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Privacy Policy

Gamewise LLC U.S. Privacy policy

Last modified: May, 2021

1. Scope

Your privacy is important to Gamewise LLC (“BETLY” or “we”) as is your trust in BETLY’s gambling products and services. We want you to know that the information you share with us will be treated with care. 

This Privacy policy addresses what personal information we collect and how we process the personal information shared with us. It shall apply to personal information we obtain from and about individuals interacting with BETLY and its websites, products and services, and does not apply to personal information we obtain in our capacity as an employer. 

This Privacy policy covers BETLY controlled subsidiaries and affiliates processes, except Delaware North Companies Gaming and Entertainment Inc. and its subsidiaries and affiliate, which have their own privacy policy (www.delawarenorth.com/privacy). 

Please note that privacy statements of BETLY partners or providers may be independently or in combination with this Privacy policy applicable and should carefully be reviewed by the player, for example payment method providers such as www.sightlinepayments.com or external providers (such as your Android or iOS provider) or social media platform such as www.facebook.com.

2. Key points about our privacy practices

Information

We may collect information about you, such as first name, last name, birthdate/age, gender, birthplace, ID card/scan, passport, pseudo, address (including city, region, country, continent ID-code), email, language, IP address, player ID, phone number, registration date, Facebook name/profile, auto-exclusion status, bank account, deposits and withdraw history and method, currency, connections log, card imprint, electronic wallet, token, conversation history, game history, game logs, stake, win, played game, session duration, configuration policy and functional data, UID matching the external ID of BETLY database, coins, VIP status/level, sponsorship code, browser, browser size, browser version, device category, flash version, network domain, operating system, operating system version, screen resolution, service provider, source property display name, source property tracking ID, devices room, product preference, user bucket, user type, page viewed and related player experience data, through your use of BETLY products or services, and through BETLY affiliates, partners and providers of BETLY product and services.  

Purpose

We may use your information to operate and provide gambling products and services (notably players/wagers registration and authentication, payment, risk & fraud, customer support), as well for i) safety and product research purposes, and ii) marketing purposes (player acquisition, player retention, newsletter, event, loyalty program, quality survey, sponsoring).  

Use

We may, whether or not by automated means, process information by way ofcollection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, your information as required by law and the aforementioned purposes, within BETLY, with our BETLY controlled subsidiaries and affiliates, as well as BETLY partners and providers.

Choices

You have choices regarding how we use your information for marketing and other purposes, as per described in this Privacy policy.

Cookies and Tracking

We may use cookies, pixel tags, web beacons and similar tracking technologies to help provide our products and services, understand and customize your preferences, and display relevant advertising.

Mobile Applications

BETLY has developed mobile application that you may download to your mobile device (“BETLY Application”). When you download BETLY Application, there may be an opportunity for you to provide us with or for us to obtain information about you, subject to the same conditions as BETLY website. 

Third Party Products and Services 

Through the use of BETLY products and services, you may be able to access third party services, applications and websites not controlled by BETLY or covered by this Privacy policy. Some of these Third Party Product and Services are part of BETLY product and services, such as, platform and games providers, payment method providers, risk and fraud tool providers, notably.

Access and Update

You may access your online account to update your information or you may contact us to learn about how to do so. See “contact Us” section.

Security Measures

We maintain reasonable and adequate security controls, according to highest industry standards, to protect your information and require our service providers by contract to do the same.

Retention

We keep information for as long as necessary to provide our products and services, operate our business, and comply with legal obligations. 

Children's Privacy

BETLY’s website and application do not target or knowingly collect any information from children under the age of thirteen (13), according to Children’s Online Privacy Act (COPPA) – 15 U.S.C Chapter 91

International Data Transfers 

We may have to proceed for the aforementioned Purposes to cross-border transfers of your information to European Union. Any of these transfers shall be subject to appropriate protections for cross-border transfers, as required by law for international data transfers, such as encryption measures in accordance with Special Bulletins issued by the National Institute of Standards and Technology. 

