As used in this Policy, the word “including” means including, without limitation. Capitalized terms not defined in this Policy have the definitions set forth in the Terms and Conditions for the Services. If you have any questions about this Policy, please contact us at email@example.com. If you do not want us to collect, use, or share your information in the ways described in this Policy, please do not use the Services. By using the Services, you consent to the collection and use of your information (including personally identifiable information) by us as identified herein, in compliance with this Policy and the Terms and Conditions for the Services.
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 and are being offered by BetMGM as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (http://www.igamingontario.ca/en). In the course of providing the services (i) 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, and the operating agreement entered into between BetMGM and iGaming Ontario.
I. INFORMATION WE COLLECT
We collect personal information from a variety of sources and in a variety of ways, including the following:
A. Account Information. In order to use the Services, you must register for an online Ontario wagering account (a “Wagering Account”). When you register for a Wagering Account, we may access and collect the personal information you provide including your full name, full address, e-mail address, telephone number, descriptive occupation (i.e., job position and industry), date of birth, mobile phone number, government-issued photo identification such as your driver’s license, or passport, and certain information from your Canadian credit bureau file.
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 Terms and Conditions, 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 (an “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 at https://www.mgmresorts.com/en/mgm-rewards/program-rules.html and MGM Resorts International’s (“MGM”) privacy practices with respect to the MGM Rewards program at https://www.mgmresorts.com/en/privacy-policy.html. 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 II.B below.
IF YOU PROVIDE A CELL PHONE NUMBER AND EXPRESSLY CONSENT TO RECEIVE TEXT MESSAGES FROM BETMGM, YOU EXPRESSLY CONSENT TO RECEIVE RECURRING INFORMATIONAL AND TRANSACTIONAL TEXTS—INCLUDING TEXTS MADE USING AN AUTODIALER—FROM OR ON BEHALF OF BETMGM TO THE NUMBER YOU PROVIDED. BY PROVIDING A CELL PHONE NUMBER AND EXPRESSLY CONSENTING TO RECEIVE SMS MESSAGES FROM BETMGM, YOU WARRANT AND REPRESENT THAT YOU ARE EITHER THE ACCOUNT OWNER OF THE CELL PHONE NUMBER YOU PROVIDE TO US, OR YOU HAVE THE EXPRESS PERMISSION OF THE ACCOUNT HOLDER TO PROVIDE THE NUMBER AND TO CONSENT TO AUTOMATED TEXTS TO THAT NUMBER.
ALTHOUGH THERE IS NO FEE ASSOCIATED WITH THIS SERVICE, YOUR CARRIER MAY CHARGE YOU FOR EACH MESSAGE YOU RECEIVE IN ACCORDANCE WITH YOUR CALLING PLAN. YOU AGREE THAT WE ARE NOT RESPONSIBLE IN ANY WAY FOR SUCH CHARGES. YOU CAN STOP RECEIVING TEXT MESSAGES FROM BETMGM AT ANY TIME. JUST TEXT "STOP" IN RESPONSE TO ANY SMS MESSAGE YOU RECEIVE FROM BETMGM. AFTER YOU SEND THE SMS MESSAGE "STOP" TO US, WE WILL SEND YOU A SINGLE MESSAGE TO CONFIRM THAT YOU HAVE BEEN UNSUBSCRIBED. AFTER THIS, YOU WILL NO LONGER RECEIVE TEXT MESSAGES FROM US. IF YOU WANT TO JOIN AGAIN TO RECEIVE MESSAGES, JUST SIGN UP AS YOU DID THE FIRST TIME, AND WE WILL START SENDING MESSAGES TO YOU AGAIN.
B. Location, Gaming, and Transaction Information. When you use the Services, we and our third-party service providers may collect information about your physical location, your gaming activity, and all transactions associated with your Account. We may share this information, and any other information we collect about you, with iGaming Ontario, other government officials, and with your consent third parties, including business partners.
D. Referrals. If you choose to use our referral program to tell a friend about our Services, we will ask you for your friend’s name and email address. We will send your friend a one-time email on your behalf inviting them to sign up for our Services. We store this information for the sole purposes of sending this one-time email and tracking the success of our referral program, and we do not use the names or email addresses submitted in these circumstances for any other purpose without consent to do so. You are responsible for ensuring that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message.
