Data Protection Officer
Office 1/5297 Level G, Quantum House, 75, Abate Rigord Street, Ta’ Xbiex, XBX 1120, Malta
Telephone number: +13433035151
PlayOJO is operating as part of the open and regulated internet gaming (igaming) market in Ontario conducted and managed by iGaming Ontario (iGO) and is collecting, using and disclosing personal information on behalf of, and as agent to, iGO. iGO asserts the legal authority to collect personal information under the Freedom of Information and Protection of Privacy Act (Ontario) and
- Reg. 722/21: LOTTERY SUBSIDIARY - IGAMING ONTARIO made under the Alcohol and Gaming Commission f Ontario Act, 2019 (Ontario).
Here at PlayOJO we like making things simple and easy for our customers and that includes being clear, transparent and open about what we collect, and how and why we use the data we collect, so this page goes into great detail.
Our Policy explains how we use your personal data, whether you are just visiting, making a deposit or playing one of our games. This policy includes information you may not already know about your data privacy rights, circumstances in which we share and obtain information about you and how we use it to personalize the marketing you receive, so please take time to read all the sections carefully.
If we make any material updates to this Policy, we will inform you and you will be requested to consent to the changes.
Please note that all our employees undertake regular training on Information Security and are required to comply with confidentially obligations as well as internal policies and procedures whenever they handle your information.
We hope you will find this page helpful, but should you have any concerns or questions, regarding Data Protection, please feel free to contact our Data Protection Officer at firstname.lastname@example.org
PlayOJO will always value and respect the privacy of each and every one of its customers. Your privacy is important both to you and to us and we make the following promise to you:
PlayOJO is committed to protecting your privacy. We believe in using your personal information to make things simpler and better for you. We will always keep your personal information safe. We’ll be clear and open with you about why we collect your personal information and how we use it. Where you have choices or rights, we’ll explain them to you and respect your wishes.
PlayOJO website and content are not intended for persons under 19 years of age (“Minors”). We are not collecting personal data from Minors. If a parent or guardian becomes aware that their Minor child has provided us with personal data, the parent or guardian may contact us to have such Minor’s data deleted.
The Types of Information We Collect
We collect two types of data and information from our customers.
Personal Information which can be used to identify an individual. The Personal information we collect through our Services includes information which is submitted directly by the you, such as: phone number; full name; e-mail address; home address; date of birth; payment means (e.g. card number); and other financial information that we may need in order to provide our Services. We also collect Personal Information from your device (e.g. geolocation data, IP address) and information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).
The list of data that we collect is:
- Full legal name (including middle name or initial, if applicable)
- Full address (house/apartment number, city, province/state, country, postal/zip code)
- Date of birth
- Personal telephone number
- Descriptive Occupation
- Email address
- Player identification document details (Source of the credit file (i.e., name of the Canadian Credit Bureau) Player’s credit file number Date of verification,
- Player’s country of residencE
- Player’s business telephone number, employer name and the address of the employer
- Player’s citizenship
- Player’s alias/preferred name (if applicable)
- IP address
- Geolocation of the player
- Gaming event and transaction history (game session outcomes and game transactions)
- Deposit and withdrawals financial services provider
- Method and source of funds used for
The second type of information is un-identified and non-identifiable information pertaining to you which may be made available or gathered via your use of the Services We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services.
If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined. For the avoidance of doubt, if there is a possibility that information can be linked to an identifiable account, it will be treated as Personal Information
How We Collect Your Information
Collecting Information about you, from you
PlayOJO collects personal information about you whenever you use our services. Some of it you provide directly to us, for example, when you register an account or fund your account. Other information is collected during your interactions with us, such as the bets you place or online chats with our customer services team and through Cookies (Please refer to the dedicated section about Cookie’s for more information on our usage of cookies) Also, if you consent we will also record all telephone conversations. We also collect information about the way you access, view, share, contribute to and communicate with and through our services, for example when you post comments via our social media channels or chat functionalities.
Collecting Information about you, from your device
We collect information from the devices you use when using PlayOJO content, products and services. This includes but is not limited to the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version number.
Collecting Information about you, from Cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate. The cookies we use can be grouped into four separate categories and are explained in the section further below set out for Cookies.
Collecting Information about you, from external companies
To help us comply with our legal and regulatory KYC and Social Responsibility obligations:
- When you open your account, we will cross reference the information you supplied to us with external/governmental companies for Anti-Money Laundering and identity verification processes, as well as to ascertain whether you are registered with them because you asked not to be allowed to gamble or receive marketing. Electronic Know Your Client (“EKYC”) or automatic verification solutions provided by a third party providers such as GBG PLC, Equifax and Jumio can be used to ascertain a player's identity in accordance with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requirements.
