All Bets Are Off (“ABAO”), is the owner of the website Sallysslots.com
The terms “ABAO”, “we”, “us”, or “our” refer collectively to ABAO, and its current and future subsidiaries (“Group Members”).
This Privacy and Cookies Policy (“Policy”) describes the practices of All Bets Are Off, including the Group Members involved in the operation of the ABAO’s websites in different geographic locations and the rights and choices available to individuals regarding personal data.
1. PURPOSE OF THIS POLICY
ABAO respects your privacy and is committed to protecting your personal data. Personal data means any information that relates to an identifiable individual. It does not include data where the ability to identify an individual has been removed (anonymous data).
This Policy describes the rights and choices regarding your personal data. It is important that you read the Policy carefully. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
We may alter this Policy as needed for certain services of ABAO and to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries. This Privacy Notice does not apply to ABAO’s processing of the personal data of its personnel, such as employees and contractors.
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect, use or otherwise handle data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our websites, we encourage you to read the privacy policy of every website you visit.
2. THE PERSONAL DATA WE COLLECT
We collect personal data about individuals from various sources described below. Where applicable, we indicate whether and why individuals must provide us with personal data, as well as the consequences of failing to do so. We may collect, use, store and transfer different kinds of personal data about you (“Personal Data”) which we have grouped as follows:
“Personal Information” includes any information from which you can be personally identified, including your name, surname, email address, telephone number or mobile number.
“Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access our websites;
“Usage Data” includes information about how you use our websites.
We also may collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect any information about your race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
We automatically collect Technical Data and Usage Data. If you are using a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, app crashes and other system activity.
3. COLLECTION OF PERSONAL DATA
We may use different methods to collect data from and about you including the following:
· Via direct interactions. You may give us your Personal Information and Recruitment Process Data by providing an email address to receive our newsletter, or providing your contact details via our newsletters form.
· Automated technologies. As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies.
· Third parties or publicly available sources. We may partner with third parties (such as content providers and analytics companies including Google Analytics and others) to help us improve the services of our website, including to provide you with relevant and interesting content and to conduct analytics and measurement to understand how our services are used. These companies may collect information from you automatically in connection with your visit.
Generally, our websites can be accessed and used without registration and without having to provide us any Personal Data (Personal Information, Profile Data, and/or Recruitment Process Data). You may opt in to receive information about promotions, bonuses, bets, tips and strategy by subscribing to our mailing list by providing your email address. You may any time opt out from receiving such communications by writing to us or clicking the “unsubscribe” button in any of our emails to you. In case you contact us, whether by email, through contact forms, or in other writings, we may keep a copy of that correspondence. We will not share your Personal Data with third parties for marketing purposes unless you have provided us with your express consent to do so.
4. USE OF PERSONAL DATA
We may use your Personal Data for the purposes of:
Providing our services, which may include:
· Operating, evaluating, maintaining, improving, and providing the features and functionality of our services;
· Communicating with you regarding service-related emails or messages (e.g., messages regarding account verification, changes or updates to the functionality of our services, technical and security notices and alerts, and support messages)
· Personalizing the manner in which we provide our services;
· Administering and protecting our business; and
· Providing support and maintenance for our services, including responding to your service-related requests, questions, and feedback.
For research and development
We use the information we collect for our own research and development purposes, which include:
· Developing or improving our services; and
· Developing and creating analytics and related reporting.
Marketing
We may use your Personal Data to form a view on what services we think you may want or need or what may be of interest to you.
We may contact you with marketing communications using the Personal Data you have provided to us if you have actively expressed your interest in availing of our services or have availed of our services and, in any case, you have not opted out of receiving that marketing, to the extent permitted by applicable law.
You can ask us to stop sending you marketing messages at any time by contacting us using the details below or clicking on the opt-out link included in each marketing message.
Should you choose to opt out of receiving our marketing messages, we will continue to conduct our other relevant activities using your Personal Data, including sending non-marketing messages.
Complying with law
We use your Personal Data as we believe necessary and appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
Compliance, fraud prevention and safety
We use your Personal Data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent
In some jurisdictions, applicable law may require us to request your consent to use your Personal Data in certain contexts, such as when we would like to send you certain marketing messages. If we request your consent to use your Personal Data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.
To create anonymous data
We may create anonymous data from your Personal Data and other individuals whose Personal Data we collect. We make Personal Data into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.
5. TO WHOM DO WE PROVIDE PERSONAL DATA
We may have to share your data to the following parties:
Group Members
We may disclose your Personal Data to other Group Members for purposes consistent with this Policy.
Service providers
We may employ third parties to administer and provide services on our behalf (such as third parties that provide customer support, third parties that we engage to host, manage, maintain, and develop our websites, mobile applications, and IT systems, and third parties that help us process payments). These third parties may use your information only as directed by us and in a manner consistent with this Policy. These third parties are prohibited from using or disclosing your information for any other purpose.
Participants in the transaction processing chain
We may share your Personal Data with companies in the transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members.
Professional advisors
We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary, in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety
ABAO may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
6. DATA SECURITY AND DATA RETENTION
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, subsidiaries, affiliates and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place commercially reasonable procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will process and store the relevant Personal Data for as long as it is necessary or required in order to fulfil our legal, contractual, or statutory obligations and/or for the establishment, exercise or defence of legal claims.
7.YOUR RIGHTS AND CHOICES
In this section, we describe the rights and choices available to all users. Users who are located in Europe may read additional information about their rights in paragraph 8 below.
