Privacy Policy
Last updated: 1 October 2026
This Privacy Policy describes how Calpe Nexus Limited ("we", "us") processes personal data when you use Peer2Bet (peer2bet.com), our peer-to-peer football bet escrow platform. It applies alongside our Terms of Service.
1. Who we are (data controller)
Peer2Bet is operated by Calpe Nexus Limited, a company incorporated in Gibraltar. Registered office: [TODO for owner: registered office address]. Company registration number: [TODO for owner: Gibraltar company number]. Data controller contact: [email protected]. Data Protection Officer: [TODO for owner: confirm whether a DPO is appointed and give contact]. Until then, privacy enquiries go to the contact details below.
2. Data we collect
We collect the following categories of information, depending on how you use the service: • Account and profile — name, username, email address, password (stored hashed), preferred language, optional phone number, email verification status, terms acceptance timestamp, and referral relationship. • Wallet and transactions — wallet balances, deposit and withdrawal requests, escrow funding and settlement records, fees, payout addresses or ChangeNOW email details you provide, and cryptocurrency transaction references from our payment processor. • Identity / compliance — if we or an admin enables KYC verification on your account, we store verification status and related notes managed in our admin tools (we do not operate a full automated KYC vendor in the public app unless configured separately). • Registration and sign-in — when you create an account or log in (including with “remember me”), we record your IP address, browser user-agent string, and sign-in timestamp. We use this for security, fraud and multi-account prevention, and to help detect referral abuse. • Technical and usage — IP address, browser and device user-agent, pages visited, locale detection, session identifiers, activity and security logs (for example bet actions, login events, and errors), and visitor analytics records (path, referrer, approximate location/ISP from IP geolocation, bot/human flag). • Communications — messages you send to support and notification delivery metadata (email; optional WhatsApp/SMS if you provide a phone number and notifications are enabled). • Cookies and similar technologies — session cookies required to keep you logged in and, when configured, analytics cookies (see section 9).
3. How and why we use data (purposes and legal bases)
We use personal data to: • Provide escrow, wallet, betting, referral, and account features (performance of a contract / steps prior to contract). • Process crypto deposits and withdrawals through our payment partners (contract; legal obligation where applicable). • Prevent fraud, abuse, multi-accounting, and security incidents (legitimate interests; legal obligation). • Operate disputes, settlement review, and customer support (contract; legitimate interests). • Send service emails and optional instant messages about bets and wallet activity (contract; consent where required for marketing). • Monitor platform health, improve UX, and measure marketing effectiveness via analytics (legitimate interests; consent for non-essential cookies where required). • Comply with applicable law, respond to lawful requests, and enforce our Terms (legal obligation; legitimate interests). Where Gibraltar GDPR / UK GDPR-style rules apply, we rely on the bases above. You may withdraw consent for optional processing (such as non-essential analytics) without affecting core escrow services you still use.
4. Sharing and processors
We do not sell your personal data. We share data only as needed to run Peer2Bet, including with: • NOWPayments (and related payout networks such as ChangeNOW where enabled) — to process cryptocurrency deposits and withdrawals. • Hosting and infrastructure providers that store and serve the application and database. • Google Analytics 4 — when analytics is enabled, usage events may be sent to Google (see cookies section). • Email delivery providers used to send account and security messages. • WhatsApp or similar messaging gateways — only if you provide a phone number and we send optional notifications. • Internal admin tools — authorised staff access for support, dispute resolution, and compliance review. • Telegram or other alerting channels — operational alerts to administrators may include minimal technical metadata (not used for marketing to users). Processors act on our instructions under appropriate agreements. We may also disclose data if required by law or to protect rights, safety, and integrity of the service.
5. International transfers
Our servers and providers may process data outside Gibraltar, including in the European Economic Area, United Kingdom, United States, or other countries where our hosting or payment partners operate. Where required, we implement appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) for cross-border transfers.
6. Retention
We keep personal data only as long as needed for the purposes above: for example, account and escrow records while your account is active and for a reasonable period afterward for disputes, tax, anti-money-laundering, and legal compliance. [TODO for owner: specify retention schedule for wallet/KYC/financial records]. Visitor logs and analytics may be retained for shorter operational periods unless a longer period is required for security investigations.
7. Security
We use administrative, technical, and organisational measures appropriate to an online financial escrow service (access controls, encryption in transit, hashed passwords, audit logging, and monitoring). No method of transmission or storage is completely secure; please use a strong unique password and protect your email and wallet payout details.
8. Your rights
Depending on applicable law (including Gibraltar GDPR), you may have the right to: • Access a copy of your personal data. • Rectify inaccurate data. • Erase data in certain circumstances. • Restrict or object to processing in certain circumstances. • Data portability for data you provided, where applicable. • Withdraw consent where processing is consent-based. • Lodge a complaint with the Gibraltar Regulatory Authority (GRA), which acts as Gibraltar's data protection authority. To exercise rights, contact [email protected] with enough information to verify your account. We respond within applicable time limits.
9. Cookies and analytics
Essential cookies and session storage keep you signed in and maintain security (for example Laravel session cookies). When enabled, we load Google Analytics 4 to understand aggregate usage (page views and configured conversion events such as registration or deposit funnels). You can block non-essential cookies in your browser; core escrow functions may still require essential cookies.
10. Children
Peer2Bet is for adults aged 18+ (or higher local legal age). We do not knowingly collect data from children. If you believe a minor has registered, contact us to request deletion.
11. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated date. Continued use after changes means you accept the updated policy where permitted by law.
12. Contact
Questions or privacy requests: email [email protected] or visit our Contact page.
Calpe Nexus Limited · Gibraltar · [email protected]