1. INTRODUCTION
Sabiá Administração Ltda., duly incorporated and owner of the fixed odds betting platforms and other online gaming brands, namely Br4bet (br4.bet.br), Gol de Bet (goldebet.bet.br), and Lotogreen (lotogreen.bet.br), collectively referred to as "Platforms," reaffirms its unwavering commitment to regulatory rigor and the principles of integrity, ethics, and Responsible Gaming, in strict compliance with Federal Law No. 14,790/2023, SPA/MF Ordinance No. 2,579/2025, and SPA/MF Normative Instruction No. 31/2025, and other applicable regulations.
Through this Responsible Gaming Policy ("Policy"), Sabiá establishes mandatory diligence protocols for consumer protection, actively working to prevent harmful behavior and immediately enforce legal restrictions. Sabiá aims to promote a completely safe experience, taking precautions to ensure that individuals in situations of financial, emotional, or social vulnerability, or who may be at risk, are not exposed to excessive gambling practices.
In this Policy, we detail the two-pronged approach we have adopted: on the one hand, the Centralized Impediment Module, which ensures the blocking of legally prohibited groups (Social Programs and Centralized Self-Exclusion); and, on the other, the Mandatory Self-Care Tools (including limits, breaks, and self-exclusion), which are essential for bettors to prevent and mitigate the risks associated with any form of gambling-related harm, including addiction.


2. TO WHOM THE POLICY APPLIES Full
observance, compliance, and operational application of this Policy, in strict accordance with the Secretariat of Prizes and Betting (SPA/MF), are mandatory and apply to:
● All employees, administrators, and members of senior management at Sabiá Administração Ltda.;
● Service providers, business partners, and any third parties who, directly or indirectly, perform functions related to the operation, promotion, offering, support, or IMPEDIMENT MODULE of the Platforms (Br4bet, Gol de Bet, and Lotogreen), with compliance obligations to be incorporated into their respective contracts and agreements;
● All bettors (and users), including those under Centralized Self-Exclusion, who access, register, and use the online betting and gaming services offered on our Platforms.
Sabiá expects, requires, and will monitor that all individuals and entities listed above act in strict compliance with the principles of Responsible Gaming and the operational audit rules established herein, subject to contractual and legal sanctions for non-compliance.


3. DEFINITIONS
Bettor: Also called a customer or user, is an individual over the age of 18 (eighteen) who participates in fixed-odds betting and online games on Sabiá's platforms.
Responsible Gaming: A set of principles, tools, and intervention protocols adopted by Sabiá to ensure the integrity of the operation and promote the safe and controlled use of fixed-odds betting, preventing and actively acting to mitigate damages of any nature (social, financial, and individual) arising from the activity. Responsible Gaming is exercised in full compliance with current legislation, including Ordinance SPA/MF No. 1,231/2024, amended by Ordinance SPA/MF No. 2,579/2025, and Normative Instruction SPA/MF No. 31/2025.
Gambling Addiction: A mental health condition clinically recognized by the World Health Organization (WHO), characterized by a loss of control over the urge to gamble, resulting in significant damage to the individual's personal, family, professional, and financial spheres, requiring the application of Sabiá's Prevention and Exclusion Mechanisms.
Vulnerable Public: Individuals who, due to intrinsic and/or extrinsic factors, are at high risk of developing adverse damage or harm from participating in betting. They include, but are not limited to:
i) Individuals legally barred from access (beneficiaries of Social Programs, according to IN SPA/MF No. 22/2025);
ii) Minors (under 18 years of age) - access prohibited;
iii) People registered in Centralized Self-Exclusion;
iv) Bettors diagnosed with or suspected of having gambling addiction;
v) People in a situation of financial, social, or emotional fragility that could be aggravated by gambling.
Specific Self-Exclusion: Blocking a bettor's access to platforms managed by Sabiá for a fixed or indefinite period, requested and managed directly on the platform.
Centralized Self-Exclusion: Blocking a bettor's access to all fixed-odds betting systems, registered and managed in the SPA/MF Centralized Self-Exclusion System (SIGAP).


