Privacy Policy

This Privacy Policy explains how Halcyon Super Holdings B.V., operating the Cloud Bet version of the cloyd.bet website, collects, uses, discloses and protects your personal data when you visit our website, open an account, place bets or otherwise interact with our services. It applies to players, account holders, website visitors and other users who access cloyd.bet from the United Kingdom or other locations. It is designed to comply with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and other applicable data protection laws. Effective date: 6 November 2025.

Observe: This section clarifies who this policy applies to and from when.

Expand: By using cloyd.bet you acknowledge that your data will be processed in accordance with this Privacy Policy and the Terms & Conditions available on our website.

Reflect: If you do not agree with this Privacy Policy, you should not use the Cloud Bet services provided via cloyd.bet.

Who We Are

Observe: You need to know who is legally responsible for your personal data and how to contact us.

cloyd.bet is owned and operated for the Cloud Bet site by Halcyon Super Holdings B.V., a company incorporated under the laws of Curaçao.

Legal entity: Halcyon Super Holdings B.V.
Registered office / legal address: Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curaçao
Company registration: Registered in the commercial register of Curaçao under number 151622 (Halcyon Super Holdings B.V.)
Gaming licence: Licensed and regulated by Curaçao eGaming under Master Licence 1668/JAZ for the operation of online gambling services under the Cloud Bet brand
Official website: https://cloyd.bet

Data Protection Contact / DPO: We have appointed a person responsible for data protection matters (Data Protection Officer or equivalent).

Email: support@cloyd.bet (please include "Privacy" in the subject line)
Postal contact for privacy matters: Data Protection Officer, Halcyon Super Holdings B.V., Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curaçao
Online contact: 24/7 live chat available on the cloyd.bet website

Expand: For users in the United Kingdom, Halcyon Super Holdings B.V. acts as the "controller" of your personal data for the purposes of the UK GDPR. Where required, we may also appoint a local representative to facilitate communications with the UK Information Commissioner's Office ("ICO").

Reflect: You can contact our data protection contact or DPO at any time with questions about this Privacy Policy, our processing of your data or to exercise your privacy rights.

What Personal Data We Collect

Observe: We collect different categories of data when you visit cloyd.bet, interact with the Cloud Bet services or communicate with us.

Identification and Contact Data

Basic details: Full name, username, date of birth, gender, preferred language and country of residence.
Contact details: Email address (for example, the address you use to contact us via support@cloyd.bet), telephone number (if provided), postal address and any other contact channels you choose to share.
KYC / verification data: Copies of identity documents (passport, ID card, driving licence), proof of address, selfies or video verification, and other information we require to comply with age verification, Know Your Customer ("KYC") and anti-money laundering ("AML") obligations.

Account, Gaming and Behavioural Data

Account information: Account ID, registration date, account status, preferences, communication settings and security settings.
Gaming and betting history: Details of your deposits, wagers, wins and losses, bonuses and promotions used, game sessions, betting markets and timestamps.
Responsible gambling data: Self-exclusion information, deposit or loss limits, cooling-off periods, account closure requests and information relating to potential problem gambling behaviour where identified.
Interaction data: Records of your interactions with our customer support (email, live chat logs), clicks and navigation paths on the site, and responses to surveys or feedback forms.

Technical and Device Data

Technical identifiers: IP address, device identifiers, browser type and version, operating system, time zone setting and language preferences.
Usage and log data: Login and logout times, pages viewed, referral URLs, clickstream data, error logs and performance data related to your use of cloyd.bet.
Location data: Approximate location derived from your IP address or other technologies to help us comply with territorial restrictions and fraud prevention.

Payment and Financial Data

Payment details: Limited payment instrument information (for example, truncated card numbers, wallet identifiers, account references) processed via our payment service providers.
Transaction data: Deposits, withdrawals, refunds and chargeback information, along with related dates, amounts, currencies and payment method types (including crypto-asset transactions where applicable).
AML and risk data: Information created or obtained as part of AML screening, sanctions checks, source of funds/wealth assessments and fraud investigations.

Cookies and Similar Technologies

Cookies: Small text files stored on your device, including session cookies, persistent cookies and third-party cookies for analytics and advertising.
Similar technologies: Pixel tags, web beacons, SDKs and local storage used to remember your preferences, maintain sessions and measure performance.

Special Categories of Data: As a rule, we do not intentionally collect sensitive data (such as health data) except where it is directly relevant to responsible gambling measures or legal obligations (for example, information you voluntarily share about gambling-related harm). We treat such data with enhanced safeguards.

