Privacy Policy

1. About Us

1.1  KTO.COM is operated by Bravalla B.V., with registration number 147847 and registered address: Korporaalweg 10, Curaçao. KTO is authorized and regulated by the Government of Curaçao. Throughout this Privacy Notice, whenever we mention “KTO.COM”, “KTO“, “we”, “our” and “us”, we are referring to Bravalla B.V., the data controller and the responsible for this platform.

2. Scope

2.1  Your privacy is important to us, and we are committed to protecting your personal data. The purpose of this Privacy Notice is to explain how KTO.COM uses the personal information collected when you access and/or use our services. We will clarify the purposes for collecting your personal data, clarify the data processing activities conducted by us, and explain how you can exercise your rights.

2.2 ACCEPTANCE AND AGREEMENT WITH THIS PRIVACY NOTICE ARE NECESSARY FOR YOU TO ACCESS AND UTILIZE OUR SERVICES. If you do not agree to any of the conditions and/or statements outlined in this Privacy Notice, we kindly request that you refrain from registering an account with us or cease accessing and using our platform and services.

2.3 Please be aware that we cannot guarantee the protection of any information you provide to third-party platforms linked to our services by you, the controllers of these platforms may collect your information in accordance with their respective privacy policies, which may differ from ours.

3. Data Collection

3.1 The information and personal data we collect and process include: 

  • Identification data (such as full name, national identification number, identification documents, and biometric data).
  • Contact information (such as full name, email address, home address, proof of address, mobile number, telephone number).
  • Demographic data (such as date of birth, nationality, gender, location).
  • Financial information (such as proof of income, source of wealth, payment information, transaction history).
  • Browsing data (such as IP address, cookies, device data, browser data, website usage preferences and interactivity).
  • Gambling activities (such as betting and gaming history).

3.2 We collect personal data and information from users who access our platform and/or utilize our services. Data collection is essential for the provision of our services, and occurs in various stages, including but not limited to the initial account creation process, during financial transactions, when engaging in sports betting and/or casino activities, as well as when utilizing any other services made available on our platform.

3.3 Additionally, certain personal information and data may be collected if you choose to provide information voluntarily while browsing our website, disclose information in public areas of our platform, and/or provide data when contacting our Customer Support.

3.4 We are committed to making our platform as user-friendly as possible, aiming to facilitate access and usage, and we are continually working to enhance the user experience. To achieve this goal, we collect information and data about your interaction with our platform. This is an essential action to ensure the provision and quality of our services.

3.5 The collection of information and data takes place during the use of our platform, and our servers maintain records of activities, including but not limited to the originating IP address, access time, date of access, visited web pages, selected language, software error reports, and the type of browser used.

3.6 Please be aware that biometric data identification technology refers to utilizing unique physical or behavioural characteristics for individual identification and authentication. Through a service provider that is the controller of this process, we employ facial recognition whenever deemed necessary to meet and implement preventive controls. The procedure includes requesting a photograph from you holding your identification document, which will be submitted to a pattern recognition algorithm that analyses trait samples obtained from various sensors.

3.7 KTO employs Biometric technology to gather facial trait information for identity verification, user authentication, impersonation deterrence and crime prevention. KTO utilizes the services of a Provider, Cyber Assessment Framework (CAF), to facilitate these functions. CAF’s facial recognition technology analyses photos you submit to gather biometric data, such as measurements of your facial geometry (e.g., the distance between eyes, the height of the forehead, frontal breadth, biogonia breadth, width of nose, upper face height etc.). Subsequently, the technology compares this biometric data with that of a distinct reference photo you provide, ensuring identity verification and preventing unauthorized access to your account. We strongly encourage you to review CAF’s Privacy Policy.

3.8 With the aim of ensuring the security of our customers, preventing any fraudulent activity, as well as promoting responsible gaming practices and complying with legal or regulatory obligations, we may conduct a security review at any time to validate the personal data and information provided by and from you.  We also may verify your use of our services and our platform to prevent and/or identify violations of our Terms and Conditions and our Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Countering the Financing of Proliferation of Weapons of Mass Destruction (FPWMD)  measures. Security reviews may include but are not limited to requesting proof of address, proof of income, source of wealth, credit reports, and/or verifying the information provided by you against third-party databases.