4. RESPONSIBLE GAMING
GUIDELINES This chapter establishes the mandatory due diligence protocols that extend across all links in the operational and business chain, including the contractual responsibility of third parties and partners to comply with the Responsible Gaming guidelines and the Impeded Module of the Secretariat of Prizes and Bets (SPA/MF).
Sabiá ensures an environment of integrity, transparency, and subject to SPA/MF oversight, in which each party involved—whether internal or external—understands and respects the verification and blocking guidelines, creating a solid foundation of trust essential to the sustainability of the regulated sector.
We adopt prevention and support mechanisms, taking precautions to ensure that individuals in situations of financial, emotional, or social vulnerability are not exposed to excessive gambling practices, nor are they in disagreement with the legal criteria for access (IN 22/2025 and IN 31/2025).
4.1 PROHIBITION OF PARTICIPATION FOR RESTRICTED CATEGORIES
Access to and participation in Sabiá's Platforms is strictly prohibited for the categories described below. Sabiá will adopt all necessary continuous verification measures (registration, login, and periodic scanning) to identify, prevent, block, and, if necessary, suspend and terminate accounts that violate these restrictions, in full compliance with the SPA/MF schedule and technical requirements.
A. Immediate Prohibition by Impeded Module (IN 22/2025 and IN 31/2025)
It is mandatory to block access for individuals listed as "Blocked" in the SPA/MF systems, in strict compliance with the Normative Instructions governing the Blocked Module: Social Program
Beneficiaries (IN SPA/MF No. 22/2025): It is strictly prohibited for individuals identified as beneficiaries of the Bolsa Família Program (PBF) and the Continuous Cash Benefit Program (BPC) to register and use betting systems.
Persons in Centralized Self-Exclusion (IN SPA/MF No. 31/2025): Access is prohibited to any bettor who has registered their request for self-exclusion in the SPA/MF Centralized Self-Exclusion System (SIGAP). Critical Compliance
Action: The identification of any impediment by the Module will result in the immediate and definitive closure of the account. Sabiá will guarantee a maximum period of two (2) days for the bettor to voluntarily withdraw the existing balance, after which the amount will be reverted in accordance with applicable law.
B. Minors
It is strictly prohibited for individuals under the age of eighteen (18) to register, open accounts, or participate in any type of game.
Control Measures (KYC): The Platforms will require proof of age during registration and will perform identity and age checks (Know Your Customer - KYC) using reliable databases and in strict legal compliance.
Consequence: Any account identified as belonging to a minor will be immediately blocked, the balance will be confiscated in accordance with Law No. 14,790/2023, and the case will be reported to the competent authorities, if necessary.
C. Restrictions due to Integrity and Conflict of Interest
To ensure the transparency and integrity of operations and prevent conflicts of interest (SPA/MF Ordinance No. 1,231/2024), participation in the Platforms is prohibited for:
● Sports Integrity: Individuals with the ability to influence the outcome of sporting events, including athletes, coaches, managers, referees, or anyone with access to privileged information.
● Prohibition for Employees and Related Parties: Employees, administrators, spouses, and relatives up to the second degree (ascendants, descendants, and collateral relatives) of the aforementioned individuals.
● Regulatory Agents and Legal Prohibitions: Public officials or persons in regulatory positions with functions directly related to the inspection, control, or supervision of betting activities, or other categories whose participation is prohibited by Law No. 14,790/2023 or complementary regulations.
D. Internal Risk and Vulnerability (Proactive Monitoring)
Sabiá reserves the right to refuse, block, restrict, or terminate the registration and participation of bettors considered at risk through internal monitoring, going beyond the legal prohibitions of the Centralized Module.
Risk Criteria (Personal Vulnerability): These include, but are not limited to, individuals with a history of self-exclusion requests, excessive gambling patterns, signs of financial or emotional problems aggravated by gambling, or a diagnosis of gambling addiction not registered in SIGAP.
Action: The identification of profiles in vulnerable situations, through internal data analysis or notification by the bettor themselves or third parties, will subject the bettor to the appropriate restrictive measures, primarily for their protection.
4.2 AWARENESS AND RISKS ASSOCIATED WITH BETTING
In compliance with its legal duty of Responsible Gaming, Sabiá alerts bettors to the risks inherent in fixed-odds betting and online gaming. Gambling should be strictly considered an entertainment activity and never a source of income or a tool for financial recovery.