Expand: We obtain most data directly from you, but may also receive data from third parties such as payment providers, identity verification services, analytics providers and anti-fraud partners.

Reflect: All categories of personal data are processed only to the extent necessary for the purposes described in this Privacy Policy and in line with applicable law.

Legal Basis for Processing

Observe: Under the UK GDPR and similar laws, we must have a valid legal basis to process your personal data.

Performance of a Contract

Account creation and management: We process your identification, contact, account and technical data to register your account, authenticate you and provide access to the Cloud Bet services on cloyd.bet.
Provision of gambling services: Processing of gaming history, transaction data, bonuses and rewards is necessary to operate bets, games, payouts and promotions in accordance with our Terms & Conditions.
Customer support: We use your data to respond to your questions, handle complaints, resolve technical issues and provide other support services.

Compliance with Legal Obligations

KYC and AML: We are legally required under Curaçao regulations and widely accepted AML standards to verify your identity, age, location and source of funds, and to monitor transactions for suspicious activity.
Accounting and reporting: Transaction and financial data may be processed to comply with tax, accounting, regulatory and record-keeping obligations.
Legal claims: We may process data to establish, exercise or defend legal claims, cooperate with lawful requests from competent authorities or comply with court orders.

Legitimate Interests

Service improvement and analytics: We process usage and analytics data to maintain, optimise and enhance the performance, security and usability of cloyd.bet.
Fraud and abuse prevention: We use behavioural, technical and transactional data to detect and prevent fraud, abuse, bonus misuse, security incidents or breaches of our Terms & Conditions.
Business management: We use aggregate and pseudonymised data for internal reporting, risk management, planning and business continuity.

Where we rely on legitimate interests, we carefully balance our interests against your fundamental rights and freedoms and implement safeguards to minimise impact on your privacy.

Consent

Marketing communications: We send email, SMS or in-app marketing messages only where you have given your consent or where permitted by law, and you can withdraw this consent at any time.
Non-essential cookies: We place analytics and advertising cookies only with your consent through our cookie banner or settings, as required by applicable electronic communications laws.
Optional data: If you provide information beyond what is strictly necessary (for example, survey responses or feedback), we process it based on your consent or our legitimate interests, as appropriate.

Vital Interests and Other Bases

In very rare cases, we may process your data to protect your vital interests or those of another person (for example, if we reasonably believe there is a serious and imminent risk of harm related to gambling behaviour and applicable law requires or permits us to act).

Expand: For users in the UK, the main legal bases are performance of a contract, legal obligation, legitimate interests and consent under the UK GDPR and Data Protection Act 2018. For users in jurisdictions where Mexican privacy law applies, we also take into account compatible legal bases under the Federal Law on Protection of Personal Data Held by Private Parties.

Reflect: For each processing activity, we assess and document the appropriate legal basis and review it periodically to remain compliant with evolving regulation.

Purpose of Processing

Observe: We process personal data only for specific, explicit and legitimate purposes.

Provision and Operation of Casino Services

Account registration and access: To create and manage your Cloud Bet account on cloyd.bet, verify your identity, authenticate logins and ensure that only you can access your account.
Game and betting operations: To enable deposits, wagers, gameplay, settlements, payouts, bonuses, loyalty programmes and other core gaming functionalities.
Customer support and communication: To respond to your questions, provide assistance, send service-related notifications and inform you of important changes to our services or policies.

Compliance, Security and Risk Management

KYC/AML and regulatory compliance: To conduct identity checks, age verification, sanctions screening and transaction monitoring in line with AML and counter-terrorist financing requirements.
Fraud and integrity: To detect, investigate and prevent fraud, money laundering, collusion, bonus abuse, chargebacks, account takeovers and other prohibited activities.
Security and technical integrity: To secure our networks, systems and services, protect accounts, manage incidents and maintain business continuity.

Service Improvement, Analytics and Personalisation

Usage analytics: To understand how users interact with cloyd.bet, identify usability issues, and improve site performance and stability.
Product development: To develop new features, games and promotions based on aggregated and anonymised usage and performance data.
Personalisation: To customise content, recommendations and promotions within legally acceptable boundaries and, where required, based on your consent.

Marketing and Promotions

Direct marketing: To send you promotional emails or messages about offers, bonuses and products, subject to your consent or other lawful basis.
Advertising and attribution: To measure the effectiveness of our marketing campaigns and affiliates, using cookies and similar technologies where permitted by law.

Expand: We do not sell your personal data to third parties. Marketing partners may receive limited pseudonymised identifiers for campaign measurement and attribution as further described in the "Disclosure & Sharing" and "Cookies & Tracking Technologies" sections.

