Operators’ Privacy Policy

Privacy Policy Summary

  1. Purpose. This Privacy Policy (hereinafter, "the Privacy Policy") aims to inform you about how we gather, process, and protect your Personal Information when you use our services through our websites, mobile applications and Electronic Channels. We rely on your consent for processing your Personal Information, by reading and accepting this Privacy Policy you consent to us processing your Personal Information. However, please also note, that much of the information we collect about you is also required to meet our contractual, legal and regulatory obligations, such as the Operating Agreement executed between us and iGaming Ontario, iGaming Ontario´s Privacy Directive, applicable gambling legislation, Anti-Money Laundering laws and any other Applicable law.

You can always revisit and revise this Privacy Policy through the links available in the footer of our Operator Website site.

  1. What Personal Information we collect. We collect Personal Information to provide our services, and any other information you provide to us. This may include: your name; contact information; information to establish your identity; date of birth; gender; information about your use of our services, such as transactional information, and your bets, winnings, losses, deposits and withdrawals; payment information; information in your communications with us (including call recordings, and survey responses and your social media interactions with us); user IDs or online identities; information about customer wellbeing; images and selfies; preferences and interests; whether you click or respond to our marketing; risk scores and profile classifications; and information regarding your active software applications and active processes while using the Operator Website.
  1. How we collect information using technology. We may collect information using technology, including your: IP Address, MAC address, device type, apps, location, log in details and information about how you use our mobile applications and websites. We use this to provide customer service, to meet our legal obligations, for identity verification, to present content in an effective manner, to improve our products and services, optimize business processes, ensure the integrity of our systems and to manage our Information Technology, undertake quality assurance, support management of our staff, analyze and improve the performance of webpages, services, or promotions, and to provide content that is relevant to you. We also use it to prevent or detect crime, fraud, or breaches of our terms; and to exercise or defend legal claims. We also use cookies to track who, how and when Players use the site in order to deliver relevant regional and Personal Information, and for compliance, security and analysis, such as reducing fraud.
  1. What we do with the information we collect. We use the information we collect to provide our services, and as we describe in this policy. This may include processing information to: provide our products and services; meet contractual and regulatory obligations; provide notice of changes to our service terms or policies; provide customer service and address questions or concerns; to meet legal obligations; to perform identity checks, age verification and ensure responsible gambling (including self-exclusion, or our choice to exclude you ); to communicate with you; for surveys, competitions and promotions; to improve our products and services; to understand the effectiveness of our advertising, and make it more relevant; build a profile of you, your preferences and your habits to better understand your interests; to prevent or detect crime, fraud or breaches of our terms; and to exercise or defend legal claims.
  1. When we disclose Personal Information. We may disclose Personal Information to third parties that help us process it for the purposes we describe. We may also disclose it if we undergo a business transaction or where permitted or required by law. We will also disclose Personal Information to verify your identity, including to confirm your age, identity, and payment details.
  1. Your choices. If you receive commercial email from us, you may unsubscribe from them. You may also change your marketing preferences under “Settings” in your account. Subject to limits in the law, you may access and correct your Personal Information, exercise certain other rights regarding how we use your Personal Information. If you withdraw consent to our processing of information necessary to provide our services, we may no longer be able to provide those services to you.

Definitions

“Applicable Law”

means:

(a)any domestic or foreign statue, law, treaty, code, ordinance, rule, regulation, restriction or by-law, including the Criminal and the Gaming Control Legislation;

(b)any judgement, order, writ, injunction, decision, ruling, decree or award, guideline, policy, standard (including any standard of the AGCO), directive or bulleting, in each case, of any Governmental Authority; and

(c)any franchise, license, qualification, authorisation, consent, exemption, waiver, right, permit or other approval, in each case, of any Governmental Authority,

in each case, in force in the Province of Ontario or otherwise binding on the person referred to in the context in which the term is used, or any provisions of any of the foregoing, including general principles of common law, civil law and equity.

“Electronic Channel”

means an electronic channel accessible via the Internet and includes, but is not limited to, web-based channels (i.e. websites) and download based channels (i.e. applications, downloadable software clients etc.).

“Eligible iGames”

means the prescribed online lottery schemes iGaming Ontario is authorized to conduct and manage pursuant to, and as set forth in, the iGaming Ontario Act and the Alcohol, Cannabis and Gaming Regulation and Public Protection Act, 1996 (Ontario).

