Privacy Notice

INTRODUCTION

Welcome to Pret Play Limited’s (“Pret Play”, “we”, “us”, “our”) Privacy Notice which applies to the provision of our services on casumo.com/on and any related software applications (collectively referred to as the “Website”).

We respect your privacy and we are committed to protecting your personal information. This commitment exists throughout the lifecycle of the personal information which we collect, from the design of any service which uses personal information to the deletion of that personal information. Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

Pret Play is providing the Website and its offerings as part of the open and regulated internet gaming (igaming) market in Ontario conducted and managed by iGaming Ontario (“iGO”) and is collecting, using and disclosing personal information on behalf of, and as agent to, iGO. The personal information collected, used and disclosed by Pret Play on behalf of iGaming Ontario is collected, used and disclosed pursuant to the Freedom of Information and Protection of Privacy Act (Ontario) (“FIPPA”) and O. Reg. 722/21 made under the Alcohol and Gaming Commission of Ontario Act, 2019 (Ontario) and Pret Play’s Operating Agreement with iGO.

We are committed to collecting, using, and disclosing your personal information in compliance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

Please note that other privacy and data protection laws,may apply to Pret Play and its collection, use, and disclosure of personal information.

This Privacy Notice will inform you as to how we collect, use, disclose and look after your personal information. This Notice covers, among other topics:

• Information about who we are and how to contact us;
• Transparency about how we collect, use, and disclose your personal information, including when and how it is shared and the categories of recipients;
• Information on how we protect your personal information;
• Information about your rights, the choices available to you, and how we will facilitate your rights and respond to your questions.

This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE INFORMATION WE MAY COLLECT ABOUT YOU
3. HOW IS YOUR INFORMATION COLLECTED
4. HOW WE USE YOUR PERSONAL INFORMATION
5. SHARING OF YOUR PERSONAL INFORMATION
6. INTERNATIONAL TRANSFER
7. SECURITY
8. RETENTION
9. YOUR LEGAL RIGHT
10. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice (the “Privacy Notice” or the “Notice”) aims to give you information on how Pret Play collects and processes your personal information, including any personal information you may provide through this Website when you sign up using our registration form, send us an email, make a phone call or use our Live Chat service and any personal information we may collect about you to provide you with our online gaming and betting services (the “Services”) with respect to our relationship with you as a player.

It is important that you read this Privacy Notice together with our Cookie Policy and any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This Privacy Notice supplements the other notices and is not intended to override them.

This Website and our Services are not designed or directed to persons under the age of 19 with respect to the use of the Services (“Legally of Age”). If you are not Legally of Age, you should not use the Services nor provide any personal information to us. If you are the parent or guardian of someone who is not Legally of Age and who has provided us with their personal information, please contact our Privacy Officer as indicated below and we will delete such personal information.

PRIVACY OFFICER CONTACT DETAILS

The Company has appointed Privacy Officer who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions relating to this Privacy Notice, including any requests to exercise your rights, please contact the Privacy Officer using the details given below.

We also have a Policy to address complaints, including complaints related to the collection, use and disclosure of personal information. If your complaint about the collection, use or disclosure of personal information has not been resolved through the customer care complaints process, you may ask the Privacy Officer to resolve your questions or concerns. To do so, you may contact the Privacy Officer using the contact information provided below. If you are not satisfied with our response to your complaint, you can request a copy of your case file in order to escalate your compliant to iGO. Please see our Policy for more information about this process.

Our full details are:

Full name of legal entity: Pret Play limited
Company registration number: C77857

Postal address: Suite 5B, Watergardens 1, Gibraltar, ATTN Privacy Officer

Data Protection Officer Email: dpo@pretplay.com 

We may collect, use, store and transfer different categories of personal information about you, which we have grouped together as follows:

• Registration Data includes first and last name, username or similar identifier, date of birth, social insurance number (where permitted or required by law), gender, country.
• Contact Data includes postal address, email address and telephone number(s).
• Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) includes first and last name, permanent address and proof of address, date of birth, nationality, employment history and information, adverse media report, financial status and information (e.g. bank statement, source of income and source of wealth, tax information), Politically Exposed
• Person check, sanction check screening, masked credit card details, proof of e- wallet ownership such as Neteller, Skrill, Paypal, Paysafe, KYC documentation (e.g. ID card, passport, utility bill, any other document as may be specified in sectoral implementing procedures issued by the relevant regulatory authorities).
• Responsible Gambling Data (RG) including name, surname, postal code, email, phone number, country, date of birth, social insurance number (where permitted or required by law), approved transactions (deposits and withdrawals), denied transactions (deposits and withdrawals), Identification and Verification Data, Self-exclusion Data.
• Self-exclusion Data includes personal information pertaining to you and your self-exclusion such as your Registration and Contact Data and your self-exclusion details such as reason, start and date, utilisation of self- exclusion tools such as exclusions, session limit, loss limit, wager limit, deposit limit, reality check.
• Financial Data includes payment card details and bank account details.
• Transaction and Usage Data includes details generated through your use of our Services (e.g. playing Games) and include payments to and from you (deposits, withdrawals, failed deposits and reversed withdrawals) and other details of Services you have purchased from us (such as bets, wagers (real and bonus), wins), date and time of the transactions, account balances (bonus and real), bonuses used (conversion and forfeiture), bonuses turnover, bonuses balance, channels used, transaction games played, language, country, account balances.
• Login Data includes internet protocol (IP) address, your logins (first login, last login, last failed login), duration of logins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
• Profile Data includes internal notes to your account, interests and preferences.
• Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out).
• Other Communication Data provided by you in communication with us (via recorded calls, chats, emails, or SMS) which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes.
• Analytics Data include various data provided by your observed with respect to your use of our Website and Services such as your player ID, language, location, browser data, campaigns utilised, channels used, device, payment provider, Transaction and Usage Data and in case of online acquisition Analytics and pages visited, postcards clicked, scroll depth. Certain information is collected using cookies and/or similar tracking technology as described in our Cookie Policy.

