Last Revised: August 4, 2022
1. PURPOSE AND SCOPE
Any questions in this regard may be directed to the Privacy Compliance Officer using the contact information provided below.
3. HOW WE COLLECT AND USE INFORMATION
We collect and use the following types of information as follows:
(A) Information you provide us directly: We and/or our service providers may ask for certain personal information from you, including your first and last name, postal address, email address, telephone number, date of birth, social security number, driver license number, credit card information, banking information (collectively “PII”), and other demographic information about you (such as your gender, industry of your occupation, job title, and employer information) (“Demographic Details”), in order to verify your identity, to provide the Service to you, or in order to verify your identity if you contact or interact with us. You must advise us of any relevant changes to your information as provided to us and we do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the information that you previously provided to us. We may also retain any messages you send through the Service, and may retain other information you voluntarily provide us with, including but not limited to your comments and other content. Please note that specific items of PII and Demographic Details we and/or our service providers may request from you may differ depending on the laws and regulations of the jurisdiction from which you access the Service.
(B) Information collected by the Service when you use the Service: In addition to the information you provide to us directly, we and/or our third party service providers may utilize technology that automatically or passively store or collect certain information when you access the Services (“Service Usage Data”). This Service Usage Data may be stored or accessed using technologies that may be downloaded to the device you use to access the Service. Service Usage Data and the technology used to process them include the following:
- Log file information: Log file information is automatically reported by your browser each time you access a web page or other content within the Service. We may also receive log information relating to your device and your use of our Apps. When you use the Service, our servers automatically record certain log file information (“Server Logs”). These Server Logs may include anonymous information such as your web request, Internet Protocol (IP) address, operating system, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. The information contained in Server Logs is used to monitor, assess, manage, diagnose problems with, improve and otherwise administer the Service.
- Clear gifs/web beacons information: “Clear Gifs” (also known as web beacons) are used to anonymously track the online usage patterns of our users. We also may use Clear Gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. You can disable the ability of Clear Gifs to track certain information by setting your browser to refuse certain Cookies. The information allows for more accurate reporting, monitoring and improvement of the Service.
- Embedded Scripts and Browser Fingerprinting: “Embedded Scripts” are lines of code that is designed to collect information about your use and interaction with the Service, such as links you tap on. Embedded Scripts are temporarily loaded onto your device by us and/or our service providers when you connect to or access our Service. They are active only when you remain connected to the Service and are deactivated or deleted when you disconnect. “Browser Fingerprinting” is the collection and analysis of your device’s information, such as your operating system, plug-ins, and other data, for identification purposes.
- Device identifiers: When you access the Service by or through a mobile device (including but not limited to smartphones or tablets), we and/or our third party service providers may access, assign, collect, monitor and/or remotely store one or more unique device-specific identifiers, such as a universally unique identifier (UUID) (“Unique Identifiers”). Unique Identifiers are small data files or similar data structures stored on and/or associated with your mobile device, which uniquely identify your mobile device. A Unique Identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us. A Unique Identifier may convey information to us and our service providers about how you browse and use the Service. A Unique Identifier may also be used to help you log in faster and enhance your navigation through the Service.
- Entity Tag: An opaque identifier is assigned by a web browser, as a feature of the cache in browsers, to a specific version of a resource found at a URL (“Entity Tag” or “ETag”). A new ETag is assigned if the resource content at that URL changes. When used this way, an ETag is a form of device identifier.
- Advertising identifiers: Advertising identifiers are unique strings associated with your mobile device provided by the operating system (“Advertising Identifiers”). We may use Advertising Identifiers for our own internal analytics purposes to identify application usage, for marketing and promoting our and our affiliates’ products and services to you, and for troubleshooting and technical support purposes.
- Recognition Technologies: These are technologies that attempt to identify, recognize, and/or make assumptions about users and their devices use and interaction with the Service, which may include applying statistical probability to existing data sets, machine learning, and artificial intelligence. When you use the Service, certain information regarding your use of the Service may be used by us or our service providers using recognition technologies to enable the provision of the Service to you, to identify general usage trends about our Service, and to analyze and mitigate risks related to the Service.
