Customer Privacy Policy (Canada)

Who are we

ElectraWorks Limited is a member of Entain Group of companies and this Policy explains what your personal information will be used for. 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. Entain is a global business, and for operational purposes other entities without our group will have access to your data, we may also share controllership jointly with another of our group companies. In these cases, we ensure that your rights are enforceable through the Controller mentioned below.  Please see the section on Your Rights for further information.  

Territory

Name of the Controller

Details

Canada

ElectraWorks Limited

Suite 6, Atlantic Suites, Europort Avenue,

Gibraltar, GX11 1AA

We are committed to protecting your personal information when you use our services through our website and mobile application and take the security of your information very seriously. We have strict security measures in place to protect your personal information which includes robust security procedures, which are regularly tested and reviewed. If you have any concerns about the way in which we process or protect your personal information or would like to contact us about any aspect of this Policy, please get in touch through the contact details at the bottom of this statement.

This privacy Policy should be read in conjunction with our Cookie Policy, any policies or terms on our site.

By agreeing to this Policy, and by use of our site or otherwise, you agree that we may store and use information about you and your account(s) for the purposes outlined in this Policy.

Personal Information we collect about you

We will collect personal information about you from the following sources:

  • When you register for an account with us
  • When you visit our website or our social media sites
  • Through surveys you complete
  • When you communicate with us (by email, mail, phone, 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 public sources of information such as public records or social media postings
  • From cookies and tracking devices on your devices where you have permitted their use
  • From third parties’ databases to comply with our legal and regulatory obligations
  • From online vendors and service providers such as financial and shared liquidity services, and from customer lists lawfully acquired from third-party vendors.

What We Use your Personal information for

What we use your Personal information for

Typical Personal information

Further information

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, gender
  • Log in information
  • Game Transactional information and payment methods

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

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

To identify if the services are restricted in your location and to comply with local laws and regulations.

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

Customer 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.

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

Meeting our legal and regulatory obligations
  • 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 and tracing data.

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 electronic methods 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 gender
  • Log in details, websites and webpages visited
  • Game Transactional information and payment methods
  • IP Address, MAC address, device type, apps, location and tracing data.
  • Historic communications and account notes, call recordings
  • Information on customer’s wellbeing
  • Images and selfies
  • Additional checks which may include obtaining data from other sources such as public domain information or credit history.

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

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

To identify if the services are restricted in your location and to comply with local laws and regulations.

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.

Some of these interactions may be online or through social media.

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.  We may use these profiles to contact you through social media to promote our business.

Improve our services and ensure our systems are secure and up to date
  • Player ID
  • Log in details, websites and webpages visited
  • 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 customers
  • Name, Online Identity, Player ID, Contact Information
  • Log in details, websites and webpages visited
  • Games played, bets, winnings and losses, credits and withdrawals, payment methods
  • Online images of play, video footage and screenshots
  • IP Address, MAC address, Device type, apps, location and tracing data.
  • 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
  • Other additional checks which may include obtaining data from other sources such as public domain information or credit history.

To prevent or detect crime, fraud, theft or loss to our business and our customers and prevent the use of unfair practices in our websites or 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, location data and your online transactions and payments.

 

In certain circumstances, such as high depositing players and/ or politically exposed persons, we will carry out enhanced due diligence focused on source of funds and background checks. These due diligences could include additional documentation provided by players, based on a case-by-case basis, or information available in the public domain.

Business sale, acquisition and rights 
  • Name, Online Identity, Player ID, Contact Information
  • Log in details, websites and webpages visited
  • 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

Much of the information we collect about you is required to meet our legal and regulatory obligations, such as gambling legislation or any other applicable laws, however, we will rely on your consent prior to the collection, use, or disclosure of personal information, unless an exception applies. Where we have specified that the legal basis upon which we collect your information is in relation to the performance of a contract, failure to provide that information to us may delay or prevent us from fulfilling our contract with you. Where we require information to enable us to perform a contract with you or to comply with our legal obligations, failure to provide that information to us could mean that you are unable to use any of the services we provide.

We may also store more sensitive personal information about you which may come directly from you, from other sources as described above or from decisions we have made about you (e.g. Responsible Gambling related data).

Some of the decisions or actions we may take in managing your account or meeting our legal obligations may involve 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.

In jurisdictions where consent is the legal basis on which personal data may be processed, you consent to our processing of your personal data for the purposes set out above, subject to your ability to withdraw consent at any time by contacting us using the details in the ‘Contact’ section below. This will only affect the way we use information when our reason for doing so is based on your consent (e.g. for marketing purposes) and does not have retroactive effect. See the ‘Your rights as a data subject’ section for more information about the other rights you have in relation to your personal information.

In the event of a registration where we receive notice that a player submitted an inaccurate birth date (upon account creation) and is under the legal Age of Majority, we will close their account.

