Betway - Privacy Policy

Privacy Policy

Effective Date: 5/9/2023.

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://az.betway.com/ and other websites that link to this Privacy Policy) (each, a “Website” and collectively, the “Websites”) and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the “Betting Apps”) (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the “Services”), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as “Betway”, “we”, “us”, or “our”). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not
govern the data practices of third parties that may interact with our Services.

In addition, please review the Services’ Terms of Use, which governs your use of the Services. By using our Services, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use the Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

It is important that you read and understand the entire Privacy Policy before using the Services. However, this table of contents highlights the topics covered and you can click on the headings to be taken to the full explanation.

What Information Do the Services Collect?

(a) Information You Provide to Us
(b) Information We Collect and Store As You Access and Use the Services
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Services
(e) Information You Provide About a Third Party
(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties
(b) Third Parties Providing Services on our Behalf
(c) Administrative and Legal Reasons
(d) Affiliates and Business Transfer
(e) Sweepstakes, Contests and Promotions
Your California Privacy Rights

(a) Personal Information We Collect
(b) How We Use Your Personal Information
(c) Sources of Personal Information
(d) Who We Share Personal Information With
(e) Your Privacy Rights
(f) Notice of Right to Opt-Out
(g) Right to Opt-Out of Sharing For Direct Third Party Marketing
Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights
(b) Your Connecticut Privacy Rights
(c) Your Virginia Privacy Rights
Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

Contact Us

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

On the Services, we or our service providers may ask you to provide certain types of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, email address, home or mailing address, birth date, credit card or other banking information, social security number and phone numbers ("Personal Information"); and (2) demographic information, such as information about your gender and age ("Demographic Information"). We may collect this information through various forms and in various places on the Services, including through "contact us" forms, when you register for an account with the Services, deposit funds into an account, on document upload pages, when you wager or otherwise purchase products or services from us or if you request to receive communications from us. In addition, Personal Information once "De-identified" (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements including through anonymization, pseudonymization and/or hashing) is not considered Personal Information and may be used and shared by us or other third parties without obligation to you, except as prohibited by applicable law.

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

We may use various methods and technologies to collect and store Usage Information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.

Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.

Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.

Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

There may be other Tracking Technologies now and later devised and used by us in connection with the Services. Further, third parties may use Tracking Technologies in connection with our Services, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

(c) Information Third Parties Provide About You

We may receive information about you from your friends and others that use the Services, such as when they submit your information to us about you, if for example, they invite you to take part in a special promotion we are offering. Additionally, we may, from time to time, supplement the information we collect directly from you on our Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content and ads to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Services, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.

(d) Interactions with Third-Party Services

The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third-party website, application or other service. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party sites’ interfaces or links on the Services to facilitate your sending a communication from the Services. For example, we may use third parties to facilitate emails, Tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Betway may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Services.

(e) Information You Provide About a Third Party

You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

(f) Photographs and Biometric Information

In some circumstances, we may require you to provide your photograph and/or facial image in order to verify your identity and/or comply with our legal and regulatory obligations. These photographs may be received and processed by third party service providers to provide these services on our behalf and for our exclusive benefit. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology.
We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms; provided, however if required by applicable law or third party platform, we will make commercially reasonable efforts to honor a user’s settings.

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.

3. How and When Do We Disclose Information to Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. Also, we may now or in the future share your Personal Information with third parties with whom we have marketing or other relationships for the third parties’ direct marketing purposes. If you are a California resident, you have the right to request additional information about this sharing, so please see Section 4 below. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We may disclose your information as follows:

(b) Third Parties Providing Services on our Behalf.

We may use third-party vendors to perform certain services on behalf of us or the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons.

We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer.

We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions.

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information, collected via any medium, including online and offline. Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression)
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as, facial scans, faceprints or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy)
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers
Professional or employment-related information.	Current employment status; compensation-related information
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We use the personal information we collect about you for all of the business purposes outlined in Section 2 above.

The sensitive personal information that we collect as described in Section 4(a) above may be used for any of these purposes.

We will not retain any information we collect form you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

(c) Sources of Personal Information

We may collect the categories of personal information listed above from the following categories of sources:
From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell/ share” personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting, selling, or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/ Sharing You have the right to opt-out of the sale/sharing of your personal information by a business. as those terms are defined by California law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to [email protected].

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process a request, we may not include personal information if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state, or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at: [email protected], with “California Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

We may now or in the future elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2021 will receive information about 2020 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: [email protected], with "California Privacy Rights" as the subject line or mail us a letter to: Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030. You must include your full name, email address with which you registered on Betway, and postal address in your request.

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

While we don’t sell your personal information now as defined by Nevada law, Betway reserves the right to sell personal information to third parties in the future should it change its policy. Nevada S.B.220 allows Nevada residents to opt-out of the sale of their personal information now in the event if we change our policy in the future. If you are a Nevada resident we want you to know that you have choices and can opt-out of Betway selling your personal information by contacting us at [email protected]. This may prevent or restrict your use of the Services in the future.

