Privacy Policy of 191bet – LGPD and Your Rights

The controller of personal data collected by the platform 191bet is the operating company behind the site 191bet.click. As the data controller, 191bet is responsible for defining the purposes and means by which your personal data is processed, ensuring that all processing takes place in accordance with the LGPD and the principles of good faith, transparency, necessity, and proportionality.

When you create an account at 191bet, make a deposit via Pix or any other available Brazilian payment method, or simply browse the site with active cookies, you are interacting with systems managed by 191bet that collect and process data as described in this policy.

This policy applies to all data collected through the 191bet.click website and the official mobile app of 191bet for Android and iOS. This does not apply to third-party websites or apps that may be mentioned in our content — each third-party service has its own privacy policy, for which 191bet is not responsible.

The 191bet collects only the data necessary to provide the platform's services and comply with legal obligations. We collect data at three main points: during registration, while you use the platform, and through automated technologies (such as cookies).

We do not collect sensitive data categories such as racial or ethnic origin, religious belief, political opinion, health or sexual life data, except where strictly required to fulfill responsible gambling legal obligations — and always on an appropriate legal basis under the LGPD.

The 191bet uses your personal data exclusively for legitimate, specific, and disclosed purposes. Below are all the purposes for which we process your data:

• Creating and managing your account: keep your registration up to date, enable secure login, and manage account preferences;
• Transaction processing: process deposits via Pix, boleto bancário, credit and debit card, PicPay, Mercado Pago, and withdrawals to Brazilian bank accounts;
• Provision of gaming services: provide slots, live casino, crash games, poker, blackjack, jackpots, and all other games in the catalog;
• Identity verification (KYC): confirm that you are 18 years of age or older and that the registration details you provided are accurate, as required by law;
• Fraud and money laundering prevention: monitor suspicious transactions and fulfill financial compliance obligations;
• Responsible gambling: monitor behavioral patterns that may indicate problem gambling and activate protection tools;
• Account-related communications: send transaction confirmations, security alerts, and bonus and promotion notifications;
• Platform improvement: analyze usage data to improve the user experience, fix bugs, and develop new features;
• Compliance with legal obligations: respond to requests from competent Brazilian authorities when required by law.

The 191bet does not use your personal data to sell third-party advertising or to build behavioral profiles for commercial purposes unrelated to the platform's services.

The LGPD requires that all personal data processing have a specific legal basis. The 191bet uses the following legal bases, as set out in Art. 7 of the LGPD:

• Contract performance (Art. 7, V): to process transactions, keep your account active, and deliver the games and services you signed up for;
• Fulfillment of legal obligation (Art. 7, II): for identity verification (KYC), anti-money laundering compliance, and fulfillment of requests from competent authorities;
• Legitimate interest (Art. 7, IX): for fraud prevention, platform security, service improvement, and communications about existing features — always in a proportionate manner and in full respect of your rights;
• Consent (Art. 7, I): for marketing communications, sending promotions by email or SMS, and for non-essential analytics and personalization cookies. You may withdraw your consent at any time.

For special category data — such as health-related data in the context of responsible gaming — the additional legal basis is the protection of the data subject's life and health, pursuant to Art. 11 of the LGPD.

The 191bet does not sell, rent, exchange, or share users' personal data with third parties for those third parties' own commercial purposes. Data sharing occurs only in the situations below, limited strictly to what is necessary:

• Payment processors: when making a deposit via Pix, boleto bancário, credit or debit card, PicPay, or Mercado Pago, your transaction data is shared with the relevant payment processor solely to complete the payment. These partners have their own privacy policies and confidentiality obligations;
• Brazilian banks: for withdrawals via TED or Pix to accounts at Nubank, Itaú, Bradesco, Banco do Brasil, and others, the required banking details are transmitted securely to the national financial system;
• IT service providers: hosting, security, and infrastructure companies that support platform operations, always under contract with confidentiality and data protection clauses;
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, and other partners receive minimal technical data (such as a session identifier) required for the games to function — not full identification data;
• Brazilian public authorities: when required by court order or a substantiated request from a competent authority with jurisdiction in Brazil.

All partners acting as data processors for 191bet are contractually bound to process data solely in accordance with the instructions of 191bet and in compliance with the LGPD. The 191bet does not transfer personal data internationally to countries that do not offer a level of protection adequate or equivalent to the LGPD, except where the guarantees provided under Brazilian law are in place.

The 191bet uses cookies and similar technologies (such as tracking pixels and local storage) to ensure the platform functions correctly, improve the user experience, and — with your consent — personalize content and analyze site performance.

