OH Party Privacy Policy

Last Updated: Nov 28, 2022

PRIVACY POLICY

Identity of Data Controller
For the purposes of this privacy policy (the “Privacy Policy”), the “data controller” (i.e., the person responsible for the capture, storage and use of your personal information) is BETFRED USA SPORTS, LLC or BETFRED SPORTS (OHIO) LLC (collectively, the “Sportsbook”). The Sportsbook is providing sports wagering products and services via certain distribution channels, which may include desktop, mobile web and retail.

The Sportsbook and its affiliated companies, are licensed and regulated by certain federal, state and tribal regulatory authorities (collectively, the “Regulators”) for the purposes of operating and offering real-money Internet-based, mobile application-based and/or retail-based sports wagering services (“Services”). BETFRED USA SPORTS, LLC or BETFRED SPORTS (OHIO) LLC and such of its affiliated companies and other vendors and providers (collectively, the “Operator”) is the provider of the Services to you as set out in the Terms and Conditions (the “Terms” or the “Agreement”).

Our Commitment to Our Players’ Privacy
We are committed to maintaining the confidentiality of the personal information collected by us, utilizing information security technology and procedures, in accordance with applicable laws and requirements of the Regulators.

Purpose of this Privacy Policy
The purpose of this Privacy Policy is to enable you to understand how we collect, store, use and safeguard your personal information and to explain your rights in relation to that information and its use.

Our Legal Obligations
We will comply with the terms of applicable data protection regulations (“Applicable Law”) when processing your personal information. Your personal information may be also processed or transferred by us to other members, suppliers, vendors, agents and other third parties of Operator and Provider, including, but not limited to, processing and transferring such information in, to and from jurisdictions inside and outside of the United States of America. In this event we will comply with the terms of Applicable Law in relation to any such processing and/or transfer. By accepting this Privacy Policy, you hereby consent to your personal information being shared, where and when necessary, outside of the United States of America. We will only use your name in publicity materials with your consent. The name you register with us must be your own name. In addition, it is very important that you complete the account details with valid information, since it will be used in the course of validating financial transactions and the other purposes of this Privacy Policy, the Agreement and the Additional Rules. You are required to advise us of any relevant changes to your personal information. Users are able to change account details within the Software or by contacting Customer Service for assistance.

What do the capitalized terms mean?  Unless we give them a specific meaning in this Privacy Policy, capitalized terms shall have the meaning given to them in the Agreement, which takes precedence over any conflicting provision of this Privacy Policy.

Overview of Privacy Policy

Your Agreement to the Privacy Policy

What Information is Collected and for What Purpose

Information Sharing, Disclosures and Recipients

Deposit and Withdrawal Processing

Confidentiality

Limits of Confidentiality

Your Rights in Relation to Your Information

Cookies

Geolocation

Further Information

Your Agreement to the Privacy Policy Agreement
By using the Services, you (hereinafter referred to as the “User” or “you”) agree to the terms of this Privacy Policy as may be amended by us from time to time.

Amendments
We reserve the right to amend this Privacy Policy from time to time and will make Users aware that an updated Privacy Policy is available for review. Any amendments will come into effect immediately upon such change being notified on the Online Software or as part of the Services. We therefore encourage you to visit this Privacy Policy from time to time to make sure that you are aware of the current version and any changes that we may make.

What Information is Collected and for What Purpose
Registration Details: As part of the account initial sign in process on the Online Software and to allow us to provide our Services to you, we will ask you to provide us with certain personal information, including, but not limited to, your name, date of birth, social security number, postal address, telephone number, email address and password as well as certification that you are at least 21 years old or older in jurisdictions in which the minimum age for use of the Services, the Online Software and the Software is greater than 21. Any information obtained in respect to your registration or account establishment will be done in compliance with this Privacy Policy. The name you register with us must be your own name. In addition, it is important that you complete the account details with valid information, since it will be used in the course of validating financial transactions and for other purposes described in this Privacy Policy, the Terms and Conditions and the House Rules. You must advise us of any relevant changes to your personal information as provided to us and we do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the personal information that you have provided to us.

Mobile Gambling
You are reminded that you may only participate in sports wagering if you are physically present in the state of Ohio and in compliance with regulatory requirements for access and use of the Services, the Online Software and the Software. If you wish to use the Services via a device (a personal desktop, laptop computer, mobile device or any other device or equipment (each a “Device”), you will be required to consent to the use of location-based services by us (or through third parties acting on our behalf) or other operating software information that can be derived from your Device (which may include, but is not limited to, your IP address, Wi-Fi connection, GPS data and cookies data), to detect your geographic location. If you do not permit your location to be known, we will not be able to provide the Services, the Online Software and the Software to you.

