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PRIVACY POLICY

Last Updated: January 7, 2019

This Privacy Policy describes The Abenakis Council of Wolinak’s policies and procedures for the collection, use, and disclosure of information that we receive when you use the mobile applications (“Apps”), online and mobile games (“Games”), certain promotions and giveaways that may be sponsored by either us or third party companies (“Promotions”) and the game client, server software, web technologies and branded websites used to provide the Games and Promotions (collectively, the “Platform”), or related services (collectively, the Apps, Games, Promotions, and the Platform are referred to as the “Service”) provided by The Abenakis Council of Wolinak (“ACW”, “us” or “we”).

1. PERSONAL INFORMATION

For the purposes of this Privacy Policy, personal information means information that can be used to identify and contact you, specifically your name, address, e-mail address, country of residence, as well as other information when such information is combined with your personal information. Personal information does not include “aggregate” information, which is data we collect about the use of our site and our services. Our Privacy Policy does not restrict or limit our collection and use of aggregate information.

2. CONSENT

You acknowledge and agree that by using the Service, playing any Game, participating in any Promotion, or downloading and installing any App, you fully understand, accept and voluntarily consent to the collection, use, retention and disclosure of personal information in accordance with this Privacy Policy. It is always your choice whether or not you provide us with your personal information; however, a decision to withhold personal information may restrict or prevent us from providing you with a particular product or service. We will only collect, use, and disclose your personal information with your consent, except where otherwise permitted or required by applicable law or regulatory requirement. If you have any questions or comments about this Privacy Policy, please contact us at support@VIPcasino.ca.

3. COLLECTION OF INFORMATION.

a. Registration Information. When you create an account (“Account”), we may collect the following personal information (“Registration Information”):

• Name;
• Username;
• Date of birth;
• Password;
• Home address;
• Email address;
• IP address;
• Phone number;
• Payment information;
• Voice and audio information;
• Login information for social media accounts you wish to connect to your account, including your Google or YouTube login, Facebook credentials, Twitter handle, and Instagram accounts (“Social Media Accounts”); and
• Security questions and responses.

Some of this Registration Information, for example, your name and username, may be shown publicly, such as on your profile page when you log in via a social media account.

b. Additional Information. From time-to-time, you may provide us with additional information to make public, such as in connection with a Promotion. Providing the additional information is entirely optional. IF YOU PROVIDE A CELL PHONE NUMBER TO RECEIVE SMS MESSAGES FROM US, YOU EXPRESSLY CONSENT TO RECEIVING SMS MESSAGES FROM US THE PURPOSE OF WHICH IS TO MARKET ACW, THE SERVICE, AND OUR PRODUCTS AND OTHER SERVICES. ALTHOUGH THERE IS NO FEE ASSOCIATED WITH THIS SERVICE, YOUR CARRIER MAY CHARGE YOU FOR EACH MESSAGE YOU RECEIVE IN ACCORDANCE WITH YOUR CALLING PLAN. YOU AGREE THAT WE ARE NOT RESPONSIBLE IN ANY WAY FOR SUCH CHARGES. IF YOU DO NOT WISH TO CONTINUE TO RECEIVE ANY MESSAGES VIA YOUR MOBILE DEVICE, YOU MAY OPT-OUT AT ANY TIME. YOU MAY OPT OUT OF RECEIVING MARKETING MESSAGES BY TEXTING “STOP” IN RESPONSE TO A MARKETING SMS MESSAGE. FAILURE TO OPT-OUT CONSTITUTES YOUR CONSENT TO CONTINUE TO RECEIVE THESE MESSAGES UNTIL YOU ELECT TO OPT-OUT.

c. Messages, Posts, Scores and other Public Information. Our Service is primarily designed to help you share information with other users and to engage in Games and Promotions. Most of the information you provide to us is information you are asking us to make public. This includes any comments or information you provide. Our default is almost always to make the information you provide public but we generally give you settings to make the information more private if you want. Your public information is broadly and instantly disseminated. For example, your public messages may be searchable by search engines. You should be careful about all information that will be made public by us, not just your messages. What you say on our Platform may be viewed all around the world instantly.