(b) Your Connecticut Privacy Rights

Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

(c) Your Virginia Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).
For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.

For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect
We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.

Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.
We do not “sell” your personal data as that term is defined under Virginia law.
We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights
If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.
If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

If you wish to appeal our decision with regard to a request that you have previously made, please contact us using the information above or notify the Office of the Attorney General of Virginia by clicking here.

6. Ads and Information About You

Data about your activities online is being collected on our Services for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the privacy policy provides details and explains how to exercise that choice.

You may see certain ads on our Services as well as on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites by collecting information through automated means, including through the use of the tracking technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests. The information they collect includes information about your visits to our Services, such as the pages you have viewed. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may act as web beacons, which enable third parties to carry out the previously described activities.

This collection and ad targeting takes place both on our Services and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a Google Ads cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services. To learn more about how to opt out of Google’s use of cookies, visit the Google’s Ads Settings, here. To learn more about how to opt out of use of the Google Analytics cookies, visit the opt-out page, here.

Third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative ("NAI") members, and your choices regarding having this information used by these companies, including the "opt-out" procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance ("DAA") website at http://www.aboutads.info/choices. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

The Services may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Services are served to you for their own commercial purposes. In addition, when you are on the Services you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you "click" on a link, the "click" may take you off the Services onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third parties. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Services and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

8. How Do I Change My Information and Communications Preferences or Close My Account?

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Services account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and Services announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

You may agree to receive text messages regarding product offers and promotions by Betway via automated technology. You are not required to agree to receive text messages to make a purchase. You may, at any time, decide to stop receiving text messages regarding product offers and promotions by Betway by replying STOP to any text message you receive from Betway. If you need help or assistance with the messages, you may contact us. MSG and data rates may apply. Carriers are not liable for delayed or undelivered messages.

If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us as follows: Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030 (Attn: Privacy) or at [email protected].

9. What About Transfer of Information to the United States?

Our Services are operated in the United States and intended for users located in the United States and certain services may only be available to users who are located in specific states in the United States identified in our Terms of Use or on the Services. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

10. What Should Parents Know About Children?

The Services are for a general audience and we do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us via email at [email protected].

11. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

12. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Services indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than indicated at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://us.betway.com, https://co.betway.com/ and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

In addition, please review the Services’ Terms of Use, which governs your use of the Services. By using our Services, you consent to our Privacy Policy and Terms of Use a`nd our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use the Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties

(b) Third Parties Providing Services on our Behalf

(d) Affiliates and Business Transfer

(e) Sweepstakes, Contests and Promotions

Your California Privacy Rights

(a) Personal Information We Collect

(b) How We Use Your Personal Information

(d) Who We Share Personal Information With

(e) Your Privacy Rights

(f) Notice of Right to Opt-Out

(g) Right to Opt-Out of Sharing For Direct Third Party Marketing

Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier ("Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.
Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

(f) Photographs and Biometric Information

In some circumstances, we may require you to provide your photograph and/or facial image in order to verify your identity and/or comply with our legal and regulatory obligations. These photographs may be received and processed by third party service providers to provide these services on our behalf and for our exclusive benefit. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology.

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms; provided, however if required by applicable law or third party platform, we will make commercially reasonable efforts to honor a user’s settings.

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties. You may be presented with an option on our Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Services or link to them from our Services. This may include using third party tools such as Facebook, Twitter, Instagram or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. It may also include ordering or purchasing products or services from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information,
Protected classification characteristics under California or federal law.	Age ,race/ethnicity, national origin, citizenship or sex (including gender, gender identity, and gender expression)
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics, used to extract a template or other identifier or identifying information, such as, facial scans, faceprints, or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We use the personal information we collect about you for all of the business purposes outlined in Section 2 above.

The sensitive personal information that we collect as described in Section 4(a) above may be used for any of these purposes.

We will not retain any information we collect form you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell”/”share” personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting or selling any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/ Sharing. You have the right to opt-out of the sale/ sharing of your personal information by a business as those terms are defined by California. law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of thirteen (13), as we do not collect personal information from any person under the age of thirteen (13).

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process a request, we may partially or fully deny the request if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state, or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at [email protected], with “California Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/ sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights In Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).

For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.

For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.

Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.
We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

You may agree to receive text messages regarding product offers and promotions by Betway via automated technology. You are not required to agree to receive text messages to make a purchase. You may, at any time, decide to stop receiving text messages regarding product offers and promotions by Betway by replying STOP to any text message you receive from Betway. If you need help or assistance with the messages, you may contact us. MSG and data rates may apply. Carriers are not liable for delayed or undelivered messages.