When practiced inappropriately or excessively, gambling can have significant negative impacts on an individual's life. Sabiá warns of the following main risks that bettors should be aware of:
● Gambling Addiction: Risk of total loss of control over the act of betting, turning entertainment into a destructive compulsion that causes severe and lasting damage in personal, financial, and professional spheres.
● Financial Difficulties and Indebtedness: Risk of using financial resources essential for one's own or family's livelihood (such as rent, food, and basic bills) for gambling. Excessive debt can lead to insolvency and financial ruin.
● Mental Health Damage: Excessive gambling can trigger or aggravate serious emotional problems, including high levels of anxiety, stress, and depression, directly impacting quality of life.
● Professional and Academic Damage: Focusing on gambling can result in low productivity, absenteeism, and disinterest in work or study activities, which can culminate in warnings, disciplinary sanctions, and, in severe cases, job loss or dropping out of school.
● Social and Family Isolation: A tendency to hide gambling and distance oneself from friends and family, deteriorating personal relationships and leading to social isolation.
● Bettor's Contractual Responsibility: The bettor declares that they are fully aware of all the risks listed above when accessing and using the Platforms, and assumes full responsibility for monitoring their own gambling behavior, as well as for the consequences of any financial losses resulting from their bets. Acceptance of this Policy is an essential condition for maintaining registration.
4.3 PREVENTION AND SELF-CONTROL
MEASURES Sabiá implements and maintains active on its Platforms all mandatory self-control tools required by Ordinance SPA/MF No. 2,579/2025 (which amended Ordinance No. 1,231/2024), aimed at supporting bettors in the responsible management of their gaming activities:
a) Prudential Limits (Deposit, Bet, and Net Losses)
Bettors are required to set maximum limits for Deposits, Bets, and Net Losses for defined periods (daily, weekly, or monthly) before starting to place bets. The Limit tools include:
● Deposit Limit: Maximum amount that can be deposited.
● Net Loss Limit: Maximum amount that the bettor can lose.
● Time Limit: Maximum time spent on the Platform.
Rule: Any changes to increase or remove the limits set by the bettor will only take effect after the grace/reflection period defined by Sabiá, in strict compliance with the regulatory deadlines defined by SPA/MF. Limit reductions, however, are applied immediately.
b) Scheduled Break and Self-Exclusion (Specific and Centralized)
Sabiá provides accessible and easy-to-use mechanisms for bettors to temporarily suspend or permanently terminate their participation:
● Scheduled Break (Cooling-off): Temporary suspension of the account for a defined period.
Specific Self-Exclusion: Total blocking of access to Sabiá platforms for a minimum period of six (6) months or permanently. The conditions and procedure for self-exclusion are detailed in the Platform Terms and Conditions of Use available at the following addresses:
○ https://br4.bet.br/terms-and-conditions
○ https://goldebet.bet.br/terms-and-conditions
○ https://lotogreen.bet.br/terms-and-conditions
● Centralized Access (SIGAP): Sabiá maintains, in a prominent and easily accessible area on its platform, a link that directs bettors directly to the SPA/MF Centralized Self-Exclusion System (SIGAP) form.
c) Self-Assessment Questionnaire and Support Channels
With the aim of promoting awareness and proactive diligence, Sabiá will provide:
● Risk Self-Assessment Questionnaire: A validated tool that allows bettors to reflect on their gambling patterns and identify potential risks. Visit the website: https://ipjbr.com.br/autoavaliacao
● Support Channels: Educational materials and clear instructions, as well as support channels with referrals to external counseling services (e.g., IPJBR, CVV, etc.) in cases of gambling addiction.
 4.4 RESPONSIBILITY AND OPERATIONAL
COMPLIANCE Although the final control over the act of betting and monitoring one's own limits is the sole responsibility of the bettor, Sabiá fulfills its duty of diligence as an Operating Agent, ensuring compliance and systemic security.
Sabiá has a non-negotiable obligation to ensure the operational compliance of its systems, notably with regard to:
● Mandatory Accessibility and Usability: All Responsible Gaming features (Prudential Limits, Breaks, and Self-Exclusion) must always be active, functioning correctly, and prominently visible and easily accessible on all Platforms.
