1. PURPOSE AND SCOPE; OUR COMMITMENT TO PRIVACY

By using our website, services, or associated products you agree to this Privacy Policy and you consent to share relevant Personal Information as set out in this Privacy Policy and our Terms and Conditions.

The purpose of this Privacy Policy (Privacy Policy) is to provide an understanding of how Rivalry (we and us) utilise your Personal Information (Personal Information) and acknowledge how we protect that information in compliance with applicable laws. This Privacy Policy is guided by the Freedom of Information and Protection of Privacy Act (Ontario) (FIPPA), the Personal Information Protection and Electronic Documents Act, and related legislation and guidelines related to privacy rights in Ontario to provide customers accessing iGaming through our services and websites (our clients or you), a reasonable and transparent understanding of our approach to the use of your Personal Information.

We take your privacy seriously, and not simply because the law says we must, but because we think it’s the right thing to do. We are committed to protecting your Personal Information and have described the ways we do so. We maintain our website and provide our services and associated products as part of the open and regulated internet gaming market in Ontario, which is conducted and managed by the Alcohol and Gaming Commission of Ontario (AGCO) and we collect, use, and disclose Personal Information on behalf of, and as an Operator of, iGaming Ontario (iGO). We collect Personal Information under this Privacy Policy under the legal authority provided by FIPPA, Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act and the operating agreement in place between us and iGO, as amended from time to time. 

The scope of this Privacy Policy applies to the collection of your Personal Information and the what, where and why aspects of its collection. It also provides information about how to interact with the Personal Information you provide to us, how to contact us with relation to your Personal Information, how to make a complaint or request information in relation to your Personal Information and an overview of your rights and choices in relation to your Personal Information. This Privacy Policy is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.  

Rivalry will present you with a copy of this Privacy Policy at onboarding and when any material amendments are made to the Policy. You must accept the Privacy Policy and its terms before being allowed to access or continue to access the website.

2. COLLECTION OF YOUR PERSONAL INFORMATION

What Personal Information do we collect?

We do collect your Personal Information in the normal course of running our iGaming business in Ontario. To perform our Know-Your-Client requirements, we use a third party software provider, Sum and Substance Ltd (UK) (SumSub), to collect and verify the following information:

  • First name and surname;
  • Gender;
  • Date of birth;
  • Email, residential and/or postal address;
  • Verification of identity documents;
  • Phone number; and
  • Occupation.

We may also collect the following information throughout your journey on our website:

  • Cookies and internet data (Click Data);
  • Data relating to when you place bets, including the frequency, volume and value of those bets; and
  • Information about your computer, including (where available) your IP address, operating system, browser type and other individually identifiable data, for system administration, statistical and fraud prevention purposes.

Additionally, in order to ensure that you can access all of the benefits of having an account on our website, we may collect and process the following additional personal data about you:

  • The currency in which you hold your account currency, encrypted password, payment details, bank account details and card details;
  • If you contact us, we may keep a record of that correspondence;
  • Information that you submit in response to a survey(s) or poll;
  • Details of transactions you carry out through the Website and your account number with us; and
  • Details of your visits to the website including, but not limited to Bets and transaction records, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Click Data and Cookies

Like many other websites, we use technologies to automatically collect technical data from visitors to our Website. In particular, we may send a small text file to your computer called a “cookie” that identifies your browser to our server when you visit various pages of the Website. Cookies are used to better serve you when you return to our Website, and in some cases, these allow our Website to function. Many web browsers automatically accept cookies, but as part of the privacy settings of your browser, you can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, or to disable existing cookies. See https://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html for more information on how to do so. Note that the opt-out will apply only to the browser that you are using when you decide to opt out of cookies. Without cookies though, the features described here will not function properly and may prevent us from providing you with the information and services you have requested.

By using cookies, we may automatically collect certain information, including device information, such as your IP address and other unique identifiers and device information, some usage information such as the browser type, time zone settings, language preferences, operating system, length of visit, pages viewed on the Website and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website as this information helps us understand how you use the Website features and the content of the Website in order to make improvements and tailor the content to your preferences.

We also use third-party analytics, such as Google Analytics, to help us to better understand the functionality of our Website on your computer, smartphone or other device. Analytics may record data such as the frequency of use of our Website, which features are used and not used, aggregated usage and performance data. This data is generally unidentifiable and cannot connect to you.