“FIPPA”

means the Freedom of Information and Protection of Privacy Act (Ontario).

“iGaming Ontario” (“iGO”)

means a corporation without share capital established pursuant to the iGaming Ontario Act and which is for all its purposes an agent of the Crown.

“Operator”

means ELECTRAWORKS MAPLE LIMITED, company number: 01605615, registered office address 3rd Floor One New Change, London, United Kingdom, EC4M 9AF.

“Operator Offerings”

means the Eligible iGames offered to Players and operated by the Operator, on the Operator Website(s) on behalf and as agent for iGaming Ontario.

“Operator Website”

means an Electronic Channel through which the Operator provides Operator Offerings to Players for and on behalf of iGaming Ontario, and “Operator Websites” means, as applicable, any or all of them.

“Personal Information” (“PI”)

means information about an identifiable individual and includes any information that constitutes personal information within the meaning of one or more Privacy Laws.

“PIPEDA”

means the Personal Information Protection and Electronic Documents Act (Canada).

“Player”

means any person physically located in Ontario who, at the applicable time, has (i) attained the legal age to participate in the applicable Eligible iGame under Applicable Law and (ii) paid the prescribed consideration (if any) and, if and as applicable, has otherwise satisfied the conditions prescribed under Applicable Law in order to participate in the applicable Eligible Games.

“Privacy Risks”

means the risks relating to privacy including but not limited to, inadequate consent or no consent, the over-collection or over-retention of PI, use exceeding scope of identified purposes, collection, use or disclosure of PI for inappropriate purposes, unauthorized access, use or disclosure of PI or other privacy breaches, data breaches involving PI, data and cybersecurity incidents and complaints.

“Privacy Laws”

means all Applicable Law governing the collection, use, disclosure and retention of Personal Information, including the PIPEDA and FIPPA.

Who are we

Electraworks Maple Limited (or the Operator) is a member of Entain Group of companies and operates the Operator Website as part of the open and regulated internet gaming (igaming) market in Ontario conducted and managed by iGaming Ontario. Your Personal Information is collected by us on behalf of and as an agent of the iGaming Ontario.

Where we use the term “we” or “us”, this includes the entity and Brands (https://entaingroup.com/about/business-overview/our-brands/) and other companies within the Entain group.

This Privacy Policy should be read in conjunction with our Cookies and our General Terms and Conditions.

Sources from which we collect Personal Information

We will collect Personal Information about you from the following sources:

  • When you register for an account with us
  • When you visit our websites or our social media sites
  • Through surveys you complete
  • When you communicate with us (by email, mail, phone, in store or through chat, including chat rooms, or social media)
  • When we undertake analysis of your interaction with us
  • From our other group companies for internal reasons, primarily for business and operational purposes
  • From cookies and tracking devices on your devices where you have permitted their use
  • From third parties’ databases (including Credit Reference Agencies) to comply with our legal and regulatory obligations
  • From online vendors and service providers such as financial and shared liquidity services, and from Player lists lawfully acquired from third-party vendors

What Personal Information We Collect, and What We Use your Personal Information for

The collection of Personal Information is necessary for the proper administration of our lawfully authorized activity under the iGaming Ontario Act and the Alcohol, Cannabis and Gaming Regulation and Public Protection Act, 1996 (Ontario) and these constitute our legal authority. The following chart sets out the categories of Personal Information we process and describes the purposes for which we process it.

What we use your Personal Information for

Typical Personal Information

Purpose

Provision of products or services

  • Your name, home or email address, telephone number or online identity or other contact information you provide to us.
  • Your Date of Birth
  • Descriptive Occupation
  • Country
  • Log in information
  • Game Transactional information and payment methods
  • Games played, bets, winnings and losses, deposits and withdrawals, payment methods
  • IP Address
  • Electronic signature card

To meet our obligations arising from any agreements entered into between you and us and provide you with the information, products and services that you request from us, including information about changes to our website, services or our terms, conditions and policies.

Player Service matters
  • Name, online identity, Player ID
  • Contact Information
  • Account notes and communications, call recordings
  • Game Transactional information and payment methods
  • IP Address, MAC address, Device type, apps and location

To provide you with customer services, answer your questions or address your complaints or concerns.

