Last Updated March 6, 2023
You can access our Online Offerings in many ways, including from a computer or mobile device, and this Policy will apply regardless of the means of access. To the extent we provide you notice through our Online Offerings of different or additional privacy policies or practices (e.g., at the point of collection), those additional terms shall govern such data collection and use in addition to this Policy.
Please read this Policy carefully. If you do not want us to collect, use or disclose your personal information in the ways described in this Policy, please do not use our Services, provide us with your personal information, or authorize a third party to make your personal information available to us. By using our Services, providing us with your personal information or otherwise making your personal information available to us, you acknowledge that you understand that we may use your personal information as described in this Policy. Please note, as described in this Policy, we may receive your personal information from third parties who may not have expressly advised you that they will disclose your personal information to us. If you have any questions about how we collect, use, protect, disclose or otherwise process personal information, including whether we have received your personal information from a third party, please contact us via e-mail at email@example.com, or via our Customer Service portal.
This Policy governs the personal information collection, use, sharing, and related practices applicable to the Services in Ontario only. “Personal information” means information about an identifiable individual and includes any information that constitutes personal information within the meaning of the Freedom of Information and Protection of Privacy Act (“FIPPA”) and other applicable privacy laws. This Policy is separate and distinct from the privacy policies that govern the online gaming services offered by BetMGM and MGM Resorts International in other jurisdictions.
This website and the Services operate under and pursuant to the Operating Agreement (as defined below) and are being offered by BetMGM as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (www.igamingontario.ca/en). In the course of providing the services: (i) BetMGM collects, uses and discloses personal information on behalf of and as agent to iGaming Ontario; (ii) BetMGM collects personal information in accordance with FIPPA and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act, 2019, and the operating agreement entered into between BetMGM and iGaming Ontario (“Operating Agreement”).
Except as otherwise stated in this Policy, this Policy does not apply to the websites, online gaming services and other services operated, controlled or offered by MGM Resorts International (“MGM”). Furthermore, this Policy does not apply to our privacy practices with respect to our collection, use, storage, disclosure, and protection of personal information relating to our employees and job applicants.
I. INFORMATION WE COLLECT
This section describes BetMGM’s personal information collection, use and processing activities related to certain portions of the Services.
A. Information You Provide. In order to access and use our Gaming Operations, you must register for an online Ontario wagering account (a “Wagering Account”). When you register for a Wagering Account, we will access and collect the personal information you provide (including your name, username, postal address, e-mail address, descriptive occupation (i.e. job position and industry), gender, date of birth and preferences). We may also ask you for additional information, including your mobile phone number, and a government-issued photo identification such as your driver’s license, Ontario photo card, or passport.
When we verify Your identity when You first register Your Account with us, we share certain information with Canadian credit bureaus, such as TransUnion Canada (via our service provider, Aristotle) and Equifax Canada (via our service provider, GBGroup), in order to validate ID as required by applicable federal law. We will also use a third-party service provider, Jumio, where necessary, who will assist with verifying the details of your government-issued photo-identification and proof of address documents as required under applicable law. Further information about how these credit bureaus and third-party service providers treat your information can be found on their relevant websites.
We will collect certain of the above personal information, and if provided by you, your country of residence, business telephone number, employer’s name, employer’s address, citizenship, and alias/preferred name for the purposes of complying with our anti-money laundering obligations under applicable law. If you attest that you are a Politically Exposed Person (“PEP”), the Head of an International Organization (“HIO”), or a family member or a close associate of a PEP or HIO, as those terms are defined in the General Terms of Service, you will be required to provide additional information such as your source of funds, your source of wealth, the nature of your connection to the PEP or HIO if you are a family member or close associate of a PEP or HIO, the office or position of the PEP/HIO, the PEP or HIO organization/institution name and, if you are a family member or close associate of a PEP or HIO, the nature of the relationship between the family member and close associate of the PEP or HIO. Such information is collected on behalf of iGaming Ontario and may be shared with other Operators as part of enterprise level player monitoring.