Why and when do we collect Personal Information?

Generally, we try to limit the collection of your Personal Information to more obvious interactions with our business or website, where you input your information, such as in an online application form. For example: our “Sign Up” page will, by necessity, ask you for Personal Information like your e-mail address.    

We collect your Personal Information so that we can open your account and you can place bets using the services of our website and associated products. We also collect your Personal Information in the following circumstances:

  • When you interact with our customer support team and provide Personal Information;
  • In the course of being billed or organising a bill;
  • When you voluntarily provide it in the use of our website, services, or associated products;
  • Your submissions in response to a survey(s) or poll; and
  • When you personally disclose the information in public areas of the website, like forums.
  • We collect your Personal Information for a number of reasons, including;
  • Understanding your preferences and tailoring a user-friendly experience while using our services and associated products;
  • Complying with the requirements of applicable law, including rules and regulations promulgated by the AGCO in accordance with its statutory mandate and anti-money laundering rules and regulations;
  • Ensuring you are of a legal age to bet on iGaming in Ontario (19+) and otherwise eligible to use our services and associated products;
  • Confirming details about your account with us, such as the currency you hold, your encrypted password, payment details, banking and card details;
  • Identifying and assisting with fraud detection and complying with various anti-money laundering legislation, regulations and rules;
  • Market research or training purposes;
  • Marketing and promotional purposes; and
  • providing information in connection with due diligence or regulatory investigations relating to Rivalry. 

You acknowledge and agree that subsection 40(2) of FIPPA requires us to keep your Personal Information accurate and up to date and you hereby confirm that we are authorized to collect Personal Information for such purposes and to provide such information to third parties as may be required to comply with our requirements under FIPPA or any other similar privacy legislation, regulations, standards or similar requirements promulgated thereunder or by the AGCO or iGO.

How do we protect your Personal Information?

We are committed to the protection of your Personal Information. 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. We store all of the Personal Information we receive directly from you in an encrypted, at rest and password protected database residing within our secure network behind active state-of-the-art firewall software (Our Services support SSL Version TLS 1.2 with 256-bit encryption). We also take measures to ensure our business partners and suppliers employ adequate security measures.

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 Rivalry website. 

Additionally, our website may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

How long do we retain your Personal Information for?

As an Operator of iGO, Rivalry is required maintain Personal Information and records, the later of:

  • The date that is 7 years after the date on which the item or document is generated; or
  • The date on which all disputes, claims or complaints are resolved.

According to Rivalry’s record retention and disposal schedule, we will destroy all Personal Information and records in a secure way, such that the Personal Information cannot be reconstructed or retrieved.

3. HOW WE MAY DISCLOSE OR SHARE YOUR PERSONAL INFORMATION

Third parties

Once we have your Personal Information, we may disclose or share that Personal Information in a number of ways, including for the following purposes:

  • To enforce or apply the terms of this Privacy Policy, the Terms & Conditions , or any other agreements;
  • To permit our employees, contractors and service providers to maintain our website, services, and associated products and to provide such services to you;
  • To comply with the privacy legislation applicable to us, including the delivery of Personal Information to the AGCO or as otherwise required by our operating agreement with iGO;
  • To allow our affiliates, contractors, and partners to comply with their legal obligations, licence conditions and betting rules and to market directly to you, in accordance with applicable laws;
  • To verify your identity or assist with any obligation of due diligence pursuant to the AML/CTF laws;
  • To facilitate a loyalty or affiliate program with any business, company or entity that we partner with or third parties used;
  • For advertising, marketing and promotional purposes by way of mediums such as Google Ads, Meta and other social media and related messaging, email, postal mail, sms, mms or phone call, and may include our authorised and/or related third party partners to provide you product and service information directly;
  • Where we sell or buy a business or any assets, we may disclose your personal data to the prospective seller or buyer in connection with the negotiation of such transactions; and
  • Any other situation where you have consented for us to share Personal Information.

Interest-Based Advertising.

We may serve interest-based advertisements, meaning that you may see advertising on our website that is tailored to your interests or you may see advertising for Rivalry on other websites you visit. We use third party service providers, such as Google Analytics and Meta pixels as part of this interest-based advertising. Some third parties or internet browsers allow you to opt-out of interest based advertising. For example, you may opt out of Google’s use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page at http://www.google.com/policies/technologies/ads/.

