This Policy is incorporated into and is subject to our Terms of Service. In the event of a conflict between this Policy and the Terms of Service, the Terms of Service will control. This Policy governs the information collection, use, sharing, and related practices applicable to the Services in Nevada only. This Policy is separate and distinct from the privacy policies that govern the services offered by William Hill in other jurisdictions.
I. INFORMATION WE COLLECT
We collect information from a variety of sources and in a variety of ways (including from our Website, Ticket Writers and your use of the Services), as follows:
Account Information. In order to use the Services, you must register for an account. When you register for an account, we may access and collect the information you provide including your name, postal address, e-mail address, and date of birth. We may also ask you for additional information including your mobile phone number, social security number, credit or debit card number, financial account number, and a government-issued photo identification such as your driver’s license, state identification card, or passport.
Location, Gaming, and Transaction Information. When you use the Services, we and our third party service providers may collect information about your precise 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 the Nevada Gaming Control Board, the Nevada Gaming Commission and other government officials and/or agencies.
Device Information. When you use the Services, we and our third party service providers may use beacons and geofencing/geolocation services (“Verification Technologies”) to collect and analyze information about you, your device, and your activity. Information collected through Verification Technologies may include the type of device; mobile carrier you are using; your device identifiers; your (mobile) telephone number; your precise geographic location; and your activities within the Services including the links you click; the pages or screens you view; your session time; the number of times you click a page/screen or use a feature of the Services; the date and time you click on a page or use a feature; and the amount of time you spend on a page or using a feature. Information collected through Verification Technologies is stored in log files.
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 type of device you are using, your device identification number, session time, etc. There are federal law prohibitions and restrictions relating to wagering on the Internet (including such prohibitions and restrictions set out in 18 U.S.C. §§ 1084 et seq. (“The Wire Act”) and 31 U.S.C. §§ 5361 through 5367 (“Unlawful Internet Gambling Enforcement Act”). Except where permitted by applicable law, it is a federal offense for persons physically located outside of Nevada to engage in wagering on the Services. 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. Verification Technologies report your physical location from the Internet-connected device that you choose and from which you are accessing the Services. Verification Technologies obtain your physical location by accessing your device GPS coordinates. The Verification Technologies report to us, our service providers and/or applicable regulatory agencies the physical and geographic location of the Internet-connected device from which you are accessing the Services. Your precise or near-precise physical location will be reported to us, our service providers and/or applicable regulatory agencies 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 wagers offered via the Services. Your location information is retained during the time your account is active with us plus five (5) years, or as otherwise required by applicable state and federal laws and/or regulations. Location coordinate data is transmitted via Secure Socket Layer (“SSL”) technology and stored in password protected servers managed by us and our geolocation and operating partners. Neither us nor our partners will pass on or resell your location information to any third party except that they reserve the right to provide location information as necessary to satisfy any law, regulation or government agency request.
Affiliate and Third Party Information. We may obtain information about you from our affiliates, affiliated casinos, resorts, and properties that are owned, operated, managed by or affiliated with other gaming licensees (collectively ‘‘Gaming Affiliates’’) and from third parties, including our business partners.
II. HOW WE USE THE INFORMATION WE COLLECT
A. Use by William Hill
Marketing Purposes. 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, including SMS messaging. We may also link personal information (including your name, mobile phone number, and e-mail address) with non-personal information (including information collected through Verification Technologies and Wi-Fi services) 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 (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, processing and recording gaming-related activity; (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 William Hill (which includes the company group) and all other Gaming Affiliates against legal actions or claims; (9) preventing fraud; (10) debt collection; (11) satisfying contractual obligations; and (12) cooperating with law enforcement or other government agencies for purposes of investigations, 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 Gaming Affiliates
We may share the information we collect with Gaming Affiliates for marketing purposes and for Non-Marketing Purposes. If you do not want us to share your personal information with Gaming Affiliates for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.
C. Sharing with Third Parties
We may share the information we collect with our business partners and other third parties for (1) Non-Marketing Purposes, (2) joint marketing purposes, and (3) our business partners’ own marketing purposes. We require that these parties agree to process such information in compliance with this Policy and use appropriate confidentiality and security measures, and we use reasonable efforts to limit their use of such information.
D. Certain Business Transactions
We may share or sell your anonymous location information to third parties. Further, 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 Group Affiliates.