- Location data: When you access the Service by or through a mobile device or a browser, we may access, collect, monitor and/or remotely store location data, which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device (“Location Data”). Please note the following:
Location Data may convey to us information about how you browse and use the Service. Location Data may also be used to personalize and customize your experience when using the Service, facilitate the functionality of certain features within the Service, display customized promotions and offers relevant to you, provide location-based advertising to you, and to improve the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of Location Data is impaired or disabled.
(C) Photos: When you register for an account in order to use the Services, the App may request permission to access your device’s camera functionality in order to capture photographic images (“Photographs”). We and our ‘know your customer’ service providers may use Photographs for the purposes of verifying your identification and to record a copy of government issued ids for identity purposes.
(D) Information we may collect and/or receive from third parties: We may receive information about you from third parties you interact with while accessing the Service. We also may collect information about you from third party business partners, service providers, and publicly available sources for the purposes of providing the Service to you. We may supplement information we collect from you directly or from your use of the Service with information from third party sources for various purposes, including providing the Service to you, “know your customer” (KYC) verifications to confirm your identity and satisfy regulatory reporting and compliance requirements, payment transaction verification to ensure transactions are processed correctly, improving our product and service offerings, to provide you with a personalized experience when using our Service, to offer you products, services and promotions that may interest you.
(F) Information you provide about someone else: You may communicate with someone else while using the Service, which may include sending an invitation to someone you know. The information you provide about that person is used to facilitate your communication with them and to otherwise invite them to the Service. When you communicate with another person via the Service, some of your information, such as your name, nickname, and other contact information may be included in the communication to that person.
(G) Use of Information: We use the information collected for our internal business purposes and to operate, maintain, and provide to you the features and functionality of the Service. Specifically, this includes the following:
- The purposes for which you provided it
- Providing information and Service to you
- Compiling aggregate data for internal and external business purposes
- Verifying your identity (i.e. KYC verifications)
- Confirmation, processing and investigation of financial transactions
- Providing you with customer support services
- Operation of our loyalty rewards program, including sending you information on such programs via email and other electronic communication means
- Operation of promotions and special offers, including sending you information on such promotions and offers via email and other electronic communication means
- Assessing activity for responsible gaming purposes
- Providing you with a safe and secure environment and to protect and administer your account
- Analyzing anti-money laundering, fraud and credit risk
- Investigating potential or suspected violation of gambling rules, sports wagering rules, corruption of a sport’s or event’s integrity, and violation of applicable laws
- Performing our obligations under our operating agreement with iGaming Ontario (“iGO”)
- Compliance with licensing and regulatory requirements
- Assisting law enforcement and responding to subpoenas and lawful access requests
In addition, we use or may use Service Usage Data to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide personalized content and information; (iii) provide and monitor the operations and effectiveness of the Service; (iv) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (v) diagnose or fix technology problems; (vi) help you efficiently access your information after you sign in; (vii) provide targeted and personalized advertising, marketing, promotions and offers to you; (viii) automatically update our App on your mobile devices; (ix) allow you to comment on or provide content and participate in contests, special offers and/or promotions; and (x) conduct research, beta testing or surveys.
Please note that we may also use information about you for purposes that are reasonably ancillary to providing you with the Service.
(H) Commercial and marketing communications: We use the information we collect or receive to communicate with you, directly or through the use of a third party service provider. We may send you electronic messages containing Service-related notices (e.g., account verification, purchase and billing confirmations and reminders, feature notifications, technical and security notices). We may also send you electronic messages containing product and/or service offerings, promotions, invitations and special offers. You can also stop receiving electronic messages (other than Service-related notices) from us by clicking on the “unsubscribe” link provided in such communications or by changing your account preferences or settings.
(I) With consent: We may use your information for any other purpose for which you consent.