● Application of Rules and Blocked Module: Sabiá's systems immediately and unrestrictedly apply both the limits set by the bettor and the blocking and closure criteria from the SPA/MF Blocked Module.
● Monitoring, Auditing, and Logs (RNF-Audit): Employees and the Compliance Department actively monitor the use and effectiveness of these tools. Sabiá maintains auditable and non-repudiable log records (RNF-Audit) of all queries and actions taken in response to the Blocked Module and Self-Exclusion tools, ensuring traceability and proof of diligence before the regulator.


5. PROACTIVE MONITORING AND INTERVENTION
Sabiá fulfills its duty as an Operating Agent and adopts continuous and systematic monitoring measures to identify, mitigate, and intervene in behavior patterns that may pose a risk to the mental health and financial stability of bettors. Our goal is to act preventively to avoid the development of gambling addiction, always in strict compliance with the guidelines of the World Health Organization (WHO) and Ordinances SPA/MF No. 1,231/2024 and No. 2,579/2025.
Monitoring is a compliance function performed actively and constantly by the Data Intelligence, Risk Analysis, and Customer Service teams, which use intelligence systems to track and monitor bettors' profiles based on predefined risk indicators, including, but not limited to:
● Vulnerability and Mandatory Blocking (Blocked Module): Return of the information "Blocked - Centralized Self-Exclusion" or "Blocked - Social Program" from SIGAP, which results in the IMMEDIATE mandatory closure of the account in accordance with IN SPA/MF No. 22/2025 and IN SPA/MF No. 31/2025.
● Frequency and Volume of Bets: Unusual peaks in the number of sessions or the duration of bets.
● Variation in Bet Amounts: Sudden and significant increase in average bet amounts.
● Sudden Changes in Gaming Pattern: Atypical changes in the type of game or usual time of activity.
● Frequent Attempts to Increase Limits: Multiple requests to reverse or raise self-imposed deposit, betting, or loss limits.
● Signs of Loss of Control: Repeated requests for self-exclusion or pause followed by attempts to circumvent the system or immediate reinstatement before the end of the period.
● Risk Communication: Direct expression by the bettor themselves or by third parties (family members, for example) demonstrating a need for help or concern about gambling behavior.
5.1 ESCALATION INTERVENTION
PROTOCOLS Upon identifying behavior that represents high risk—such as signs of compulsion, problem gambling, or patterns of unsustainable financial loss—the responsible team will immediately document the case, attaching logs and data evidence (RNF-Audit), and report it to the Compliance Department and Legal Department for evaluation and deliberation.
Supervision, in joint analysis with Compliance, will adopt immediate and preventive intervention measures, proportional to the level of risk detected, which include, but are not limited to:
● Risk Communication (Alert Contact): Sending specific, non-promotional communications to the bettor, reinforcing the risks, self-control tools, and referral to external and independent counseling services.
● Mandatory Limit Restriction: Imposition of stricter Prudential Limits (deposit, bet, or net losses) based on an analysis of the bettor's gambling patterns, aiming to protect them from financial harm (SPA/MF Ordinance No. 2,579/2025).
● Preventive Blocking/Closure:
o (1) Temporary Blocking: Suspension of access for a specified period.
o (2) Permanent Closure: Permanent blocking of the account in serious cases of gambling addiction or loss of control, without prejudice to the duty to consult and apply Centralized Self-Exclusion (SIGAP).


6. CONTROL AND LIMITATION
TOOLS Sabiá must provide different tools to help bettors maintain control over their activity on the platform. These options are detailed in the Terms and Conditions, as well as on the specific page on Responsible Gaming, which can be found on all Sabiá websites, and complement this internal Responsible Gaming policy.
Important: any adjustments made by the bettor to the control tools (except for permanent self-exclusion) only take effect after a minimum period of 24 hours. This is a security measure to prevent impulsive decisions.
The Customer Service and Compliance team must apply the Escalation Intervention Protocol (Art. 5.1) for frequent requests to increase limits. In such cases, the request must be forwarded for internal risk analysis and, if the monitoring standards indicate vulnerability, the account may be temporarily blocked, with direct contact and an offer of Centralized Self-Exclusion.
