Mr Vegas Privacy Policy

http://mrvegas.ca/ (hereinafter the “Website”), is operated by:

Videoslots Limited (“Videoslots Ltd”), a private limited liability company constituted under the laws of Malta and has its registered office at The Space, Level 2 & 3, Alfred Craig Street, Pieta PTA 1320, Malta; or in accordance with the relevant license(s) and jurisdictions where it is licensed to operate.

Any reference to “We”, “Our”, “Us” or the “Company” in this Privacy Policy shall be construed as reference to Videoslots Ltd’s operations of Mr Vegas and/or the Website (hereinafter the “Services”). Any reference to “You” or “Your” in this Privacy Policy shall be construed as reference to Our players and customers. 

This Privacy Policy (together with Our terms and conditions and Our cookie policy) sets the standard for how the Company collects, stores and uses Your personal data when You visit Our Website, as well as what Your rights are, how the law protects these rights, and how You can exercise them (hereinafter the “Privacy Policy”).

The Company values Your integrity and privacy immensely and is committed to processing all of Your personal data transparently, fairly and lawfully.

The Services are being offered by Mr Vegas as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (http://www.igamingontario.ca/en). In the course of providing the Services; 

(i)Mr Vegas collects, uses and discloses personal information on behalf of, and as agent to, iGaming Ontario; 

(ii)Mr Vegas collects personal information in accordance with the Freedom of Information and Protection of Privacy Act (FIPPA) and The Protection of Privacy and Electronic Documents Act (PIPEDA), and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario (AGCO) Act, and the operating agreement entered into between Mr Vegas and iGaming Ontario; 

(iii)Mr Vegas also processes, handles and stores Your personal information in line with the AGCO’s Registrar Standards for Internet Gaming.

Valid from Date	Description	Version
16.12.2022	Creation of the document	1.0

1. About Us
2. Your Data
3. Sharing of Data
4. Transfers of Personal Data
5. Automated Decision Making
6. Technical and Organisational Measures
7. Data Retention
8. Your Rights

 

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1. ABOUT US

(a) Purpose of Policy

This Privacy Policy aims to provide You with a thorough understanding of how We process Your personal data collected through Your use of this Website, and also includes all data You may have provided in connection with Your registration and through Your use of Our online casino.

This Website is intended solely for persons over 19 years of age and we do not knowingly collect data related to persons under this age. If it becomes clear to us that We have collected personal data related to persons under the age of 19, for reasons related to the misuse of Our Website, We will do Our utmost to ensure that such data is processed in accordance with applicable law and Our policies and procedures. 

Unless otherwise stated in this Privacy Policy, the applicable terms herein shall have the same meaning as in the terms and conditions.

This Privacy Policy must be read in conjunction with any other confidentiality information We may have given You from time to time. This Privacy Policy is complementary to other such information and is not intended as a substitute for it.

(b) Information, Queries & Complaints

You are responsible for providing personal data that is correct and informing Us in writing of any changes that may occur, so that we can use all reasonable means to ensure Your personal information is correct and up to date. In addition, We will implement data accuracy checks in accordance with the applicable data protection laws and may ask You to verify Your data we hold on You from time to time.

As We take Your privacy seriously, We have appointed a Privacy officer (“PO”), whose responsibility is to oversee that the Company:

(i)acts in accordance with its legal obligations and 

(ii)is processing Your personal data in compliance with applicable rules and regulations. 

The PO is Your contact person regarding any questions or complaints you may have relating to this Privacy Policy or Your data. Should You have any queries, complaints or require further information regarding this policy, please contact Our PO using the information below.

If you are using the services provided by Videoslots Ltd in accordance with the relevant license(s) as provided here, the following shall apply:

Full Name of Legal Entity	Videoslots Ltd (C49090)
Mailing address	The Space, Level 2 & 3, Alfred Craig Street, Pieta, PTA 1320 Malta
Email address	[email protected]

You have the right, at any time, to lodge a complaint with the respective data protection authority in Ontario, Canada listed hereunder; 

In the event you exhaust our complaints process without what you believe to be a satisfactory resolution, you may request a copy of your case file, which we shall provide, in order to escalate the complaint to iGO. We will aid iGO in the investigation and handling of your complaint. You may also escalate any complaints or enquiries to iGaming Ontario: 

https://www.igamingontario.ca/en/player/player-support.

We would really appreciate the opportunity to resolve Your issues before contacting the respective authority, so please contact us first.