We collect your personal information through different methods, including:

• Direct interactions - you may give us your Registration, Contact, Identity and Verification, Marketing and Communications and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise when you engage with us to provide you with our Services.
• Third parties and publicly available sources - We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information and other third parties. Due to regulatory requirements we collect “know your customer” (KYC) information from specialized third parties. Such information is collected only when it is reasonably necessary for the organization’s activities.
• Automated technologies or interactions - We and our third-party service providers may collect information automatically from your device in a variety of ways, including:

1. Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your IP, device type, language and the Internet browser type you are using.
2.  Through your use of an app: When you download and use our apps, we may track and collect app usage data, such as the date and time the app on your device accesses our Servers and the information and files that have been downloaded to the app.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that personal information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information related to your query).

We will only use your personal information with your consent and when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• To process your registration, set up and look after your account (including checks made to age verify you and to guard against fraud);
• To provide and operate the Services (such as for gaming/betting and payment processing);
• To communicate with you and to keep you informed of our latest updates to our Services and, without your consent, special offers;
• For legal and regulatory reasons, to comply with our legal obligations and
• License/registration conditions such as Anti-money laundering and responsible gaming; including for the purpose of ascertaining your source of funds or income, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request;
• Providing, maintaining, enhancing and personalizing the Services and analysing how customers use the Services and the Website;
• To know your preferences and to try to ensure that the content on our Website is presented in the most effective manner for you and your computer or mobile device;
• To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
• To communicate with your and to process any of your requests to exercise your Legal Rights;
• To identify and authenticate your access to certain features of the Services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
• To investigate violations of our policies and Terms and Condition as well as enforce our policies and the Terms and Conditions; and
• To investigate and resolve disputes in connection with your use of the Services.
• For any other purpose with your consent.

PURPOSE FOR PROCESSING YOUR PERSONAL INFORMATION

We have set out below, in a table format, a description of all the ways we use your personal information.

Purpose/Activity	Type of data
To register you as a new player, identify you and verify you when you access your Account to allow you to participate in games.	(a) Registration Data (b) Contact Data (c) Log-in Data
To allow you participate in the games.	(a) Transaction and Usage Data
To process and manage transactions	(a) Financial Data (b) Transaction and Usage Data
To manage our relationship with you, to provide you with access to our Services.	(a) Registration Data (b) Contact Data (c) Profile Data (d) Other Communication Data (e) Transaction and Usage Data (f) Self-exclusion Data
For AML/CTF and due diligence purposes	(a) Registration Data (b) Contact Data (c) Identity and Verification Data (e) Transaction and Usage Data
To establish and investigate any suspicious behaviour in order to protect our business from any risk and fraud	(a) Registration Data (b) Contact Data (c) Identity and Verification Data (d) Log-in Data (e) Financial Data (f) Other Communication Data
Identification and investigation of gaming activity for responsible gaming purpose	1. Responsible Gaming Data 2. Self-exclusion Data 3. Other Communication Data
Responsible gaming profiling	(a) Responsible Gaming Data (b) Self-exclusion Data (c) Other Communication Data
To ensure that self-excluded players with respect to Pret Play or any other brand/ company within related entity are duly self- excluded and do not access our Services.	1. Self-exclusion Data
Subject to obtaining your consent, direct marketing of our own Services including bonuses, news, and promotions.	1. Contact Data 2. Marketing and Communication Data
Subject to obtaining your consent, direct marketing of products and services including promotions of any other brand/company of our affiliates.	1. Contact Data 2. Marketing and Communication Data
Social Media Marketing	1. Contact Data
Subject to obtaining your consent, customer segmentation for the purposes of tailored offers and bonuses sent via direct marketing.	1. Registration Data 2. Transaction and Usage Data
To administer and protect our business and this portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Registration (b) Contact (c) Analytics data

MARKETING

We may use your personal information, such as your email address and telephone number, ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials (including news and bonuses), concerning our Services.

We will use your personal information for the purpose of providing you with promotional materials solely where permitted by law, and where required, subject to having obtained your affirmative consent.

Such a consent may be granted by you when registering on our Website.