- We use publicly available information (on social media sites and the like) to help verify information provided to us and we log and save the results
Where we acquire personal data from a third party as part of a business or asset transfer:
We may also collect personal data about you from third parties from time to time. For example, if you are a former customer of a PlayOJO partner and your data was passed to PlayOJO we will have acquired the following categories of your personal data from your previous online betting and gaming provider in order to integrate your former account into PlayOJO’s platforms and systems, and to provide our gambling services to you in accordance with our Terms and Conditions. A non-exhaustive example (which may or may not be applicable depending on the process) of such data is:
- Your account balances – to allow you to access your funds;
- Your former providers username and password (hashed and non-decipherable by us)– to allow you to continue to access your account using the same login details;
- Your personal registration details originally supplied to your former provider, such as name, DOB, address, email address, telephone number and occupation;
- Copies of your existing KYC, identification and Enhance Customer Due Diligence documents originally supplied to your former provider – where we can, we will process these documents to allow you to access PlayOJO services without have to ask you to supply updated
- If you are a ‘time out’ or ‘self-excluded’ customer, your account status and duration of any relevant live time out or exclusion period.
We will process the above categories of personal data for the reasons outlined in this Privacy Notice and in accordance with the relevant data protection legislation.
How do we use the information we collect?
The information we collect, which may include “Personal Information”, is used for the following purposes:
- To set up your account and to provide our Services (e.g. Identification and verification of your personal details, send out cash-out checks, process your payments, consult the national self- suspension register to determine whether we can allow you access to gambling/receive marketing
- To identify and authenticate your access to certain features.
- To indicate that you had a win (in winners’ announcements on our website or on a tournament leaderboard) by using your Username. We advise against using anything that can identify you personally, however this is your choice.
- To communicate with you and to keep you informed of our latest updates
- To market our website and products or those of any of our business partners and affiliates
- To serve you advertisements
- To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests
- To support and troubleshoot our Services and to respond to your queries
- To investigate violations and enforce our policies, as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
- To audit certain elements of our business practices
- To perform our obligations under our operating agreement with iGO
- Where we decide or sell, transfer or otherwise dispose of any part of our business in the future, we may share your information with prospective purchasers and our professional advisors for that purpose.
Where the data processing is in accordance with your consent, you have the right to withdraw your consent at any time in writing to our contact details mentioned in this Policy, or by following any relevant process to withdraw your consent (eg, unsubscribing from marketing) Withdrawal of your consent does not affect the lawfulness of the treatment of your data prior to its revocation.
Companies that provide services on our behalf
We share your personal information with external organizations that carry out a range of services on behalf of PlayOJO. We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations. Please note that data processing may take place outside of Ontario and if it does the processing will take place within an EU Member state. In those cases the data is subject to the General Data Protection Regulation (GDPR) of Europe. The main functions that are or may be carried out, fully or in part, by third parties are listed below:
- Management and execution of marketing campaigns
- Payment processing and verification
- Credit Reporting Agencies including but limited to affordability checks. For more information on how Credit Reporting Agencies collect/handle and process your personal data please check Credit Reporting Agency Information Notice (CRAIN)
- Anti-fraud and Anti-money laundering checks (Including but not limited to Enhance Due Diligence reports utilizing publicly available sources and ID verification
- Checks to detect unfair use of our products and services
- Web hosting, online content services and data storage
- Management of competitions, contests and offers
- Data analytics and data cleansing
- Market research and collecting or analysing customer feedback
- IT services and support
- Audit-, Legal- & Compliance- related services
- Storing data for regulators to access and view
- Analysis of gambling habits to ascertain potentially risky behaviours
Information demands from Regulators:
On a regular basis, in all licensed jurisdictions, we are regulatory required to produce reports containing non-Personal Data. The reports consists of things such as number of self exclusions, number of registrations, number of complaints, number of suspicious transactions reported to authorities.
Other information sharing with third parties:
We may also share personal data with selected third parties in order to measure and improve customer experience, to circulate new offers and promotions that may be of interest on various similar third parties products/services and to facilitate the resolution of customer complaints and disputes.
We may also process your personal data for the purposes of any future acquisitions, sales, restructuring or other business or asset disposals or transfers of any part of our business from time to time. This may include sharing your personal data with third party prospective purchasers, bidders, investors, professional advisors and other relevant persons in respect of the transaction. Where this is the case, you will receive notice of any such transfer before it takes place, along with further details about how your personal data will be processed at the relevant time.
