Terms of Service
Last Updated: June 19th, 2025
Introduction
This document is an agreement between GambleID LLC (“GambleID,” “we,” “us,” or “our”) and you (“End User”), an individual whose personal data or transaction information is submitted to GambleID by a third-party business (“Operator”) for the purpose of compliance, identity verification, location validation, sanctions screening, payment authentication, or related services.
By continuing the use of the Operator’s platform, you acknowledge and agree to the terms, conditions, and policies outlined in this document.
This Terms of Service governs the relationship between GambleID and you as the End User, and establishes the rights, responsibilities, data practices, and dispute resolution procedures that apply to GambleID’s processing of your information.
1. Service Overview
GambleID provides services to the Operator that you are engaging with; these services may include some or all of the following:
- Identity Verification: Validating your name, address, date of birth, identification document(s), and/or biometric data.
- Location Validation: Determining your real-time location using device, network, and behavioral signals to comply with state or regional laws.
- Device Analysis: Evaluating the integrity of your device, browser, or network for fraud detection.
- Watchlist Screening: Checking your information against government-issued sanctions and restricted party lists (e.g., OFAC).
- Payment Method Authentication: Confirming whether payment information submitted is valid, authorized, and consistent with your identity.
2. Consent to Use and Processing of Information
By proceeding with your transaction or activity on the Operator’s platform, you authorize GambleID to collect, process, and store your personal information, including but not limited to:
- Personal identifiers (name, email, phone, date of birth, etc)
- Government-issued IDs or biometric data (if applicable)
- Device, browser, IP address, geolocation, and network data
- Transaction details associated with your activity
- Any other information submitted by the Operator
We will use this data solely to deliver our services, comply with legal obligations, detect fraud, and improve system performance. We do not use your personal information to market to you directly.
3. Data Use, Ownership, and Sharing
When personal data is provided via submission or otherwise legally obtained by GambleID, GambleID may process, store, license, sell, and utilize that data under the terms described in this Agreement.
A. Operator Data: Roles and Ownership
To the extent the Operator provides GambleID with PII (personal identity information) data of a customer of the Operator in connection with the services of GambleID, the Operator is deemed the data controller, and GambleID is deemed the data processor under applicable data protection laws, where such roles are required.
However, all parties acknowledge and agree that:
- The data provided may be used lawfully by both the Operator and GambleID and is considered jointly owned by both parties.
- GambleID may independently analyze, enrich, retain, and repurpose such data for lawful business purposes, including but not limited to:
- Performing and improving its core services
- Enhancing identity, fraud, and compliance models
- Supporting analytics, benchmarking, and product development
- Aggregating and/or anonymizing data for internal or external use
- Fulfilling legal, regulatory, or audit obligations
GambleID applies appropriate safeguards to protect the security of this data and operates under the assumption and agreement with the Operator that all necessary consents and / or authorizations have been secured for legally providing the data to GambleID.
B. Data Generated or Enhanced: by GambleID
The party further acknowledges that all data generated, derived, or enhanced by GambleID through its platform - including technical metadata, transaction risk scores, device signals, usage logs, behavioral patterns, and other data that currently exist or may exist in the future - is the exclusive property of GambleID.
Such data may be used for any lawful commercial, analytical, operational, or regulatory purpose, including:
- Service performance optimization
- Development of fraud detection and compliance tools
- Regulatory reporting or benchmarking
- Creating anonymized and non-anonymized datasets for industry use
C. All Data: Sharing and Licensing
You further acknowledge and agree that, in accordance with applicable federal and state laws and regulations, any data housed, stored, or processed within the GambleID platform may be used by GambleID for its own purposes and at its sole discretion, under both commercial and non-commercial terms. GambleID may also aggregate or anonymize data derived from the Operator’s use of the Services. Such data, whether anonymized, identifiable, or personal, may be shared with, licensed, or sold to trusted third parties, including but not limited to:
- Financial institutions (such as banks, lenders, underwriters, insurance carriers, and hedge funds)
- Marketing and advertising agencies
- Data analytics and artificial intelligence (AI) firms
- Regulatory technology providers
- Commercial enterprises and research organizations
These third parties may use such data for lawful business purposes, including, but not limited to: trend analysis, underwriting decisions, fraud detection, risk modeling, audience segmentation, product improvement or enhancement, product development, regulatory research, AI training, direct or indirect marketing, and other analytical or operational objectives. Such data shall be non-exclusive and may be shared or licensed to multiple parties at GambleID’s discretion. GambleID will use reasonable efforts to ensure the security and integrity of data used during AI training, but please be aware that no system is perfect and there are inherent risks in using AI technology. Operators can opt-out of having data used for this purpose at any time by contacting us or updating your privacy settings.
GambleID will only provide anonymized or aggregated data, void of any individual PII to the following trusted third parties under restrictive agreements on access and duration of usage of data: Hedge Funds, Artificial Intelligence Labs, and competitors of Operators.