d. Location Information. If you turn on your location information functions, we may also save exact coordinates to help improve our service. You can control your location information settings by using your device’s settings to turn location services on or off for the ACW Social App, however, certain features or services of our Services, Platform and App may be affected or unavailable if your location services are disabled. We may also use your location information to enable you to interact with [our third party partners (“Brands”)] and other users.

e. Log Data. Our servers automatically record information (“Log Data”) created by your use of the Service. Log Data may include information such as your IP address, browser type, the referring domain, pages visited, your mobile carrier, device and application IDs, and search terms. Other actions, such as interactions with our App and advertisements, may also be included in Log Data.

f. Links. We may keep track of how you interact with links in messages across our Service including third party services and clients by redirecting clicks or through other means. We do this to help improve our Service, including advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.

g. Cookies. Like many websites, we use “cookie” technology to collect additional website usage data and to improve our Service, but we do not require cookies for many parts of our Service such as searching and looking at public user profiles or lists. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with our Service, to monitor aggregate usage by our users and web traffic routing on our Service, and to improve our Service. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

h. Analytics. We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services.

i. Third Party Service. We use a variety of services hosted by third parties to help provide our Service, such as hosting our various blogs and wikis, and to help us understand the use of our Service.

j. Payment Information. You may be asked to provide credit card or other payment information in connection with your use of the Service. We encrypt and securely store all such information.

4. USE OF INFORMATION.

a. We may use your Registration Information to help facilitate your transactions and participation in Games, Rewards and Promotions, including with Brands, and, in our sole discretion, to resolve disputes between you and other users. We may also use your Registration Information as necessary to investigate fraud, protect our legal rights, and otherwise provide the Service.

b. We may use your information, including your Registration Information, to facilitate the provision of software updates, product support, marketing promotions, and other services to you (if any), including by sending email or text messages to your wireless phone, tablet, or other mobile device (each a “Device”). You also grant us an irrevocable, perpetual, royalty-free right and license to use your information to enhance our products and services and to develop new products and services.

5. DISCLOSURE OF INFORMATION.

ACW may use third party service providers to provide certain services to you and we may share personal information with such service providers, including Pala Interactive LLC (“Pala”). We require any company with which we may share personal information to protect that data in a manner consistent with this policy and to limit the use of such personal information to the performance of services for ACW.

Pala will have access to your personal information for the purpose of providing services to ACW, and may use such information for that purpose. In the event that Pala ceases to provide such services to ACW, Pala may use such information in connection with the provision or marketing of products or services by or on behalf of itself or third parties, and may transfer, assign or disclose such information to third parties for use in connection with such parties’ products or services.

Pala and/or ACW may transmit your personal information to a credit agency or other third parties as a means of verifying your identity. You expressly acknowledge and consent to this sharing.

We do not disclose the private elements of your Registration Information, such as passwords, or phone numbers, (“Private information”) except in the limited circumstances described here.

a. Your Consent. We may share or disclose your Private Information with your consent, such as when you use a third party web client or application to access your account with us.

b. Service Providers. We engage certain trusted third parties to perform functions and provide services to us. We may share your Private Information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to obligations mirroring the protections of this privacy policy.

c. Law and Harm. We may preserve or disclose any of your information, including your Private Information, if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property.

d. Business Transfers. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this privacy policy will apply to your information as transferred to the new entity.

e. Non-Private or Non-Personal Information. We may share or disclose your non-private, aggregated or otherwise non-personal information, such as your public messages or the number of users who clicked on a particular link (even if only one did).

f. Disclosure to Brands. We may share certain portions of your Registration Information with Brands for marketing purposes, specifically, your name and email address, along with information that we have collected about your interests and preferences based on the Game in which you choose to participate. You may opt out of receiving marketing messages from Brands by using the opt-out mechanisms and links provided by each Brand.

