Privacy Policy

Last revised: 21-Feb-2023

1. responsibility for the processing of personal information

This is the Privacy Policy of GWN Ltd., located at the Betsson Experience Centre, Ta' Xbiex Seafront, XBX 1027, Malta, GWN Ltd. (hereinafter: " Betsson ", "We" or "us"). 

GWN Limited (“GWN”) is a provider of internet gambling services (“Services”) in the regulated iGaming market managed by iGaming Ontario (“iGO”) as defined in the Operator Agreement  between GWN and iGO (“OA”). In the course of providing the services Betsson collects, uses, and discloses personal information on behalf of and as an agent for iGO, in accordance with Applicable Law governing the collection, use, disclosure, and retention of personal information including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Freedom of Information and Protection of Privacy Act (“FIPPA”), other applicable Privacy Laws (“Privacy Laws”), and regulations issued under the authority of Ontario Regulation 722/21 by the Alcohol and Gaming Commission of Ontario, and by iGO as permitted by the OA.

In particular, GWN collects and processes personal information necessary to provide the Services through Our website and mobile application under the Betsafe brand. In using the Services, You understand that Your personal information will be processed in accordance with this Privacy Policy. This Privacy Policy does not apply to any websites over which GWN has no control.

’GWN’s Services are not intended for minors and We do not knowingly collect personal information relating to Minors (individuals below 19 years of age). In the event that We become aware that a Minor has provided GWN any information, We may discard such information unless it is required to comply with any legal or statutory obligation binding upon Us. If You have reason to believe that a Minor has provided Us with personal information, please contact Us at the details set out in Section 2 below.

Betsson places great importance on privacy and the protection of personal information. This Privacy Policy describes how We handle personal information and the rights that You have. This Privacy Policy also applies to the other Betsson Group entities, which act as data processors for GWN Ltd.

GWN is part of the Betsson Group of companies. This Privacy Policy applies to any entity within the Betsson Group that performs services on behalf of GWN.

2. contact us

For questions or comments regarding this Privacy Policy or the processing of Your personal information by GWN, You may contact Our Privacy Officer via e-mail at dataprivacy@betssongroup.com or by post at Betsson, ‘Attn: Privacy  Officer, Betsson Experience Centre, Ta' Xbiex Seafront, XBX 1027, Malta’. 

You have the right to make a complaint by first contacting the Customer Services department by email at support-en@betsafe.com. If your complaint is not resolved to your satisfaction you may request secondary review by sending an email to csmanagement@betsafe.com. All complaints will be processed in a timely, fair and transparent manner. For more information on Our complaints process, please see section 28 of the Terms and Conditions. 

3. personal information processed

Personal information means information that can identify an individual, including any information that consitutes personal information within the meaning of Privacy Laws.

We process personal information of visitors to Our website, users of Our mobile applications, and participants in Our iGaming services. We also process personal information of individuals who contact Us, follow Us on social media, request to be kept informed about GWN, or with whom We otherwise have a relationship. 

We receive the personal information either when You register with Us, when You  provide data, or any other time You communicate with Us. We also collect and analyse data regarding Your gaming behaviour in order to ensure compliance with the terms and conditions, monitor the integrity of wagering activity, and to meet Our responsible gaming, anti-money laundering, and other legal obligations. We also receive data from third parties, such as providers of know Your customer services, that help Us to comply with Our legal obligations. 

We also collect certain information about Our customers and visitors to Our website using cookies and other tracking technologies. For further information about cookies, which cookies We use, why We use cookies, and how You can control which cookies are used, please read Our Cookie Policy. 

Below is an overview of the categories of personal information We process and examples thereof :

Identifying data and contact details:

• Legal name, middle name and surname

• Date of birth

• Gender

• Address (house/apartment number, city, province/state, country, postal/zip code)

• Contact details (telephone number, e-mail address)

• A code that is uniquely linked to You as a player

 

Account details:

• User name

• Password

• Location and related geolocation information

• Language preferences

 

Payment details:

• Name, address and account number 

• Payment type (debit card, credit card, e-wallet, etc.)