Reflect: We do not use your data for purposes incompatible with those described above, and we will inform you and, where necessary, seek consent if we intend to repurpose your data.

Disclosure & Sharing

Observe: In some situations we share your personal data with trusted third parties, always under appropriate safeguards.

Service Providers and Technical Partners

Infrastructure and hosting: Providers that supply data centres, cloud hosting and networking services to operate cloyd.bet securely and reliably.
Payment processors: Banks, payment institutions, crypto payment gateways and other financial intermediaries that process deposits, withdrawals and refunds.
Identity and fraud prevention services: Providers of KYC checks, document verification, sanctions screening, device fingerprinting and anti-fraud solutions.
Analytics and performance tools: Third-party tools used to monitor site performance, usage patterns and error diagnostics, typically on an aggregated or pseudonymised basis.

Regulators, Authorities and Dispute Bodies

Gaming regulator: Curaçao eGaming, in the course of supervision or investigations relating to our licence 1668/JAZ.
Law enforcement and authorities: Police, tax authorities, financial intelligence units and other competent bodies where required by law or justified to protect our rights or the rights of others.
Dispute resolution bodies: Where applicable, third parties that assist in resolving disputes, complaints or chargebacks. Note that we are not licensed by the UK Gambling Commission and do not use UK-approved ADR providers.

Group Companies and Business Partners

Affiliates and marketing partners: We may share limited information (such as anonymised identifiers and conversion data) to measure campaign performance where you arrived via a partner link, subject to cookie consent requirements.
Corporate transactions: In the context of mergers, acquisitions, restructuring or asset transfers, your data may be disclosed to prospective or actual buyers and their advisors, subject to confidentiality obligations.

Legal Protection and Enforcement

Protection of rights: We may share data where reasonably necessary to protect our business, enforce our Terms & Conditions, prevent fraud or respond to legal claims.

Expand: All third-party recipients are required to process personal data only on our instructions, under written contracts that impose confidentiality and data protection obligations in line with applicable law.

Reflect: We do not share your personal data with third parties for their own independent marketing purposes without your explicit consent.

International Transfers

Observe: As a Curaçao-based operator serving users in various jurisdictions, we may transfer your data internationally.

Your personal data may be transferred to and processed in:

Curaçao: Where Halcyon Super Holdings B.V. is established and where many core systems and staff are located.
European Economic Area (EEA) and United Kingdom: Where some of our technical, payment or support providers are based.
Other countries: Including, for example, the United States or other non-EEA jurisdictions where certain cloud, analytics, fraud-prevention or communication providers operate.

Safeguards for International Transfers

Standard Contractual Clauses: For transfers from the UK or EEA to countries not recognised as providing an adequate level of protection, we implement the European Commission's standard contractual clauses, together with the UK International Data Transfer Addendum or the UK International Data Transfer Agreement as applicable.
Technical and organisational measures: We apply encryption, access controls and security standards that aim to protect your data irrespective of the country where it is processed.
Data minimisation: Where possible, we transfer only pseudonymised or aggregated data.

We do not rely on the former EU-US Privacy Shield framework as a transfer mechanism, as it has been invalidated. Where relevant, we may use any updated or replacement mechanisms recognised by EU and UK authorities.

Expand: Details of specific transfer mechanisms and copies of relevant safeguards can be requested by contacting our DPO at support@cloyd.bet, subject to redaction for confidentiality.

Reflect: We regularly review our cross-border data transfer arrangements to ensure ongoing compliance with UK GDPR requirements and evolving regulatory guidance.

Data Retention

Observe: We retain personal data only for as long as necessary for the purposes described in this Privacy Policy and to comply with legal obligations.

General Retention Principles

Active account period: While your Cloud Bet account on cloyd.bet is active, we retain your data to operate the services and maintain accurate records.
Post-closure period: After account closure, we generally retain core account, transaction and KYC records for up to five (5) years, unless a longer period is required or permitted by law (for example, AML or tax laws may require retention for up to ten (10) years).
Marketing data: We retain marketing consent and communication history for as long as you remain subscribed and for a limited period thereafter (normally up to two (2) years) to evidence compliance and manage opt-outs.
Cookies: Cookie data is retained according to the type of cookie (see the "Cookies & Tracking Technologies" section), typically from the end of a session up to 24 months, unless you delete cookies earlier.

Deletion and Anonymisation

Deletion criteria: Data is securely deleted or anonymised when it is no longer needed for its original purpose, legal obligations, dispute resolution or security and fraud-prevention requirements.
Anonymisation: We may retain anonymised or aggregated data (which no longer identifies you) for statistical, analytical or business planning purposes.