D. Precedence and Legal Obligations
Nothing in this section prevents GambleID from meeting its obligations as a licensed data services provider or from complying with applicable U.S. or international regulations. If any term here conflicts with a jurisdiction-specific Data Protection Addendum (DPA), the DPA shall control where applicable.
4. Data Retention and Security
Your data is protected using industry-standard encryption, access controls, and monitoring. GambleID retains personal data only as long as necessary to fulfill its services or meet legal requirements, after which it is securely deleted or anonymized.
5. International Data Transfers and Jurisdiction-Specific Privacy Compliance
GambleID is a U.S.-based service provider that may process and transfer your personal data across borders, including to jurisdictions that may not have data protection laws equivalent to those in your home country. When doing so, GambleID implements appropriate legal safeguards to protect your data in accordance with international privacy standards.
A. European Economic Area (EEA), United Kingdom (UK), and Switzerland
If you are located in the EEA, UK, or Switzerland, your personal data may be transferred to the United States or other countries that have not received an adequacy decision from your jurisdiction. In such cases, GambleID will ensure that appropriate safeguards are in place, including the use of:
- The Standard Contractual Clauses (SCCs) adopted by the European Commission (for EEA residents)
- The UK International Data Transfer Addendum (for UK residents)
- The Swiss Addendum to the SCCs (for residents of Switzerland)
By using GambleID’s services, you acknowledge and consent to these transfers. Copies of the applicable contractual safeguards are available upon request.
B. Canada (PIPEDA)
If you are a Canadian resident and your personal information is subject to the Personal Information Protection and Electronic Documents Act (PIPEDA):
- GambleID commits to providing a level of protection for your personal data comparable to that required under Canadian privacy law.
- GambleID will only process your personal information for lawful purposes related to identity verification, compliance, and fraud prevention.
- If you request access to or correction of your personal data, GambleID will assist in processing that request in coordination with the Operator, if applicable.
- In the event of a data breach involving your personal information, you will be notified in accordance with PIPEDA requirements.
c. Brazil (LGPD)
If you are a resident of Brazil and your data is subject to the Lei Geral de Proteção de Dados (LGPD):
- GambleID will act as the data operator (operador) and will process your personal data based on instructions from the data controller (typically the Operator).
- Your personal data will be processed only for lawful, specific, and explicit purposes and protected using technical and administrative measures to prevent unauthorized access, loss, or misuse.
- If your data is transferred outside Brazil, GambleID will comply with applicable legal requirements under Articles 33–36 of the LGPD, including contractual safeguards or consent, where necessary.
D. United States – California (CPRA)
If you are a California resident and your personal information is subject to the California Privacy Rights Act (CPRA):
GambleID will:
- act as a “Service Provider” as defined under CPRA and will process your personal information only on behalf of the Operator, in accordance with its instructions.
GambleID will not if directed to by you:
- sell or share your personal information;
- retain, use, or disclose your personal information for purposes unrelated to the services provided;
- combine your personal information with data from other clients, except for detecting security incidents or fraud, or conducting analytics related to system performance.
GambleID will comply with all applicable service provider obligations under Cal. Civ. Code § 1798.140(v) and its implementing regulations.
6. Your Rights.
Depending on your jurisdiction, you may have rights under applicable privacy laws (e.g., GDPR, CPRA, LGPD, PIPEDA), including:
- The right to request access to or correction of your data
- The right to request deletion or restrict processing
- The right to object to certain types of processing
- The right to file a complaint with a supervisory authority
To exercise your rights, contact the Operator directly. GambleID acts as a service provider and cannot modify or delete records submitted by the Operator without their instruction.
7. Disclaimers
GambleID does not make decisions about your account approval, payment processing, or eligibility. Those decisions are made solely by the Operator.
We are not responsible for errors caused by inaccurate or outdated information provided by you or the Operator.
GambleID does not guarantee uninterrupted availability or performance of its verification systems.
8. Jurisdiction and Governing Law
These Terms shall be governed by the laws of the State of Texas, USA, without regard to conflict of law principles. Any dispute related to GambleID’s handling of your personal information shall be resolved in the courts located in Houston, Texas, unless prohibited by applicable law.
9. Updates To These Terms
We may update these Terms from time to time. When we do, we will revise the “Effective Date” above. Any changes will apply to future processing activities and will not affect prior actions unless required by law.\
10. Contact
If you have questions about how your data is used, contact the Operator who requested the service. For security reasons, GambleID may be unable to respond to inquiries without verification from the Operator.
You may also contact GambleID at:
GambleID LLC
℅ Legal Department
1121 Delano St., Suite 108
Houston, TX 77003
11. Entire Agreement and Closing
This Terms of Service agreement, along with any referenced privacy policies, data protection terms, or additional notices provided by GambleID, constitutes the entire agreement between you (the end user) and GambleID regarding your access to and use of GambleID’s compliance and verification services. It supersedes any prior communications, representations, or agreements, whether oral or written, relating to the subject matter herein.
By proceeding through the Operator’s platform or service, you confirm that you have read, understood, and agreed to the terms outlined in this agreement. Your continued use of the services provided through GambleID constitutes your acceptance of these Terms.