6.1 PRUDENTIAL LIMITS (SELF-LIMITATION OF DEPOSITS, BETS, AND LOSSES)
The platform system allows bettors to set maximum and customized limits for Deposits, Bets, and Net Losses, in accordance with Art. 33 of SPA/MF Ordinance No. 2,579/2025.
● Types of Limits:
o Deposit: Maximum amount that can be placed in the account in a given period.
o Bet: Maximum amount that can be bet at a time or in a given period.
o Net Losses: Maximum amount that the bettor is willing to lose in a given time interval.
● Periods: These limits can be set as daily, weekly, or monthly directly by the bettor, or with the support of Sabiá's customer service channel.
6.2 SCHEDULED BREAKS (SELF-LIMITATION OF PLAYING TIME)
The system also allows the bettor to set Time Limits, i.e., prudential limits (daily, weekly, or monthly) on the platform, in accordance with Art. 33 of SPA/MF Ordinance No. 2,579/2025. The configuration aims to avoid long uninterrupted periods of play, preventing the risk of compulsive behavior.
6.3 PREVENTIVE ACCOUNT
SUSPENSION Sabiá reserves the right to suspend or block the account unilaterally based on its internal risk monitoring (Art. 5.1). The block is immediate and aims to interrupt any compulsive cycle or risky activity, without prior negotiation.
6.3.1 SUSPENSION (INTERNAL DECISION - APPLIED BY THE OPERATOR):
● Reason: Applied exclusively in situations of non-compliance with the Terms and Conditions, Suspicion of Fraud, or Money Laundering and Terrorist Financing Prevention Practices (PLD/FT).
● Term: For the duration of the investigation process, for a period of up to 30 (thirty) days, extendable for an equal period.
● Access: The user can consult their personal data, history, and notifications. They cannot: Place bets, make deposits, or withdrawals.
● Scope: The suspension is applied to all brands managed by Sabiá, in a unified manner.
Please note: The suspension applies to all brands managed by Sabiá, in a unified manner.
6.3.2 TEMPORARY SUSPENSION - RESPONSIBLE GAMING
● Reason: Applied by Sabiá when intervention is necessary to protect the user (Escalated Intervention - Art. 5.1).
● Access: The user can consult their data, history, notifications, and withdraw existing amounts. They cannot: Place bets or make deposits.
6.4 COMMUNICATION WITH THE USER
The user will be notified of the block by email, containing the justification, duration, and, if applicable, guidance on how to seek specialized help.
● Reactivation (After Suspension for Responsible Gaming): Reactivation is not automatic. The user must complete the self-assessment questionnaire again. The responses will be analyzed by the Risk and Compliance team within seven (7) business days.
● Decision: Sabiá may reactivate the account with or without additional restrictions, extend the block, or formally suggest Centralized Self-Exclusion if the risks persist
.
Important: Sabiá does not commit to automatically unblocking any account. Each case is analyzed individually, considering the bettor's history and the signs of risk presented. The final decision is always made by the Risk team, in conjunction with supervision.
6.6 TEMPORARY PAUSE
The temporary pause function allows the user to decide to take a break from betting. They can choose a period of at least 24 (twenty-four) hours and a maximum of 45 (forty-five) days.
Options: 24 hours, 5, 10, 15, 20, 25, 30, 35, 40, and 45 days.
Self-exclusion can be done directly on the platform, through the following procedure: Account > Player Protection > Exclusion > Temporary or Permanent > select Reason for Exclusion > Confirm. The user chooses the desired temporary period: 24 hours, 5, 10, 15, 20, 25, 30, 35, 40, 45 days.
At the end of the maximum period of 45 days, without any indication from the user that they wish to reactivate their account, the account shall be considered as "Permanent Self-Exclusion."
During the break:
● The bettor can still access the platform (to view information, personal data, betting history, check amounts, withdraw funds);
● They are prevented from placing sports bets, playing online, and making withdrawals;
● When the chosen period ends, full access is automatically restored.
At the end of the period, an email should be sent to the user, and a pop-up should be created on the website when the user first returns to the website after the break, asking if they really want to reactivate their account.