• Information relating to a transaction e.g, currency, location, value, IP

 

Information relating to playing behaviour and (placed) bets:

• Games in which You participate including gaming activity and outcomes

• Time of play and duration

• Play frequency 

• The indicated limits of playing behaviour (maximum duration, deposits, credit) and adjustments thereof

• Exceeding Your game limits

• Total monies wagered / won / lost for session and/or period of time

• The date and time of past and current bets, and the date and time at which past bets were settled, and information about current bets

• Account balance at start and end of session

• Deposit and withdrawal history

• Bonuses

• Possible suspensions from play

• Your login history

 

Information We are required to collect by virtue of Our obligations stemming from anti-money laundering obligations:

• Descriptive Occupation (principal business), business phone number, employer name and address

• Politically Exposed Person (‘PEP’), Foreign Politically Exposed Person, Head of International Organisation (‘HIO’), and sanctions list status

• Identity verification information (e.g., government-issued ID, credit file, utility bill)

• Documents evidencing source of wealth / source of funds (e.g. payslip, bank statement) 

• Bank details for verification of ownership, such as beneficiairy name, account number and billing address

 

Information We are required to collect by virtue of Our duty of care:

• Internal and external signs of problematic or addictive behaviour, which may include health data subject to legal limitations

• If applicable: data on a personal interview with a player, its conclusions and applied intervention measures

• Utilisation of responsible gaming tools such as:

• Limits (deposit / loss / session / wagering limits);

• Time-out periods;

• Self-exclusion periods

 

Information relating to criminal offences:

• If applicable, data on criminal behaviour, such as data on an incident where fraud is suspected

 

Information on Your use of Our website, applications and online user environment:

• Activities on Our website and in online user environment 

• IP address

• Operating system 

• Unique identifiers, such as the Android Advertising ID or ID For Advertisers  

• Information collected by cookies (see also Our Cookie Policy)

• Data You actively provide or fill in forms

• Data about the device You use to use Our website or online user environment

 

Correspondence, call recordings and chat recordings

• Voice call recordings

• Online chat records

• Correspondence by mail and email with Our customer service

• Complaints

 

Direct marketing and communication data

• Your contact information (telehone number, email address, home address)

• Your preferences for receiving direct marketing and/or communication from Us

• Information about what type of events You prefer and events which You have attended

• Infromation on what type of gifts You prefer and whether You have participated in / received any giveaways

 

Information obtained from third parties and public sources:

• Information obtained from KYC, identity verification providers and credit bureaus 

• Information obtained from providers offering international and/or financial sanctions and PEP/HIO controls

• Adverse media checks by consulting publicly available sources (e.g., news releases issued by industry regulators, police and other law enforcement agencies, mainstream news media, and other credible sources) 

• Information derived from centralized self-exlcusion registers allowing players to take a break from all regulated igaming services in Ontario.

 

4. purpose and authority for processing personal information

Below is an overview of the purpose and basis for processing your personal information and examples thereof:

Purpose: Customer registration

Basis: necessary for performance of the contract

• Assess Your eligibility for account creation

• Check if You are registered in centralized self-exclusion registers

• Check Your data

• Create new player accounts

• Process and record the data You provide via Our website

• Processing changes to Your profile

 

Purpose: Verifying Your identity and whether You are of age

Basis: to comply with a legal obligation incumbent upon Us

• Checking Your identification information against publicaly available sources and/or documents provided by You

Purpose: Enabling participation in Our igaming offering 

Basis: necessary for performance of the contract

• Monitoring and detecting the location of customers attempting to place bets to ensure they are within the Province of Ontario

• Processing and managing payment transactions

• Enforcing Your set limits 

• The correct display of our website or applications using information about Your device

• Facilitating Your preferences, such as displaying the website or application in the correct language and remembering Your password

• Sending service messages

• Maintaining contact with You

• Answering Your questions / reuquests (to customer service or otherwise) and handling complaints via Our complaints process

 

Purpose: To prevent and/or combat excessive participation and gambling addiction
Basis: to comply with legal obligations incumbent on Us

• Collecting, analysing and recording Your gaming data, transaction data, and other relevant data such as communications in order to perform a risk assessment

• Carry out customer interactions 

• Action requests relating to the use of the responsible gaming tools (limits, time-outs, self-exclusion)

• Providing Your data to third parties, such as the competent authorities, if there is a legal obligation to do so

 