4. SHARING OF YOUR INFORMATION
(C) Name and Likeness: We may publish your name, voice, likeness and other information that is part of Your Content, and we may use such content, and parts of it, for advertising, marketing, publicity and promotional activities.
(D) What happens in the event of a business change: If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection therewith.
(F) Sharing certain service type information we collect about you: We may share certain service type information, including Service Usage Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third party business partners and service providers for the purposes described in the section above on “How We Collect and Use Information.” We may also aggregate or otherwise strip data of all personally identifying characteristics (such as your name and email address) and may share that aggregated, anonymized data with third parties.
(G) Promotions on the Service: We may also share certain information and data, such as Service Usage Data and other data relating to your use of the Service, to deliver promotions and offers (“offers”) from third parties advertisers that may be of interest to you within the Service.
(I) Data Analysis: We may use third party data analysis service providers to collect data and to provide information to us on the performance of our Service. These companies may use information about your use of the Service and other websites and mobile applications to compare information about the performance of our Service. These companies do not use personally identifiable information (such as your name, address, email address or telephone number) when performing data analysis. These companies may also use non-Cookie technologies to recognize your computer, browser or mobile device and/or to collect and record information about your browsing activity, including your activities on or off the Service and between multiple platforms such as your computer and your mobile device. Please keep in mind that your browser settings may not permit you to block the use of these non-Cookie technologies, and those browser settings that block Cookies may have no effect on such techniques.
5. HOW WE PROTECT YOUR INFORMATION
We care about the security of your information, and take physical, technological and administrative measures to protect the information you submit via the Service against loss, theft, and unauthorized access, use, disclosure or modification. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered or destroyed. Electronic communications sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email.
You also have a role to play in protecting the security of your account and your information. Never share your account credentials, including username, email address, password, and other log-in details, or let other people use your account. You should notify us immediately of any actual or suspected unauthorized use or access of your account or password or any other similar breach of security.
6. HOW WE RESPOND TO PRIVACY BREACHES
In the event that we become aware of any privacy breach we will investigate, contain, eradicate, and secure vulnerabilities, initiate recovery procedures in accordance with our security procedures. Further, we will provide necessary notices to affected business partners, affected users, and applicable regulatory authorities in accordance with our contractual obligations and applicable law. In Ontario, we will notify iGO of the breach and cooperate with iGO and any related authorities with any investigation or other response to the breach.
7. YOUR RIGHTS AND CHOICES ABOUT YOUR INFORMATION
(A) You control your account information and settings: You may update your account information and electronic message preferences at any time by logging in to your account and changing your profile settings or by contacting us as described in “How to Contact Us” below. You can also stop receiving electronic messages (other than Service-related notices) from us by clicking on the “unsubscribe” link provided in such communications.
(B) Access, questions, complaints or concerns: If you have any questions, complaints or concerns, or if you simply want to know whether we have any of your PII on file, you may contact our Privacy Compliance Officer as described in “How to Contact Us” below. Except as set out in applicable privacy laws, we can tell you whether we hold PII about you. You can contact us to review, change, obtain a copy of your information or have your details altered, deleted, or corrected in accordance with your rights under applicable laws and regulations. In this event we may require evidence of and be satisfied as to your identity before we take any requested action. We will use reasonable efforts to tell you the source of the information and give an account of the use that has been made or is being made of the information and the third parties to whom it has been disclosed. If you are not satisfied with the response from the Privacy Compliance Officer after making a request, you may have recourse to additional remedies under applicable privacy laws. In Ontario, you may contact our Privacy Compliance Officer as described below or in accordance with the “Disputes” section of our Ontario Terms available at https://thescore.bet/legal/ca-on-terms for privacy-related complaints. If you are not satisfied with our response to your complaint, and you feel you have exhausted all reasonable means to resolve your complaint, you may request a copy of your case file, in order to escalate your complaint to iGO.
(D) Do Not Track: At this time, we do not recognize “do not track” signals sent from browsers.