Who we share your data with

We may need to share personal information with other organisations to ensure that we meet our legal obligations, where we need support in meeting your needs or our contractual obligations or where it is permitted or required by applicable law. These other parties are typically:

  • 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, have been barred 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 (including employees and representatives) 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.;
  • 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). 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. Further information about how these agencies hold and use your information can be found on their relevant websites.
  • 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 use of the services, client identity, money laundering checks, 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 integrity organisations and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, maintaining standards of behaviour in the services we provide or other regulatory or legal matters.

We may share your personal information with other members of the Entain Group.  We will not share it with other 3rd party organisations however unless you have expressly opted-in/consented to the disclosure of your personal information for these purposes.

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 our customers 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, our customers, or others.  This includes exchanging information with other companies and organisations (including without limitation, other gambling operators and the local police or other local law enforcement agencies) for the purposes of staff and customer 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.

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 a moral obligation to identify those at harm from gambling as early as we can and help them stop gambling by placing certain limits on accounts; this could include us reaching out to you about your account(s), us enforcing deposit or product limits, or limiting the ability of an account to gamble certain products / times / periods. In order to meet these obligations, we analyse customer’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 customers (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 customers gamble responsibly and in protecting your personal information.

How long we retain your personal information

Type of Data

Typical Retention Time

Information

Customer call recordings

3 years

An extended retention may be applied on a case-by-case basis

Customer Data

(retention period which starts from the date you request the closure of your account, or your account becomes inactive)

7 years

We will only continue to hold personal information relating to your account as permitted under data protection legislation (i) where we are under a legal requirement under gambling or tax legislation to retain your data; and (ii) to exercise or defend our legal rights

If you register under the self-exclusion scheme, whilst the self-exclusion itself may have a shorter duration, a record of this will be retained longer as part of your customer profile.

*For inactive accounts, please note that accounts are fully closed after 12 months of inactivity. You may contact us and request the closure of your account at any time. The above retention periods may be extended where we need to comply with a specific regulatory obligation, address a claim, and/or provide evidence in connection with a dispute, including to exercise or defend our legal rights. If You enrol in the self-exclusion program, although the self-exclusion itself may have a shorter duration, a record of it might be kept for a longer period of time as part of your customer profile.

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 your jurisdiction in countries that do not have the same standards of protection for personal information. Your personal information may be transferred to and processed in these countries, including EEA, Gibraltar, the UK, India or another third country when the services require it. Where we transfer your personal information outside Canada, we will do so in reliance on an adequacy decision by the European Commission or the UK Information Commissioner (as appropriate) or subject to agreements with third parties that incorporate the standard data protection clauses approved by the relevant privacy authority subject to applicable privacy national laws.

 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. Please contact us on the email address below if you have any specific questions regarding international transfers.

We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your personal information is processed in accordance with applicable data protection legislation.

User Consent

By providing your personal information and accepting this privacy Policy, you explicitly consent to the collection, use, or disclosure of personal information, unless an exception applies, for the provision of the services, the purposes set put above or as otherwise provided in accordance with the Terms and Conditions.

If you wish to qualify, vary, modify or limit your consent in relation to marketing communications or in circumstances where any processing of your data is likely to cause damage or distress or such other circumstances as the law allows then you may do so by referring to the "Opting Out" section of our Privacy Policy.

Telephone calls and betting data relating to users will be recorded and may be actively monitored for training, security and complaint management purposes. Users hereby consent to these purposes.

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 customer personal information from unauthorised access, alteration, disclosure or destruction of personal information that we hold.

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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. We cannot ensure or warrant the security of any information you provide to us.

Links

The site contains links to a limited number of other sites. We are not responsible for the privacy practices or the content of such web sites.

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 boxes 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 and anti-spam rules such as telemarketing, e-mail marketing, or direct mail.

*Please consider that 'opting out' will not prevent any essential customer services correspondence e.g. bet or account correspondence.

How can I opt out of marketing correspondence?

If you do not wish to receive 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 directly.

Your rights

 

Description of Right

The right of access

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.

The right to be informed

A right to access personal information held by us about you.

The right to correction

A right to require us to correct any inaccurate personal information held by us about you, if it is inaccurate.

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 consent necessary for us to provide our services, we will not be able to provide them to you.

The right to lodge a complaint

If you have any complaints about how we have used your personal information, you can contact us using the details in the ‘Contact’ section below.

You can also have the right to submit a complaint to the Kahnawà:ke Gaming Commission and the Office of the Information Commissioner in your jurisdiction of residence.

Contact Us

If you would like to exercise any of your data protection rights, such as the right of access to your information or data deletion, directly by yourself or by a third party on your behalf, please contact [email protected].

If you have any questions about this Policy or would like further information about your rights, please contact us by emailing: [email protected].

Attention: Privacy Officer

Suite 6, Atlantic Suites,

Europort Avenue,

Gibraltar, GX11 1AA

*Please note that these channels are not monitored for any customer service-related queries.

Changes to this Privacy Policy

Any changes to this privacy Policy in the future will be posted on this page, and where appropriate, notified to you. Please check back frequently to see any updates or changes to this privacy Policy.

This policy was last reviewed and updated: 28/10/2024.