Purpose: Fighting fraud and preventing money laundering and terrorist financing
Basis: to comply with a legal obligation resting upon Us

• Verify Your identification information through publicly available sources and/or other relevant documents provided by You

• Verify Your payment account and authorization

• Establishing Your sources of wealth / source of funds

• Checking Your PEP / sanction status

• Creating a risk profile 

• Reporting of unusual transactions

• Providing Your data to third parties, such as iGO / FINTRAC, if there is a legal obligation to do so

 

Purpose: For the development and improvement of Our business operations, products and services

Basis: legitimate business interest

• Collecting statistical data on the use of Our website and services, with or without cookies

• Storing customer service enquiries to better assist You later and to improve Our services

• Conducting market research and surveys

• The use of Business Intelligence software to improve Our operations

• Deriving aggregated data from Personal Information

 

Purpose: For communication, promotion and marketing purposes

Basis: consent

• To inform You as a registered player about Our products or services that might be of interest to You, via e-mail, telephone, SMS and/or via direct messaging on social media, if You have given Your consent.
  (System messages and/or legal messages are not optional, as they are necessary for the execution of the agreement or to comply with legal obligations). 

• Push notifications (app and/or desktop)

• Enrichment of personal data

• Handling requests for objection to direct marketing

 

Purpose: To ensure the security and stability of Our services and IT systems
Basis: legitimate business interest

• Monitoring of IT systems

• Conducting internal audits and investigations

• Detection of third party software in Our games of chance/iGames/sweepstakes

• Detecting activities in violation of Our terms and conditions

 

Purpose: To provide a personalised experience

Basis: justified business interest 

• Provide personalised (game) recommendations to logged in users, based on game history, unless You indicate that You do not wish to receive such recommendations
  
  

Purpose: VIP loyalty programme
Basis: necessary for performance of the contract

• Managing VIP accounts

• Providing personalised offers/rewards 

• Providing tailor-made and rapid assistance

 

Purpose: Investigating and reporting suspicious (gambling) activities

Basis: to comply with a legal obligation incumbent upon Us

• Preventing, detecting and investigating suspicious betting activities (e.g. match fixing), and reporting such activities to the competent authorities.

• Enforcement of the rules of a sport or game and/or prevention and detection of crimes

 

Purpose: Legal protection

Basis: legitimate business interest

• Protecting and enforcing Our rights and defending Ourselves in any proceedings

5. marketing

GWN and Our appointed third party service providers use Your personal information, such as Your name, home address, email address, telephone number, and other relevant information for promotional purposes concerning the Services which We believe may interest You. You may opt-out from receiving marketing from Us by following the instructions provided on the marketing communications, such as selecting the unsubscribe button within promotional emails, via the “Marketing Settings” page on Your account, or by contacting Our Customer Support. We will comply with Your request as soon as it can be processed. You must opt-in to receive marketing of bonus promotions and other inducements to play. You may control Your exposure to Our advertising on social media through the settings offered on the respective third party platforms:

• You can manage the settings for advertising preferences in Your Facebook account or at https://www.facebook.com/ads/preferences;

• You can manage the settings for advertising preferences in Your Twitter account or under https://twitter.com/personalization;

• You can manage the advertising and general settings in Your YouTube account under https://www.youtube.com/account;

• You can manage the settings for advertising preferences in Your Instagram account or under https://www.instagram.com/accounts/privacy_and_security/.

Please note that even if You opt-out of Our mareting mailing list, You will continue to receive service-related updates as per Our legal obligations and/or contractual arrangement We have with You. 

6. recipients of your personal information

For the purposes described in this Privacy Policy, including fulfilling Our legal obligations (such as responsible gaming, anti-money laundering, and wagering activity), GWN may share Your personal information with other Betsson Group entities to enable cross-network exclusions and similar measures, where applicable, on the basis of Our intra-group data processing agreements. 