Expand: Where you exercise your right to erasure, we will assess whether we can delete the data or whether we must retain certain elements to comply with legal obligations or legitimate interests (for example, to keep a record of self-exclusion or AML investigations).

Reflect: We maintain and periodically review a data retention policy to ensure that retention periods remain proportionate and compliant with applicable law.

Your Rights

Observe: Depending on your location and applicable law (including UK GDPR and, where relevant, Mexican privacy law), you have a number of rights concerning your personal data.

Rights Under UK GDPR and Similar Laws

Right of access: To obtain confirmation as to whether we process your data and to receive a copy of the personal data we hold about you, together with related information.
Right to rectification: To request correction of inaccurate or incomplete personal data (for example, updating your contact details).
Right to erasure: To request deletion of your personal data in certain circumstances, such as where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies.
Right to restriction: To request that we limit the processing of your data in specific situations (for example, while we verify its accuracy or assess an objection).
Right to object: To object at any time to processing based on our legitimate interests, including profiling, and to object to direct marketing (including related profiling).
Right to data portability: To receive certain personal data in a structured, commonly used and machine-readable format and to transmit it to another controller where technically feasible.
Right not to be subject to solely automated decisions: To request human intervention in decisions that are based solely on automated processing and that produce legal or similarly significant effects (for example, certain risk or fraud assessments), where required by law.
Right to withdraw consent: Where processing is based on your consent (for example, marketing or non-essential cookies), you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

Alignment With Mexican Privacy Law (ARCO Rights)

Where the Federal Law on Protection of Personal Data Held by Private Parties (Mexico) applies, you may also exercise ARCO rights:

Access: To know which of your personal data we hold, how we obtained it and how we use it.
Rectification: To request correction of inaccurate or incomplete data.
Cancellation: To request that we stop processing and delete your data where appropriate.
Opposition: To oppose certain processing activities in legitimate situations.

We aim to implement these ARCO rights in a manner compatible with our UK GDPR obligations, to the extent applicable to our operations.

How to Exercise Your Rights

Submit a request: Contact us via email at support@cloyd.bet (subject: "Privacy Rights Request") or via live chat, clearly indicating which rights you wish to exercise and providing sufficient information to verify your identity.
Verification: We may request additional information or documentation to confirm your identity and protect your account and privacy.
Response timeframe: We will respond without undue delay and in any event within one (1) month of receiving a valid request. This period may be extended by up to two (2) further months where necessary due to complexity or number of requests, in which case we will inform you of the extension and reasons.
Fees: Requests are handled free of charge, unless they are manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act.

Expand: In some cases we may be unable to fully comply with your request (for example, where we must retain certain data for AML or legal reasons). We will explain the reasons where we rely on such exemptions.

Reflect: You also have the right to lodge a complaint with a data protection authority (see "Complaints & Contacts") if you believe your rights have been infringed.

Cookies & Tracking Technologies

Observe: cloyd.bet uses cookies and similar technologies to operate the Cloud Bet site, analyse usage and deliver personalised content, in accordance with applicable laws.

Types of Cookies We Use

Essential (session) cookies: Required for the site to function, e.g., to keep you logged in, manage sessions, process bets and maintain security. These are typically deleted when you close your browser.
Functional (persistent) cookies: Used to remember preferences such as language, region or display settings. These remain on your device for a defined period or until you delete them.
Analytics cookies: First- or third-party cookies that help us understand how visitors use cloyd.bet (for example, which pages are most popular, error rates, loading times) so we can improve performance and usability.
Advertising and affiliate cookies: Cookies or similar technologies set by us or by third parties to measure the effectiveness of marketing campaigns, track referrals from affiliate websites and deliver relevant promotions. These are used only in accordance with applicable consent requirements.

Managing Cookies

Cookie banner and settings: When you first visit cloyd.bet, you may be presented with a cookie banner that allows you to accept or manage non-essential cookies. You can update your preferences at any time through our cookie settings panel (where available).
Browser settings: Most browsers allow you to block or delete cookies through their settings. However, blocking essential cookies may impact core site functionality and your ability to use Cloud Bet services.
Third-party opt-outs: Some analytics and advertising providers offer their own opt-out mechanisms. Details may be provided in our cookie policy or via their websites.

Expand: For more detailed information about specific cookies and lifetimes, please refer to any dedicated cookie policy on cloyd.bet or contact us at support@cloyd.bet.

Reflect: We periodically review our use of cookies and tracking technologies to ensure ongoing compliance with UK and other applicable electronic communications and privacy regulations.

