tony-bet

Privacy Policy

Ligtip Limited, the Company as described in the T&Cs applicable to you, is committed to protecting the personal information entrusted to us by our players. The Company is part of the Tonybet group of companies (the "Group", "we", "our" or "us"). The Company provides online gambling services. We protect your personal information in accordance with all applicable law, including Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA), the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), Canada’s Anti-Spam Legislation (“CASL”) and other applicable laws (collectively the “Acts”).

This Ligtip Limited Privacy and Cookie Policy (hereafter, the “Policy”) is incorporated into and forms part of the www.tonybet.ca Terms and Conditions (the “T&Cs”). Any conflict of inconsistency between this Policy and the T&Cs shall be resolved in accordance with the T&Cs.

Our services are provided 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) Ligtip Ltd. collects, uses and discloses personal information on behalf of and as agent to iGaming Ontario; (ii) Ligtip Ltd. collects personal information in accordance with the Freedom of Information and Protection of Privacy Act 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 Ligtip Ltd. and iGaming Ontario.

This Policy governs the collection, use, disclosure, retention and other processing of personal information by Ligtip Limited, including through Ligtip Limited products and services, on Ligtip Limited websites and via mobile applications. It explains what types of personal information is collected from our customers, how it may be used, and how you can ask us questions about our privacy practices. By using the Services, you consent to the collection, use and disclosure of the Personal Information (as defined below) that we collect from you in accordance with this policy. If you disagree with or do not consent to any terms of this policy, please do not use the Services.

You may withdraw your consent to the collection, use and disclosure of your Personal Information, in whole or in part, at any time by contacting us in the manner set forth in this policy under the heading “YOUR RIGHTS” (subject to applicable laws, reasonable notice and certain other restrictions).


SCOPE

This Policy governs our practices with respect to personal information we collect from individuals through our products, services, and offerings, including through Ligtip Limited’s websites and online applications.


REGARDING CHILDREN AND MINORS

Our website, applications and the services offered on our website and applications are not directed to individuals under the age of 19. If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

We do not allow individuals under the age of 19 to create accounts, make purchases or enter contests or promotions. We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the "CONTACTING LIGTIP LIMITED?" section).


WHAT IS PERSONAL INFORMATION?

“Personal information” means recorded information about an identifiable individual.

Ligtip Limited collects the following types of personal information, although different types of information may be collected depending on the purpose of collection or if the collection is required by law:

  • Identity information (such as your full name, Driver’s License number or other official ID number, etc.);
  • Demographic information (such as your age or gender);
  • Contact information (such as your email address or phone number);
  • Location information (such as your address or the location of a device you use to access our website or applications);
  • Professional information (such as your occupation or industry of employment);
  • Banking or financial information (such as payment or withdrawal account information); and
  • Transaction information (such as play or payment history, customer service history, or other information related to transactions between you and Ligtip Limited);
  • Voluntary information (such as information provided by our VIP customers. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.

WHY DOES Ligtip Limited COLLECT PERSONAL INFORMATION?

Ligtip Limited uses the personal information it collects for a variety of purposes, as such we collect personal information for the purpose of complying with our obligations as an operator under Ontario's regulated iGaming market. The most common purposes for Ligtip Limited’s collection of personal information can be organized into three main categories:

A. For program, service, or product administration – to provide you with service you have requested or to administer your participation in a particular program, we may use personal information. That may include using personal information for the following purposes:

  • Uniquely identifying and authenticating patrons to provide them access to their account and to be sure prizes, payments, or other features of a service are properly administered;
  • To deliver marketing and promotional material, including offerings (in accordance with the Acts) tailored to the recipient;
  • To administer loyalty or responsible gambling programs;
  • To provide customer service, facilitate payments and awarding prizes, and otherwise respond to patron requests, inquiries, comments, and concerns;
  • To customize the presentation of our products, services, webpages, and applications to individual users; and
  • As otherwise described in a Notice of Collection and/or permitted under the Acts.

B. To analyze and improve upon our products, services, programs, offerings, and processes – in addition to day-to-day administration of the services you engage with, we may also use personal information to assist us in evaluating and improving our products, services, programs, offerings, and processes. That may include using personal information for purposes such as:

  • To research the operational effectiveness and business viability of current and prospective products, programs, campaigns, and services;
  • To better understand the interests of current and prospective customers;
  • To tailor or personalize offers and information (in accordance with the Acts) to receiving patrons; and
  • To engage in responsible gambling research.

