Last modified: April 12, 2022
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.
In addition to the privacy statements of BETLY, the privacy policies of our partners or third party providers may be applicable and should carefully be reviewed by the player, for example, payment method providers we use such as www.sightlinepayments.com, GeoComply or external providers (such as your Androïd or IoS provider) or social media platforms such as www.facebook.com.
2. Key points about our privacy practices
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.
We may use your information to operate and provide regulated gambling products and services (notably players/wagers registration and authentication, payment, risk & fraud, customer support), as well for i) safety and product research purposes, ii) to comply with legal requirements, such as state law requirements associated with our regulated gaming services and know your customer (“KYC”) requirements; and iii) marketing purposes (player acquisition, player retention, newsletter, event, loyalty program, quality survey, sponsoring).
We may, 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 as required by law and the aforementioned purposes, within BETLY, with our BETLY controlled subsidiaries and affiliates, as well as BETLY partners and providers.
Cookies and Tracking
BETLY has developed a 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
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.
We maintain reasonable and adequate security controls, according to industry standards, to protect your information and require our service providers by contract to do the same. We make good faith efforts to maintain the security of your information. However, despite these efforts, no information system is 100% secure and, therefore, we cannot guarantee the security of such information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time.
We keep information for as long as necessary to provide our products and services, operate our business, and comply with legal obligations.
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
At times, Gamewise may be required to transfer data to the European Union to support the website, app., and platform. 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.
Delaware North Companies Gaming & Entertainment Inc.
ATTN: General Counsel
250 Delaware Avenue
Buffalo, NY 14202, USA
Email: [email protected]
Phone: (901) 554-4988
3. Information Collected
You may provide us with information about you through a number of sources, including: BETLY website registration, BETLY application, product and related events of BETLY partners and affiliates, social media platforms, and payment methods providers.
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,
- civil status,
- ID card/scan, passport,
- address (including city, region, country, continent ID-code),
- 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;
- to provide player support and all support services as set forth in the BETLY House Rules or Terms of Services;
- 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:
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.
- 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 for marketing purposes;
- with third party providers supporting the BETLY platform, betting, games, payment method and other external providers, to the extent necessary to operate the BETLY website and BETLY Application, it being understood that such services providers must comply with contractual confidentiality obligations we impose on them and 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 all or a part of a BETLY business or its assets, including any such activities associated with a bankruptcy proceeding;
- when BETLY believes 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, legal process, 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 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 required our platform, betting and games provider, which is ISO27001 standard certified, to have specific procedures to audit all measures and their effectiveness regarding to security, availability and integrity of Information processed externally.
7. How Long We Keep Your Information
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. Prohibited minors and privacy concerns
The BETLY website is intended only for users over the age of 21. Please leave this website if you are under the age of 21. By continuing, you represent that you are over the age of 21, and release BETLY, our subsidiaries and affiliates, from any and all liability for your use or access to the BETLY website. As such, BETLY does not target or knowingly collect any information from persons under the age of twenty-one (21). Technical measures have also been implemented on the BETLY website and platform in order to prevent registration by minors.
9. Cookies/Tracking Technologies
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.
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.
Browser (mobile phone)
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, in conjunction with Gaming1, has developed a 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.
11. BETLY affiliate and partners – Third Party product and services
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 when providing services through the BETLY website and app, 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.
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) 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.
iii) Cookies. See cookies section.
13. International Data Transfers
By accessing the 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 to the industry standard in order to maximize 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
Effective date: April 12, 2022.