We will also verify whether you have a current MGM Rewards account. If you do not have a current MGM Rewards Account, you will be required to create an MGM Rewards Account as part of the registration process. You can learn more about the MGM Rewards program by visiting https://mgmresorts.com. You can review the terms and conditions for the MGM Rewards program here and MGM’s privacy practices with respect to the MGM Rewards program here. For more information about how BetMGM and MGM utilize and share information in connection with your Wagering Account and MGM Rewards Account, please see Section III.B below.
When you access, participate in, or otherwise interact with our Services, or otherwise engage with us in connection with our Services, such as requesting more information about our Services or communicating with us, we may ask you to provide us with additional personal information. Please note, if you do not provide us with personal information that is required for a particular feature of our Services, such as information we are legally required to collect when you register for a Wagering Account, you may not be able to access, participate in, or otherwise use certain portions of our Services.
B. Gaming, and Transaction Information. When you use the Services, we and our third-party service providers may collect information about your gaming activity, and all transactions associated with your Account.
Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also modify your Flash Player settings to prevent the use of flash cookies.
If you choose to decline cookies, you may not be able to experience all of the interactive features available through the Services. You can visit www.allaboutcookies.org in order to obtain more information on deleting or controlling cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services.
E. Wi-Fi and Location Information. In your use of the Services, we may collect information (directly or through third party service providers) that includes the web sites you visit, the type of device and browser you are using, your device identification number, bandwidth used, session time, etc. We and our service providers utilize several current technologies, and may use future technologies, that enable us and our service providers to determine the location of devices that engage, or attempt to engage, in any wagering activity through or in connection with our Gaming Operations (collectively, “Location Tracking Technologies”) in order to: (i) verify your physical location when you engage, or attempt to engage, in any wagering through or in connection with a specific Gaming Operation; and (ii) improve the location-based services utilized by our Services. The Location Tracking Technologies are capable of identifying the near-precise physical location of the computers or Internet-connected devices that engage, or attempt to engage, in any wagering activities through or in connection with our Gaming Operations by accessing the device’s IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates (collectively, “Location Information”).
F. Affiliate and Third-Party Information. We may obtain information about you from MGM Resorts International and casinos, resorts, platforms, and properties that are owned, operated, managed by or affiliated with MGM Resorts International (collectively “MGM Affiliates”), from our other parent and affiliated companies, including, but not limited to, Entain plc (collectively, with the MGM Affiliates, our “Affiliates”) and from third parties, including our business partners and other companies and individuals that refer you to our Services. This information may include, among other things, information related to your MGM Rewards Account that we need to make the Services available to you, information to set up your Wagering Account and information necessary to connect your Wagering Account to your account with one or more of our business partners.
II. HOW WE USE THE INFORMATION WE COLLECT AND OPT-OUT OPTIONS
A. Use by BetMGM
Marketing Purposes. With your consent, we may use the information we collect for our own marketing purposes, including notifying you of special promotions, offers, and events via push notifications, e-mail, and other means. We may also link personal information (including your name, mobile phone number, and e-mail address) and use such information for our own marketing purposes. If you do not want us to use your personal information for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.
Non-Marketing Purposes. We may use the information we collect for non-marketing purposes including:
- validating your identity.
- sending you push notifications or e-mails to provide you with alerts and updates about your Account and the Services.
- monitoring, accessing, and recording gaming-related activity.
- conducting internal research, statistical or demographic analysis.
- processing and tracking gaming and non-gaming transactions.
- complying with legal and regulatory requirements, including, without limitation, responding to subpoenas and search warrants.
- providing you with the Service sand customizing your experience with the Services.
- protecting and defending BetMGM, MGM Resorts International, and all other MGM Affiliates against legal actions or claims.
- preventing fraud.
- debt collection.
- protecting BetMGM, MGM Resorts International, and all other MGM Affiliates’ rights and property.
- tracking usage of the Services.
- assessing and improving the Services.
- creating and updating customer profiles.
- responding to customer inquiries.
- conducting background checks.
- satisfying contractual obligations.
- safety and security purposes, including cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest (collectively “Non-Marketing Purposes”).
B. Sharing with Affiliates
We may share the information we collect with Affiliates for marketing purposes and for Non-Marketing Purposes. If you do not want us to share your personal information with Affiliates for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.