In addition, 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 https://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.
F. 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, in order to (i) verify your physical location while you are wagering on the Services and (ii) improve the location-based services. Tracking Technologies report your physical location from the computer or Internet-connected device that you choose and from which you are accessing the Services. Tracking Technologies obtain your physical location by accessing your IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID ), Wi-Fi positioning system, or device GPS coordinates. The Tracking Technologies report to us, our service providers and/or iGaming Ontario the physical and geographic location of the computer or Internet-connected device from which you are accessing the Services. Your physical location will be reported to us, our service providers and/or iGaming Ontario when you use the Services. You may withdraw this consent at any time by turning off the location settings or by notifying us in writing that you would like to withdraw such consent. If you turn off the location settings or withdraw such consent, you will not be able to access real money games and tournaments via the Services. Your location information is retained for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements. Location coordinate data is transmitted via Transport Layer Security (“TLS”) technology and stored in secured servers managed by us and our geolocation and operating partners. Neither we nor our partners will pass on or resell your location information to any third party, except that we reserve the right to provide location information as necessary to satisfy any law, regulation or government agency request.
G. 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. When you register for an account with us, you will have the option to sign-up to receive marketing information, 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) with non-personal information (including information collected through Tracking Technologies and Wi-Fi services) and use such information for our own marketing purposes. If you no longer wish to receive these types of marketing communications, 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 (1) validating your identity; (2) sending you push notifications or e-mails to provide you with alerts and updates about your Account and the Services; (3) monitoring, accessing, and recording gaming-related activity, such as using automated software to report on any processes or programs running on your computer that have been identified as prohibited software to prevent the abuses caused by BOTs; (4) conducting statistical or demographic analysis; (5) processing and tracking gaming and non-gaming transactions; (6) complying with legal and regulatory requirements; (7) customizing your experience with the Services; (8) protecting and defending BetMGM, MGM Resorts International, and all other MGM Affiliates against legal actions or claims; (9) preventing fraud; (10) debt collection; (11) satisfying contractual obligations; and (12) 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 do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
We may share the information we collect with Affiliates for Non-Marketing Purposes and, with your consent, for marking purposes. If you do not want us to share your personal information with Affiliates for marketing purposes, you may withdraw your consent at any time 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 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, know-your-client 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 of the 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 Withdraw Your Consent for Sharing your Personal Information for Marketing Purposes
If you wish to opt-out of receiving marketing communications from us via postal mail, e-mail, telephone, and text messaging, or would like to withdraw your consent for 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 3, Suite 602
210 Hudson Street
Jersey City, NJ 07311
You can also unsubscribe from receiving SMS messages as described in Section I.A above, including by replying STOP to any text message you receive from BetMGM.
Although you may opt-out of the use and sharing of personal information for marketing purposes, we may still use and share information we collect for Non-Marketing Purposes.
Please note, if you would like to submit a request to opt-out from marketing relating to your MGM Rewards Account, please email your request to MGM at email@example.com. To otherwise exercise any rights or request information related to your MGM Rewards Account, please contact the MGM Rewards Member Services at firstname.lastname@example.org.
Non-gaming information and non-live gaming data collected by us through the Services is stored on secure servers located in Dublin, Ireland. Internet wagering and live game play data collected by us through the Services is stored on servers located in Dublin, Ireland and is 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 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 employees and other authorized contractors have restricted access to personal information on a need-to-know basis and are required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information. Employees and contractors 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 https://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.
We will retain the information we collect about you as long as your Account is active. When your Account is terminated, we will retain your 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.
IV. ACCESS TO PERSONAL INFORMATION
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. Subject to appliable law, you have the right to access, update, and correct inaccuracies in your personal information which is in our custody and control by contacting us at email@example.com. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
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.
If you have any questions about this Policy or would like to request any additional information, please contact our Information Security Officer at: firstname.lastname@example.org
Additionally, if you wish to make a complaint, you can make one through our complaints process, which can be found here: https://www.on.betmgm.ca/en/mobileportal/contact
Updated: April 18, 2022.