3.9 We are legally obligated to conduct these activities to deliver our services in a lawful, responsible, and compliant manner, adhering to the required legal standards and regulations. Our ability to provide our services depends on these actions. If you would rather your information not be used in this manner, your alternative is to abstain from using our services and/or to deactivate your account on the platform.

3.10 The collection and processing of information is essential to our business and aligns with the purposes and legal bases outlined as follows:

To provide our services
– Identification Data

– Contact Information

– Demographic Data

– Financial Information

– Gambling Activities
– Contract Execution

– Compliance with a legal or regulatory obligation
To provide customer support– Identification Data

– Contact Information
– Consent

– Contract Execution

– Legitimate Interest 
To prevent fraud– Identification Data

– Contact Information

– Demographic Data

– Financial Information

– Browsing Data
– Compliance with a legal or regulatory obligation

– Ensuring fraud prevention and the security of the data subject
To analyse and monitor activities on our platform– Browsing Data

– Gambling Activities

– Legitimate interest

– Ensuring fraud prevention and the security of the data subject
To protect the rights and guarantee the safety of our company, our customers, and/or third parties
– Identification Data

– Contact Information

– Financial Information 

– Browsing Data

– Gambling Activities
– Contract execution

– Exercise of rights 

– Legitimate interest 
For marketing purposes
– Contact information

– Demographic data
– Consent

– Legitimate interest

3.11 In accordance with our policies and legal obligations, minors are prohibited to create an account with us, and we do not process any minors’ data. However, if, by any chance, we receive data from minors through our Customer Support channels as a result of a breach of our Terms and Conditions, we will proceed with the deletion of such data.

3.12 Please be aware that to use our platform, create an account, make financial transactions, participate in sports betting and casino games, contact our Customer Support, and/or utilize our services in any other way, we need to collect your information and, in some cases, share it with third parties. For more details on how we share your data and for what purposes, please consult the “Information Sharing” section of this Privacy Notice. If you do not agree with how your information is used, we recommend refraining from using our platform.

4.  Data Transfer

4.1 KTO implements preventive controls for data transfer, including specific contractual clauses and codes of conduct, as the information and personal data collected within our services may be stored and processed in any country where we, our affiliates, suppliers, providers, and agents maintain facilities. By utilizing our services, you explicitly provide your consent for the transfer of information outside of your residing country.

4.2 The international transfer of personal data will occur to countries or international organizations that provide adequate personal data protection. In the event that transfers to non-adequate jurisdictions are necessary, we will take reasonable steps to ensure that the information is treated with the same level of security.

4.3 Please be aware that the National Authority has yet to publish the regulation regarding international data transfers, including the list of jurisdictions deemed to have an adequate level of data protection, specifying the required level of protection, and identifying the countries and international organizations considered suitable to receive personal data from Brazil.

5.  Information Sharing

5.1  We may share information and data, including personal data, with third parties in order to be able to provide our services. This sharing occurs when needed and involves the following third parties and/or serves the purposes described below:

  • With payment providers for processing financial transactions in order to execute our services in accordance with our terms and conditions.
  • With sportsbook providers to conduct sports betting services.
  • With casino providers for the undertaking of our services.
  • With helpdesk software to assist in customer support and issue resolution in order to execute our services in accordance with our terms and conditions.
  • With anti-fraud software to help detect and prevent fraudulent activities and protect our users.
  • With data analysis software for analytical purposes, in line with our legitimate interests for the execution of our services.
  • With cloud services for data storage and management, in line with our legitimate interests for the execution of our services.
  • With competent authorities for compliance with legal or regulatory obligations.
  • With competent authorities or entities if we identify an attempt at cheating, fraud, or any form of game or payment manipulation, whether by you or other users of the service.
  • To protect and exercise the rights, property, or safety of our company, our users, or third parties.
  • With your consent for specific data-sharing instances.