Regarding sharing of information with MGM about your MGM Rewards Account, we will provide MGM with certain information (subject to compliance with applicable laws and with your consent where required) related to your gaming activity that is necessary for MGM to administer your MGM Rewards Account, including, but not limited to: (1) the amount of money credited to, debited from or present in your Wagering Account; (2) the amount of money you wagered on any game or gaming device; (3) your Wagering Account number and secure personal identification method that identifies you; (4) the identities of particular entities on which you are wagering or have wagered on in the past; and (5) your name, address or other information that BetMGM possesses that would identify you to anyone other than BetMGM or applicable gaming regulators (“Account Information”). The Account Information we will provide to MGM represents the information MGM needs to provide you with certain benefits and rewards as more fully described in the terms applicable to your MGM Rewards Account. For opt-out information specific to your MGM Rewards Account and its connection with your Wagering Account, please see the “How to Opt-Out” section below.
C. Sharing with Business Partners and Other Third Parties
We may share the information we collect with our business partners and other third parties for joint marketing purposes and/or our business partners’ (or our own) marketing purposes. Even if you opt-out of permitting us to share your personal information with our business partners and other third parties for marketing purposes, we may still share the information we collect with them for Non-Marketing purposes such as processing transactions, fulfilling your requests, responding to your inquiries, etc.
D. Service Providers
We may engage service providers to provide certain services to us or to perform certain services on our behalf including analytics, marketing, fulfillment, identity verification etc. In some cases, service providers may collect or be provided with access to your information as reasonably necessary to perform such services on the condition that they not use or disclose your personal information for other purposes.
Our service providers may be located in the USA, or other foreign jurisdictions. In the event personal information is transferred to the USA or other foreign jurisdiction, the storage and other processing maybe be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.
E. Certain Business Transactions
We may share all information we collect with any successor to all or part of our business in connection with a transaction involving a sale, purchase, reorganization, merger, or transfer of any our assets or the assets of Affiliates.
F. How to Opt Out of Marketing from Us and How to Opt-Out of having Your Personal Information Shared with Others for Marketing Purposes
If you wish to opt-out of receiving marketing communications from us via postal mail, e-mail and telephone, or do not want us to share your personal information for marketing purposes with our business partners, third parties or Affiliates, please e-mail us at firstname.lastname@example.org or write to us at:
Harborside Plaza 2, Suite 700
200 Hudson Street
Jersey City, New Jersey 07311
Alternatively, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email.
Although you may opt-out of the use and sharing of personal information for marketing purposes, you may continue to receive transactional or account-related communications from us.
Please note, if you would like to submit a request to opt-out from marketing relating to your MGM Rewards Account, please submit your request to MGM via e-mail to email@example.com; via telephone at +1-866-761-7111; by clicking the “unsubscribe” link at the bottom of each email; or via postal mail, with your specific request(s), to:
MGM Resorts International
Corporate Compliance Department
71 E. Harmon
Las Vegas, Nevada 89109
G. Your Consent or Instructions
We will share your personal information with any third party to whom you consent or instruct us to provide your personal information.
1. Requests to Access and to Correct Your Personal Information
You have the right to request access to any personal information we have about you in our custody and under our control, and to update or correct any inaccuracies in such personal information. While, BetMGM will use reasonable efforts to ensure your personal information is up to date and accurate, we ask that you update your information through your account whenever your information is incomplete, out of date or otherwise changes. Your e-mail address and phone number may be updated by logging in to your Account on the BetMGM platform and making the applicable changes. You can update and correct any other inaccuracies in your personal information by contacting us by email at firstname.lastname@example.orgMGM.ca or by phone at +1-343-488-5355.
All requests are subject to verification of your identity to protect the privacy and security of your personal information.
2. Withdraw Consent to Process Your Personal Information
You have the right withdraw your consent to our processing of your personal information. All such requests are subject to verification of your identity. If we verify your request and cease processing your personal information pursuant to the request, we will also instruct our service providers (if any) to cease processing your personal information, subject to applicable legal requirements.
3. Verification Procedures
In order to verify requests made pursuant to applicable laws, we may require two (2) or more pieces of identifying information that match information maintained by us or, if you have a Wagering Account, to verify your identity through your Wagering Account. In some cases, we may require additional identifying information and a signed declaration attesting to your identity.