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://us.betway.com, https://in.betway.com/ and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties

(b) Third Parties Providing Services on our Behalf

(d) Affiliates and Business Transfer

(e) Sweepstakes, Contests and Promotions

Your California Privacy Rights

(a) Personal Information We Collect

(b) How We Use Your Personal Information

(d) Who We Share Personal Information With

(e) Your Privacy Rights

(f) Notice of Right to Opt-Out

(g) Right to Opt-Out of Sharing For Direct Third Party Marketing

Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier ("Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked. By way of example, location-based services incorporated or used by the Services, including those provided by GeoComply, make use of your location data. You consent to us, GeoComply and other service providers we work with transmitting, collecting, maintaining, processing and using your location data in order to provide and improve location-based services. You may withdraw this consent at any time by turning off the location settings or by notifying us at [email protected] that you would like to withdraw such consent.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.
Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third-party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms; provided, however if required by applicable law or third party platform, we will make commercially reasonable efforts to honor a user’s settings.

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act (of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”)) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information, collected via any medium, including online and offline. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern;information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes information made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, sex (including gender, gender identity, and gender expression).
Commercial information.	Records of personal property; products or services purchased, obtained, or considered;; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as facial scans, faceprints, keystroke, gait, or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law. These are:

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation.
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We use the personal information we collect about you for all of the business purposes outlined in Section 2 above.

The sensitive personal information that we collect as described in Section 4(a) above may be used for any of these purposes.

We will not retain any information we collect from you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we do enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a) including the listed sensitive personal information for one or more business purposes.

We - “sell”/“share” your personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting, selling, or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale/sharing of your personal information by a business, as those terms are defined by California law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only, the uses necessary for us to provide products and services to you or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of thirteen (13), as we do not collect personal information from any person under the age of thirteen (13).

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process a request, we may partially or fully deny the request if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state, or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform.
Email us at [email protected], with “California Privacy Rights” as the subject line.
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).

For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.

For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.
Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.
We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

You may agree to receive text messages regarding product offers and promotions by Betway via automated technology. You are not required to agree to receive text messages to make a purchase. You may, at any time, decide to stop receiving text messages regarding product offers and promotions by Betway by replying STOP to any text message you receive from Betway. If you need help or assistance with the messages, you may contact us. MSG and data rates may apply. Carriers are not liable for delayed or undelivered messages.

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://us.betway.com, https://ia.betway.com/ and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). Accordingly, any personal information collected by us during account registration and establishment of the must adhere to this privacy policy. This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

In addition, please review the Services’ Terms of Use, which governs your use of the Services. By using our Services, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use the Services. Any information obtained in respect to player registration or account establishment is obtained in compliance with this Privacy policy. Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?

(a) Information You Provide to Us
(b) Information We Collect and Store As You Access and Use the Services
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Services
(e) Information You Provide About a Third Party
(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties
(b) Third Parties Providing Services on our Behalf
(c) Administrative and Legal Reasons
(d) Affiliates and Business Transfer
(e) Sweepstakes, Contests and Promotions
Your California Privacy Rights

(a) Personal Information We Collect
(b) How We Use Your Personal Information
(c) Sources of Personal Information
(d) Who We Share Personal Information With
(e) Your Privacy Rights
(f) Notice of Right to Opt-Out
(g) Right to Opt-Out of Sharing For Direct Third Party Marketing
Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights
(b) Your Connecticut Privacy Rights
(c) Your Virginia Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?
What About Data Retention?

What About Changes to the Privacy Policy?

Contact Us

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.
Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(c) Information Third Parties Provide About You

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) Photographs and Biometric Information

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties.

You may be presented with an option on our Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Services or link to them from our Services. This may include using third party tools such as Facebook, Twitter, Instagram or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. It may also include ordering or purchasing products or services from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf

We may use third-party vendors to perform certain services on behalf of us or the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons

We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer.

We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions.

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. Any information about player accounts which is not subject to disclosure as described immediately above or elsewhere in this Privacy Policy will be kept confidential, except where the release of that information is required by law.

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and other relevant California laws and regulations. For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression).
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as facial scans, faceprints, or other physical patterns (as further detailed in Section1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law. These are:

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

The sensitive personal information that we collect as described in Section 4(a) above may be used for any of these purposes. We will not retain any information we collect form you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

(c) Sources of Personal Information

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes. We “sell”/“share” your personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below. In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting, selling, or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale/sharing of your personal information by a business as those terms are defined by California law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of thirteen (13), as we do not collect personal information from any person under the age of thirteen (13). We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process a request, we may partially or fully deny the request if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform.
Email us at :[email protected], with “California Privacy Rights” as the subject.
Mail us at: Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law. If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webformand opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.” Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

(c) Your Virginia Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”). For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information. For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy. Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii) What We Do With Your Personal Data We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes. (iii) Who We Disclose Personal Data To We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf. We do not “sell” your personal data as that term is defined under Virginia law. We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below. (iv) Your Privacy Rights If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13). The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws. We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification. If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at[email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Data Retention

We will not retain any information we collect from you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

All player information will be securely erased from hard disks, magnetic tapes, solid state memory, and other devices before the device is properly disposed of. If erasure is not possible, the storage device will be destroyed.