C. To help Ligtip Limited comply with applicable law and to maintain the integrity of Ligtip Limited’s operations – in certain circumstances, Ligtip Limited may be permitted or required to collect, use or disclose personal information so that it can comply with applicable law, or to maintain the integrity of its business. That could include using personal information for purposes such as:

  • Ensuring that players are eligible to participate in lottery schemes or to claim a prize;
  • Collecting, organizing, and assessing patron information and transaction data to meet record keeping, patron monitoring, risk mitigation and reporting requirements under applicable law, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act;
  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
  • To investigate suspected violations of our policies, to enable us to resolve disputes in connection with your use of the Services and to establish and defend our legal claims.
  • Administering responsible gambling programs; and

As otherwise required or permitted under applicable law, regulation or as detailed in a Notice of Collection.


DOES Ligtip Limited DISCLOSE PERSONAL INFORMATION?

From time to time, Ligtip Limited may disclose personal information to Companies within the Group and other affiliated companies, service providers or vendors acting on its behalf to enable them to perform specific types of processing and other specialized services.

For example, Ligtip Limited may partner with third parties to offer contest entrants a prize, and those third parties may require personal information in order to deliver that prize to the rightful contest winners. Service providers and vendors may collect, use, and disclose personal information on Ligtip Limited’s behalf as described in this policy. Service providers and vendors who process personal information on behalf of Ligtip Limited are contractually obliged to protect the privacy of Ligtip Limited customers and to only process personal information for the specific purpose(s) for which Ligtip Limited provides instruction or permission.

Additionally, Ligtip Limited may disclose personal information to law enforcement, regulators, and other third parties were permitted or required by law.


HOW IS PERSONAL INFORMATION RETAINED AND SECURED?

If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. Thereafter, the Group will retain your Personal Information only for such additional periods as are strictly necessary to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations, as well as to meet the Group’s contractual obligations.

In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information as long as is strictly necessary for the Group’s legitimate business interests, such as fraud prevention and record keeping, responsible gaming reasons, resolving or exercising claims regarding potential disputes, and where the Group is guided to do so by the applicable supervisory authority.

Ligtip Limited is required to maintain all records in accordance with the Proceeds of Crime, Money Laundering and Terrorist Financing Act (‘PCMLTFA’) and its Regulations, to ensure consistency with iGaming Ontario record retention policies and standard auditing practices. A record (or a copy) will be kept in an electronic form. The records are maintained in such a manner that they can be provided to FINTRAC within 30 days of a request.

After the applicable retention period for records containing personal information has elapsed, the records are securely disposed of in accordance with applicable information security and personal data protection requirements. Throughout the retention period, Ligtip Limited will make reasonable efforts to ensure personal information in our custody or under our control is kept accurate, complete, and up to date. Please contact the Ligtip Limited Support Center - [email protected] to advise Ligtip Limited of any updates or corrections you would like to make regarding your personal information.

Ligtip Limited has implemented physical, procedural, and technological security measures to protect the personal information in its custody and under its control. Access to personal information at Ligtip Limited is restricted to individuals who require such access to perform their duties. Furthermore, Ligtip Limited imposes information security requirements on third party vendors and service providers to whom personal information is disclosed. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Ligtip Limited therefore does not warrant, represent, or guarantee the absolute security of personal information in our custody or under our control.


HOW IS THE PERSONAL INFORMATION OF Ligtip Limited’s INTERNET GAMING CUSTOMERS PROCESSED?

You can visit Ligtip Limited’s websites and download its mobile applications without registering for an Internet Gaming account (“Internet Gaming”). However, certain products and services available through Ligtip Limited websites and mobile applications require that you register for an Internet Gaming account. Should you choose to register for an Internet Gaming account, Ligtip Limited will process your personal information in the course of administering your account. The following types of information may be collected throughout your registration for, and use of, an Internet Gaming account:

  • Name
  • Date of Birth
  • Full Home Address
  • Email Address and Phone Number
  • Transaction and Play History
  • Supporting Documents to Verify Identity
  • Device Information and connection IP address
  • Payment Information
  • Withdrawal Account Information
  • Language and Marketing Preferences
  • Device Location
  • Supporting Documents to Confirm Withdrawal Account Ownership
  • Responsible Gambling Settings/Limits
  • Username and Password
  • Security Questions and Answers
  • Occupation and Industry
  • Customer Service Records
  • Player ID (assigned by Ligtip Limited)

In general, and in addition to other processing as described throughout this Policy, the processing of personal information for administering Internet Gaming accounts can be organized into four main phases:

A. Registration & Account Activation – when you choose to register for an account, Ligtip Limited will collect certain identity, demographic, employment, and contact information. This information will be used to administer your account throughout your use of the Internet Gaming service, to confirm your eligibility for registration, and for anti-fraud and legal compliance purposes. Additionally, Ligtip Limited will seek to confirm that the device you use to register is located in Ontario, as Ligtip Limited’s Internet Gaming service is only available to persons residing in Ontario and who use the service while physically located in Ontario.