Essential cookies cannot be disabled because they are required for the platform's basic functionality — without them, login and transactions will not work. For analytics and functional cookies, you can manage your preferences through the cookie banner shown on your first visit or by accessing the cookie settings in the site footer.

You can also manage cookies directly in your browser settings. Most modern browsers — Google Chrome on Android, Safari on iPhone, Firefox — let you view, block, or delete cookies from any site. Blocking essential cookies, however, will prevent 191bet.

The 191bet retains personal data only for as long as necessary to fulfill the purposes for which it was collected or to meet legal retention obligations. The general timeframes are:

• Active account data: retained for as long as the account remains active on the platform;
• Financial transaction data: retained for a minimum of 5 years after the transaction, as required by Brazilian anti-money laundering legislation and tax obligations;
• Identity verification data (KYC): retained for a minimum of 5 years after account closure;
• Betting history: retained for 5 years for audit and dispute resolution purposes;
• Responsible gambling data: self-exclusion records and limits are retained for the duration of the exclusion period plus 5 years to prevent re-registration during an active exclusion;
• Marketing data (with consent): retained until consent is withdrawn by the data subject.

Once the retention period ends, data is irreversibly anonymized or securely deleted from our systems. Anonymized data may be kept for statistical purposes, as it no longer allows individual identification.

If you request account deletion, data removal follows the retention periods outlined above — data required for legal compliance cannot be deleted before the minimum retention period, even at the account holder's request.

The 191bet implements appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, unauthorized disclosure, or destruction. Key measures in place include:

• Encryption in transit: all communication between your device and the servers of 191bet is protected by TLS/SSL — the padlock icon you see in your browser's address bar;
• Encryption at rest: stored sensitive data, such as financial information and KYC documents, are encrypted on our servers;
• Access control: only employees of 191bet with a verified need to access the data may do so, and every access is recorded in an audit log;
• Two-factor authentication: available to all users as an additional layer of protection for account access;
• Security monitoring: intrusion detection systems monitor the platform 24 hours a day for suspicious activity;
• Periodic testing: we conduct regular penetration testing and security audits to identify and address vulnerabilities before they can be exploited.

In the event of a security incident that may affect your personal data, 191bet will notify the National Data Protection Authority (ANPD) and the affected data subjects within the timeframes and through the means established by the LGPD. Notification will occur as soon as possible after the incident is confirmed.

The LGPD grants you, as a data subject, a set of rights that may be exercised at any time with 191bet. See each right and how to exercise it below:

To exercise any of these rights, contact the DPO at 191bet by emailing contato@191bet.click with the subject line "LGPD – [Right Name]". We respond within 15 business days with confirmation and next steps for your request.

The services of 191bet are intended exclusively for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. Registration requires confirmation of legal age, and identity verification (KYC) validates this through an official document.

If 191bet identify that an account was created by a minor, that account will be closed immediately, the data will be deleted in accordance with legal retention periods, and any deposited funds will be returned. Protecting minors is an absolute priority for this platform.

Parents, mothers, and guardians who believe a minor has improperly accessed the platform of 191bet should contact us immediately at contato@191bet.click so we can act without delay. Parental control tools are also available on major mobile operating systems and can be used to block access to the site on shared devices.

The 191bet may update this Privacy Policy periodically to reflect changes in Brazilian law, industry practices, or platform features that affect how data is handled.

When changes are deemed significant to the rights of data subjects, 191bet will notify registered users at least 7 days in advance via their registered email and through a notification on the platform's login screen. For minor changes, such as text corrections or contact updates, the updated version will be published directly on this page.

The date of the last update is always shown at the top of this page. We recommend checking back periodically. The current version of this policy is available at 191bet.click/privacy-policy.

Continued use of the platform after notification of material changes constitutes acceptance of the updated policy. If you do not agree with the changes, you may close your account through support before they take effect.

To exercise your rights as a data subject, ask questions about this policy, or report any concerns regarding the processing of your personal data by 191bet, please reach out through the following channels:

• DPO (Data Protection Officer): contato@191bet.click — subject line "LGPD – [Your Request]" — response within 15 business days;
• General customer support: live chat on the platform, available 24 hours a day, 7 days a week, in Brazilian Portuguese;
• WhatsApp: available via the platform's live chat for urgent matters;
• National Data Protection Authority (ANPD): if your complaint is not resolved to your satisfaction by 191bet, you have the right to file a petition directly with the ANPD, Brazil's data protection regulatory authority.

When contacting us about LGPD rights, please include in your email: your full name, registered CPF, a clear description of your request, and any supporting documents if applicable. This speeds up the process and ensures your request is handled as a priority.