13. What About Changes to the Privacy Policy?

14. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 08/01/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://la.betway.com and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?
How Do We Use the Information Collected?
How and When Do We Disclose Information to Third Parties?
Your California Privacy Rights
Your Privacy Rights in Other States
1. Your Nevada Privacy Rights
2. Your Connecticut Privacy Rights
3. Your Virginia Privacy Rights
Ads and Information About You
Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?
How Do I Change My Information and Communications Preferences?
What About Transfer of Information to the United States?
What Should Parents Know About Children?
What About Security?
What About Changes to the Privacy Policy?
Contact Us

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.
Recognition Technologies.Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.
Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality Related.We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(c) Information Third Parties Provide About You

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) Photographs and Biometric Information

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

(b) Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

4. Your California Privacy Rights

For the purposes of this Section 4 only, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information covered by certain sector-specific privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression).
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as, facial scans, faceprints (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.

Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law. These are:

•   Social Security number, driver’s license, state identification card, or passport number;
•   Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
•   Precise geolocation;
•   Racial and/or ethnic origin; and
•   Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We use the personal information we collect about you for all of the business purposes outlined in Section 2 above.

The sensitive personal information that we collect as described in Section 4(a) above may be used for any of these purposes.

We will not retain any information we collect form you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

(c) Sources of Personal Information

We may collect personal information from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Share Personal Information With

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell”/“share” personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting or selling any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

•   Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
•   Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
•   Right to Opt-Out of Sale/ Sharing. You have the right to opt-out of the sale/sharing of your personal information by a business as those terms are defined by California law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
•   Right to Correct. You have the right to request the correction of your inaccurate personal data.
•   Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
•   Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. In order to verify you, you must provide us with name and email address and in some cases, additional information such as last four digital of your Social Security number. These rights are also subject to various exclusions and exceptions under applicable laws.

You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to [email protected].

We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of thirteen (13), as we do not collect personal information from any person under the age of thirteen (13).

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process request, we may partially or fully deny the request if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state, or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at: [email protected] with “California Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

(c) Your Virginia Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).
For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.
For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.

Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii) What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii) Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.

We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv) Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

Third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You may provide updates and changes by contacting us. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Similarly, because applicable law or instructions, guidance or recommendations from regulatory bodies require us to retain certain information for a minimum period of time, we do not offer an option to delete your account. However, you may close your account with us. To do so, please see the instructions in the Closure of Accounts section of the Terms of Use or contact Customer Support to request account closure. When you close your account, we retain certain of your data as required by applicable law or to comply with instructions, guidance or recommendations from a regulatory body, such as the state gaming regulator.

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Services account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. You may agree to receive text messages regarding product offers and promotions by Betway via automated technology. You are not required to agree to receive text messages to make a purchase. You may, at any time, decide to stop receiving text messages regarding product offers and promotions by Betway by replying STOP to any text message you receive from Betway. If you need help or assistance with the messages, you may contact us. MSG and data rates may apply. Carriers are not liable for delayed or undelivered messages.

If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us as follows: Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030 (Attn: Privacy) or at [email protected].

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://us.betway.com, https://nj.betway.com and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

In addition, please review the Services’ Terms and Conditions, which governs your use of the Services. By using our Services, you consent to our Privacy Policy and Terms and Conditions and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use the Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties

(b) Third Parties Providing Services on our Behalf

(d) Affiliates and Business Transfer

(e) Sweepstakes, Contests and Promotions

Your California Privacy Rights

(a) Personal Information We Collect

(b) How We Use Your Personal Information

(d) Who We Share Personal Information With

(e) Your Privacy Rights

(f) Notice of Right to Opt-Out

(g) Right to Opt-Out of Sharing For Direct Third Party Marketing

Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier ("Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services
Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting-Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) Photographs and Biometric Information

In some circumstances, we may require you to provide your photograph and/or facial image in order to verify your identity and/or comply with our legal and regulatory obligations. These photographs may be received and processed by third party service providers to provide these services on our behalf and for our exclusive benefit. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology. We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third-party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms; provided, however if required by applicable law or third party platform, we will make commercially reasonable efforts to honor a user’s settings.

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

(c) Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms and Conditions or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(e) Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”)) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal information does not include publicly available information lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression).
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics, used to extract a template or other identifier or identifying information, such as, facial scans, faceprints, or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell”/“share” personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold” or “shared” the following personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting, selling, or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/Sharing You have the right to opt-out of the sale/sharing of your personal information by a business as those terms are defined by California Law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at [email protected], with “California Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

(i) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.
Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.
We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

This collection and ad targeting takes place both on our Services and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a Google Ads cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services. To learn more about how to opt out of Google’s use of cookies, visit the Google’s Ads Settings, here. To learn more about how to opt out of use of the Google Analytics cookies, visit the opt-out page, here.

