Recruitment Privacy Policy

1. Scope and Overview

1.1. This Privacy Policy explains how SPINTERA LIMITED S.R.L., a company incorporated and existing under the laws of the Republic of Costa Rica, corporate number 3-102-924150-2, with its registered office at Avenues 8 and 10, Street 39, Second Office on the Right, LY Center, San Pedro, Los Yoses, Montes de Oca, San Jose, Costa Rica ("Company", "we", "us"), collects, uses, stores, transfers, and protects personal data submitted through this career website betscareers.io (the "Site").

1.2. This Policy applies exclusively to the processing of personal data submitted by job applicants, prospective contractors, consultants, service providers, affiliate partners, and other individuals or legal representatives who use the Site to express interest in professional or commercial cooperation ("you", "your", "Candidates"). The Policy does not apply to:

• a) users of any gaming services operated by the Company or its affiliates;
• b) individuals interacting with operational or customer-facing websites of the gaming brand;
• c) any activities subject to licensing requirements within the iGaming sector.

This separation is intentional and reflects the standalone nature of this Site as a recruitment and business-engagement portal.

1.3. By accessing the Site or submitting data through application forms, CV uploads, partnership submissions, or communication tools integrated into the Site, you acknowledge that your data will be processed in accordance with this Policy. If you do not agree with this Policy, you should not use the Site.

1.4. For the purposes of applicable data protection legislation, SPINTERA LIMITED S.R.L. acts as the Data Controller, determining the purposes and means of processing personal data collected through the Site.

1.5. To operate the Site and manage application workflows, we may engage reputable third-party recruitment, HR, or partner-management platforms as Data Processors. These processors act strictly on our instructions, under written agreements, and only for the purposes described in this Policy. The list of processors may be updated from time to time and is available upon request.

1.6. The Company is established outside the European Economic Area. Nevertheless, when processing data of individuals located in the EEA, the UK, or other jurisdictions with specific privacy regulations, we follow internationally recognised data protection principles, including GDPR-aligned requirements regarding transparency, lawfulness, security, and rights of individuals.

1.7. This Policy forms part of the legal framework governing your use of the Site. It does not constitute an offer of employment, partnership, contract, or engagement. Submission of personal data does not create any obligation on the Company to proceed with any recruitment or cooperation process.

2. Categories of Personal Data We Collect

2.1. We collect only the information that is relevant for evaluating your suitability for employment, contractual cooperation, or partnership. The categories of personal data processed through the Site include:

A. Data Provided Directly by Candidates

2.2. Information voluntarily submitted by you when completing application forms, uploading documents, or communicating with us, including:

• a) identification and contact details (full name, email address, telephone number, country of residence);
• b) CVs, resumes, cover letters, portfolios, certificates, or other materials you choose to upload;
• c) information regarding your professional background, education, skills, and qualifications;
• d) details regarding your preferences, availability, remuneration expectations, and employment or cooperation interests;
• e) answers provided in application questionnaires, screening questions, or technical assessments;
• f) communication records exchanged with our recruitment or partnership teams.

B. Data Related to B2B

2.3. If you use the Site to express interest in a commercial, affiliate, consultancy, or service-provider relationship, we may collect:

• a) business identification details (company name, registration information, website, business email);
• b) representative details (name, position, contact information);
• c) information about the proposed services, affiliate traffic, market experience, and relevant documentation voluntarily submitted;
• d) compliance-related information where necessary to conduct preliminary due diligence.

C. Automatically Collected Technical Data

2.4. When you access the Site, we may collect limited technical information required for security, fraud prevention, and optimisation:

• a) IP address and browser type;
• b) device information and basic system parameters;
• c) time zone and general location inferred from technical data;
• d) log data related to page access, form submission, and session integrity.

This information is not used to profile Candidates and is processed solely for safeguarding the Site and maintaining operational functionality.

D. Sensitive or Special Category Data

2.5. We do not request or require special category data (such as health information, ethnicity, political views, or biometric data) unless it is strictly necessary for a specific recruitment process and permitted by applicable law. If such information is required, we will obtain your explicit consent before processing it.

E. Data Obtained from Third Parties

2.6. Where permitted by law and relevant to the position or cooperation requested, we may receive additional information from:

• a) professional networking platforms (e.g., LinkedIn) if you choose to apply through them;
• b) recruiters, referrers, or agencies acting on your instruction;
• c) service providers conducting assessments or background checks, only after you are informed and, where required, consent is obtained.

F. Voluntary Disclosure

2.7. Any information provided beyond the categories above is considered voluntary. We advise Candidates not to include unnecessary or excessive personal data in uploaded documents or messages.