Ongoing Data Capture
In addition, when you use the Services, the Online Software and the Software, we capture and store certain personal information, including, but not limited to, information on your activity on the Online Software, information held on the Device(s) you use and information required by the Regulators, to allow us to enhance the Services, the Online Software and the Software that we provide to you. We also use ‘cookies’ and our ‘cookie’ policy is explained below.

Data Retention
We retain your personal information for as long as necessary for the purposes of the Operator, which includes, but is not limited to, any period of historic retention that may be required for regulatory purposes. Should you close (or if we shut down) your wagering account with us, we will retain your personal data for such necessary period of time to allow us to meet our regulatory and legal obligations and defend ourselves against any claims. All customer information will be securely erased from hard disks, magnetic tapes, solid state memory and other devices before the device is properly disposed of by the Operator.

Purposes
We, together with our affiliates and third parties providing services to us or to you on our behalf, will use your personal information for the purpose of conducting our business and providing the Services, the Online Software and the Software to you as well as to ensure that you are not using any prohibited third party software or tools. Specifically, this includes the following purposes, but we also reserve the right to use your personal information for any other purposes that are reasonably ancillary to the business of providing you with wagering products and services:

• to confirm financial transactions.
• to analyze your credit and fraud risk and verify your credentials using third parties, including financial institutions, identification verification agencies and credit reference agencies.
• to verify source of funds and to comply with anti-money laundering requirements.
• to assess your wagering activity for responsible gaming purposes.
• to verify whether you have registered with any mandatory self-exclusion bodies (as may be applicable), for responsible gaming reasons.
• to provide the Services, the Online Software and the Software to you;
• identification, verification and vetting purposes.
• statistical analysis and research.
• research and development.
• marketing, market research, customer surveys and customer profiling.
• data analysis.
• to comply with licensing and regulatory requirements.
• to carry out batch testing of documents prior to the deployment of tools sourced from or provided by third parties.
• to combat against security risks and fraudulent activity to confirm your geographic location.
• Information Sharing, Disclosures and Recipients: We may also be required to disclose your personal information as follows:
• to any recipient if required to do so by law or by regulatory authority;
• to any regulatory, licensing or self-regulated body or authority;
• to third parties for the purposes of settling or making payment in connection with any wager;
• to third parties who provide products or services to us or on our behalf;
• to third parties for marketing purposes, provided you have consented or not objected, as the case may be, as described in “Marketing Clause” below;
• to any payment management or debt collection company engaged by us to handle payment and collection processes to and from our users;
• to any third party that purchases us or our business or any part of us or our business;
• to credit reference agencies;
• if we believe in good faith that such action is necessary, to comply with any law or comply with legal process served on us and to protect and defend our rights or property;
• with your consent;
• for the purposes of disaster recovery;
• or as set out in this Privacy Policy, Terms and Conditions or the House Rules.

General Disclosures
In addition to the specific examples of disclosures listed above, we may disclose your personal information to our employees, employees of other companies of or affiliated with Operator, our agents and to third party service providers who use your personal information to provide products and services to us in relation to you being a user of our Services.

Combined Personal Data
We may combine your personal information collected from your use of the Services, the Online Software and the Software in accordance with this Privacy Policy with other information collected from your use of other services operated by any other entity of or affiliated with Operator as well as all products which are related or ancillary thereto, including, but not limited to, mobile and social networking services. We will treat this combined information in accordance with and will use it for the purposes set out in, this Privacy Policy.

Credit References
Where you fail to reimburse us for any chargebacks, denial, or reversal of deposits you make, we may give details of your accounts and how you manage them to Credit Reference Agencies (“CRA”). The CRA will record the outstanding debt. This information may be supplied to other organizations and records will remain on the CRA file for six (6) years after the date of the chargeback, denial, or reversal of payment. The information will be used by the CRA to prevent crime, fraud, money laundering, verifying your identity if you, your partner other members of your household, your business or financial associates apply for other credit facilities, monitoring the operation of accounts you may hold, making decisions for credit, credit related or other facilities, tracing your whereabouts, recovering debts that you owe, statistical analysis and system testing.

Deposit and Withdrawal Processing
In the course of making a deposit, Users will need to provide deposit method information. This information in conjunction with your other personal information might be used to clear or carry out financial transactions executed by you on the Online Software. You are required to advise us of, and update on your wagering account with, any relevant changes to your personal information.

Confidentiality
What Do We Do? We have undertaken efforts to protect the confidentiality of the identity, preferences and other information we have collected about individual Users and we will not knowingly allow access to this information to anyone outside of our and our Provider’s respective group of companies and its and their vendors and suppliers and applicable government and regulatory authorities, other than to Users themselves or as described in this Privacy Policy, the Terms and Conditions or the House Rules.