2. YOUR DATA

(a)  Definitions

Applicable privacy laws define personal information as follows:

Our Services collect “personal information,” which means recorded information about an identifiable individual other than contact information i.e. information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including any information that constitutes “personal information” under applicable privacy laws. 

As a customer of the Company, You are an "individual" in relation to this Privacy Policy. In short, all personal data relating to You as a person or individual is protected under the applicable data protection laws and legislation. However, it does not include data where the identifiers relating to a "data item" have been removed in such a way that the data is rendered anonymous, meaning when You are not or no longer identifiable (i.e. anonymous data) or data which relates to an individual’s business or place of work.

In carrying out Our Services, We might make use of certain “Know Your Client” (KYC) technology which allows the Company to be able to verify the identity of the players in its customer base, falling in line with its regulatory obligations as a licensed operator in Ontario. 

We may collect, use, store and transfer various kinds of personal data. In this section We will explain the following:

•What kind of data do we collect?

•How do we collect data - Do We get data directly from You? Do We get it from other sources?

•For what purpose do We collect data? - How and why do We use data? 

•What is our legal basis for data processing?  The possible legal bases that could justify it are:

Legal obligations – Are We required by law or regulations to process this data? Do We need to process this data to fulfil a legal obligation? 

Legitimate interest - This means that We process Your data because it relates directly to and is necessary in order for the Company to be able to offer its Services to You, which forms part of our legitimate interest as a Company. Before We process Your data in line with this basis, We ensure that We assess the potential impact such treatment may have on You and Your rights. Therefore, We do not use a method where Your rights and interests as an individual override Our interests in processing Your data.

In performance of a contractual obligation - Processing of personal data is necessary to fulfil the contractual obligations We enter into with You and of which You are a part (i.e. terms and conditions). Collection of Your personal information is required in order for Us to be able to render Our Services to you and in certain cases, such as when You as a player are either a Politically Exposed Person (PEP) or a Head of International Organisation (HIO), We might request further personal information from You in order to adhere to Our legal obligations. 

Consent - Your consent is used as a legal basis for processing Your data, We only process Your data as long as We have Your consent to do so. If at any time You feel that You no longer wish to have Your data processed, We will no longer do so. However, this does not affect any processing of personal data that We have performed with Your consent before You have cancelled Your consent. Please see section 8 of this Privacy Policy for more information on how to cancel Your consent.

Certain data We collect and process about You is classified as aggregate information, meaning information which cannot lead to Your identification as a natural person, yet may be used by us as a Company to better our services and product offering to You as an end-user and consumer. These types of aggregate information, how they’re collected and the reasons for which We use them are detailed in the table below. 

Here is a more detailed breakdown of which personal information We process, when and why We process it and which legal basis We rely on to do so:

Data collected	When do we collect Your data?	Purpose of dta collection	Legal basis for data processing
Geolocation Data: This includes data relating to Your location as a player when using the Website	Upon registration and throughout the relationship between the player and the operator	(1)Identify location of player and ensure the player is situated in Ontario	A.Legal obligation  B.Legitimate Interest
Identification data:  This includes name, selected username, date of birth, gender	Requested upon registration	(1)Identify the customer before the contract is performed (2)Identify the customer and create a unique customer profile  (3)Verify the customer for Anti-Money Laundering (“AML”) reasons	A.Execution of contract B.Legal obligation C.Legitimate interest
Contact details:  This includes email address, home address and mobile number	Requested upon registration	(1)Identify the customer before the contract is performed  (2)Contact the customer  (3)Disseminate marketing material should the player have consented to receiving said material	A.Execution of contract B.Legal obligation C.Legitimate interest D.Consent
Identification of individual through documentation:  This includes ID documents, proof of address, proof of income and proof of wealth	Uploaded by the player upon request. Request usually done through a pop-up message on the website or via email	(1)Verify player’s identity  (2)Compliance with AML obligations	A.Legal obligation  B.Legitimate interest
Financial data:  This includes data relating to Your chosen deposit method i.e. Your bank details, credit card details amongst others.	Collected by player depositing or withdrawing funds to and from their account with the Company. May also be requested via email and/or through chat with Customer Support.	(1)Fulfil legal obligations  (2)Fulfil security checks  (3)Offer service to player  (4)Fulfil internal policies such as “closed-loop” policy	A.Execution of contract B.Legal obligation  C.Legitimate interest
Transaction data:  This includes transaction details which relate to payments made to and from You	Automatically generated and collected when player makes deposits or withdrawals on the Website	(1)Fulfil legal and regulatory obligations and gaming licence requirements  (2)Offer service to player	(1) Execution of contract. (2) Legal obligation. (3) Legitimate interest
Game data:  This includes game activity and data relating to games You play on our Website	Automatically generated and collected when player plays a game on the Website.	(1)Fulfil legal and regulatory obligations and gaming licence requirements  (2)Offer service to player	A.Execution of contract B.Legal obligation
Communication data:  This includes data regarding Your communications as a player with the Company	Collected through email correspondence and communications You make through emails or chat with Customer Support. Telephone conversations or calls may also be recorded.	(1)Fulfil legal and regulatory obligations and gaming licence requirements  (2)Offer service to player	A.Execution of contract B.Legal obligation
Profile data:  This includes data relating to Your gaming activity, gaming habits and preferences	Automatically generated and collected through gaming activity on Website, and through the use of cookies onsite.	(1)Offer service to player  (2)Create a more personal and tailored user experience for the player (3)Segment player based on gaming activity and preferences, in order to better understand player needs and satisfy said needs as efficiently as possible (4)Target marketing communications to player’s preferences, should the player have consented to receiving said marketing	A.Legitimate interest  B.Consent
Technical Data:  This includes Your internet protocol (IP) address, Your login information, browser type and version, time zone, location, system and platform	Collected through cookies.	(1)Fulfil legal and regulatory obligations and gaming licence requirements  (2)Fulfil security checks  (3)Offer service to player	A.Execution of contract  B.Legal obligation C.Legitimate interest
RTP data: This includes data relating to Your number of bets, total number of spins,overall RTP, wins, losses and bets	Automatically generated and collected when player plays a game on the Website	(1) Offer service to player	A. Execution of contract  B. Legitimate interest
Marketing data: This includes data about your preferences regarding offers, promotions and marketing communications	Collected at registration stage, nature of data is dependent on whether You choose to receive marketing material or not	(1) Offer service to player	A. Consent B. Legitimate Interest
Cookie Data: please see our Cookie Policy for further information about how and for which purpose we collect Your Cookies.