3. Purposes and Legal Bases of Processing

3.1. We process personal data submitted through the Site solely for clearly defined and legitimate purposes connected to recruitment, contractor engagement, affiliate assessment, or other professional cooperation. We do not use data submitted via this Site for any gaming-related, marketing, or customer-facing activities of the Company.

A. Recruitment and Engagement Purposes

3.2. We process your personal data to:

• a) evaluate your suitability for the position, role, engagement, or cooperation you applied for;
• b) review and assess qualifications, skills, experience, and background;
• c) communicate with you about the recruitment or cooperation process, including invitations, interviews, assessments, or updates;
• d) maintain application records and internal notes relevant to the evaluation process;
• e) consider you for alternative roles or future opportunities, where permitted by law or based on your preferences;
• f) verify the accuracy of information you provide, and, where applicable, conduct screening steps consistent with the position applied for.

B. B2B, Affiliate, Consultant, or Service-Provider Evaluation

3.3. When you submit information for potential commercial cooperation, we process data to:

• a) review your business profile or proposal;
• b) assess the compatibility of your services, affiliate traffic, or partnership model with the Company's requirements;
• c) perform preliminary compliance checks, due diligence, or risk assessments where applicable;
• d) communicate with you regarding partnership evaluation or next steps.

C. Site Operation, Security, and Administration

3.4. We process certain technical or log data to:

• a) ensure proper functioning of the Site;
• b) maintain cybersecurity, prevent fraud, and safeguard system integrity;
• c) diagnose technical issues and improve user experience;
• d) monitor access and ensure adherence to security standards.

4. Data Sharing and International Transfers

4.1. We do not sell, lease, or commercially disclose your personal data. Data submitted through the Site is shared only when necessary for the purposes described in this Policy and only with parties that are subject to appropriate confidentiality and data protection obligations.

A. Sharing with Internal Teams

4.2. Your personal data may be accessed by authorised personnel within SPINTERA LIMITED S.R.L., including individuals responsible for recruitment, human resources, compliance, risk assessment, business development, and partner evaluation. Access is granted strictly on a need-to-know basis and subject to internal confidentiality requirements.

B. Sharing with Data Processors

4.3. For the operation of the Site and the processing of submissions, we may engage third-party service providers acting as Data Processors, including:

• a) recruitment and applicant-tracking systems;
• b) HR workflow platforms;
• c) affiliate and partner-management systems;
• d) communication or scheduling tools;
• e) cloud hosting providers and IT infrastructure partners.

4.4. Data Processors act exclusively under our documented instructions, in accordance with written data processing agreements that include confidentiality, security, sub-processing controls, and restrictions on data use.

C. Sharing with Third Parties Involved in Evaluation

4.5. Where relevant for recruitment or partnership evaluation, we may share limited information with:

• a) external assessors, technical testing providers, or interview panels;
• b) consultants assisting in specialised evaluation;
• c) background-check or verification service providers, only where legally permitted and where you have been informed in advance;
• d) professional advisors (e.g., legal or compliance consultants) in connection with assessment or risk review.

4.6. Any such sharing is limited to what is necessary for the specific evaluation and is carried out under duties of confidentiality.

D. Sharing Required by Law

4.7. We may disclose personal data if required by:

• a) applicable laws;
• b) lawful requests from competent authorities;
• c) court orders or legal proceedings;
• d) regulatory obligations applicable to the Company or to any recruitment, compliance, or partnership process.

4.8. If disclosure is required, we will restrict the information shared to what is strictly necessary to meet the specific legal obligation.

International Transfers

4.9. As SPINTERA LIMITED S.R.L. is incorporated and operating from Costa Rica, personal data may be transferred to and stored in jurisdictions outside your country of residence, including countries that may not offer the same level of data protection as your local regulations.

4.10. When data of Candidates located in the EEA, the UK, or other jurisdictions with transfer restrictions is transferred internationally, we implement recognised safeguards, which may include:

• a) Standard Contractual Clauses (SCCs);
• b) UK International Data Transfer Addendum;
• c) contractual protections ensuring equivalent data protection standards;
• d) organisational and technical measures appropriate to the nature of the data and risks involved.

4.11. Where Data Processors or partner-evaluation providers are located outside your jurisdiction, transfers are conducted in accordance with the safeguards noted above.

4.12. If you submit information from a location outside Costa Rica, you explicitly acknowledge that your data will be transferred to Costa Rica and other jurisdictions where our processors or cooperation-evaluation tools are located.

5. Data Security

5.1. We apply technical and organisational measures to protect personal data submitted through the Site from unauthorised access, alteration, loss, or misuse. Access to data is restricted to personnel who require it for recruitment or cooperation evaluation.

5.2. Our controls include role-based access, secure transmission of data, internal handling procedures, and limited retention periods. Third-party platforms engaged as Data Processors are required to maintain security standards appropriate to the nature of the data they process.