Disclosure and Sharing of Your Personal Information Outside of Ontario

We may choose to share or disclose your Personal Information outside of Ontario (including outside of Canada) for the following reasons:

  • For cloud data storage purposes;
  • IT support that may be based in another country or jurisdiction;
  • Fraud, identity and verification checks; and
  • Working with international firms that we may reasonably engage from time to time for the principal purpose of activities related to our business. 

If we do transfer any of your information outside of Ontario, we will take reasonable steps to ensure that it is treated as securely as it is within Ontario and is subject to the same rules, regulations, and standards as if your information had remained solely in Ontario.

4. YOUR RIGHTS AND CHOICES REGARDING YOUR PERSONAL INFORMATION

Website options

Your use of the Rivalry website, services, and associated products is optional. You may choose to navigate away, or not use the site or our services and associated products if you do not agree with this Privacy Policy.

As mentioned above, you may also limit Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Rivalry website.

How You Can Update, Access, or Delete Your Personal Information

If you wish to update Personal Information you believe is incorrect, you may contact [email protected] . Please note that you may be able to update some of your information via the ‘My Account’ page on our website.

You may also request a copy of your Personal Information record or request deletion of Personal Information by the following process;

  1. Contact us at [email protected] or through this link;
  2. We will also require valid proof of your identity to provide with your request; and
  3. After we have had a reasonable time to process the request, and your verification of identity, we will respond within a reasonable time (usually thirty (30) days).

Further, we reserve our right to reject an unreasonable request for Personal Information in circumstances where the form of the request would be unreasonably arduous or otherwise unreasonable, or where we believe the change would violate any law or legal requirement or cause the information to be incorrect.

It is Your responsibility to maintain your Personal Information and ensure that it is up-to-date and accurate.

Personal Information requests, questions or other related privacy issues may also be made via live chat or by e-mail to the Rivalry Data Privacy Officer at [email protected].

How You Can Protect Your Personal Information

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 the Rivalry website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Rivalry website like message boards, which any Rivalry website visitor can view. In addition, practicing some of the following measures may assist in protecting your Personal Information: 

  • Read this Privacy Policy and our Terms & Conditions in full to understand how we care for your Personal Information;
  • Ask questions and clarify any items you may not understand;
  • Ensure you have appropriate protection on your devices including passwords, anti-spam or firewall programs;
  • Protect all your passwords;
  • Understand your privacy settings on your devices, browsers, sites and apps you use; and
  • Ensure you discard your devices appropriately.

5. HOW YOU CAN MAKE A COMPLAINT

Complaint Procedure

There are two steps available to you with relation to any Personal Information dispute:

1. Talk to us: As a first step, you may put your complaint in writing and seek to resolve your dispute with us directly. Your complaint may be made to [email protected] and will be promptly reviewed by a member of our team. Following that review, you will be contacted and provided with a response intended to resolve your dispute.

2. Escalate the matter to iGO: If we are unable to resolve your dispute with us, you may wish to escalate your complaint to the iGO at http://www.igamingontario.ca. Upon receiving a request from you to elevate your dispute to the iGO, we will provide the case file generated in respect of your dispute to the iGO and you expressly consent to the provision of such case file and any other information requested by the iGO in connection with the resolution of your dispute.

6. INCIDENT BREACH MANAGEMENT AND COOPERATION

We define an information security incident breach as an attempted or successful unauthorized access, use, disclosure, modification or destruction of information. This can include:

  • A breach, attempted breach or other unauthorised access of Personal Information originating from within the Rivalry network or an outside entity;
  • An exposure of sensitive or confidential non-public information;
  • An intentional disruption or attack impacting Personal Information resources;
  • A loss or theft of an information system asset.
  • If you become aware of an incident such as the one described above, we ask that you escalate the matter to [email protected] with a description of the nature of the breach and as much supporting information as possible.

Senior management will be informed immediately and a plan to respond to the incident breach will be developed to be executed. In addition, we will notify and aid iGO and any other related authorities in, breach management and the handling of any results from a breach.

7. HOW TO CONTACT US OR ASK QUESTIONS ABOUT THIS PRIVACY POLICY

You may contact us in relation to any matter involving your Personal Information, any question regarding this Privacy Policy or otherwise at [email protected] or on our 24-hour chat support at https://www.rivalry.com.

Last updated: April 4, 2022