If many consecutive requests for suspension and return are identified, the case will be analyzed more carefully by the Sabiá team. If necessary, the registration may be blocked preventively.
6.7 VOLUNTARY
SELF-EXCLUSION This is a voluntary tool requested by the user to delete their account for a period longer than that provided for in the Temporary Break, with immediate blocking of access to the platform.
Self-exclusion can be done directly on the platform, through the following procedure: Account > Player Protection > Exclusion > Temporary or Permanent > select Reason for Exclusion > Confirm. The user determines the desired period (minimum 46 days or indefinite period), and may include the option of permanent account deletion.
During the self-exclusion period:
● The bettor will not have access to their account;
● They will not be able to place bets or receive promotions from Sabiá.
Reactivation requires:
● Full compliance with the defined period;
● Complete KYC process;
● Confirmation of reading and acceptance of the Terms and Conditions;
● Manual review and approval.
After reactivation, they must:
● Have access to registration data;
● Have access to betting history;
● Have access to financial transactions.
Art. 6.8. CENTRALIZED SELF-EXCLUSION - Impedidos Module - IN 31/2025. 
Registration and use of platforms managed by Sabiá are verified with the SPA/MF Impeded Module (SIGAP) to ensure that users are not registered in Social Programs (IN 22/2025) or in the Centralized Self-Exclusion System (IN 31/2025).
● Operator's Duty: Sabiá maintains, in a prominent and easily accessible area, a link that directs the bettor directly to the SPA/MF Centralized Self-Exclusion System (SIGAP) form.
● Sole Paragraph (Mandatory Closure): In cases of account closure due to legal impediment, Sabiá will notify the user and guarantee a non-negotiable period of two (2) days for the bettor to voluntarily withdraw the existing balance (functional withdrawal). After this period, the amounts will be returned to the original bank account or to the legal fund (FIES/FUNCAP). The operator must document all communications and the closure process in RNF-Audit Logs for a minimum period of five (5) years.
6.9 WINNINGS DURING SELF-EXCLUSION
Any bets placed before self-exclusion or blocking will remain valid and will be settled as normal. If there are winnings resulting from these bets, the amount may be requested from the support team at any time through Sabiá's official channels. Payment will be processed within the regular withdrawal deadlines.
This measure guarantees the bettor's right to the amounts due, without compromising the period of absence defined for their well-being.


7. RISK ALERT AND
COMMUNICATION MECHANISMS Sabiá implements and maintains mandatory alert and communication mechanisms to ensure the continuous reinforcement of awareness, inherent risks, and self-control tools.
7.1 LIMIT APPROACH ALERTS (OPTIONAL FOR BETTORS)
Bettors have the option to activate notifications to be alerted by email or push notification whenever they are approaching the financial (deposit, loss) or time limits they have set. This feature aims to reinforce control and conscious use of the Platform.
7.2 ALERTS FOR TIME ELAPSED PER SESSION
In compliance with legal requirements (Art. 34 of SPA/MF Ordinance No. 1,231/2024), Sabiá will issue visible, clear, and prominent alerts on the bettor's screen at intervals of no more than 60 (sixty) minutes during the same gaming session. The goal is to interrupt the uninterrupted flow of bets and encourage reflection and pause, requiring the bettor's interaction to continue.
7.3 CONTINUOUS COMMUNICATION OF RISKS
After registration, the bettor will receive an initial communication by email, detailing the risks, the signs of gambling addiction, and the importance of gambling as entertainment. Sabiá will reinforce these messages through periodic educational campaigns on its Platforms, in compliance with Article 9 of SPA/MF Ordinance No. 1,231/2024.


8. CUSTOMER SERVICE CHANNELS AND EXTERNAL SUPPORT
Sabiá guarantees accessible customer service channels and trains its teams to offer immediate support and responsible guidance to anyone who shows signs of problem gambling.
8.1 SABIÁ SUPPORT
CHANNELS Sabiá maintains customer service channels available 24 hours a day, every day of the week, for continuous support to bettors. These channels are available on the Platforms and can be used by both users and family members or close friends (concerned third parties).
The team is prepared to provide guidance on protection resources, self-control tools, and indicate ways to care for mental health, always in a discreet and welcoming manner:
● Chat: Available on the Platforms (24/7).