Prior to account activation, Ligtip Limited will seek to verify the identity of a registering individual. To confirm your identity, Ligtip Limited shares some of the information you provide at registration with a third party identity verification service(s). If your identity cannot be verified with the information you provided at registration, we may require that you submit additional information or proof of identity prior to the completion of registration. Access to this additional information will only be provided to Ligtip Limited personnel who require such access to complete the identity verification process. The information will be retained in a manner consistent with this Policy and Ligtip Limited’s internal retention and information security procedures.

Although Ligtip Limited take reasonable steps and employ appropriate security measures to safeguard information, the Internet is not completely secure.  We cannot guarantee the security of your PI and any transmission of your PI through the Internet is at your own risk. Ligtip Limited cannot be responsible for the acts of those who gain unauthorized access to your PI, and make no warranty, express, implied, or otherwise, that Ligtip Limited will prevent such access or abuse. Ligtip Limited will however promptly notify you if your PI is impacted by a privacy breach that could reasonably result in a real risk of significant harm to you. We will also report any such privacy breach to the authorities as required by applicable laws and keep a record of any such privacy breach to the extent required by applicable laws. We will notify iGO of the breach and cooperate with iGO and any related authorities with any investigation or other response to the breach.

B. Use of the Service - after registration and account activation, you will be able to securely log into Ligtip Limited’s Internet Gaming service. When you log in, Ligtip Limited will seek to confirm that the device you are using is located in Ontario, as Ligtip Limited’s Internet Gaming service is only available to persons residing in Ontario and who use the service while physically located in Ontario. Additionally, information about your use, such as transaction data, responsible gambling settings, and play history will be retained and used to provide you access to your overall account history, for responsible gambling purposes including monitoring, analyzing and communicating with you about your use of the Internet Gaming service, and for purposes as otherwise described throughout this Policy.

C. Purchasing and Withdrawals – while logged in to your Internet Gaming account, you will have the option to purchase certain Ligtip Limited products and services. Should you choose to do so, Ligtip Limited will collect payment card information and payment through its third party secure payment providers. Transaction information will be processed to provide you access to a history of your transactions, for anti-fraud purposes, for compliance with applicable law and regulation, and as otherwise described throughout this Policy.

Should you choose to withdraw funds from your Internet Gaming account, Ligtip Limited will collect bank account information from you to process your withdrawal requests. This information will be shared with Ligtip Limited’s partner financial institution to process your withdrawal request. Where permitted or required for compliance with applicable law, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Ligtip Limited may collect additional information a third-party identity verification service.

In addition, you will be required to upload supporting documentation to confirm your withdrawal information. Access to uploaded supporting documentation will only be provided to Ligtip Limited personnel who require such access to complete the withdrawal process. The documentation will be retained in a manner consistent with this Policy and in compliance with applicable personal data processing laws.

D. Inactivity & Deletion –in certain circumstances as described in the T&Cs, your account may be deemed inactive or dormant. In such circumstances, personal information will be retained in accordance with applicable law and Ligtip Limited legal obligations.

After the applicable retention period for records containing personal information has elapsed, the records are securely disposed of in accordance with Ligtip Limited information security policies.

In addition to the processing as described above, your personal information associated with your Internet Gaming account may be processed in circumstances unique to you. Examples of such processing include:   

  • Customer Service – additional personal information may be collected and processed to assist you with your customer service inquiries.
  • Prize Winner Publication – should you win a qualifying prize; your personal information may be published as described in the T&Cs and where permitted or required by law.

To provide Internet Gaming products and services, your personal information may be disclosed to third party service providers assisting Ligtip Limited in the administration of Internet Gaming. Examples of such third parties include:

  • Identity Verification Services – to prevent fraudulent activity and for compliance with applicable law, Ligtip Limited shares your name, date of birth, and address with a third-party identity verification service at registration or in the course of administering active Internet Gaming accounts;
  • Content Providers – to provide casino games and sports wagering, Ligtip Limited shares your language preferences and a unique alphanumeric identifier assigned by Ligtip Limited to your Internet Gaming account with third party content providers.;
  • Address Verification – to confirm your address is entered correctly at registration, Ligtip Limited shares the address with an address verification service. The other information you provide Ligtip Limited is not shared for address verification.
  • Payment Provider – to facilitate payment, your payment card information is collected and processed by Ligtip Limited’s secure payment provider. Your full payment card information is retained by the secure payment provider, and is not shared with or stored by Ligtip Limited;
  • Banking Provider – to facilitate your requests for withdrawals of funds, the bank account information you provide is shared with Ligtip Limited’s partner financial institution. This information is used to ensure your withdrawals are deposited into your account;
  • Geo-location Provider – the Ligtip Limited Internet Gaming service is only available to eligible individuals who are physically located in Ontario. Accordingly, your connection information and the location of the device you use to access the Internet Gaming service may be shared with Ligtip Limited’s third-party geo-location service; and
  • Responsible Gambling Researchers – from time to time, Ligtip Limited shares de-identified play data with responsible gambling researchers. In such case all personal data is irreversible anonymized.

Personal information collected while administering the Internet Gaming service is stored by Ligtip Limited in Canada and is retained in accordance with its records retention policies and applicable regulations. Personal information disclosed to third party service providers may be stored in other jurisdictions.


INTERNATIONAL TRANSFER OF INFORMATION

Since Ligtip Limited and we operate globally, it may be necessary for the provision of Services and to the extent required for the specific purpose, as stipulated in this Privacy Policy to transfer your Personal Information to countries outside Canada.

As the Company operates from Malta and engages with sub-contractors that are located globally, your Personal Information will be processed outside of Ontario.

Whenever we transfer your Personal Information outside Canada, we make sure that the recipients of your Personal Information have policies and process in place to ensure that your Personal Information will be properly safeguarded at all times. We use contractual and other means to ensure that such Recipients provide a level of protection for your Personal Information that is adequate and equivalent to the level of protection set forth in this Privacy Policy, and to that end we use contractual and other means to secure your Personal Information. We do however advise that where Personal Information is collected from you and processed in a foreign country, this information may be accessible to law enforcement and national security authorities of that jurisdiction.

For more information about the transfer of your personal data outside of Canada, please contact us (our contact details are available under the "CONTACTING Ligtip Limited” Section).


YOUR RIGHTS

If you have an account, you may \ contact us at any time by email (our contact details are available under the "CONTACTING Ligtip Limited " section), and request:

  1. To access or delete any Personal Information relating to you;
  2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
  3. That we will restrict or cease any further use of your Personal Information;
  4. That we will provide the Personal Information (i) you volunteered to us by giving us explicit consent for processing or (ii) that has been used for the purpose of executing an agreement with You, in a machine-readable format;
  5. To object to the processing of your Personal Information (such as for marketing purposes);
  6. To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
  7. To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. Please note that withdrawing your consent to the collection, use and disclosure of your Personal Information, and/or asking that we delete your Personal Information, may result in our being unable to continue to provide you with the Services. As well, please note that we may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

For assistance, please contact the Ligtip Limited Support [email protected].

To exercise any of the rights set out in this policy, or if you have any general questions or complaint about the Services, the information that we collect about you and how we use it or our compliance with data protection laws, please contact our Data Protection Officer:

Attn: Data Protection Officer

email: [email protected]

Ligtip Limited, C 86844,

Valletta buildings, second floor, suite 7, south street, Valletta VLT 1103, Malta

Email – [email protected]

iGaming

If you have any questions or concerns arising from our collection or handling of your non-gaming Information, or compliance with this Privacy Policy (a "Privacy Complaint"), you may contact our Privacy Team at any time by contacting us at [email protected] to provide a better service and for your protection, telephone conversations, chats, and emails may be recorded and/or monitored by designated staff.

We endeavor to respond to all Privacy Complaint as soon as possible. If you are not satisfied with the way that our Privacy Team handled your Privacy Complaint, our management may intervene to resolve any outstanding grievance and we will endeavor to satisfy your concern. If any concerns are not resolved to your satisfaction, you may contact the applicable privacy regulator, as follows:

Information and Privacy Commissioner of Ontario: 

Bloor Street East, Suite 1400 

Toronto, Ontario M4W 1A8

Telephone

Toronto Area: 416-326-3333 

Long distance: 1-800-387-0073 

TDD/TTY: 416-325-7539

We reserve the right to provide a copy of your complaint and relevant documentation to the privacy regulator.


Your right to complain to the regulator


If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to iGaming Ontario. Further details can be found here. We would, however, appreciate the chance to deal with your concerns before you approach the iGaming Ontario so please contact us in the first instance.


COOKIES & WEBSITE LOG DATA

In addition to any information that you choose to submit to us, we or selected third parties may use a variety of technologies that store or access information already stored on your personal computer, laptop, tablet or mobile phone (each a “device”) whenever you visit or interact with our Internet Gaming website or applications.