Third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit (http://www.networkadvertising.org/choices), which provides information regarding this practice by Network Advertising Initiative ("NAI") members, and your choices regarding having this information used by these companies, including the "opt-out" procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance ("DAA") website at (http://www.aboutads.info/choices). Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

9. What About Transfer of Information to the United States?

Our Services are operated in the United States and intended for users located in the United States and certain services may only be available to users who are located in specific states in the United States identified in our Terms and Conditions or on the Services. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://oh.betway.com/ and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?

(a) Information You Provide to Us
(b) Information We Collect and Store As You Access and Use the Services
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Services
(e) Photographs and Biometric Information
(f) Information You Provide About a Third Party
(g) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties
(b) Third Parties Providing Services on our Behalf
(c) Administrative and Legal Reasons
(d) Affiliates and Business Transfer
(e) Sweepstakes, Contests and Promotions
Your California Privacy Rights

(a) Personal Information We Collect
(b) How We Use Your Personal Information
(c) Sources of Personal Information
(d) Who We Share Personal Information With
(e) Your Privacy Rights
(f) Notice of Right to Opt-Out
(g) Right to Opt-Out of Sharing For Direct Third Party Marketing
Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights
(b) Your Connecticut Privacy Rights
(c) Your Virginia Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

Contact Us

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.
Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality‑Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting‑Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(c) Information Third Parties Provide About You

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

(f) Photographs and Biometric Information

In some circumstances, we may require you to provide your photograph and/or facial image in order to verify your identity and/or comply with our legal and regulatory obligations. These photographs may be received and processed by third party service providers to provide these services on our behalf and for our exclusive benefit. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology.

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression).
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as, facial scans, faceprints, or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

(c) Sources of Personal Information

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell”/”share” personal information with third parties. as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting selling or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale/sharing of your personal information by a business. as those terms are defined by California law. Information about how to exercise these opt-out rights is set forth, in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at [email protected], with “California Privacy Rights” as the subject line
Mail at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/”share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

(c) Your Virginia Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).

For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.

For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.
Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.
We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You may provide updates and changes by contacting us. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Similarly, because applicable law or instructions, guidance or recommendations from regulatory bodies require us to retain certain information for a minimum period of time, we do not offer an option to delete your account. However, you may close your account with us. To do so, please see the instructions in the Closure of Accounts section of the Terms of Use or contact Customer Support to request account closure. When you close your account, we retain certain of your data as required by applicable law or to comply with instructions, guidance or recommendations from a regulatory body, such as the state gaming regulator.

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Services account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and Services announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

9. What About Transfer of Information to the United States?

10 .What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy ("Privacy Policy") governs our websites (including, without limitation: https://us.betway.com, https://pa.betway.com and other websites that link to this Privacy Policy) (each, a "Website" and collectively, the "Websites") and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the "Betting Apps") (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the "Services"), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as "Betway", "we", "us", or "our"). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

In addition, please review the Services’ Terms of Use, which governs your use of the Services. By using our Services, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use the Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties

(b) Third Parties Providing Services on our Behalf

(d) Affiliates and Business Transfer

(e) Sweepstakes, Contests and Promotions

Your California Privacy Rights

(a) Personal Information We Collect

(b) How We Use Your Personal Information

(d) Who We Share Personal Information With

(e) Your Privacy Rights

(f) Notice of Right to Opt-Out

(g) Right to Opt-Out of Sharing For Direct Third Party Marketing

Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

your IP address, UDID or other unique identifier ("Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Services;
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the date and time of day of your visit, among other information.

Cookies. A cookie is a data file placed on a Device when it is used to visit the Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Services functionality.
Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
Targeting-Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

(f) Photographs and Biometric Information

In some circumstances, we may require you to provide your photograph and/or facial image in order to verify your identity and/or comply with our legal and regulatory obligations. These photographs may be received and processed by third party service providers to provide these services on our behalf and for our exclusive benefit. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology.

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms; provided, however if required by applicable law or third party platform, we will make commercially reasonable efforts to honor a user’s settings.

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

(c) Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression.
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as, facial scans, faceprints, or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers..
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell”/”share” personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting, selling or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/Sharing You have the right to opt-out of the sale/ sharing of your personal information by a business as those terms are defined by California., law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process a request, we may partially or fully deny the request if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state, or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at [email protected], with “California Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.
We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

This collection and ad targeting takes place both on our Services and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a Google Ads cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services. To learn more about how to opt out of Google’s use of cookies, visit the Google’s Ads Settings, here. To learn more about how to opt out of use of the Google Analytics cookies, visit the opt-out page, here.