BETLY contact  

If you have concerns or questions regarding BETLY's privacy practices or this Privacy policy, please contact us. Our permanent representative agent will be pleased to answer any query you may have:

Delaware North Companies Gaming & Entertainment Inc.

ATTN: General Counsel

250 Delaware Avenue

Buffalo, NY 14202, USA

Email: [email protected] 

Phone: (901) 554-4988 or (807) 394-7211. 

Changes

We may update this Privacy policy from time to time. Any update shall be implemented by posting additions or modifications to this page. 

3. Information Collected

As you interact with BETLY, there may be opportunities for you to provide us with your Information. Additionally, we may Use certain Information about you, for the Purposes set out in this Privacy policy.

You may provide us with information about you through a number of sources: BETLY website registration, BETLY application, product and related events of BETLY partners and affiliate, social media platforms, payment methods providers, notably. 

Depending on the Purpose of the Use, the types of information that BETLY may Use about you shall include, but are not limited to:

  • first name and last name,
  • birthdate/age,
  • birthplace
  • gender,
  • civil status,
  • ID card/scan, passport,
  • pseudo,
  • address (including city, region, country, continent ID-code),
  • email,
  • language,
  • IP address,
  • player ID,
  • phone number,
  • player registration date,
  • Facebook name/profile,
  • bank account, deposits and withdraw history and method, currency,
  • Functional players data such as: auto-exclusion status, connections log, card imprint, electronic wallet, token, accept mailing (opt-in), conversation history, game history, game logs, stake, win, played game, session duration, configuration policy and functional data, UID matching the external ID of BETLY database, coins, VIP status/level, sponsorship code, browser, browser size, browser version, device category, flash version, network domain, operating system, operating system version, screen resolution, service provider, source property display name, source property tracking ID, devices room, product preference, user bucket, user type, page viewed and related player experience data, through your use of BETLY products or services, and through BETLY affiliates, partners and providers of BETLY product and services. 

4. Use and Purposes

Information BETLY may Use about you shall consist, whether or not by automated means, process information by way of  collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, your information, within BETLY, with our BETLY controlled subsidiaries and affiliates, as well as BETLY partners and providers, with the following Purposes :

  • to provide and operate BETLY products and services on BETLY website and BETLY Application and maintain customer relationships, including online registration processes, administer your account(s) and process your payments;
  • to provide player support and all support services required by law or BETLY House of Rules or Terms of Services available here;
  • to improve the quality, safety, and security of BETLY website and app and related products and services;
  • to improve players online experience;
  • to provide information and updates on BETLY products and services and develop new products and services;
  • for marketing and analytics purposes;
  • to customize and improve communication content;
  • to comply with legal, regulatory or contractual requirements.

Following Information shall be Used for specific Purposes as follows:

Information

Related Purpose

Customer service

First name, last name, birthdate, email, pseudo, IP address, account creation date, conversation history, ID card, game history, player ID, stake, win

Risk & Fraud

First name, last name, birthdate, email, pseudo, IP address, location, account creation date, conversation history, ID card/scan, game history, player ID, stake, win, phone, passport number, bank account, electronic wallet token, deposit, withdraw, payment method, transaction history, currency, connection logs, games logs/date, played games, game party details (including duration/session)

Marketing (player acquisition, player retention, newsletter, event, loyalty program, quality survey, sponsoring)

First name, Last name, address, mail, pseudo, phone, password, ID/passport number, birthplace, birthdate, age, civil status, gender, language, account status, accept mailing (opt-in), coins value, VIP level, UID matching the external ID of our DB, sponsorship code, browser, browser size, browser version, city, city ID, ZIP code, continent, continent ID, country, country ISO code, device category, flash version, network domain, operating system, operating system version, region, region ID, region ISO Code, Screen resolution, service provider, session duration, source property display name, source property tracking ID, sub continent, sub continent code, user bucket, user type, last connection date, first and last deposit date, auto-excluded date, real wager, credit balance.