In certain circumstances, we may decline a request to exercise the ‘Requests to Access and Correct’ (II.G.1) or ‘Withdraw Consent’ (II.G.2) described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
We store certain non-gaming information and non-live gaming data collected through the Services on secure servers located in the United States. Internet wagering and live game play data collected by us through the Services is stored in Canada, the United States and other foreign jurisdictions and may, subject to applicable laws and lawful access by US or foreign courts, law enforcement or other government authorities.
Our servers are protected by firewalls and other industry standard security measures. These security measures are intended to protect our servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. We have controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach. We maintain a BetMGM ‘Information Security Policy/Information Security Standards’ document, which contains Data Breach security standards. We will provide you notice in the event of an incident that materially impacts your personal information (a “Data Incident”). We will notify you, iGaming Ontario, and any other applicable regulatory authority about the Data Incident, and we will aid iGaming Ontario and any applicable authorities in the management and handling of the Data Incident.
Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information. Personnel who violate our privacy policies are subject to disciplinary action, up to and including termination of employment.
We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you may use to send e-mails and submit information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of information that you send us before we receive it.
As a standard security practice, we will take reasonable steps which are generally recognized in the industry to ensure that the communication methods used to support the Services do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using the Services, it may be an indication that you need to upgrade your internet browsing tool or application to a newer version that supports more secure communication methods. In order to protect your account, we strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately. For general information on how to protect your information online, please refer to the resources posted by the Information and Privacy Commissioner of Ontario at www.ipc.on.ca/privacy-individuals/ensuring-your-privacy-is-protected/.
In situations where your personal information is collected by third parties under contract with us for performance of their contractual duties and other purposes, we require such third parties to exercise reasonable care to protect that information and restrict the use of your personal information to the purposes for which it was provided. When we share your personal information with MGM Affiliates or third parties in accordance with this Policy, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them.
IV. ACCESS TO AND DELETION OF PERSONAL INFORMATION
With respect to personal information associated with your Wagering Account (“Wagering Account Personal Information”), we will retain such Wagering Account personal information as long as your Account is active. When your Wagering Account is terminated, we will retain applicable Wagering Account personal information for as long as necessary to comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements. Once we determine that we no longer need to retain such Wagering Account Personal Information, pursuant to applicable law, all such Wagering Account Personal Information will be securely erased from hard disks, magnetic tapes, solid state memory, and other devices, as applicable, before the device is properly disposed of by us. If erasure is not possible, the device will be destroyed.
For all other personal information that we collect in connection with our Services, we will retain such personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements. Once we determine that we no longer need to retain such personal information, pursuant to applicable law, such personal information will be securely erased from hard disks, magnetic tapes, solid state memory, and other devices, as applicable, or we will aggregate, anonymize or otherwise de-identify such personal information so that it no longer identifies you.
V. OTHER WEBSITES
We are not responsible for the information collection or privacy practices of other websites, including websites accessible through the Services. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any personal information on them.
VI. INTERNATIONAL TRANSFERS
Information collected on the Services may be stored and processed in any country in which we or our affiliates, suppliers, third-party electronic payment processors and/or financial institutions or agents maintain facilities. By using the Services, you expressly consent to any transfer of information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.
VII. PERSONS UNDER 19
The Services are for use by persons 19 or older. If you are under 19, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of personal information via the Services from persons under 19. If a parent or guardian becomes aware that his or her child under the age of 19 has provided us with personal information, the parent or guardian may contact us at the details set out below in the “Contact Us” section to have such personal information deleted.
VIII. CHANGES TO THIS POLICY
We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions by sending you an e-mail and/or by placing notice of the revised Policy on the Services or any place through which you access the Services. For material changes to the Policy, you may be required to acknowledge acceptance of such change. For non-material changes, or changes approved by iGaming Ontario where an acknowledgement is not required, your continued access or use of the Services following any amendments to the Policy constitutes your acceptance of the Policy as amended. It is your sole responsibility to review the Policy and any revisions thereto each time you use the Services.
IX. CONTACT US
If you have any questions about this Policy or would like to request any additional information, please contact our Information Security Officer at: email@example.com.
Additionally, if you wish to make a complaint, you can make one through our complaints process, which can be found here: www.on.betmgm.ca/en/mobileportal/contact.