5.2  Please be aware that as you engage with our platform by making financial transactions, placing bets, and participating in casino activities, the privacy policies and terms and conditions of the respective providers of these products and services may apply to you.

5.3  We may also share information for research purposes, specifically related to our Responsible Gaming policy. We may also share information related to betting activities in line with our anti-corruption policies, with the intention of combating betting-related corruption and safeguarding the integrity of sports and our business operations. In these situations, the data shared will be anonymized.

5.4  We collect and share analytical information through services provided by Google, such as Google Analytics and Google Tag Manager. Google Analytics is a web analysis service that uses the collected data to track and analyse the usage of our platform, to generate reports on its activities, and to share these reports with other Google services. Google may also utilize the collected data to tailor and personalize advertisements within its advertising network.

5.5  We also share information with partners for the purpose of analysing and monitoring engagement, as well as identifying your preferences. This includes, among other methods, the utilization of behavioural metrics, heatmaps, and session data. These efforts aim to enhance our services, facilitate site optimization, address fraud and security concerns, and support advertising initiatives.

5.6  We will ensure that third parties with whom we share such information are committed to maintaining the confidentiality and security of the shared data, and wherever possible and feasible, we will implement pseudonymization measures to protect the privacy of your personal data before sharing it.

6.  Cookies

6.1  Cookies are text files containing a small amount of information that are downloaded to your device when you visit a website. This information might be about you, your preferences or your device and is mostly used to improve your online experience and to ensure that relevant content and functions are delivered and used more effectively. Your browser makes cookies available each time you visit our websites.

6.2  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

6.3  We utilize cookies and traffic analysis to enhance the performance and ensure the efficiency of our platform while continually improving our services. Please be aware that by accessing and utilizing our platform and services, you explicitly accept and agree to our Cookie Policy. For details on how we use cookies, please consult our Cookie Policy

6.4  You have the option to accept or reject cookies at any time through various methods, including managing your preferences in the “Cookie Settings” menu, adjusting your browser settings, and/or clearing existing cookies. For instructions on updating your browser settings, please refer to the official website of the respective browser developer. To enhance your comprehension regarding this topic, including guidance on reviewing set cookies, we suggest viewing the information available on or

6.5  Please be aware that if you adjust your cookies settings via your web browser then, unless you delete or block each cookie individually, the changes will apply to all websites that you visit – not just our websites. You will also need to adjust your cookies on a browser-by-browser basis.

6.6  Please also note that deleting our cookies or disabling our future cookies means that you may not be able to access certain areas or features of our platform. For example, if your browser is set to disable session cookies, you won’t be able to log on to your account.

7.  Security Measures 

7.1  At KTO.COM, we are committed to safeguarding your personal information and ensuring the utmost privacy and security of your data. This section of our Privacy Notice outlines the measures we take to protect your personal information when it is shared with us.

7.2  We employ state-of-the-art end-to-end encryption protocols to ensure that any data you transmit to us is securely protected during its transfer. This means that your information is scrambled into an unreadable format before leaving your device and can only be unscrambled by us upon arrival. This encryption method helps to prevent unauthorized access, interception, or eavesdropping during data transmission.

7.3  Your personal information is stored in password-protected databases with stringent access controls. Only authorized personnel who require access for legitimate business purposes are granted permission to access this data. We regularly review and update our security measures to stay ahead of emerging threats and maintain the confidentiality and integrity of your information.

7.4  We take the privacy and security of your personal information seriously. Therefore, we ensure that our subsidiaries, agents, affiliates, and suppliers also employ similar robust security measures to protect your data when they are entrusted with it. We have established contractual obligations and data protection standards that all such entities must adhere to, as stipulated in our agreements with them. This is done to maintain consistency in the protection of your personal information, regardless of where or how it is processed within our ecosystem.

7.5  While we do our utmost to protect your personal information, it’s important to remember that no method of data transmission or storage can guarantee 100% security. If you ever have concerns about the security of your personal information, please don’t hesitate to contact us using the contact information provided in this Privacy Notice.