5. Sharing

BETLY shall not sell or share Information that identifies you individually or makes it possible for other parties to contact you directly without your consent, except as disclosed in this Privacy policy.

In addition to the specific situations discussed elsewhere in this Privacy policy, BETLY may Use Information by way of disclosing to Third Party Product and Services providers, in the following instances:

  • within BETLY, with our BETLY controlled subsidiaries and affiliates, including BETLY platform provider, to the extent necessary to operate BETLY website and BETLY Application, including online registration processes, administer your account(s) and process your payments and marketing purposes;
  • with BETLY platform, betting, games, payment method and other external providers, to the extent necessary to operate BETLY website and BETLY Application, it being understood that such services providers do not have an independent right to use the Information to which they have access or that we disclose to them, except otherwise agreed with the player;
  • with our BETLY business partners for BETLY marketing activities, business partner marketing activities or both, such as Delaware North Companies Gaming and Entertainment Inc. ;
  • with third parties for research and development purposes (such as university research institutes for improving responsible gaming and BETLY platform safety);
  • in connection with the sale, transfer or financing of a significant part of a BETLY business or its assets, including any such activities associated with a bankruptcy proceeding;
  • when BETLY believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, prevent fraud or money laundering, or respond to a law enforcement request;
  • as required by law or US gambling authorities, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process.

Apart from the Purposes listed above, BETLY shall not share information about you with other third parties for their independent use without your prior consent.

6. BETLY’s confidentiality, integrity, availability measures related to your Information

To help maintain Information accuracy, prevent unauthorized access to or disclosure of, and ensure the appropriate use of your Information, physical, electronic, such as encryption, and managerial procedures have been implemented and are subject to periodic audit, in accordance with highest industry standards and ISO27001 certification standard as well as Tennessee Legal Gaming Authority requirements.  In the event that we are required by law to inform you and relevant authorities of any unauthorized access to your Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

BETLY also requires by contract (other than in an emergency situations) that third party services providers acting on our behalf or with whom we share your information also undertake to provide such security and confidentiality measures in accordance with industry standards. We have also agreed with its platform, betting and games provider, which is ISO27001 standard certified, specific procedure to audit all measures and their effectiveness regarding to security, availability and integrity of Information processed externally.

7. How Long We Keep Your Information

BETLY may keep the information we Use for as long as necessary, based on the Purposes of the Use as per described in this Privacy policy and to satisfy our legal or contractual obligations.  Information shall be stored to provide products or services to you, to operate our business, to enable us to communicate with you, for your safety, research, evaluation of use, or troubleshooting purposes, etc. 

Where required, we will provide our best endeavours to anonymize or dispose of the Information we collect when we no longer need it for the uses described above.

8. Children’s Privacy

BETLY websites do not target or knowingly collect any information from children under the age of thirteen (13). All technical measures have also been implemented on BETLY website and Application in order to prevent such registration.

9. Cookies/Tracking Technologies

BETLY may use cookies, pixel tags, web beacons and other tracking technologies on our websites, applications, email messages and advertisements to gather information about your visit (such as demographic data, browser type, IP address, pages visited, activities conducted on the page, and the day and time of your visit). 

BETLY website and Application use four (4) categories of cookies, namely:

  • Essential cookies: the cookies that are necessary for the functioning of the website and, notably, for the purposes of allowing players to access the offer of online gaming and betting, and allowing the website and the Application to comply with legal and contractual obligations;
  • Cookies to improve user experience: the cookies that improve online experience (preferences, etc.);
  • Performance cookies: the cookies that measure the website’s and Application’s performance and adverts displayed;
  • Cookies for advertising purposes: the cookies that allow you to receive advertising, particularly personalized adverts and create a personalized profile so you are not shown adverts that do not correspond to your profile.

The use of cookies by the website and its partners is subject to information and notice set out in this Privacy policy.

Please will find herewith the list of cookies below. This list is non-exhaustive and is likely to change on the understanding that website or Application will request your consent for all non-functional cookies.  

