Privacy Policy

1. General Information

Well Played Media Unipessoal LDA, with company registration number 516739972 of Avenida Arriaga, N.º 30, 1.º Andar, Sala A 9000 064 Funchal Ilha da Madeira (“We”, “Us”, “Our”) is committed to protecting and respecting the privacy rights of the user (“You”, “Your”) of the Website www.casinodays.com/on ( “Website”), which includes any Personal Information that You may choose to provide Us on this Website. For the purposes herein, We are the Data Controller.

This Privacy Notice (together with Our Terms and Conditions and Cookie policy) is meant to help You understand what data We collect, why We collect it, and what We do with it. When You share information with Us, We can make our services even better for You. For instance, We can show You more relevant search results and ads, help You connect with people or to make sharing with others quicker and easier. As You use our services, We want You to understand how We are using information and the ways in which You can protect Your privacy.

Please read the following carefully to understand Our views and practices and where You can find controls to manage Your information and protect Your privacy and security.

2. How is Your data collected?

2.1. Information We collect from You

Our Website collects data to operate effectively and provide You with the best experiences with Our services. You provide some of this data directly, such as when You create a personal account. As is described in further detail in our Cookie Policy, We get some of it by recording how You interact with Our services by, for example, using technologies like cookies, and receiving error reports or usage data from software running on Your device. We also obtain data from third parties (including other companies). The data We collect depends on the services and features You use.

In particular, We process personal details such as name and surname, email address, postal address, telephone number and date of birth collected pursuant to legal obligations we are subject to. Personal Information may include, but is not limited to, information that You provide when You register to use Our Website, enter any competition or promotion, complete surveys, communicate with our Customer Support team and/or when You report a problem with Our Websites. The information You provide Us may include Your name, address, e-mail address and phone number, personal description, and photograph. In addition, when You interact with the Websites, Our servers keep an activity log unique to You that collects certain administrative and traffic information including, but not limited to: source IP address, time of access, date of access, device and browser used to access the Website, Your activity on the Website, games played, session times, financial transactions, play limits set, language and other account preferences, and software crash reports. This information is essential for the provision and quality of the services provided by the Website. We do not collect Personal Information about You on the Website without Your knowledge.

We are, on the basis of the applicable laws and license conditions, legally obliged to monitor Our players in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and interact with them to offer help or support. To this end, and to fulfil this obligation, by using historic data describing behaviour of players, in particular certain responsible gambling data, transaction and usage data, and other generic communication data (in particular, specific sentiments used in messages or chats) We have established rules regarding who is likely to suffer from gambling addiction and then take relevant action.

We are also legally obliged to monitor Our players in order to identify potentially suspicious activities regarding AML/CFT. Based on data describing the behaviour of players, in particular transaction and usage data, the algorithm suggests a risk profile. Any decisions on the basis of the prediction are not taken automatically and require human intervention.

The collection, storage, use and disclosure of Your personal data, including Personal Information, is undertaken pursuant to, and in accordance with the Freedom of Information and Protection of Privacy Act (Ontario), 1990 (“FIPPA”) and Personal Information Protection and Electronic Documents Act (“PIPEDA”).

We operate and make our services available via the Website as part of Our participation in the regulated internet gaming market in Ontario, which is conducted and managed by Alcohol and Gaming Commission of Ontario (AGCO).

2.2. Registration and Account Activation

Upon registering an account with Us, We will collect certain identity, demographic, and contact information from You. This information will be used to administer Your account throughout Your use of Our products and services, to confirm Your eligibility for registration, and for anti-fraud and legal compliance purposes.

Prior to activating Your account, We will seek to verify Your identity. To do so, We may share some of the information You provide at registration with reputable third-party identity verification service(s). In the event that Your identity cannot be verified with the information You provided at registration, We may require that You submit additional information or proof of identity prior to the completion of registration and the activation of Your account. Access to any such additional information will be strictly controlled and only those of our personnel who require access to the same to complete the identity verification process will be granted access. The information will be retained in a manner consistent with this Privacy Policy and Our internal retention and information security procedures.

3. How We Process Your Information

When You create an account, You are giving Us Your Consent to collect and process Your personal data as explained in this Privacy Notice.

We use the information that we hold about You, including Personal Information, to:

carry out Our obligations pursuant to the contract entered into between You and Us in accordance with the Terms and Conditions and to provide You with the information, products and services that You request from Us;
provide You with information about other services We offer that are similar to those that You have already used, enquired about and/or shown an interest in;
permit and assist the Website’s compliance with applicable law and regulatory obligations, and to maintain the integrity of Our business;
notify You about changes to Our service;
to ensure that content from Our Websites is presented in the most effective manner for You and for Your device.
We may monitor, record, store and use any telephone, email or other communication with You in order to confirm any instructions given to us, for training purposes, for fraud and/or crime prevention and to improve the quality of our customer service.

Personal Data that are automatically collected about You and/or received from third parties will be used to operate Our Websites as well as to ensure that content from Our Websites is presented in the most effective manner for You and Your device. To give a few examples this includes:

administration of Our Website and internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
keeping Our Website safe and secure;
combining Personal Data from third parties with the information We hold to personalize and enhance Your experience on Our Websites.