In some cases, We are required by law to share Your personal information with government entities, law enforcement, regulators, and sports governing bodies for the purpose of combating gambling addiction and preventing or investigating potential criminal activity. Pursuant to the OA We are obliged to provide Your Personal Information, including any aggregated data, to iGO which manages igaming in the province of Ontario, Canada. iGO may in turn be legally required to further disclose Your Personal Information with other entities, or with other operators as part of enterprise level player monitoring,

GWN may engage third parties to process Your data in accordance with this Privacy Policy to provide You with the Services. These parties usually act as processors for GWN. In some cases, these parties act as joint or independent controllers. This is, for example, the case for payment service providers and social media platforms. In such cases, the privacy statement of the third party in question will apply. We shall only share Your data with these providers subject to appropriate agreements. Categories of recipients with whom We share personal information are:

• Gaming and software providers; 

• Risk management providers;

• Third-party vendors that provide technical support and help Us maintain Your account with Us; 

• Analytics and search engine providers that help Us improve and optimise Our website;

• Suppliers for communication purposes, such as Our marketing platforms and providers of mobile communication services for telephony and SMS;

• Partners who carry out surveys and market research on Our behalf;

• Interactive media platforms (such as social media platforms);

• Organisations that enable Us to provide relevant advertisements on third party websites and platforms that You visit;

• Payment service providers and payment facilitators;

• Cloud service providers;

• Anti-fraud, risk and compliance service providers (such as know Your customer (KYC) providers);

• Providers of information verification services to validate the information You provide to Us (such as credit reference bureaus TransUnion and Equifax);

• Professional advisers such as lawyers, accountants, consultants and insurers, who provide Us with legal, advisory and insurance services;

• Other partners who help Us create a better experience for You.

We may transfer some or all of Your Personal Information with any subsequent owner, co-owner or operator of the service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all Our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization. Alternatively, We may seek to acquire other businesses or merge with them. In the event of a change to Our business, We will inform You in accordance with applicable law.

While using the services You may find links to third-party websites/applications (for example social media platforms). Please note that this Privacy Policy does not apply to such third-party websites/applications. In order to find out more about processing of Your personal information by these third-party websites/applications, We instruct You to carefully read their privacy statements and the terms of use before using their services. 

7. transfer of personal Information to other countries

GWN is a part of Betsson Group, a global igaming operator. As a result, some of GWN’s service providers may be located outside of Canada. Your personal information is only transferred outside of Ontario and/or Canada in accordance with applicable laws. GWN shall ensure the comparable level of security and protection as required for personal information located in Ontario by means of specific contracts and other means regulating the personal information being transferred.

8. retention of your personal data

GWN will not retain personal information longer than necessary for the purposes for which it is collected or processed, unless longer retention is required by law. If Your information is no longer necessary for Us, We will securely delete the relevant personal information or anonymise it.

The necessary retention period is determined by various criteria inlcuding the nature of the data, purpose of the processing, the legal basis, whether there are any applicable legal obligations or industry codes of conduct, and other factors. 

We will keep Your personal information for as long as Your account is active. If Your account is closed (by Yourself or by Us), We will retain all Your information for the period required by applicable laws such as tax laws, AML laws, and gambling laws. We will also retain Your personal information as required by laws governing potential legal disputes as per Our retention and disposition policy. 

 

Throughout the retention period aggregated data may be derived from Personal Information and is shared with senior management for business analytics purposes. After the retention period expires and Personal Information is anonymized, GWN Ltd. may continue using anonymized aggregated data for business analytics purposes. 

 

For further information about data retention in Your specific jurisdiction please contact Us (see “Contact Us”). 

 

9. automated individual decision-making

In some cases, GWN uses fully or partially automated decision-making. GWN applies innovative technology to detect patterns or bets that may indicate fraud or money laundering and to observe a player's playing behaviour in order to prevent undue participation in ’GWN’s offering. This technology enables GWN to make fast, fair, and responsible decisions in accordance with applicable law.

• We use automated tools to check against sanction / PEP lists and the centralized self-exclusion scheme, in accordance with Our legal obligations under relevant legislation to take necessary anti-money laundering and responsible gaming measures. 

• We analyse Your transactions and gaming behaviour in order to establish a risk profile in accordance with Our legal obligations and licensing requirements to take measures to identify and investigate suspected illegal or fraudulent activities in connection with the Services, including money laundering, terrorist financing and fraud. 

• In accordance with Our licensing obligations, We are required to monitor users who are experiencing or at risk of developing an addiction. Therefore, We conduct risk assessments of players by analysing behaviour, transactions, usage patterns and other data such as communications. Furthermore, Our tools assess whether limits set by players have been reached.  