If you do not wish to receive direct marketing any longer, you may opt out, easily, at any time, either by:

• unsubscribing or activating the relevant link at the end of an electronic message, or
• contacting us, or
• changing your Settings in your profile.

In case of social media marketing, you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third-party platforms (e.g. Facebook).

In addition, if you download our mobile application to your device from the Apple AppStore or Google Play, the only way to prevent receipt of notifications is by changing the settings on the device itself.

THIRD-PARTY TRACKING TECHNOLOGIES

When you visit the Website or access our Services, we use (and authorise third parties to use) cookies, pixels, and other technologies ("Tracking Technologies").

The Tracking Technologies allow us to automatically collect information about you and your online behaviour, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our users and players.

For further information on what Tracking Technologies/cookies are, which cookies we use, how and why we use cookies, and how you can control which cookies are dropped, please read our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it.

If we need to use your personal information for an unrelated purpose, we will notify you and seek your consent before engaging in any such use.

Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

We do not rent, sell, or share your personal information with third parties (“Recipients”) except as described in this Privacy Notice. The personal information will be disclosed to Recipients only to the extent required for the specific purpose(s), as stipulated in this Privacy Notice.

We may have to share your personal information with the following categories of Recipients:

Professional advisers including lawyers, bankers, auditors and insurers based in Malta who provide consultancy, banking, legal, insurance and accounting services.

Any service providers, including those that are related entities, that may require access to your personal information in rendering us with their support services, for example, IT service providers, payment service providers, game providers for the purpose of provision of games, AML providers providing and/or processing certain personal information for the purposes of compliance with our AML obligations, analytic services providers, service providers that technically enable communication with you (via email, chat, SMS, phone), marketing service providers, hosting service providers, Website performance and security systems service providers.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Notice. 

Credit Reference Agencies as part of Our Affordability checks and to ensure compliance with Our Player Protection responsibilities. Please see https://www.transunion.co.uk/legal/privacy-centre/pc-bureau for more information on the Agency we use for these services.

We require all third parties that are acting as processers to Pret Play to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

When you create an account on the Website, you must choose a password and personal question used to retrieve access to your account. You are responsible for keeping your username, password and personal question details private and confidential. Do not share your password with anyone and please change it periodically to reduce the risk that your account may be compromised. If you suspect your password has been disclosed to anyone, please change it immediately.

Where required by law, your personal information may be disclosed to an applicable governmental, regulatory, or enforcement authority. Your personal information may also be disclosed to any regulatory body in connection with policing the integrity or enforcing the rules of a game and/or prevention and detection of crime and where Pret Play considers that there are reasonable grounds to suspect that you may be involved in a breach of such rules or the law, have knowledge of a breach of such rules or the law or otherwise pose a threat to the integrity of the relevant game. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

We may process, store, and transfer your personal information in jurisdictions outside of Ontario, with different privacy laws that may or may not be as comprehensive as applicable Canadian privacy laws. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

Whenever we store or process personal information outside Ontario, we provide the same security as is required were the personal information being processed or stored in Ontario. Whenever we transfer your personal information to a service provider outside Ontario, we ensure a comparable degree of protection is afforded to it by contractually obligating service providers to keep Personal Information confidential, to use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you, iGO and any applicable regulator of a breach where we are legally required to do so and in accordance with the requirements of applicable law. We will also aid iGO and any related authorities in breach management and handling of any results from a breach.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, regulatory, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal information are available in our disposition which you can request from us by contacting our Privacy Officer.

Where your personal information is no longer required by us, and where permitted by law, we will either securely delete or anonymise the personal information in question in accordance with our disposition policy.

By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send a request to our Privacy Officer using the contact information provided above asking to access to, correct, or delete any personal information that you have provided to us.

If you would like to correct the information provided, you may contact our Privacy Officer using the contact information provided above.

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our Privacy Officer using the contact information provided above. Please note that if you withdraw your consent we may not be able to provide you with a particular aspect of the Services. We will explain the impact to you at the time to help you with your decision.

WHAT WE MAY NEED FROM YOU

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

RIGHT TO MAKE A COMPLAINT

We try to follow the highest standards in order to protect your privacy and rights. However, should you have any concerns in connection with this Privacy Notice, we encourage that you get in contact with us in the first instance by contacting our Privacy Officer using the contact information provided above. We will deal with your queries as soon as we can and keep you informed of progress.

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Privacy Notice, and with applicable privacy laws. To discuss our compliance with this policy please contact our DPO using the contact information provided above.

We may amend this Privacy Notice in our sole discretion from time to time. If we make changes to this Privacy Notice, we will provide notice of such changes by sending an email notification; or publishing a notice of the revised Privacy Notice on our Website; and updating the ‘Last updated’ date applicable to this Privacy Notice.

Where we make material amendments to how we treat our customer's personal information, we will require you to accept and consent to the amended Privacy Notice prior to accessing the Website.

You are encouraged to regularly check our Privacy Notice whenever you access or use either our Website or Services in order to consider any updates or changes. If you do not agree to our revised Privacy Notice, you should not access or use either our Website or Services.

It is also important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us.

This Privacy Notice was last updated on: June 2, 2022