A cookie is a text file placed on a device when a user visits a website. Cookies can be temporary (i.e. session) or permanent (e.g., persistent). They can also be first party (i.e., placed by us) or third party (i.e.., placed by a third party advertiser or advertisements server).

Cookies that may be used to store or access information already stored by Ligtip Limited on your device include but are not limited to:

     1. Mandatory and performance cookies.

These cookies are necessary for the website to function and will be placed on your device once you access the website. Most of these cookies are set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These cookies provide a convenient and complete use of our website, and they help users efficiently use the website and make it personalized. These cookies identify the user’s device insofar, so we would be able to see how many times our website is visited, but do not collect any additional personally identifiable information. You can set your browser to block or alert you about these cookies, but some parts of the site will then not work. These cookies do not store any personally identifiable information and are stored on the user’s device until the end of session or permanently.

     2. Analytical cookies.

These cookies collect information about how users interact with our website, for example, to determine which sections are most frequently visited and which services are most often used. The collected information is used for analytical purposes to understand the interests of our users and how to make the webpage more user friendly. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. For analytical purposes, we may use third-party cookies. These cookies are stored on the user’s device for as long as set by the third-party cookie provider (ranging from 1 day to permanently).

     3. Marketing and targeting cookies.

These cookies collect information about how users interact with our website, for example, to determine which sections are most frequently visited and which services are most often used. Before you agree to the use of all cookies, Ligtip Limited will only collect anonymous data regarding the access of Ligtip Limited’s website. The collected information is used for analytical purposes to understand the interests of our users and how to make the webpage more user friendly. For analytical purposes, we may use third-party cookies. These cookies are stored permanently on the user’s device.

     4. Third-party cookies.

 Our website may use third party services, for example, for analytics services so we would know what is popular in our website and what is not, thus making the website more usable. You can learn more about these cookies and their privacy policy by visiting the websites of respective third parties. All information processed from third party cookies are processed by the respective service providers. At any point in time, you have the right to opt-out from data processing by third party cookies.

Ligtip Limited uses both session cookies (used only during your visit and expire when you close your browser) and persistent cookies (stored on your device for longer than just your visit) on its Internet Gaming website. Cookies used by Ligtip Limited collect certain information about your device, such as its IP Address, operating system and browser specifications, but do not collect personal information such as your name or email address.

Ligtip Limited installs First Party cookies on devices that access its websites unless the browser used by the device has disabled the installation of cookies. The first party cookies Ligtip Limited installs ensure the website functions as intended, and in some circumstances are necessary for Ligtip Limited to provide services requested by website visitors. For example, enabling first party cookies is required to log in to your www.tonybet.ca Internet Gaming account, as first party cookies are used to support the log-in process.

Ligtip Limited also installs Third party cookies on devices that access its websites unless the browser used by the device has disabled the installation of cookies. Third party Cookies are used by Ligtip Limited to analyze and improve the performance of our websites, offerings, and advertisements. Ligtip Limited uses web analytics services, including Google Analytics, to understand the interests of our visitors, to market our products and services, and for other internal business purposes.

You can learn more about data collection and use via Google Analytics by visiting https://policies.google.com/technologies/ads?hl=en-US, and can make use of Google’s free Google Analytics opt-out tool at https://support.google.com/analytics/answer/181881?hl=en.

The site is using Adform cookies to track users. You can find more information about the Adform cookies by this link.

You can opt out of the installation of cookies, or delete cookies that were previously installed, by updating your settings in the browser you use to visit Ligtip Limited websites. Please note, however, that cookies allow for optimal functionality of Ligtip Limited websites and are required for some features of our websites to operate. By using Ligtip Limited’s websites and applications, you consent to the installation of cookies by or on behalf of Ligtip Limited as described in this Policy.


THIRD PARTY LINKS

In some cases, our websites provide links to other sites created and maintained by other public and/or private sector organizations. We provide these links solely for your information and convenience.  Ligtip Limited is not responsible for the privacy practices of websites not administered by or on behalf of Ligtip Limited.


CHANGES TO THIS POLICY

Ligtip Limited reserves the right to modify this policy at any time.

Whenever we do so, we will post the updated version on our websites along with the last updated date and post the update in the Policy updates.


CONTACTING Ligtip Limited

Ligtip Limited, an Operator incorporated in Malta, registration code C 86844, having its   registered office at Valletta buildings, second floor, suite 7, south street, Valletta vlt 1103, Malta

Email – [email protected]

Data protection officer's email: [email protected]