You can find further information below about how We process Your data for the following reasons:

• Our own marketing activities-  We do Our best to ensure that You have the greatest control over what kind of marketing material You receive from Us or from third parties who act as data processors to Us, processing Your data on our behalf and following Our instructions. You can view and change Your marketing related choices in Our Privacy section of Your account. If You feel that You would like more control over which marketing material We send to You, then You are welcome to contact our PO using the contact information provided above. Should You wish to withdraw Your consent, it may take up to 48 hours before We can be assured that the changes have been implemented in our system and in the systems of our marketing partners (and for this reason, You may receive emails or information from us within those 48 hours). Section 8 explains exactly how You can withdraw Your consent.  

• Marketing activities of Our business partners - We never share Your personal data with our business partners for their own marketing activities without Your consent.

Your personal data will not be processed for purposes other than those for which they were collected. Should further processing be required, we shall perform compatibility assessment (to confirm that any such further purpose is compatible with the initial purpose for which data was collected) and You will be informed of that purpose and provided with all necessary information. 

3. SHARING OF DATA

Due to the nature of Our service, in order to process Your data as explained in section 2 of this Privacy Policy, We may need to share Your personal and aggregate information with a number of trusted third parties. These 3rd parties include:

(i)  Game Providers - At times, Our game providers will need access to selected data (such as username and IP address) in order to provide us with the games You play on Our Website.

(ii)  Payment Providers and Related Service Providers - Similarly, We may share some of Your personal information with the payment provider You use to make deposits and withdrawals on Our Website.

(iii)  Marketing Partners  -  When You consent to us sending You marketing communications and promotions, We may share Your contact information (such as email address or postal address) with our marketing partners who are responsible for sending Our marketing material to You.

(iv) Government or Regulatory Authorities - We may, if necessary or authorized by law, provide Your personal data to law enforcement agencies, government or regulatory organizations, courts or other public authorities. 

(v) Client communication software - We use third party software to help us communicate with You. This software allows us to send emails to You and talk to You on Our live chat whenever you have any questions.

(vi)  AML and anti-fraud tools - We use third party software to perform certain AML and fraud verification checks, which in this case are necessary to comply with Our legal obligations.

We always ensure that a third party who has access to Your personal data is obliged to respect the security of Your personal data, and always process it in a lawful manner, as well as in accordance with Our Privacy Policy and strict contractual provisions. We do not allow any third party service provider to use Your personal data for their own purposes, except when Your personal data is shared with another data controller, such as for example, the governmental and regulatory authorities.

