Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act. The legal authority under which we collect Personal Information is FIPPA, Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act, and the Operating Agreement between iGo and the Group.
We are running our Services as part of the open and regulated internet gaming (igaming) market in Ontario conducted and managed by iGO and is collecting, using and disclosing PI on behalf of, and as agent to, iGO.
The Group provides the Services through the following applications and platforms (collectively the “Platforms”):
By using the Services, you consent to the collection, use and disclosure of the Personal Information (as defined below) that we collect from you in accordance with this policy. If you disagree with or do not consent to any terms of this policy, please do not use the Services.
You may withdraw your consent to the collection, use and disclosure of your Personal Information, in whole or in part, at any time by contacting us in the manner set forth in this policy under the heading “YOUR RIGHTS” (subject to applicable laws, reasonable notice and certain other restrictions.
We collect two types of information from our Users:
The first type of information which we collect is information that identifies or may reasonably identify an individual with reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-personal Information we collect from or about you:
This section outlines the underlying purposes and legal bases for the processing of your Personal Information:
|Provision of our Services; support and customer relations. We collect and use your Personal Information, such as your name and email address, for consumer services purposes. This includes, for example, managing your account, operating the Services, and responding to your inquiries.||The legal bases for processing this data are the performance of our contractual obligation towards you; your consent (for example, when you provide Personal Data); compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.|
|Improving our Services. We collect, use and disclose information about you and your usage of our Services in order to analyse such usage to improve the usability and effectiveness of our Services.||The legal bases for processing this data are our legitimate interests, in this case – providing and improving our Services.|
|Marketing, advertising and analytics. We collect and use your Personal Information in order to provide you with personalized advertisements when you visit our Services, to market our Services and to gather aggregate usage information and analytics.||The legal basis for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests and to promote our Services.|
|Dispute resolution and protection of our legal claims. We collect, use and disclose your Personal Information in order to investigate suspected violations of our policies, to enable us to resolve disputes in connection with your use of the Services and to establish and defend our legal claims.||The legal basis for processing this data is our legitimate interests. Our legitimate interests in this case are to establish and defend our legal claims.|
|Corporate transactions. We may disclose your Personal Information to potential purchasers, successors or investors in the Company or any other member(s) of the Group or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to the Company or any other member(s) of the Group.||The legal basis for processing this data is our legitimate interests.|
|Prevention of fraud. We may collect, use and disclose your Personal Information to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services.||The legal basis for processing this data is our legitimate interests. Our legitimate interests in this case are to protect our Company and customer against fraud.|
|Compliance with applicable laws. We collect, use and disclose your Personal Information to comply with our various legal obligations including without limitation obligations relating to responsible gaming, anti-money laundering, identity verification, prevention of fraud and complying with data subject rights.||The legal basis for processing this data is to comply with our various legal obligations and our legitimate interests.|
Special Categories of Personal Data
Our processing of your Personal Information may also involve special categories of personal data. We will process such information, as well as disclose it to competent authorities (such as licensing bodies or law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act, (i) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes. In addition, we may process and disclose such information where it is necessary for the purposes of safeguarding your (or others’) economic well-being (such as detection and retention of information pertaining to those with responsible gambling issues). We, or third parties on our behalf, may also process your biometric data, based on a photo provided by you, to comply with our legal obligation to verify your identity.
The Services are not designed for or directed to the use of persons under the age of 19 (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the "HOW TO CONTACT US?" section).
We use your Personal Information for the purposes listed below:
The Group will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; or (ii) the Group's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose your Personal Information with our Marketing Affiliates for the purpose of providing you with different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
You may at any time decline receiving further marketing offers from us or from Marketing Affiliates by either: following the guidelines available on the marketing communications, (such as selecting the opt-out link inserted in the promotional emails) via “My Account” page on the site or by contacting support (our contact details are available under the "HOW TO CONTACT US?" Section). Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Please note: you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third party platforms (e.g. Facebook).
In addition, if you download any of our mobile applications to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the settings on the device itself.
We use third-party advertising technology to serve advertisements when you visit the Platform and use the Services. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA").
For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: https://optout.networkadvertising.org/ and http://www.aboutads.info/choices.
We may disclose Personal Information to any of the following Recipients:
As the Company operates from Gibraltar and engages with sub-contractors that are located globally, your Personal Information will be processed outside of Ontario.
For more information about the transfer of your personal data outside of Canada, please contact us (our contact details are available under the "HOW TO CONTACT US OR SUBMIT COMPLAINTS” Section).
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You knowingly and voluntarily assume all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. Thereafter, the Group will retain your Personal Information only for such additional periods as are strictly necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations, as well as to meet the Group’s contractual obligations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information as long as is strictly necessary for the Group’s legitimate business interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where the Group is guided to do so by the applicable supervisory authority.
You may contact us at any time by email (our contact details are available under the "HOW TO CONTACT US?" section), and request:
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. Please note that withdrawing your consent to the collection, use and disclosure of your Personal Information, and/or asking that we delete your Personal Information, may result in our being unable to continue to provide you with the Services. As well, please note that we may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
We are responsible to ensure that the Personal Information you provide to us remains accurate and up-to-date. You are responsible to inform us in case of any change or update of the Personal Information you have provided us.
We take great care in implementing and maintaining the security of the Services and your Personal Information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to properly use the information we collect from you. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
Although we take reasonable steps and employ appropriate security measures to safeguard information, the Internet is not completely secure. We cannot guarantee the security of your Personal Information and any transmission of your Personal Information through the Internet is at your own risk. We strongly advise you to create a strong password when registering to our Services, and to not share you log-in credentials with any third-party.
We cannot be responsible for the acts of those who gain unauthorized access to your Personal Information or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access or abuse. We will however promptly notify you if your Personal Information is impacted by a privacy breach that could reasonably result in a real risk of significant harm to you. We will also report any such privacy breach to the authorities as required by applicable laws (including, without limitation, the Office of the Privacy Commissioner of Canada), and keep a record of any such privacy breach to the extent required by applicable laws.
In case we detect that a privacy breach had occurred, we will promptly analysis the scope of the breach, and will use our best efforts to rectify the breach. We shall conduct a risk assessment procedure and will notify the effected users, iGO and any other relevant authority. We shall aid iGO or any other relevant authority in handling the results of the breach, as necessary.
All complaints and disputes will be processed, recorded and addressed in a timely, fair, transparent and appropriate fashion. Each complaint will be assessed on its merits on a case-by-case basis, and we will make an effort to reply within a reasonable timeframe.
Please note that if you are unsatisfied with our response to your complaint, you have the right to lodge complaint with the Office of the Privacy Commissioner of Canada or iGaming Ontario.
To exercise any of the rights set out herein in the “YOUR RIGHTS” section of this policy, or if you have any general questions or complaint about the Services, the information that we collect about you and how we use it or our compliance with data protection laws, please contact our accountable privacy executive:
Attn: Data Protection Officer
Suite 601–701, Europort Avenue,
Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
Last updated in June, 2022