Essential cookies

Cookies

Function

Length of storage

ASP.NET_SessionId

Management of the player's session

Session

Third Party Cookies

Third Party

Function

Length of storage

__cfduid

cloudflare

Cybersecurity prevention

29 days

io_token_*

f-token_*

Iovation

Anti-fraud management

1 year

1 year

Local Storage

Function

i18nextLng

Language content preference

ZD-suid

ZD-store

ZD-arturos

ZD-buid

Livechat, management and support access

Io_temp

fp_temp

Anti-fraud

Cookies to improve user experience

Local storage

Function

lastVisit

Management of the "Remember me" feature in the login module

searchHistory

Website Search history of user

hasUserAlreadyLoggedIn

Management of the connection of user

Performance cookies

Third Party Cookies

Third Party

Function

Length of storage

_dc_gtm_UA-*

_gat_UA-*

Google Analytics

Google tag manager – Business Intelligence – statistical tools

1 min

_gid

_ga

Google Analytics

Memorize a unique username and visits for statistical purposes

1 day

2 years

_hjid

_hjTLDTest

_hjFirstSeen

_hjAbsoluteSessionInProgress

Hotjar

Analyze the player's experience during their Site visit

1 year

Session

1 hour

30 min

fs_uid

Fullstory

Visualize the player's experience during their Site visit

1 year

_dd_s

Datadog

Performance measure – bug detect

1 day

Local storage

Third Party

Function

_fs_uid

Fullstory

Visualize the player's experience during their Site visit

Cookies for advertising purposes

Cookies

Function

Length of storage

home_news home_news_connected

Management of information to be communicated to the player depending on their last login date

1 year

Third Party Cookies

Third Party

Function

Length of storage

fr

_fbp

Facebook.com

Use for distribution of advertising products

3 months

_gcl_au

Google Ads

Analyze information relating to advertising

3 months

_uetvid

_uetsid

Microsoft UET

Analyse information for advertising purposes

16 days

1 day

C

Uid

TPC

CM14

adform

Analyse information for advertising purposes

60 days (cookies allowed) 

10 years (cookies opt-out)

2 months

14 days

14 days

Whether on your computer or on your mobile phone, you may manage your preferences and decline your consent to the cookies used by BETLY website and Application and BETLY partners by configuring your cookies via the Cookie settings tab.

Please note that most browsers are configured to automatically accept cookies. You are free to set your browser so it sends a notice when a cookie is used and therefore you can accept it or not.

Please note it is also possible that third parties could use cookies to generate traffic without BETLY’s consent. You have the option of deleting these cookies by directly contacting these third parties.

You can opt out of receiving advertising based on your browsing behaviour from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behaviour you should also disable the cookies on your browser.

10. Mobile Application

BETLY has developed mobile application that you may download to your mobile device (“BETLY Application”). When you download BETLY Application, there may be an opportunity for you to provide us with or for us to obtain Information about you. 

Any access or Use of BETLY Application shall be subject to player’s approval of this Privacy policy.

11. BETLY affiliate and partners – Third Party product and services

 Through the use of BETLY products and services, you may also access to third party services, applications and websites not controlled by BETLY or covered by this Privacy policy. BETLY and BETLY affiliate, providers and partners are separate legal entities with their own privacy practices which may differ from our Privacy policy. 

We encourage to read BETLY affiliate, providers and partners own privacy policies to ensure that you understand its privacy practices and procedures. While BETLY provides best endeavours to ensure full compliance of its affiliate, providers and partners, with all applicable privacy legislation, BETLY is not responsible for their compliance with applicable law. For questions about their privacy practices including opting out of marketing communications, please contact them directly.

