infinitumssolutions.com.

ACCEPTANCE

By making available the Privacy Notice and/or by providing us with your Personal Data and the lack of any opposition manifestation by the Data Subject, we understand that the Data Subject grants the Data Controller its consent to carry out the processing of the Personal Data that would have been provided and/or those that for any of the purposes set forth herein will be provided in the future.

It is important to highlight that when the purpose of the processing of your Personal Data is to provide you with our services and to comply with the obligations, we have with you, in terms of the PD Legislation, it is not necessary to obtain your consent for the processing of your Personal Data for such purposes.

Privacy Policy

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Privacy Notice last updated: 15 April 2025

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