7.6  By using our services, you acknowledge and consent to the security measures described in this Privacy Notice. We are committed to continuously improving and adapting our security measures to meet evolving threats and industry best practices, all in the interest of safeguarding your personal information.

8.  Data Subjects Rights

8.1  As a data subject, you possess certain rights that safeguard and protect your privacy. Your personal data protection rights include:

  • Right to confirm the existence of processing of your personal data.
  • Right to access your personal data.
  • Right to rectify incomplete, inaccurate, or outdated data.
  • Right to anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data.
  • Right to data portability.
  • Right to the deletion of personal data processed with consent.
  • Right to information about data sharing.
  • Right to information about the possibility of not providing consent and the consequences of refusal.
  • Right to withdraw consent.
  • Right to submit a petition regarding the processing of your personal data to the National Authority.
  • Right to object to the processing carried out.
  • Right to review automated decision-making.

8.2  To confirm the existence of the processing of your personal data, please access the “My Account” menu on our platform or contact our Customer Support team at the email address: [email protected].

8.3  To rectify your personal information, please access the “My Account” menu on our platform. If you wish to rectify information that is not possible to update through the mentioned menu, please contact our Customer Support team via email at [email protected].

8.4  To access the personal information we hold about you, please contact our Customer Support via the email address: [email protected].

8.5  You have the right to discontinue using our platform at any time. You can exercise this right by deactivating your account utilizing the self-exclusion tools or by making a request to our Customer Support team. However, we may retain your information for as long as is reasonably necessary to meet any potential obligations and requirements. For more details on the retention period, please consult the “Data Retention” section of this Privacy Notice.

8.6  You have the right to object to the processing activities carried out for our legitimate interests. However, since the activities involved are central to supporting and promoting our business, if you wish to object beyond managing Cookies and Marketing preferences, it may be necessary for you to discontinue using our platform and services and/or close your account with us.

8.7  If you provide us with your consent, we will send you offers and promotions via email, SMS, or online channels. You have the right to withdraw your consent or update your marketing preferences at any time. To exercise your rights, please access the “Settings” option in the “My Account” menu or contact our Customer Support. By choosing not to provide your consent for receiving offers and promotions, you will cease to receive communications of such nature. Consequently, this decision may result in your ineligibility to participate in and/or access exclusive promotions and offers.

8.8  If you wish to file a complaint, provide feedback, seek clarification, ensure your data protection rights, and/or express any concerns regarding this Notice, our procedures, and/or any other matter relating to personal data processing activities conducted by us, please contact our Data Protection Officer (DPO) at the following email address: [email protected]

8.9  You can exercise your rights free of charge and in an easy way. We are committed to promptly addressing your requests within the stipulated timeframes. When necessary, to ensure the security of our customers’ information, we may request proof of identity to process your request. Please be aware that the timeline for addressing your requests will commence only after your identity has been verified.

8.10  Please be aware that the National Authority has not yet issued regulations regarding the right to portability of personal data to another service or product provider.

9.  Data Retention

9.1  The personal data and information collected and processed by us are stored and retained for the necessary period to fulfil the purposes outlined in this Privacy Notice.

9.2  The minimum data retention period is five years as stipulated by legal provisions. However, we may be obligated to retain information for a longer period considering regulations regarding Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Countering the Financing of Proliferation of Weapons of Mass Destruction (FPWMD) measures, along with Gambling regulations and any other legal obligations that may be deemed necessary, and/or to comply with orders from competent authorities. Once the mentioned period has passed or when your personal information is no longer required, we will proceed with the data deletion process.

10.  Changes

10.1  We reserve the right to update, amend, or undertake any other action to this Privacy Notice whenever necessary to align with legal trends and/or ensure compliance with regulations. We strongly encourage you to regularly review this Privacy Notice to stay informed.

10.2  Any changes made become effective upon update of this Privacy Notice. The current version and the last update date can be verified at the end of this page.

Effective from 26/01/24