4. TRANSFERS OF PERSONAL DATA

Service providers referred to in section 3 above may be based in countries that are located outside of Ontario. This may mean that Your data may be shared outside of Canada. Whenever a transfer of Your personal data is made to a data processor or a data controller based outside Canada, We always ensure that Your data is protected in the same way as it is in Ontario. To ensure the protection of Your data, We will implement at least one of the following safeguards:

(I)Adequacy basis - We ensure that We transfer Your personal data to countries that provide an adequate level of data protection.

(II)Standard Contractual Clauses - When an organization is not based in Canada, We may use special contracts, known as standard contractual clauses. These contracts also ensure that personal data is afforded the same protection as it is in Canada. 

When establishing and implementing our business relationships, We do not use automated decision making. If We use this method in individual cases, i.e. only when the processing activities based on automated decision-making are permissible under the exceptions within the applicable data protection laws, these operations shall be subject to suitable safeguards to protect Your rights and freedoms. Most importantly, You will be provided (i) the appropriate information, (ii) the right to obtain human intervention on the part of the controller, (iii) the right to express Your point of view, (iv) the right to obtain an explanation of the decision reached after such assessment and (v) the right to contest the decision, unless prohibited by applicable law.

6.TECHNICAL AND ORGANISATIONAL MEASURES

The Company always strives to ensure that Your personal data is secure, both in Our hands and in the hands of any third party to whom we may have passed on Your personal data. Internally, We have implemented a number of technical, contractual, as well as organizational measures, to ensure that Your personal data is not accidentally lost, used, accessed in an unauthorized manner, altered or disclosed. We also ensure that access to Your personal information is determined on a "need-to- know" basis, which means that only people with direct needs to access Your personal data will have access to them. In addition, anyone who has access to Your personal data is bound by confidentiality.

We also have procedures in place to deal with any suspected or actual personal data breaches. We will inform both You and iGO, the regulatory authority affected by such data security, and we will maintain a list of any such breaches. In this case, we will notify iGaming Ontario and other relevant authorities, and assist the same in reporting and resolving data breaches. 

7. DATA RETENTION

The Company will only retain Your personal data for as long as it is necessary to fulfil the purpose for which it was collected and in accordance with our data retention policies. Some objectives may include the satisfaction of any legal, accounting or reporting requirements. Once the purpose for which the personal data has been collected and processed is reached, and unless We have no other legal obligations to hold onto Your personal data, We will ensure that Your personal data is disposed of permanently, safely and securely. 

When determining how long a retention period is appropriate for Your personal data, We take into account various factors, such as the nature and sensitivity of the personal data, the potential risk of unauthorized use or disclosure of such data, the purpose We collected and processed such data for and applicable laws and/or legal requirements imposed on Us.

You are welcome to contact Our PO using the contact information provided in this Privacy Policy for further information about Our storage and data retention periods.

8. YOUR RIGHTS

Applicable legislation gives You certain rights which You may exercise in relation to Your personal information. In accordance with the law, You have the right to:

Request Access to Your Personal Data - This means that You have the right to request a copy of the personal data We hold about You against a minimal fee. To request such access, please exercise Your right by filing a Freedom of Information Request with iGaming Ontario here: https://www.igamingontario.ca/en/freedom-information-requests. 

Request for Correction of Your Personal Data - This means that if any of the personal information We hold about You is incomplete or incorrect, You have the right to have it corrected. Keep in mind, however, that We may need You to provide proof and documentation (such as Your ID documentation or proof of address) in order to comply with Your request.

Request to have Your personal data deleted - This means that You can request to have Your personal data deleted if We no longer have a legal reason to continue to process or store it. Please note that this right is not guaranteed - in the sense that We do not have the ability to comply with Your request if We are subject to a legal obligation to store Your data or if We have the reason that it is necessary to store Your personal data, in order to defend ourselves in a legal dispute.

Withdraw Your consent at any time when we rely on Your consent to process Your personal data - Termination or withdrawal of Your consent will not affect the legality of the processing We have performed until the time You withdrew Your consent. Withdrawal of Your consent means that in the future You no longer want to have Your data treated in the same way. This means that You can no longer give us permission to provide certain services (e.g. Marketing). You can withdraw Your consent at any time via the Privacy section located on "Your Account" on the Website. In addition, You can withdraw Your consent from marketing through the ‘opt-out’ unsubscribe button provided in the email You receive from us.

File a complaint -  As explained in section 1 (b) of this Privacy Policy. We will respond to all legitimate requests within a 30-day timeframe from the submission of a request. If Your request is particularly complex, or if You have made multiple requests in a certain period, it may take us a little longer. In such a case, we will notify You of this necessary extension.