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

9. What About Transfer of Information to the United States?

Our Services are operated in the United States and intended for users located in the United States and certain services may only be available to users who are located in specific states in the United States identified in our Terms of Use or on the Services. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Effective Date: 5/9/2023

Introduction

Welcome to Betway! This privacy policy (“Privacy Policy”) governs our websites (including, without limitation: https://va.betway.com and other websites that link to this Privacy Policy) (each, a “Website” and collectively, the “Websites”) and the mobile, tablet and any other Betway mobile apps (all of which together are referred to herein as the “Betting Apps”) (the Websites and Betting Apps and any services or functionality available in connection therewith are collectively referred to as the “Services”), which are operated and controlled by Digital Gaming Corporation USA (referred to herein as “Betway”, “we”, “us”, or “our”). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Services.

In addition, please review the Services’ Terms of Use, which governs your use of the Services. By using our Services, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use the Services.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with Betway.

What Information Do the Services Collect?

(a) Information You Provide to Us
(b) Information We Collect and Store As You Access and Use the Services
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Services
(e) Information You Provide About a Third Party
(f) California / Delaware Do Not Track Disclosures

How Do We Use the Information Collected?

How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties
(b) Third Parties Providing Services on our Behalf
(c) Administrative and Legal Reasons
(d) Affiliates and Business Transfer
(e) Sweepstakes, Contests and Promotions
Your California Privacy Rights

(a) Personal Information We Collect
(b) How We Use Your Personal Information
(c) Sources of Personal Information
(d) Who We Share Personal Information With
(e) Your Privacy Rights
(f) Notice of Right to Opt-Out
(g) Right to Opt-Out of Sharing For Direct Third Party Marketing
Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights
(b) Your Connecticut Privacy Rights
(c) Your Virginia Privacy Rights

Ads and Information About You

Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

How Do I Change My Information and Communications Preferences?

What About Transfer of Information to the United States?

What Should Parents Know About Children?

What About Security?

What About Changes to the Privacy Policy?

Contact Us

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

On the Services, we or our service providers may ask you to provide certain types of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, email address, home or mailing address, birth date, credit card or other banking information, social security number and phone numbers (“Personal Information”); and (2) demographic information, such as information about your gender and age (“Demographic Information”). We may collect this information through various forms and in various places on the Services, including through “contact us” forms, when you register for an account with the Services, deposit funds into an account, on document upload pages, when you wager or otherwise purchase products or services from us or if you request to receive communications from us. In addition, Personal Information once “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements including through anonymization, pseudonymization and/or hashing) is not considered Personal Information and may be used and shared by us or other third parties without obligation to you, except as prohibited by applicable law.

(b) Information We Collect and Store As You Access and Use the Services

In addition to any Personal Information or other information that you choose to submit to us via our Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Services. Usage Information may be non‑identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information. This Usage Information may include:

We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

We may use Tracking Technologies for a variety of purposes, including:

There may be other Tracking Technologies now and later devised and used by us in connection with the Services. Further, third parties may use Tracking Technologies in connection with our Services, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

(c) Information Third Parties Provide About You

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

(f) Photographs and Biometric Information

In some circumstances, we may require you to provide your photograph and/or facial image in order to verify your identity and/or comply with our legal and regulatory obligations. These photographs may be received and processed by third party service providers to provide these services on our behalf and for our exclusive benefit. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology.

We only process this information for the specific purposes listed above and under Section 2 of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable laws and regulations. Where a third party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

(g) California / Delaware Do Not Track Disclosures

2. How Do We Use the Information Collected?

to process, track and complete gambling, betting and other transactions;
to verify your identity, including your accounts on the Services and to perform know your customer verification and background checks;
to provide you with information and other communications such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;
to enable you to participate in a variety of the Services’ features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
to assist with responding to audit requests;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
to provide the Services, including the gaming opportunities available on the Services;
to improve the Services, marketing endeavors or our product and service offerings;
to customize your experience on the Services or to serve you specific content or ads that we believe are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
manage and protect our information technology infrastructure;
to protect and administer your Services account;
to process Services account registration;
to offer location-based services;
to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
to send you information about bets or wagers you have placed on the Services;
to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
to identify you as a customer and to identify your preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services policies;
to measure and analyze audience traffic and to improve the overall experience at the Services and our merchandise and services;
to understand whether you read our communications and clicked on links within those messages;
to develop aggregated data, analytics and statistics;
to comply with our legal and regulatory obligations;
for internal business purposes; and
for purposes as otherwise set forth in this Privacy Policy.

(a) When You Request Information from or Provide Information to Third Parties.

You may be presented with an option on our Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Services or link to them from our Services. This may include using third party tools such as Facebook, Twitter, Instagram or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. It may also include ordering or purchasing products or services from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf.