E. How to Opt-Out
Subject to applicable law, if you wish to opt-out of receiving marketing communications from us, or do not want us to share your personal information for marketing or sale purposes, please e-mail us at firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, call us at (855) 754-1200, or write to us at:
William Hill US
6325 S. Rainbow Blvd., Suite 100
Las Vegas, NV 89118
Although you may opt-out of the use and sharing of personal information for marketing or sale purposes, we may still use and share information we collect for non-marketing and non-sale purposes.
Non-gaming information and non-live gaming data collected by us through the Services is stored on secure servers located in the United States. Internet wagering data collected by us through the Services is stored on secure servers located in the State of Nevada. Our Nevada and other United States-based servers may not offer a level of privacy protection as great as that offered in other jurisdictions. We make no representation that the practices described in this Policy are compliant with laws outside of the United States.
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.
Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information. Employees 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 to a newer version that supports more secure communication methods.
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 Gaming 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 PERSONAL INFORMATION
We will retain the information we collect about you as long as your account is active plus five (5) years, or as otherwise required by applicable state and federal laws and/or regulations. 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. You may access, update, and correct inaccuracies in your personal information which is in our custody and control by visiting a William Hill sports book, by contacting us at email@example.com, firstname.lastname@example.org, email@example.com, by calling us at (855) 754-1200, or writing to us at:
William Hill US
6325 S. Rainbow Blvd., Suite 100
Las Vegas, NV 89118
V. OTHER WEB SITES
This policy applies only to William Hill. It does not apply to the practices of companies we do not control, or to people we do not employ. We are not responsible for the information collection or privacy practices of other web sites, including web sites 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 the U.S. (including to countries that may not have been assessed as having adequate privacy laws).
Notice to EU Residents. This Policy applies only to the Services and does not govern the separate websites, applications, platforms, and services of affiliates or any third parties that may link to or be linked to/from the Services. In addition to the terms of the Policy, under the General Data Protection Regulation (“GDPR”), you have the right to access and request information from us regarding the personal information we collect about you, rectification of that information, the portability of that information, and to restrict (or withdraw consent as it relates to) the use of that information (see section II.E above). To correct any inaccuracies of your personal information, please contact us using the information in section IV above. We will respond to your request free of charge, although you may be charged if the request will result in an undue burden to us or is excessive.
In certain circumstances, we may not be able to respond to a particular request where (1) we are complying with Non-Marketing Purposes (see section II.A above); (2) the request will have an adverse impact on the privacy, health or safety of others; or (3) as otherwise prohibited by applicable privacy and data protection laws. Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests or have reason to believe requests are being made unreasonably we reserve the right not to respond.
We will always take reasonable steps to protect your personal information from misuse, loss, and unauthorized access or disclosure. Please be aware that while we have safeguards in place, there are inherent security risks associated with transmitting information, including personal information, across the Internet. You accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security.
In connection with the provision of Services, we may need to transfer data (including your personal information) to other companies in our company group and our partners and subcontractors who are based in the European Economic Area (“EEA“). Our company group is committed to do so under standard contractual clauses or binding corporate rules or any other acceptable method that ensures a protection of your personal information to the standard required within the EEA.
Should you have an issue with the manner in which we manage our Policy or feel that we have not complied with applicable data protection laws, you may contact us using the information provided in this Policy and we will investigate the matter. If you are not satisfied with our response, or you prefer not to contact us, you have the right to file a complaint with the applicable data protection authority in your country.
VII. PERSONS UNDER 21
The Services are for use by persons 21 or older. If you are under 21, 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 21. If we learn that we have collected the personal information of someone under 21 years of age, we will take the appropriate steps to protect this information. If you are a parent or guardian and discover that your child has submitted personal information, you may alert us at firstname.lastname@example.org.
In the event that we are acquired by or merge with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control so that our Services can continue operations. In the unlikely event of a bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.
IX. 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 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 each time you use the Services.
By using our Services, you consent to: receive text/SMS messages (including advertisements); data, emails and information sent through other data channels; pay carrier data, messaging, and other fees resulting from your usage of our Services; and the collection, use, disclosure, transfer, and storage of your personal and non-personal Information (including location information related to your wireless device) as described in this Policy.
Effective: October 1, 2019.