Marketing communications
You can ask us to stop sending you marketing messages at any time by contacting us or clicking on the opt-out link included in each marketing message. You may continue to receive service-related and other non-marketing messages.
Choosing not to provide your Personal Data
Where we request Personal Data directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we may be unable to provide services to you.
Accessing, modifying or deleting your information
In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete their Personal Data in some. You may contact ABAO directly to request access to, modify or delete your information. We may not be able to provide access to, modify, or delete your information in all circumstances.
Complaints
If you have a complaint about our handling of your Personal Data, you may contact our data protection officer using the contact information below. We request that a complaint be made in writing. Please provide details about your concern or complaint so that we can investigate it. We will determine whether to take action in response to your complaint, which, if we do so, may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency.
8. ADDITIONAL INFORMATION FOR EUROPEAN USERS
Data Controller
ABAO is the data controller for the purpose of the General Data Protection Regulation (“GDPR”), and other applicable data protection laws. This means that ABAO is principally responsible for looking after your Personal Data and this Policy determines the means and purposes of processing of Personal Data.
Legal bases for processing
We are required to inform you of the legal bases of our processing of your Personal Data, which are described in the table below. If you have questions about the legal basis of how we process your Personal Data, please contact us at marketing@sallysslots.com
Use for new purposes
We may use your Personal Data for reasons not described in this Policy where permitted by law and the reason is compatible with the purpose for which we collected it.
How long will we use your Personal Data?
We will use your Personal Data for as long as necessary based on why we collected it and what we use it for. This may include our need to satisfy a legal, regulatory, accounting, or reporting requirement.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In general terms, we will retain your Personal Data for the duration of your involvement/engagement with us and for as long as reasonably necessary afterwards. There are also certain types of information which are required to be retained for a certain period by law.
Your individual legal rights
You have the right to obtain access, rectification, erasure, restriction of Personal Data, portability of Personal Data and to object to the processing of your Personal Data, under the conditions and restrictions laid out in Chapter III of the GDPR as follows:
· Access. You are entitled to ask us if we are processing your Personal Data and, if so, for a copy of the Personal Data we hold about you, as well as obtain certain other information about our processing activities.
· Correction. If any Personal Data we hold about you is incomplete or inaccurate, you can require us to correct it, though we may need to verify the accuracy of the new data you provide to us.
· Erasure. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.
· Object. Where our reason for processing your Personal Data is legitimate interest, you may object to processing as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
· Restriction. You may ask us to suspend our use of your Personal Data in the following scenarios:
· if you want us to establish the data’s accuracy;
· where our use of your Personal Data is unlawful but you do not want us to erase it;
· where you need us to hold your data for a longer period than we usually would, because you need it to establish, exercise or defend legal claims; or
· you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
· Transfer. Where it is possible, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to Personal Data provided by you which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent. Where our reason for processing is based on your consent, you may withdraw that consent at any time. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
9. COOKIES INFORMATION
Cookies are small pieces of data served on your computer that remember what you enter while you’re browsing a website. For more information about cookies and how they work, please visit: www.aboutcookies.org.
We use cookies to improve our service, and to enhance your user experience, for example, to show you the most relevant information when you return to our site.
When we use cookies, we do not typically process any information that personally identifies a user. By using our websites, you are consenting to us using cookies. You can manage cookie usage, disable or delete cookies, through your browser settings at any time. The help function in your preferred browser should provide you with the correct information.
More information on how to deactivate or delete cookies can be found below as well as on https://www.aboutcookies.org/cookie-faq/.
Some browsers provide helpful cookie guides:
· Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
· Firefox: http://support.mozilla.org/en-US/kb/Cookies
· Internet Explorer: http://support.microsoft.com/kb/278835
· Safari 5 for Mac: https://support.apple.com/e
· Opera: http://help.opera.com/Linux/10.50/en/cookies.html
In addition, Google Analytics provides its own opt-out options:
· http://tools.google.com/dlpage/gaoptout
In the case of mobile devices, it may be necessary to consult the device’s instruction manual to manage cookies effectively. Restriction of cookies may have an impact on the functionality of our websites.
TYPES OF COOKIES
We may use cookies for different purposes and with different functions.
Essential cookies are necessary for our websites to work effectively. They help to make our websites usable by enabling basic functionalities such as page navigation and accessibility to secure areas of our websites. Cookies of this nature may also be used to protect and accelerate our websites for security reasons and to identify our trusted visitors. They may filter bots and distinguish them from legitimate users, preventing any form of spam activity on our websites.
Preference cookies enable our websites to remember information that changes the way our websites behave or look. They may also be used to provide services you have asked for.
Analytics cookies analyse information about how our websites are being used. Analytics cookies can process information about the number of visitors to our websites, where visitors to our websites came from, the pages they visit, scrolling activities, downloads, information about user agents, time spent on our websites and approximate geo-location of a device that you use to access our websites. We use this information to compile reports that help us to improve our websites.
In case we allow others to service cookies through our websites and/or apps, these cookies are called “third party cookies”.
Please note that our advertisers may also use cookies on their websites, and we have no control over such use.
If you have any questions about this Policy or you wish to exercise any of the rights set out above, please contact us at marketing@sallysslots.com
We will respond to all legitimate requests promptly and, in any event, within any timeframes prescribed by applicable law. In general, we must respond to queries within one month from the receipt of the request. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