Data Security

Observe: We take the security of your personal data seriously and implement technical and organisational measures to protect it.

Technical Security Measures

Encryption in transit: Data transmitted between your browser and cloyd.bet is protected using up-to-date transport layer security (TLS 1.2 or higher), helping to prevent unauthorised interception and tampering.
Encryption at rest: Where appropriate, personal and financial data is stored in encrypted form or protected by equivalent safeguards within secure environments.
Access controls: Access to personal data is restricted to authorised personnel who require it for their role, using role-based access controls, unique user IDs and authentication measures.
Multi-factor authentication: Administrative and sensitive systems are protected by multi-factor authentication where feasible to reduce the risk of unauthorised access.

Organisational and Procedural Measures

Security policies: We maintain internal policies and procedures covering data protection, information security, incident response and acceptable use.
Staff training: Employees and contractors with access to personal data receive training on data protection, confidentiality and security best practices.
Vendor management: Third-party service providers are assessed for security and data protection practices and are bound by contractual obligations to protect your data.
Audits and testing: We periodically review and test our systems, including through vulnerability assessments and other checks, to identify and address security weaknesses.

Incident Response

Detection and containment: We monitor systems for suspicious activity and have procedures to contain and investigate potential incidents.
Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify relevant supervisory authorities and affected individuals in accordance with legal requirements.

We design our security programme by reference to internationally recognised standards such as ISO 27001 and SOC 2. This reference does not imply that we hold formal certifications unless explicitly stated on cloyd.bet.

Expand: No system can be guaranteed to be 100% secure, but we continually improve our safeguards in line with technological developments and industry practices.

Reflect: You also play an important role in security by keeping your password secret, using strong and unique credentials and promptly informing us of any suspected unauthorised access to your account.

Complaints & Contacts

Observe: You are entitled to raise questions or complaints about how we handle your personal data.

Contacting Us First

Initial contact: If you have questions, concerns or complaints about this Privacy Policy or our data practices, please contact our data protection contact/DPO:
- Email: support@cloyd.bet (subject: "Privacy Complaint")
- Postal: Data Protection Officer, Halcyon Super Holdings B.V., Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curaçao
- Live chat: 24/7 via the cloyd.bet website
Our handling of complaints: We will acknowledge your complaint where appropriate and aim to investigate and respond within one (1) month. For complex cases, this may be extended by up to two (2) additional months, in which case we will inform you.

Escalation to Supervisory Authorities

United Kingdom (UK GDPR): If you are located in the UK and are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: https://www.ico.org.uk
- Telephone (UK): +44 303 123 1113
- Postal: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Mexico (where applicable): If Mexican data protection law applies to you, you may contact the Mexican data protection authority (INAI - Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales):
- Website: https://www.inai.org.mx
Other EEA jurisdictions (where applicable): If EU/EEA data protection law applies to you, you may also lodge a complaint with your local data protection authority in the EU/EEA.

Please note that while Curaçao eGaming provides player protection and dispute resolution mechanisms for gambling-related issues (https://curacao-egaming.com/player-protection-and-dispute-resolution), it is not a data protection authority. Data protection complaints should be directed to the authorities mentioned above.

Expand: Using these complaint channels does not affect any other rights or remedies you may have under applicable law.

Reflect: We encourage you to contact us directly first so we can attempt to resolve your concern efficiently.

Updates

Observe: We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements or data processing practices.

How We Notify You of Changes

Website publication: The most current version of this Privacy Policy will always be available on https://cloyd.bet/en/privacy-policy/, with a "Last updated" date at the top or bottom of the page.
Email notifications: For material changes that significantly affect your rights or how we process your data, we will, where appropriate, notify you by email using the address registered to your Cloud Bet account.
On-site notices: We may display banners, pop-ups or dashboard alerts on cloyd.bet to draw your attention to important updates.

Timing and Your Choices

Advance notice: Where changes are material and not required immediately by law, we will provide at least 30 days' advance notice before the updated policy takes effect.
Your continued use: Continued use of cloyd.bet after the effective date of an updated Privacy Policy will constitute acceptance of the changes.
Right to object or close account: If you do not agree with an update, you may object where permitted by law or close your account. We will then cease processing your data except as necessary to comply with legal obligations and legitimate interests such as record-keeping and dispute resolution.

Expand: We maintain internal version control and records of material changes (for example, significant updates to legal bases, new processing purposes or new categories of recipients) to demonstrate compliance.

Reflect: Last updated: 6 November 2025. We recommend that you review this Privacy Policy periodically to stay informed about how we protect your personal data when you use the Cloud Bet services on cloyd.bet.