We may use third-party vendors to perform certain services on behalf of us or the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons.

We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(e) Sweepstakes, Contests and Promotions.

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

4. Your California Privacy Rights

This Section provides additional information regarding the personal information about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Betway’s responsibilities, under the California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (together, the ““CCPA”) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information, collected via any medium, including online and offline. Personal information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified or aggregated, or other information covered by certain sector-specific and/or federal privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) Personal Information We Collect

Betway may collect, or has collected, the following categories of personal information about you over the last twelve (12) months:

Category	Examples
Identifiers.	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, Social Security number, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Your first and last name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Protected classification characteristics under California or federal law.	Age, race/ethnicity, national origin, citizenship, or sex (including gender, gender identity, and gender expression).
Commercial information.	Records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution.
Biometric information.	Facial image and similar physiological characteristics used to extract a template or other identifier or identifying information, such as, facial scans, faceprints, or other physical patterns (as further detailed in Section 1(f) of this Privacy Policy).
Internet or other similar network activity.	Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”).
Geolocation data.	GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s).
Sensory data.	Audio, electronic, visual, or similar information, including records of calls to or from our customer service centers.
Professional or employment-related information.	Current employment status; compensation-related information.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social Security number, driver’s license, state identification card, or passport number;
Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account;
Precise geolocation;
Racial and/or ethnic origin; and
Processing of biometric information for the purpose of uniquely identifying a consumer (as further detailed in Section 1(f) of this Privacy Policy).

(b) How We Use Your Personal Information

We use the personal information we collect about you for all of the business purposes outlined in Section 2 above.

The sensitive personal information that we collect as described in Section 4(a) above may be used for any of these purposes.

We will not retain any information we collect form you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

(c) Sources of Personal Information

We may collect the categories of personal information listed above from the following categories of sources:

From you, including via our Services, websites, telephone, postal mail, social media, forums, or other means.
From other individuals using our Services who may provide information about you to us through content submissions or postings on the Service, or to facilitate communication with you.
Our affiliated businesses and brands, including our other gambling sites or services.
Through our service providers, including our communications and analytics service providers as well as parties that perform verification services for us.
Business partners to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
Third party social media or communications platforms, such as if you choose to use a third-party social media platform to facilitate your registration with our Services. Process a transaction, or otherwise link your accounts.
Other third party data sources, such as companies that may collect information about you that is provided to us for marketing purposes.

We may supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers.

(d) Who We Disclose Personal Information To

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 4(a), including the listed sensitive personal information, for one or more business purposes.

We “sell”/”share” personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. We have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have disclosed, “sold,” or “shared” the following categories of personal information to the following categories of third parties:

Categories of third parties	Categories of personal information disclosed for a business purpose	Categories of personal information sold/ shared
Affiliated businesses and brands	Identifiers and Internet or other similar network activity.	N/A
Service providers	All categories	N/A
Advertising partners	N/A	Identifiers; commercial information; information relating to Internet activity or other electronic network activity

We do not have actual knowledge of collecting, selling, or sharing any personal information of California residents under the age of sixteen (16).

(e) Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a twelve (12)-month period, request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Opt-Out of Sale/Sharing You have the right to opt-out of the sale/ sharing of your personal information by a business as those terms are defined by California law. Information about how to exercise these opt-out rights is set forth in Section 4(f) below.
Right to Correct. You have the right to request the correction of your inaccurate personal data.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on.In order to verify you, you must provide us with name and email address and in some cases, additional information such as last four digital of your Social Security number These rights are also subject to various exclusions and exceptions under applicable laws.

You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf.The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to [email protected].

We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of thirteen (13), as we do not collect personal information from any person under the age of thirteen (13).

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. When we respond to or process a request, we may partially or fully deny the request if the CCPA recognizes an exception. For example, we may be required by applicable law to retain personal information about use of the Services, and if you submit a Right to Delete request, we will not delete personal information that is subject to an exemption or exception or that is otherwise necessary to maintain to comply with a federal, state, or local law or applicable regulatory requirements.

You may exercise any of the rights described in this section in any of the following ways:

Access our webform
Email us at [email protected], with “California Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030.

(f) Notice of Right to Opt-Out

We “sell”/“share” personal information, as those terms are defined under California law, only to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law.

If you wish to opt-out of our selling/sharing of the personal information that is gathered when you visit our Services for purposes of targeted digital advertising, access our webform and opt-out of “Selling/Sharing of Personal Information and Targeted Advertising.”

Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request.

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

We may now or in the future elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2021 will receive information about 2020 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: [email protected], with “California Privacy Rights” as the subject line or mail us a letter to: Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030. You must include your full name, email address with which you registered on Betway, and postal address in your request.

5. Your Privacy Rights in Other States

Depending on your state of residency, you may have certain other privacy rights as described below.

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

(c) Your Virginia Privacy Rights

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Services, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).