Meeting our legal and regulatory obligations

  • All information included in first section above
  • Name, Online Identity, Player ID, Contact Information
  • Games played, bets, winnings and losses, deposits and withdrawals, payment methods
  • Online images of play and screenshots
  • IP Address, MAC address, Device type, apps, location

To discharge our legal and regulatory obligations and duties which include (but are not limited to) gambling legislation and responsible gambling obligations, Anti-money Laundering, Anti-fraud & Anti-terrorism laws. This may include third party ID verification services and Electronic methods using any Electronic Channels of identifying you, such as through the use of cookies, and images on online play.

Identity Checks, Age Verification and Responsible Gambling
  • Name, Online Identity, Player ID, Contact Information, date of birth and proof of address (utility bill)
  • Log in details
  • Game Transactional information and payment methods
  • IP Address, MAC address, Device type, apps, location
  • Historic communications and account notes, Call Recordings
  • Information on Player’s wellbeing
  • National IDs and passports
  • Images and selfies
  • Any other Personal Information (including sensitive Personal Information) you disclose to us.

To discharge our legal and regulatory obligations and duties which include (but are not limited to) gambling legislation, Anti-money Laundering, Anti-fraud & Anti-terrorism laws.

To meet our Responsible Gambling obligations (such as recording self-excluders and where we believe a Player has a gambling problem).

To check your or validate your identity, age and protect your information.

This may include electronic methods of identifying you, such as through the use of cookies.

Undertake Surveys competitions and promotions
  • Name or online identity
  • Contact details, Home address, Email or phone number
  • Contact preferences
  • Responses to surveys, click through on marketing, preferred products, feedback you provide

To invite you to take part in competitions, to provide us with feedback on your experiences, take up promotions or to keep you informed about products of services which may be of interest to you.

To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

You may opt out of receiving direct marketing communications at any time.

Lifestyle and demographic Insight and Profiling
  • Contact preferences
  • Responses to surveys, click through on marketing, preferred products, feedback you provide
  • Interests and habits

To build a profile of you, your preferences and your habits to better understand your interests and how you play.

Improve our services and ensure our systems are secure and up to date
  • Player ID
  • Log in details
  • Games played,
  • IP Address, MAC address, Device type, apps, location
  • How you use mobile applications and websites

To ensure that content from the site is presented in the most effective manner for you and for your computer, maintain and improve our products and services, optimise business processes, ensure the integrity of our systems and manage our Information Technology estate, undertake quality assurance, support efficient management of our staff, analyse performance of webpages or promotions and provide content that is relevant to you

Prevention and Detection of Crime,

Prevention of loss,

Protection of staff and Players
  • Name, Online Identity, Player ID, Contact Information
  • Log in details
  • Games played, bets, winnings and losses, credits and withdrawals, payment methods
  • Online images of play, video footage and screenshots provided by you when requested.
  • IP Address, MAC address, Device type, apps, location
  • Risk scores, profile classifications
  • Historic communications and account notes
  • List of active software applications and active processes while using our website, including access to files and site-related program folders, according to section 29.4.3 of our Generic Terms and Conditions

To prevent or detect crime, fraud, theft or loss to our business and our Players and prevent the use of unfair practices or advantage over other Players on the site and potential breach of our General Terms and Conditions and of Applicable Law.

To protect our staff and other individuals from harm or loss.

This may include monitoring online activity, electronic methods of identifying you, such as through the use of cookies, your online transactions and payments.

Business sale, acquisition and rights
  • Name, Online Identity, Player ID, Contact Information
  • Log in details
  • Games played, bets, winnings and losses, credits and withdrawals, payment methods
  • IP Address, MAC address, Device type, apps, location
  • Risk scores, profile classifications
  • Historic communications and account notes

To exercise or defend legal claims or acquiring or selling a business

Some of these decisions or actions we may take in managing your account or meeting our legal obligations may involve fully automated decisions. We will however always provide you with contact details where you can ask for a review of the decision or get further information from us.

Who we share your Personal Information with

We may need to share Personal Information with other organisations to ensure that we meet our legal obligations or where we need support in meeting your needs or provide theservices. We may also share information with other organisations where it is permitted or required by Applicable Law.