What Can You Do? You should also play your part in protecting your personal information. Your login credentials are confidential and you are obligated to keep your login credentials secret and confidential at all times and to use your best efforts to protect their security, secrecy and confidentiality.

Limits of Confidentiality
Legally Required Disclosures. Any information about player accounts which is not subject to disclosure pursuant to this privacy policy will be kept confidential, except where the release of that information is required by law. Due to the legal, regulatory and security environment in which we operate, we may be required, under certain circumstances, to disclose personally identifiable information about our Users and we may not be permitted to inform you that we have done so. We will use reasonable endeavors to limit such disclosure to the following: (a) where we believe in good faith that we are required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights. Further, we can, and you authorize us to, disclose your User identification, name, date of birth, street address, city, county, post code, country, phone number, email, account activity, transactions, transfers to and communications with other Users and details of financial instruments used to deposit and withdraw, to our third party agents or official government and self-regulatory bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.

Marketing. Subject to your consent, we may use your email address and phone number for the purpose of sending you news, promotions and other marketing offers from us, strictly in relation to our products and services. If you no longer wish to receive marketing communications, you can easily unsubscribe by following the opt-out instructions included in the marketing communication that you receive or by contacting Customer Service for assistance.

Third Party Offers of Goods and Services. Where you have provided us with your consent to do so, we may also share your email address and phone number with third parties so that they may send you offers of their products and services. You may request at any time not to receive such offers by contacting Customer Service for assistance. If you request not to receive these offers we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you will need to unsubscribe separately from marketing communications sent by partners who have received your contact details from us prior to your request to be removed from these lists.

Publicity. We will only use your name and details in publicity materials with your written consent.

Your Rights in Relation to Your Information
Right to Request Information About You. We aim to keep our information about you as accurate as possible. You can contact us at any time to review, change, obtain a copy of your information or have your details altered or corrected in accordance with your rights under applicable law. In this event, we may require evidence of and be satisfied as to your identity before we take any requested action. You can contact us to update your information by contacting Customer Service for assistance. We may, in certain circumstances, levy a small charge to cover the cost of administration regarding any request made by you in this regard or deal with your query in accordance with applicable law.

Additional Rights. In relation to your personal data you may:

• request that we cease processing information that is likely to cause or is causing damage or distress;
• object to decisions being taken by automated means; and
• request, in certain circumstances, to have inaccurate personal data rectified, blocked, erased or destroyed.

Please note that if we close or if you request us to close your wagering account for any reason, your personal details will be retained for such period as may be required under applicable anti- money laundering regulations or other license and/or regulatory requirements. Additionally, you acknowledge and agree that if you request the foregoing, that your access and use of the Services, the Online Software and the Software may be limited, blocked and/or terminated.

Cookies
Cookies are text-only strings of information that are downloaded to Device when you visit a website. They are then sent back to the originating website on each subsequent visit or to another website that recognizes those cookies.  Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences and generally improving user experience. Sometimes cookies are used to help ensure that advertisements you see online are relevant to you and your interests. We use cookies in order to track referrals to our Sites, to remember your preferences, and to generate anonymized statistical data, which we use to improve the user experience. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited a website and to provide advertisements that are more relevant to your interests.

Please see www.allaboutcookies.org for information about what cookies are and what they do. Review the functionality of your browser to determine how you can turn off cookies or control which cookies are set on your Device.

Geolocation
Certain services including geolocation services such as GeoComply, will make use of your location data. If you use such services, you consent to us 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 in writing that you would like to withdraw such consent. Additionally, you acknowledge and agree that if you request the foregoing, that your access and use of the Services, the Online Software and the Software may be limited, blocked and/or terminated.

Further Information
We are happy to provide you with further information on how we protect and use your personal information. Please contact Customer Service for more details.

Who are we?  The licensed operator of the sports wagering website and applications is Betfred Sports (Ohio), LLC.

support.oh@betfred. com or 1 (404) 620-4975

California Privacy Rights – California Consumer Privacy Act

California residents and residents of certain other states (“CA customers”) have certain rights concerning their personal information, including under the California Consumer Privacy Act of 2018 (“CCPA”). The preceding sections of this notice describe Our practices regarding the collection, use, disclosure, and sale of personal information. This section supplements the preceding sections by describing CA customers’ additional rights with respect to their personal information and explaining how to exercise such rights.

As provided above, we collect and use the following categories of personal information stated in the CCPA for the business and commercial purposes described in this notice: real name; username; postal address; email address; telephone number; social security number; driver’s license, state identification, and passport numbers; date of birth and age; profile photographs; credit card, debit card, and bank account numbers and other payment and financial information; tax information and documents; commercial information, including records of products or services purchased, obtained, or considered; information on users’ interaction with the Website and Application(s) and other websites and applications, including information on preferences, usage, communications, subscriptions, associations, likes, and public profile information; and inferences drawn from such information. We collect this personal information from the categories of sources described above. We may disclose the foregoing categories of personal information for our business and commercial purposes to the extent permitted by applicable law.