5.3. While we take reasonable steps to safeguard your information, no online system is entirely risk-free. You should avoid including unnecessary sensitive information in documents you upload.

5.4. In the event of a security incident involving personal data, we will take measures required by applicable law, including investigation, mitigation, and notification where legally necessary.

6. Retention of Personal Data

6.1. We retain personal data only for as long as necessary to complete the recruitment or cooperation-evaluation process and to meet internal record-keeping requirements.

6.2. Candidate profiles, CVs, and related application materials are generally retained for up to 24 months from the date of the last activity on your account or submission, unless a shorter or longer period is required by applicable law or justified by legitimate interests (such as resolving a dispute or documenting the outcome of an application).

6.3. Data related to B2B, affiliate, or service-provider submissions may be retained for a similar period, taking into account compliance and due-diligence requirements.

6.4. After the retention period expires, personal data is deleted or anonymised in a manner that prevents further identification.

6.5. You may request deletion of your data at any time in accordance with this Agreement. Such requests will be honoured unless retention is required by law or necessary to protect the Company's legitimate interests.

7. Your Rights

7.1. Depending on your jurisdiction, you may have certain rights regarding the personal data processed through the Site. These rights typically include:

• a) Access - to obtain confirmation whether we process your data and to receive a copy.
• b) Rectification - to correct inaccurate or incomplete information.
• c) Erasure - to request deletion of your data when there is no valid reason for continued processing.
• d) Restriction - to limit how your data is used in certain circumstances.
• e) Objection - to object to processing based on legitimate interests.
• f) Portability - to receive data in a structured, commonly used format when processing is based on consent or pre-contractual steps.
• g) Withdrawal of consent - where processing relies on your consent.
• h) Complaint - to lodge a complaint with a relevant supervisory authority, if applicable.

7.2. To exercise any of these rights, you may contact us. We may need to verify your identity before responding.

7.3. We aim to respond to requests within the timelines required by applicable law. Certain rights may not apply in all jurisdictions, and requests may be declined where permitted by law or when necessary to protect legitimate interests or comply with legal obligations.

8. Cookies and Tracking Technologies

8.1. The Site may use essential cookies and similar technologies necessary for its proper functioning, including session management, security, and form submission integrity.

8.2. We may also use basic analytics tools to understand aggregated usage trends, improve performance, and maintain system stability. These tools do not identify Candidates individually and are not used to profile or evaluate applicants.

8.3. You can manage or disable non-essential cookies through your browser settings. Disabling certain cookies may affect the operation of some Site features.

8.4. The Site does not use tracking technologies for marketing, behavioural advertising, or gambling-related purposes.

9. Optional Communications and Alerts

9.1. When submitting your application or cooperation request, you may choose to receive optional updates regarding new vacancies, project opportunities, or partnership openings relevant to your profile.

9.2. Such communications are sent only if you opt in. You can withdraw your preference at any time by using the unsubscribe option or by contacting us.

9.3. We do not send promotional, gambling-related, or advertising content through the Site. Communications are limited strictly to recruitment or cooperation matters.

9.4. If you choose not to receive optional alerts, this does not affect your ability to apply for roles or submit cooperation requests.

10. Disclaimer and Separation From Gaming Activities

10.1. This Site is a dedicated recruitment and cooperation portal. It is entirely separate from any gaming, wagering, or entertainment services that may be operated under brands associated with SPINTERA LIMITED S.R.L. or its affiliates.

10.2. Personal data submitted through this Site is used exclusively for recruitment, evaluation of contractors, service providers, affiliates, or business partners, and for internal administrative purposes. It is not used for customer onboarding, gaming account creation, AML/KYC processes, responsible gaming checks, or any operational activity relating to gaming services.

10.3. Submitting information through this Site does not:

• a) create any employment or contractual relationship;
• b) constitute an offer or guarantee of employment, partnership, or cooperation;
• c) grant access to any gaming products or systems of the Company;
• d) serve as an indication that your profile meets requirements for regulated activities within the iGaming sector.

10.4. The Company's operational gaming platforms, where applicable, maintain their own legal terms, privacy policies, AML/KYC obligations, and compliance frameworks, which do not apply to this Site.

10.5. Nothing in this Policy should be interpreted as establishing obligations under gambling legislation, licensing conditions, or regulatory frameworks. This Site operates solely as an informational and professional communication tool.

11. Applicable Law

11.1. This Privacy Policy is governed by the laws of Costa Rica, without prejudice to mandatory data protection rules that may apply to individuals located in other jurisdictions.

11.2. In case of conflict between this Policy and mandatory provisions of applicable data protection law, such mandatory provisions shall prevail.

12. Last Updated

12.1. This Privacy Policy was last updated on: 01 day of November 2025.