4. Disclosure of Your Information

For the purposes described above, Your personal data may be shared with any third party and any associated company within the Rhino Entertainment Group to which WPM belongs. We share Your personal data with Your consent or as necessary or provide any service You have requested or authorized. We also share personal data with vendors or agents working on Our behalf for the purposes described in this statement. For example, companies We contract with to provide customer service support or assist in protecting and securing Our systems and services may need access to personal data in order to provide those functions. In such cases, these companies must abide by Our data privacy and security requirements and are not allowed to use personal data they receive from Us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Additionally, we may disclose Your Personal Information to any regulatory authority, law enforcement agencies or if so required by any legal obligations.

5. Data Storage and Data Retention

Personal Information We collect is retained in accordance with applicable law and Our records retention policies, as amended from time to time. After any applicable retention period for records containing Personal Information has elapsed, the records are securely destroyed in accordance with Our information security policies, unless and to the extent required to be retained by any ongoing legal and/or regulatory obligations. Throughout the retention period, We will make reasonable efforts to ensure personal information in Our custody, or under Our control, is kept accurate, complete, and up to date. Please contact [email protected] to advise Us of any updates or corrections You would like to make regarding Your Personal Information.

We have implemented industry-standard physical, procedural, and technological security measures to protect any personal information in Our custody and under Our control. By submitting Your personal data, You agree to Our storing and processing Your Personal Information. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy including, but not limited to, the entering into of written data processing agreements, as appropriate, with any third party which may be requested to process data on Our behalf.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect Your personal data, We cannot guarantee the security of Your data transmitted to the Website; any transmission is at Your own risk. Once We have received Your information, We will use strict procedures and security features to try to prevent unauthorised access. We will notify You and any applicable regulator of a suspected data security breach where We are legally required to do so.

6. Your Rights

You can view or edit Your personal data online for many of Our services. You can also make choices about Our collection and use of Your data. How You can access or control Your personal data will depend on which services You use.

Right of access

You have the right to access Your personal data and to receive Your personal data which You have provided to Us in a structured, commonly used and machine-readable format;

Right to correction

You have the right to require Us to correct any mistakes and/or changes to Your information in Our possession;

Right of erasure

You have right for Your personal data to be deleted if there is no other legal basis that justify their retention;

Right to data portability

You have the right to transmit Your personal data to a third party;

Right to object

You have the right to object at any time to processing of Your personal data for direct marketing and to object to processing of Your personal data in a situation where such processing is based on tasks carried out in public interest or based on legitimate interest;

Right to restrict

You have the right to ask for Your data not to be processed for the period of deciding about Your complaint in regard of challenging legality of processing of data, punctuality of data, if legitimate interest is outweighing Your rights and in situations where You want Your data to be kept for potential legal claims;

Right to lodge complaint

You may adjust Your preferences in the “My Account” section of the Website and You may also exercise these rights at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of the processing of data which was carried out by Us or on Our behalf, before consent was withdrawn.

Our Website may, from time to time, contain links to and from the websites of Our partner networks, suppliers, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.

When exercising your rights by contacting us, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

7. International transfers

The data that We collect from You will be transferred to, and stored within EU borders, and will be processed by individuals operating outside of Ontario who work for Us, or for one of Our suppliers. This includes staff engaged in, among other things, the fulfilment of Your requests, and the provision of support services.

We will take all steps reasonably necessary to ensure that, at all times, Your data is treated and handled securely and in accordance with this Privacy Policy and all applicable laws and agreements including, but not limited to, the entering into of written data processing agreements, where appropriate, which oblige Our suppliers to comply, in all material respects, with the protections afforded to Your personal data by the applicable laws.

8. Complaints and Enquiries

You may address any complaints or enquiries that You may have regarding Our handling of Your personal data by following the below process:

In the first instance, please submit Your complaint/enquiry via email to [email protected], providing as much detail as possible. Our Customer Support team will endeavour to respond to You within 7 days of receiving Your complaint/enquiry.

In the event that You feel that Your complaint/enquiry has not been dealt with satisfactorily by Our Customer Support team, You may request that the matter be escalated to Our Data Protection Officer, who will review Your case and endeavour to respond to You within 30 days, which period may be extended by two months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within 30 days of receipt of the request, together with the reasons for the delay. Please note that the Data Protection Officer may elect not to respond directly to complaints/enquiries which have not first been submitted to Our Customer Support team.

Should You not be satisfied with the response you receive from Our Data Protection Officer, You may elect to escalate Your complaint/enquiry to Information and Privacy Commissioner of Ontario (IPC) by requesting a copy of Your complaint file from Our Data Protection Officer and furnishing the same to IPC via any methods set out on the IPC web page from time to time.

9. Privacy breach

The protection of Your personal data is of the utmost importance to Us, and We are committed in Our efforts to prevent and/or restrict third parties from being able to gain access to Your Personal Information and other data (“Privacy Breach”).

No systems are entirely infallible and it is possible that Privacy Breaches may occur, in which case We are also committed to cooperating and working with the necessary regulatory bodies, and law enforcement agencies, to minimise the extent of any such Privacy Breach, as well as its potential impact on those affected.

Should you become aware of, or suspect, a breach of Your, or any other person’s privacy, you should immediately report the same to Us by emailing [email protected].

10. Changes

We reserve the right to make changes and corrections to this Privacy Notice from time to time. Any remarkable changes or corrections that change the material contents of this Privacy Notice will be posted on Our Site. Please note that each version of this Notice is identified by its effective date.

11. Contact

Our Data Protection Officer can be contacted by emailing [email protected].