These other parties are typically:

  • iGaming Ontario as required by Ontario appliable law and our obligations under our agreement with iGaming Ontario;
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, or self-excluded, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing from us;
  • members of the Entain Group and third-party suppliers and service providers for any of the purposes identified in the table above; third party suppliers and service providers to the extent they assist the Entain Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
  • selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your Personal Information for these purposes;
  • analytics and search engine providers that assist us in the improvement and optimization of our site and other selected third parties;
  • other 3rd party organisations who ask, encourage or collate feedback and any online views of your experiences with us to help us improve and optimize our services;
  • banks, credit card companies and relevant agencies who may share with third parties for the purpose of investigating and safeguarding against underage, fraudulent, criminal or suspicious activity or safer gambling (or other activities we are bound by law, regulation or guidance to investigate and safeguard against) or if we have reason to believe that you have undertaken such activity; and
  • our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, applicable independent adjudication services and betting and casino or relevant integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in our services and products or other regulatory or legal matters;
  • when we check your identity when you first register with us, we share information with Credit Reference Agencies, such as TransUnion Canada (via Aristotle provider) and Equifax Canada (via GBGroup). This check will leave a footprint (“Soft-Mark”) on your credit record. Further to the Credit Reference Agencies mentioned above, we will also utilise the services of Jumio, who assist with the capture, verification, and extraction of details from Identity Documents and Proof of Address documents. Further information about how these agencies hold and use your information can be found on their relevant websites.

We may also disclose your Personal Information to third parties in the following circumstances:

  • in the event that we consider selling or buying any business or assets, in which case we will disclose your Personal Information to any prospective sellers or buyers of such business or assets;
  • in the event of any insolvency situation (e.g. the administration or liquidation) of Entain Group plc, or a data controller or any of its group entities;
  • if we, or substantially all of our assets, are acquired by a third party, in which case Personal Information held by us about Players will be one of the transferred assets;
  • in order to enforce or apply our website terms of use;
  • to protect the rights, property, or safety of us, our staff, Players, or others. This includes exchanging information with other companies and organisations (including without limitation, the local police or other local law enforcement agencies if required by law) for the purposes of staff and Player safety, crime prevention, fraud protection and credit risk reduction;
  • if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime;
  • Where you have self-excluded yourself from gambling, we may share this information with our regulators or other companies in our field where we believe it is important to support your exclusion.

We will not share it with other 3rd party organisations unless you have expressly opted-in/consented to the disclosure of your Personal Information for these purposes.

Meeting our Responsible Gambling Obligations

  • We take responsible gambling very seriously at Entain. We may share your information across our brands in the Entain Group, and where required with other organisations to meet our responsible gambling commitments.
  • We have an obligation to identify those at harm from gambling as early as we can and help them stop gambling by placing certain financial and time-based limits on accounts; this could include deposit limits, spend limits or loss limits. In order to meet these obligations, we analyse Player’s transactions and evaluate behaviour or financial status across our products and brands, which may lead us to make decisions on your account(s).
  • We are also constantly looking at innovative ways to help spot Players who may be on a path to difficulties and identify them digitally. This means that we may use systems that identify Players (such as cookies on Player’s devices or images sent by you) and internally we have developed systems to understand your play to better communicate any risks concerning your activity. In all these cases, please be assured that we take our obligations very seriously, in helping Player’s gamble responsibly and in protecting your Personal Information.

How long we retain your Personal Information

The period for which we may retain Personal Information about you will depend on the purposes for which these were collected, whether you have withdrawn your consent, and whether any legal obligations require the retention of the Personal Information (for example, for regulatory compliance). We will retain Personal Information about you for as long as is necessary to fulfil the purposes for which the Personal Information was collected in accordance with our data retention policies and procedures. Where we process your Personal Information for marketing purposes or with your consent, we process the Personal Information until you ask us to stop and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future.

Locations that we may transfer your Personal Information

From time to time, service providers, members of the Entain Group and organisations with whom we work with, may be located outside Canada in countries that do not have the same standards of protection for Personal Information as Canada. Your Personal Information may be transferred to and processed in these countries, including the UK, Gibraltar, India, the EEA, Isle of Man and the USA. We will only transfer your Personal Information outside of Canada where appropriate safeguards have been put in place, such as contractual or other means to provide a comparable level of protection. However, Personal Information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

Security

We take compliance with security regulations, standards, guidelines and privacy laws very seriously and implement security measures that will help maintain the confidentiality, integrity and availability of Personal Information.