6. OUR POLICY TOWARDS MINORS

You must be 19 years of age to use the Service except in Alberta, Mantioba and Quebec, where the admissible age is 18. Our Service is not directed to people under such minimum ages. If you become aware that an individual under the applicable minimum age has provided us with personal information without your consent, please contact us at support@VIPcasino.ca. We do not knowingly collect personal information from individuals under the indicated minimum ages. If we become aware that an individual under the applicable minimum age has provided us with personal information, we take steps to remove such information and terminate such individual’s account within a reasonable time.

7. CHANGES TO THIS POLICY.

This Privacy Policy will be continuously assessed against new technologies, business practices and our users’ needs. As we update, expand and diversify our products and services, this Privacy Policy may evolve. Please check this Privacy Policy from time to time for updates by checking the date of the “Last Update” at the top of this document. If we make any material changes to this Privacy Policy, we will notify you here. A link to our Privacy Policy will be provided at the bottom of each web page on our Platform, as well as in the navigation menu of any mobile application. You acknowledge and agree that your access of our Platform and your use of our Services following any posted changes to the Privacy Policy indicate your acceptance of such changes.

8. SECURITY.

We take commercially reasonable steps to help protect your information against loss, misuse and unauthorized access, or disclosure. HOWEVER, WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION.

9. THIRD PARTY ACCOUNTS.

We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our App. As such, we only receive the limited information that each Social Media Account permits to be transferred.

10. CREDIT CARD INFORMATION.

When you use a credit card on our website, you are actually using a secure connection to a third party payment processor. WE DO NOT COLLECT STORE OR PROCESS ANY CREDIT CARD INFORMATION.

11. DATA TRANSFER.

The Service is hosted and all Promotions and Games take place within the geographic territories of Canada on tribal land. Accordingly, by submitting any personal information to the Service, you are transferring your personal information to such locations, consenting to such transfer, and agreeing to the jurisdiction of the tribal courts of the Abenaki Council of Wolinak with respect to any disputes related to this Privacy Policy.

12. YOUR RIGHTS

Opt Out of Emails

You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your contact preferences and changes to your information including requests to opt-out of sharing your personal data with third parties by emailing support@VIPcasino.ca.

Cookie Opt Out

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services, Platform and App.

Withdraw Consent

You can withdraw your consent for the use of your personal information at any time by notifying us at support@VIPcasino.ca. Information may be retained by us for audit or archival purposes or as required by applicable federal and provincial laws.

Access, Correction of Personal Information

If you are a registered user of our Service, we provide you with tools to access or modify your Registration Information. You can also close your account with us. You will be able to reopen your account at any time after it has been closed. If you wish to request that we delete your account and any personal information associated with us, please contact us using the information below.

Additionally, you can request to see your personal information. If you want to review, verify or correct your personal information, please contact us using the information below. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact us.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

13. YOUR CALIFORNIA PRIVACY RIGHTS

The Services may only be accessed and used by legal residents of Canada, and are not intended for use by California residents. Notwithstanding the foregoing, if you are a California resident with a good faith belief that you have provided us with your personal information, you may submit an email request for information to us regarding whether we have disclosed your personal information to third parties for their direct marketing purposes during the preceding calendar year. This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: support@VIPcasino.ca.

14. VOICE RECORDINGS

If you contact us for support or other reasons via telephone, we will request permission to record the call. If you consent, we will store the recording and reference it to provide you with better service in the future or resolve disputes. If you decline, we will not be able to proceed with the call.

15. INTERPRETATION

This Privacy Policy does not create or confer upon any individual any rights, or impose upon us any obligations, in addition to any rights or obligations imposed by Canada’s applicable federal and provincial privacy laws. Should there be any inconsistency between this Privacy Policy and Canada’s applicable federal and provincial privacy laws, this Privacy Policy will be interpreted to comply with the applicable privacy laws.

16. CONTACT

If you have any questions or wish to file a complaint, please contact us using the following information:

Attention: Privacy and Customer Support Manager
10120 rue Kolipaio
Wôlinak, Quebec
G0X 1B0
Email: support@vipcasino.com

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