● Email: Specific customer service email for each Platform (24/7).
● Ombudsman: Second-level channel for resolving any conflicts.
● Phone: 0800 033 0396 (Human service during business hours: 9 a.m. to 6 p.m., Monday through Friday).
● WhatsApp: 011 3578-4125 (Human service: 24/7).
8.2 PROFESSIONAL SUPPORT INFORMATION (EXTERNAL SUPPORT)
Sabiá actively guides and encourages bettors to seek psychological support or external help whenever necessary, providing the following references and support information on its channels and Responsible Gaming pages:
● CVV (Life Appreciation Center): Telephone 188 – Free and confidential emotional support and suicide prevention service, available 24 hours a day.
● CAPS (Psychosocial Care Center): Recommendation for bettors to seek the CAPS closest to their location for mental health treatment.
● IBJR (Brazilian Institute for Responsible Gaming): Content and support tools for a safe gaming environment.
Important: Sabiá does not recommend or maintain ties with specific professionals, but guarantees guidance and access to information about external support services, respecting the bettor's autonomy in their choice of treatment.


9. LIMITATION OF LIABILITY AND DUTY OF CARE
Sabiá fully complies with the preventive measures, proactive monitoring protocols, and systemic Responsible Gaming obligations established in this Policy and in the current SPA/MF Ordinances. However, the Operating Agent's liability will be limited and will not cover damages suffered by the bettor (financial, emotional, social, or other) as a direct result of betting or the development of gambling addiction.
The Limitation of Liability is based on the fact that:
a) The final control and responsibility for the use of self-limitation tools and the management of gambling behavior are the sole and exclusive responsibility of the bettor. 
b) The bettor uses the services at their own risk, having been duly warned about the risks and accepted the Terms and Conditions after Sabiá fulfilled its duty of information and transparency (Art. 4.2). 
c) Sabiá maintains active Proactive Monitoring (Art. 5) and Blocked Module (Art. 6.7) systems, with the RNF-Audit Logs serving as proof of non-negotiable diligence against systemic failure.
Disclaimer:
Sabiá will only be held liable in cases of proven failure in its systems (as recorded in the RNF-Audit Logs) that results in the violation of mandatory blocks (e.g., allowing betting or user registration that the Impediments Module or the SPA/MF Centralized Self-Exclusion has formally reported as impeded), constituting a breach of the legal duty of diligence.


10. DATA STORAGE AND
PROCESSING Sabiá is unwaveringly committed to treating the personal data of its bettors with the highest level of security, confidentiality, and responsibility, in strict compliance with the General Data Protection Law (LGPD), Law No. 13,709/2018, and other laws and regulations applicable to the betting industry.
Data processing is carried out for the purpose of complying with legal and regulatory obligations (including Know Your Customer - KYC, Responsible Gaming, and Money Laundering Prevention - PLD/FT), ensuring the integrity of operations and the safety of bettors.
10.1 SECURITY AND ACCESS
All information is stored in a secure technological environment and access is strictly limited to authorized professionals, through strict access control mechanisms, as provided for in our Privacy Policy. Technical and administrative measures are adopted to protect data against unauthorized access, accidental or unlawful situations of destruction, loss, alteration, communication, or any form of inappropriate or unlawful treatment.
10.2 RETENTION AND DISPOSAL PERIOD Personal data
is kept for the period strictly necessary to fulfill the purposes and legal obligations. Due to regulatory requirements related to PLD/FT and transaction records, the information is kept for at least five (5) years after the closure of the bettor's account, or for a longer period, as required by current legislation (Law No. 14,790/2023).
Supporting documentation for communications and account closure processes due to legal impediments (IN SPA/MF No. 22/2025) must be retained for a minimum period of five (5) years.
After the legal retention period has expired, the data is discarded in a secure and irreversible manner.
10.3 ADDITIONAL
DETAILS Further details on the legal basis, the rights of data subjects, and the specific processing of data can be found in the Privacy Policy of each platform, available at:
https://br4.bet.br/privacy-policy
● https://goldebet.bet.br/privacy-policy
● https://lotogreen.bet.br/privacy-policy