8. HOW LONG WE KEEP YOUR INFORMATION AND YOUR CONTENT
After the relevant period described above, we will dispose of your PII or other information in accordance with our applicable data retention and destruction policy.
9. LINKS TO OTHER SITES AND SERVICES
10. CHILDREN'S PRIVACY
Individuals who do not satisfy the legal gambling age for the jurisdiction(s) in which they seek to access the Services are not eligible to use the Services. Accordingly, we do not knowingly collect personal information from individuals under the legal gambling age in their jurisdiction. If you are under the legal gambling age in your jurisdiction, please do not submit any personal information through the Service. If you have reason to believe that we may have accidentally received personal information from an individual under the legal gambling age in their jurisdiction, please contact us immediately at firstname.lastname@example.org.
If you are the parent or guardian of a minor child who has provided us with any personal information, you may request that we delete such information by contacting us at email@example.com.
11. CALIFORNIA CONSUMER PRIVACY ACT (CCPA) RIGHTS
As of January 1, 2020, if you are a California resident, the following rights as expressed under the California Consumer Privacy Act of 2018 (“CCPA”) are applicable to you:
a. You may request that we disclose to you, free of charge (unless your requests are manifestly unfounded or excessive):
i. the categories and specific pieces of personal information that we have collected in the preceding twelve (12) months;
ii. for personal information that we have collected in the preceding twelve (12) months, the categories of personal information that we have collected about you, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, and the specific pieces of personal information we have collected about you;
iii. for personal information that we have sold or disclosed for a business purpose in the preceding twelve (12) months, the categories of personal information that we have collected about you, the categories of personal information that we have sold about you, the categories of third parties to whom the personal information was sold (by category or categories of personal information for each category of third parties to whom the personal information was sold), and the categories of personal information that we have disclosed about you for a business purpose;
To exercise the above right, you must provide a verifiable consumer request by either emailing us at firstname.lastname@example.org or by writing to our Privacy Compliance Officer at the address below.
b. You may request that we delete personal information about you that we may have collected. To exercise this right, you must provide a verifiable consumer request by either emailing us at email@example.com or by writing to our Privacy Compliance Officer at the address below. The CCPA contains exceptions which may limit how we respond to your direction. Please note that due to the nature of the Services and the regulatory requirements related to the Services, you may not be able to use the Services if you request that we delete your personal information that we may have collected.
c. Under the CCPA, “sell” means sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. If you wish to exercise the right to opt out, you may email us at firstname.lastname@example.org or by writing to our Privacy Compliance Officer at the address below. The CCPA contains exceptions to this definition which may limit how we respond to your direction. Please note that due to the nature of the Services and the regulatory requirements related to the Services, you may not be able to use the Services if you opt out.
i. User Data: PII, Demographic Details, Photographs
ii. Service Usage Data: Analytics Information, Cookies, Server Logs, Clear Gifs, device information, usage history
iii. Identifiers: Unique Identifiers, ETag, Advertising Identifiers, Location Data
If you are a California resident and you have questions regarding your rights under the CCPA, you can email us at email@example.com or write to us at:
Privacy Compliance Officer
500 King Street West, 4th Floor
Toronto, Ontario M5V 1L9
12. LEGAL AUTHORITY - ONTARIO
In Ontario, Canada, we operate the Service as part of the open and regulated internet gaming (iGaming) market in Ontario conducted and managed by iGaming Ontario and we collect, use and disclose personal information on behalf of, and as an agent to, iGO under our Operating Agreement with iGO. iGO asserts the legal authority to collect personal information under the Freedom of Information and Protection of Privacy Act (Ontario) and O. Reg. 722/21: LOTTERY SUBSIDIARY - IGAMING ONTARIO made under the Alcohol and Gaming Commission of Ontario Act, 2019 (Ontario).
14. HOW TO CONTACT US
For user account related inquiries, please contact our Customer Support team by email at firstname.lastname@example.org.
Privacy Compliance Officer
500 King Street West, 4th Floor
Toronto, Ontario M5V 1L9