For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.

For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(i) What Personal Data We Collect
We may collect the personal data from or about you as detailed in Section 4(a) of this Privacy Policy.

Certain of the personal data described above constitutes “sensitive personal data” as defined under Virginia law, including:

Racial or ethnic origin;
Biometric data (as further detailed in Section 1(f) of this Privacy Policy); and
Precise geolocation data.

(ii)        What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Section 4(b) of this Privacy Policy. To the extent we collect sensitive personal data as identified in Section 5(c)(i) above, it may be used for any of these purposes.

(iii)       Who We Disclose Personal Data To

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.

We do not “sell” your personal data as that term is defined under Virginia law.

We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 5(c)(iv) below.

(iv)       Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

Right to Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for sales or profiling in this manner.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that the Services are for a general audience and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide, such as name, email address, and in some cases, additional information such as last four digital of your Social Security number. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, you may do so in any of the following ways:

Access our webform
Email us at [email protected], with “Virginia Privacy Rights” as the subject line
Mail us at Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

The Services may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Services are served to you for their own commercial purposes. In addition, when you are on the Services you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Services onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third parties. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Services and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

8. How Do I Change My Information and Communications Preferences or Close My Account?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You may provide updates and changes by contacting us. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Similarly, because applicable law or instructions, guidance or recommendations from regulatory bodies require us to retain certain information for a minimum period of time, we do not offer an option to delete your account. However, you may close your account with us. To do so, please see the instructions in the Closure of Accounts section of the Terms of Use or contact Customer Support to request account closure. When you close your account, we retain certain of your data as required by applicable law or to comply with instructions, guidance or recommendations from a regulatory body, such as the state gaming regulator.

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Services account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and Services announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

You may agree to receive text messages regarding product offers and promotions by Betway via automated technology. You are not required to agree to receive text messages to make a purchase. You may, at any time, decide to stop receiving text messages regarding product offers and promotions by Betway by replying STOP to any text message you receive from Betway. If you need help or assistance with the messages, you may contacting us. MSG and data rates may apply. Carriers are not liable for delayed or undelivered messages.
If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us as follows: Digital Gaming Corporation USA, d/b/a Betway, 330 Washington St., PMB 502, Hoboken, NJ 07030 (Attn: Privacy) or at [email protected].

9. What About Transfer of Information to the United States?

Our Services are operated in the United States and intended for users located in the United States and certain services may only be available to users who are located in specific states in the United States identified in our Terms of Use or on the Services. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Email	[email protected]
Mailing address	Digital Gaming Corporation USA, d/b/a Betway 330 Washington St., PMB 502 Hoboken, NJ 07030 (Attn: Privacy)

Privacy Policy

Introduction

Table of Contents

The Full Detailed Privacy Policy

Introduction

Table of Contents

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

2. How Do We Use the Information Collected?

3. How and When Do We Disclose Information to Third Parties?

4. Your California Privacy Rights

5. Your Privacy Rights In Other States

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

Introduction

Table of Contents

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

2. How Do We Use the Information Collected?

3. How and When Do We Disclose Information to Third Parties?

4. Your California Privacy Rights

5. Your Privacy Rights in Other States

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Changes to the Privacy Policy?

13. Contact Us

Introduction

Table of Contents

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

(a) Information You Provide to Us

(b) Information We Collect and Store As You Access and Use the Services

(c) Information Third Parties Provide About You

(d) Interactions with Third-Party Services

(e) Information You Provide About a Third Party

(f) Photographs and Biometric Information

(g) California / Delaware Do Not Track Disclosures

2. How Do We Use the Information Collected?

3. How and When Do We Disclose Information to Third Parties?

(a) When You Request Information from or Provide Information to Third Parties.

(b) Third Parties Providing Services on our Behalf

(c) Administrative and Legal Reasons

(d) Affiliates and Business Transfer.

(e) Sweepstakes, Contests and Promotions.

4. Your California Privacy Rights

(a) Personal Information We Collect

(b) How We Use Your Personal Information

(c) Sources of Personal Information

(d) Who We Disclose Personal Information To

(e) Your Privacy Rights

(f) Notice of Right to Opt-Out

(g) Right to Opt-Out of Sharing for Direct Third Party Marketing

5. Your Privacy Rights in Other States

(a) Your Nevada Privacy Rights

(b) Your Connecticut Privacy Rights

(c) Your Virginia Privacy Rights

6. Ads and Information About You

7. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

8. How Do I Change My Information and Communications Preferences or Close My Account?

9. What About Transfer of Information to the United States?

10. What Should Parents Know About Children?

11. What About Security?

12. What About Data Retention

13. What About Changes to the Privacy Policy?

14. Contact Us

Introduction

Table of Contents

The Full Detailed Privacy Policy

1. What Information Do the Services Collect?

2. How Do We Use the Information Collected?