Right to Know About Personal Information Collected, Used, Shared, or Sold.

CA customers have the right to request that we disclose the following information for the period covering the 12 months preceding their request:

• the categories of personal information we collected about you;
• the categories of sources from which we collected personal information about you;
• the categories of personal information that we have disclosed about you for our business purposes and the categories of suppliers to whom the personal information was disclosed;
• the categories of personal information that we sold to third parties and the categories of third parties to whom the personal information was sold, if any;
• the business or commercial purpose(s) for which personal information about you was collected, shared or sold; and
• the specific pieces of personal information we collected about you.

Right to Request Deletion of Personal Information.

ICA customers have the right to request that we delete the personal information we maintain about them, subject to certain exceptions.

Right to Opt-Out of the Sale of Personal Information.

CA customers have the right to opt-out of a business’s sale of their personal information. Under the CCPA, the terms “sell,” “selling,” or “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a CA customer’s personal information to another business or third party for monetary or other valuable consideration. The CCPA provides that a business does not sell personal information when:

• the customer uses or directs the business to intentionally disclose his or her personal information or uses the business to intentionally interact with a third party, as long as the third party does not also sell the personal information; or
• the business uses or shares with a service provider personal information of a customer that is necessary to perform a business purpose, as long as (i) the business has provided appropriate notice that personal information is being used or shared and (ii) the service provider does not further collect, sell, or use the personal information of the customer except as necessary to perform the business purpose.

As described above, we and certain other companies place tracking technologies on our Services, which allow us and such companies to receive information about your activity on our Services that is associated with your browser or device. Based on our current understanding of the CCPA, we believe this is not a “sale” of personal information and that we have not sold the personal information of CA customers, including minors under 16 years of age, within the preceding 12 months. CA customers may control the use of certain tracking technologies and request to opt-out of the “sale” of personal information by submitting a request by sending us an opt-out request through the Contact Us web form located at https://oh.betfredsports.com/p/contact-us and describe your request as “Data Sharing Opt-out”.  Please also keep in mind that your cookie and tracking tool preferences are specific to the device, website, and browser you are using and are deleted when you clear your browser’s cache.

Right to Non-Discrimination for Exercising Privacy Rights.

We will not discriminate against CA customers for exercising their rights under the CCPA.

How To Exercise Your Rights.

You may submit a request by sending us a privacy request through the Contact Us web form located at https://oh.betfredsports.com/p/contact-us. Please note that we may deny or fulfill a request only in part, based on our legal rights and obligations. Please also note that, except as otherwise provided by applicable California law, for purposes of these rights, personal information does not include information about job applicants, employees and other of our personnel or information about employees and other representatives of third-party entities we may interact with.  When we receive a request, we will verify the identity of the requestor and undertake to respond within the periods set by California law. If a CA customer has a password-protected account with us, we may verify their identity through our existing authentication practices and will require him or her to re-authenticate themselves before disclosing or deleting the customer’s data. If a CA customer does not have a password-protected account, we will take reasonable steps to verify their identity in accordance with the CCPA prior to responding any request. The verification steps may vary depending on the sensitivity of the personal information. If we cannot verify a requestor’s identity using these methods, we may use an appropriate third-party verification service.

Designating an Authorized Agent to Submit Privacy Requests.

CA customers may use an authorized agent to submit a Request to Know or a Request to Delete. An authorized agent is a person or entity registered with the California Secretary of State that a CA customer has authorized to act on his or her behalf. If you choose to submit a privacy request to us through an authorized agent, we may require that you provide the agent with written permission to do so and that the agent verify their own identity with us. If your privacy request is submitted by an agent without proof that they have been authorized by you to act on your behalf, we may deny the request.

“Shine the Light” Law
A CA customer who has provided personal information to a business with whom he has established a business relationship for personal, family, or household purposes is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a CA customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy or notice) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the business gives users a mechanism to opt out of having their personal information disclosed to third parties for their direct marketing purposes. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost-free means to exercise the right.

We have opted for this alternative approach. As stated in this notice, we give customers a mechanism to opt out of having their personal information disclosed to third parties for their direct marketing purposes. Therefore, we are not required to maintain or disclose a list of third parties that received your personal information for marketing purposes. If you wish to opt-out of sharing your personal information with third parties for their direct marketing purposes, please send us a privacy request through the Contact Us web form located at https://oh.betfredsports.com/p/contact-us and describe your request as “Re: Opt-out”.