We use reasonable organisational, technical and administrative measures to protect Player´s Personal Information from unauthorised access, alteration, disclosure or destruction and mitigate Privacy Risks.

As a business, we have secure firewalled datacentres, certified encrypted webpages and we are ISO27001:2013 certified. We also take steps to help ensure our subsidiaries, agents, affiliates and suppliers employ adequate levels of security across the business.

We also have in place a process to handle security breach incidents ensuring they are dealt with efficiently and with a consistent approach in order to investigate and mitigate the risks associated with the breach incident. In case of a security breach, we will work closely with the iGaming Ontario and other relevant authorities to prevent any adverse effects to you.

Unfortunately, the transmission of information via the internet is not completely secure and no security measures can provide absolute protection. Although we will do our best to protect your information, we recommend you to always keep your information safe.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password secret and confidential and you should update it regularly. We ask you not to share your password with anyone else. We recommend you set up a random and unique password with at least 8 characters long and has a combination of upper and lowercase letters, numbers.

Cookies

We use cookies for various purposes including making your experience of our website better. For more information on our use of cookies, please see our Cookies Policy.

Marketing Communications and your choices

When we first collect your Personal Information, we’ll ask you to tell us how you would like to hear from us in future about our other products and services. It will normally be via a tick box on forms or web page and you can opt-out at any time.

What is 'Opting Out'?

The term opt-out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns such as telemarketing, e-mail marketing, or direct mail.

*Please consider that 'opting out' will not prevent any essential Player correspondence e.g. bet or account related matters.

How can I opt out of marketing correspondence?

If you do not wish to continue receiving any offers, promotions, information on events and tailored communications based on your account activity, you can request to be made un-contactable by:

  • Using the “unsubscribe” option provided in any marketing communication you receive
  • changing your preferences on your account settings
  • contacting our Customer Support

Your rights

You have the following rights, subject to limits set out in the law.

Description of Right

The right of access

A right to access Personal Information held by us about you.

The right to correction

We take reasonable steps to ensure that your Personal Information we process is accurate, complete and up to date in order for us to provide our services effectively. We have established internal processes to verify the accuracy of your information and meet our obligations. We will review your Personal Information on a regular basis to safeguard that we only process the most up to date information.

You are entitled to have your Personal Information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in your Personal Information that we hold.

However, please remember that it is also your responsibility to keep your information accurate and up to date.

The right to withdraw consent

A right to withdraw your consent, where we are relying on it to use your Personal Information (for example, to provide you with marketing information about our services or products). Please note that if you withdraw your consent necessary for us to provide our services, we will not be able to provide them to you.

In addition, if you are a guardian or a parent and become aware that a minor has provided us with his/her Personal Information you have the right to request their erasure.

The right to lodge a complaint

If you have any complaints about any aspect of this Privacy Policy or any other privacy-related issue, you may submit your complaint to us directly by contacting our Privacy Officer at dataprotectionofficer@entaingroup.com or alternatively by following our standard complaint process available at section 22 of our General Terms and Conditions.

If you are unsatisfied with the resolution of your complaint you have the right to lodge a complaint to iGaming Ontario or the Office of the Privacy Commissioner of Canada.

Contact Us or our Privacy Officer

If you have any comments or questions about this Privacy Policy or would like further information about your rights, including exercising them, please contact us by one of the following means:

Our Privacy Officer can also be contacted;

By emailing; dataprotectionofficer@entaingroup.com

By telephone; 0044 2039380000

You may also submit requests to us in writing to: Data Protection Officer, registered office address 3rd Floor One New Change, London, United Kingdom, EC4M 9AF.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the Privacy Laws and all Applicable Laws governing the collection, use, disclosure and retention of Personal Information, including the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA) and Freedom of Information and Protection of Privacy Act (Ontario) FIPPA.

Changes to this Privacy Policy

Any substantial changes to this Privacy Policy in the future will be posted on this page, and where appropriate, notified to you.


This Privacy Policy was last reviewed and updated: 12-04-2022