How long do we keep your information?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations including as required by iGO policies and our operating agreement with iGO, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to gambling and gaming, anti-money laundering, taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuse of our services, and audit requirements. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we delete it securely or anonymize it in accordance with the applicable retention policy and schedule.
You have the following Data Subject Rights:
- The right of access. This enables you to e.g. receive a copy of the personal data we hold about you.
- The right to Correction/Rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected/rectified.
- The right to This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
- The right to withdraw consent. You may withdraw any consent you have provided to us for the collection, disclosure or use of your personal information at any time. However, if you do so, we may no longer be able to provide you with services that rely on that personal information.
In order to exercise any of your rights over your personal information or to raise any complaints about our treatment of your personal information, please contact email@example.com or as set out above.
We are permitted to ask for your ID in order to verify your identity prior to fulfilling your request. However, we reserve our right, in certain situations, to request for your Identity to be verified via additional methods/ways up to the point we are satisfied of the veracity and/or legality of the request. Such additional verification measures are applied to ensure that your personal information is not released to unauthorised persons.
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the relevant supervisory authority.
In Ontario, if you are not satisfied with our response of your complaint, you can request a copy of your case file, in order to escalate your complaint to iGO. Please see information regarding our Complaints Process in Clause 22 of our Terms and Conditions
Keeping your Personal Information Accurate and Current
You may update your account information by logging into the casino software and visiting your Personal Information page. You agree that you will verify and update this information regularly, to ensure that it remains accurate.
We will also keep player information and data accurate and up todate, pursuant to Section 40(2) of the Freedom of Information and Protection of Privacy Act (Ontario) (“FIPPA”).
What are Cookies?
'Cookies' are small text files stored in your web browser that enable us to recognize your computer when you visit our website. Cookies are essential to keep certain parts of our website functioning correctly and securely. We also use them to make things quicker, easier and more personal to you and to help us understand how our website is used. They can also be used to present you with more tailored advertising content.
They also enable PlayOJO to find out which advertisement brought you to our website, we may use the PlayOJO cookies on your computer. In the event that we do collect such information, you will remain personally unidentifiable and we will not share this information with any unconnected third-party.
The Cookie Categories
The Cookies we use fall into the following categories:
- Strictly Necessary
This type of cookie allows you to navigate the website and use essential features like secure areas and online registration. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet. These cookies are essential in our being able to guarantee the performance of our website, should you disable them we won’t be able to ensure your security or predict how our website will perform during your visit.
This type of cookie collects information about how you use our website e.g. which pages you visit, and if you experience any errors. The information collected is anonymous and is only used to help us improve how our website works, gauge what interests our users and assess the effectiveness of advertising.
This type of cookie remembers your preferences for tools found on our website, so you don’t have to re-set them each time you visit. Some of them are managed by third parties. They may for instance determine whether you see the latest or oldest comments made in relation to an article first. They may also help us greet you by name or remember your choice of language or region).
These cookies are used to analyse what advertising might be most relevant to a user of the website based on the areas of the website that the user visits.
Controlling my Cookies
All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:
- Cookie settings in Chrome
- Cookie settings in Firefox
- Cookie settings in Microsoft Edge
- Cookie settings in Safari
The Use of Google Analytics
Your opt-out choice is applied only to the browser from which you make the choice, so if you use different browsers you will need to opt out in each one. This opt-out is cookie based, so if you delete your cookies, you will no longer be opted out and will need to opt out again. Google Analytics, from which you can control through your browser settings: opt out. https://tools.google.com/dlpage/gaoptout
PlayOJO goes to great lengths to guarantee that your personal and financial information remains 100% secure and confidential. We employ industry standard security protocols (The connection to this site is encrypted and authenticated using TLS 1.2 (a strong protocol), ECDHE_RSA with X25519 (a strong key exchange), and AES_128_GCM (a strong cipher) to ensure that all transactions including deposits and withdrawals are carried out in a totally secure manner. This technology protects you from having your information intercepted by anyone other than PlayOJO while it is being transmitted between you and PlayOJO.
In the event that we become aware of any privacy breach we will act in accordance with section XVI of our Incident Management of our Information Security and Governance Policy’. In addition, we will notify iGO of the breach and cooperate with iGO and any related authorities with any investigation or other response to the breach.
You also have a role to play in protecting the security of your account and your account information. Never share your password or let other people access or use your account.
Limits of Confidentiality
For legal reasons, PlayOJO may be required under certain circumstances to disclose your personal information. Reasons for this may include:
- to protect and defend our rights or property;
- to comply with any legal process served on us