12. Players privacy right and choices

BETLY shall grant players with following privacy rights:

  • Access to Your Information. Upon request, BETLY shall grant you with access to Information that we Use about you. You may request access to your Information by contacting us with such request pursuant to the “How to Contact Us” section below. 
  • Right of rectification. You may contact us to correct or update Information about you in our records. You may request access to your Information by contacting us with such request pursuant to the “How to Contact Us” section below. We also rely on you to update and correct your Personal Information. Most of our Websites allow you to modify your account profile and related Information. Note that we may keep historical information in our backup files as permitted by law. If BETLY website or BETLY Application does not permit you to update or correct certain information, contact us with such request pursuant to the “How to Contact Us” section below.
  • Right of deletion. BETLY retains your Information for the period necessary to fulfil the purposes outlined in this Privacy policy, unless a longer retention period is required or permitted by law.  In addition, we may keep your Information as needed to comply with our legal obligations, resolve disputes, and/or enforce our agreements.  You may, however, request that we delete your Information by contacting us with such request pursuant to the “How to Contact Us” section below and we will delete such Information to the extent required by law or any Use which shall be justified by BETLY contractual Purposes under Terms of Services of BETLY website or Application. 
    We may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. 
  • Right of opt-out / choices. You may revoke consent, or object, to specific processing of your Information by contacting us with such request pursuant to the “How to Contact Us” section below.  If you revoke your consent for the Use of Information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. 
    BETLY is pleased to offer players following choices regarding to the Use of their Information :
    i) Promotional Mailings/Emails. If at any time you do not want to receive offers, circulars, newsletters, surveys, offers, and other promotional materials from us or Delaware North Companies Gaming and Entertainment Inc., you are allowed to remove yourself from our mailing list by following the unsubscribe instructions in emails that you receive or by contacting us or Delaware North Companies Gaming and Entertainment inc., with such request pursuant to the “Contact Us” section below and including “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed, as well as mailing which strictly relate to legal requirement or to BETLY contractual obligations regarding to BETLY product and services offer.
    ii) Promotional Text Messages. If you receive a text message from us that contains promotional information, you can opt out of receiving future text messages by replying “STOP” or otherwise contacting us with such request pursuant to the “Contact Us” section below.
    iii) Telephone solicitation. To the extent telephone solicitations and use of automated telephone equipment are permitted by law, BETLY shall comply with The Telephone Consumer Protection Act 47 USC, § 227, and offer players to withdraw any consent provided for such solicitation or use.
    iv) Cookies. See cookies section.

13. International Data Transfers

BETLY may Use your Information by transfer among the company, our subsidiaries, providers and/or our affiliate companies for the Purposes described in this Privacy policy. As a result, your Information may be processed in a foreign country where privacy laws may be less stringent than the laws in force in jurisdiction BETLY website or Application is being used. Nonetheless, where possible we take steps to Use Information using the same privacy principles that apply pursuant to the law of the country in which we first received your Information.

By accessing to BETLY Website or Application, you agree to the transfer, storage and processing of your Information in a country other than your country of residence including in the European Union. Such transfer out of the United States shall be subject to appropriate encryption measure according highest industry standard in order to maximise protection of your Information.

When BETLY and affiliates in the United States transfer Information out of the United States, such as to Europe, BETLY is acting as a data controller for all Use and transfer related to BETLY website and Application operation, by subcontracting provision of any betting or gaming services, data hosting, maintenance, support, and troubleshooting of services, as well as other redundant back office support, by non-US providers. BETLY remains solely liable and responsible towards players regarding transfer of their Information out of the United States.

For any information concerning our attempts to apply the privacy principles applicable in one jurisdiction to Information transfers to another jurisdiction, please can contact us pursuant to the “How to Contact Us” section below.

14. How To Contact BETLY ?

Delaware North Companies Gaming & Entertainment Inc.

ATTN: General Counsel

250 Delaware Avenue

Buffalo, NY 14202, USA

Email: [email protected] 

Phone: (901) 554-4988 or (807) 394-7211.

15. Changes To This Privacy Policy

We may update this Privacy policy from time to time. We will do so by posting additions or modifications to this page.

Effective date: June 4th, 2021