• We analyse Your playing patterns and activities to investigate and identify possible issues related to integrity, malpractice, and other serious inappropriate behaviour in sport, such as match-fixing.

• We process data about Your activities and play behaviour in order to monitor compliance with Our Terms and Conditions and internal policy documents. 

• We will assess Your eligibility for VIP status by analysing Your transaction and game history.

• Based on Your game history, We will provide You with tailored recommendations unless You object to such processing by indicating Your preferences in Your account or by contacting Us. 

Please note that any decision with a legal or material impact on You will not be taken without human intervention, unless it is (i) permitted by law,(ii) necessary for the performance of the contract with You, or (iii) based on Your express consent. In decisions made based on provisions (ii) and (iii), above, You have the right to request a new (manual) assessment by a GWN employee (right of human intervention).

GWN’s systems are tested on a regular basis to ensure fair, effective, and unbiased operation. We cannot disclose detailed information about Our detection systems, in particular the logic behind them, as this would harm their operation by allowing users to circumvent these mechanisms, which are aimed at protecting users, Our Company and at ensuring compliance with legal obligations.

10. what are your rights?

You have a number of rights with regard to the processing of Your personal information, including:

• Right to withdraw Your consent at any time, if We have asked Your permission for a certain processing of Your personal information;

• Right to obtain confirmation from Us if We are processing Your personal information and, if so, to access that personal information , except where We are legally prohibited from disclosing that information;

• Right to rectification if personal data are incorrect or incomplete. GWN takes all reasonable measures to ensure Your personal information is accurate, complate and up to date.  If You believe that the personal information GWN holds about You is inaccurate, incomplete or not current, You must either update the information from the “My Account” section on Your profile or contact Us immediately and We will correct the information if We are satisfied that a correction is required; and

• Right to lodge a complaint with the Office of the Privacy Commissioner of Canada or iGaming Ontario. 

Please note that these rights are not absolute and requests are subject to any applicable legal requirements. We will respond to requests concerning Your rights without undue delay. We cannot give You legal advice.

11. protection of your personal information

We take appropriate measures to prevent abuse, loss, unauthorised access, unwanted disclosure, and unauthorised modification of personal information. For example, We use secure network connections, firewalls, encryption, and anonymise data where possible. However, You acknowledge that no method of transmission over the Internet, nor any method of electronic storage, is 100% secure. We do Our best to protect Your personal information, but We cannot guarantee its absolute security. GWN’s employees, agents, and contractors have restricted access to personal information to a need-to-know basis subject to confidentiality agreements.

In order to protect Your account, You are ultimately responsible for maintaining Your username and  password confidential and secure. We will never ask You for Your password except when You log in to Our website and enter Your password at which time it is encrypted. If You become aware of any unauthorized access to or use of Your account, You are required to notify Us immediately. Our mobile application(s) require biometric authentication upon each login. Your credentials will be securely encrypted by and stored on Your device. They will not be stored in Our mobile application(s) nor held or accessed by Us in any way. We will only know whether You have been successfully identified or not. Please note that if You store fingerprints of other persons on Your device, those persons will also be able to access Our mobile application(s) via fingerprint when fingerprint is enabled. 

For general information on how to protect Your information online, please refer to the resources posted by the Information and Privacy Commissioner of Ontario at https://www.ipc.on.ca/privacy-individuals/ensuring-your-privacy-is-protected/.  

We have adopted procedures to deal with any actual or suspected breach of security safeguards involving personal information. Unless otherwise prohibited by applicable law, We will promptly notify You in the event of a breach which could reasonably result in a real risk of significant harm to You. We will also report any such breach to the competent authorities as required by applicable laws (including, without limitation, iGO and the Office of the Privacy Commissioner of Canada), and keep a record of any such breach to the extent required by applicable laws. We will aid iGO and any related authorities in breach management and handling of any results from a breach as necessary.

12. changes to this privacy policy

We reserve the right at Our discretion to change or modify Our Privacy Policy from time to time. To the extent that the Privacy Policy or sections thereof are subject to a material change, We shall inform You of such change through reasonable measures including email or notice on the webiste and require re-acceptance of the Privacy Policy. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last revised” date, and Your continued use of the Services after the Last revised date will constitute acceptance of, and agreement to be bound by, those changes.