Privacy Policy www.on.wheeloffortunecasino.com – Wheel of Fortune Casino Ontario Online Gaming Services

Last Updated August 6, 2024

This privacy policy (“Policy”) describes how BetMGM Canada Inc. and its applicable affiliates and subsidiaries (collectively, “BetMGM”, “we,” “our” or “us”) collect, use, protect and share personal information we collect or receive in connection with your access and use of: (1) BetMGM-operated gaming websites and mobile gaming applications, including all features, functionalities, applications, browser extensions and other services available through them (collectively, our “Gaming Operations”); and (2) other websites that we operate, including, without limitation, our corporate website, located at www.betmgminc.com (however, please note the corporate privacy policy on the aforementioned website is only applicable to our United States operations), and other websites or mobile applications we operate that provide a link directly to this Policy, including all features, functionalities, applications, browser and extensions and other services available through them (collectively, our “Corporate Websites” and, together with our Gaming Operations, our “Online Offerings”). This Policy also applies to any personal information we collect or receive in connection with any other interactions we have with you outside of our Online Offerings related to our business operations, such as when you contact us or use other services we provide (collectively, together with our Online Offerings, our “Services”).

You can access our Online Offerings in many ways, including from a computer or mobile device, and this Policy will apply regardless of the means of access. To the extent we provide you notice through our Online Offerings of different or additional privacy policies or practices (e.g., at the point of collection), those additional terms shall govern such data collection and use in addition to this Policy.

Please read this Policy carefully. If you do not want us to collect, use or disclose your personal information in the ways described in this Policy, please do not use our Services, provide us with your personal information, or authorize a third party to make your personal information available to us. By using our Services, providing us with your personal information or otherwise making your personal information available to us, you acknowledge that you understand that we may use your personal information as described in this Policy. Please note, as described in this Policy, we may receive your personal information from third parties who may not have expressly advised you that they will disclose your personal information to us. If you have any questions about how we collect, use, protect, disclose or otherwise process personal information, including whether we have received your personal information from a third party, please contact us via e-mail, or via our Customer Care portal (chat feature is included).

This Policy governs the personal information collection, use, sharing, and related practices applicable to the Services in Ontario only. “Personal information” means information about an identifiable individual and includes any information that constitutes personal information within the meaning of the Freedom of Information and Protection of Privacy Act (“FIPPA”) and other applicable privacy laws. This Policy is separate and distinct from the privacy policies that govern the online gaming services offered by BetMGM and MGM Resorts International (“MGM”) in Ontario or in other jurisdictions.

This website and the Services operate under and pursuant to the Operating Agreement (as defined below) and are being offered by BetMGM as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (“iGO”) (www.igamingontario.ca/en). In the course of providing the services: (i) BetMGM collects, uses and discloses personal information on behalf of and as agent to iGO; (ii) BetMGM collects personal information in accordance with FIPPA and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act, 2019, and the operating agreement entered into between BetMGM and iGO (“Operating Agreement”).

Except as otherwise stated in this Policy, this Policy does not apply to the websites, online gaming services and other services operated, controlled or offered by MGM. Furthermore, this Policy does not apply to our privacy practices with respect to our collection, use, storage, disclosure, and protection of personal information relating to our employees and job applicants.

I. INFORMATION WE COLLECT

This section describes our personal information collection, use and processing activities related to certain portions of the Services.

A. Information You Provide. In order to access and use our Gaming Operations, you must register for an online Ontario Wheel of Fortune wagering account (a “Wagering Account”). When you register for a Wagering Account, we will access and collect the personal information you provide (including your name, username, postal address, e-mail address, descriptive occupation (i.e. job position and industry), gender, date of birth and communication preferences). We may also ask you for additional information, including your mobile phone number and a government-issued photo identification such as your driver’s license, Ontario photo card, or passport.

When we verify your identity when you first register your Account with us, we share certain information with Canadian credit bureaus, such as TransUnion Canada (via our service provider, Aristotle) and Equifax Canada (via our service provider, GBGroup), in order to validate ID as required by applicable law. We may also use a third-party service provider, Jumio, where necessary, who will assist with verifying the details of your government-issued photo-identification and proof of address documents as required under applicable law. Further information about how these credit bureaus and third-party service providers treat your information can be found on their relevant websites.

We will collect certain of the above personal information, and if provided by you, your country of residence, business telephone number, employer’s name, employer’s address, citizenship, and alias/preferred name for the purposes of complying with our anti-money laundering obligations under applicable law. If you attest that you are a Politically Exposed Person (“PEP”), the Head of an International Organization (“HIO”), or a family member or a close associate of a PEP or HIO, as those terms are defined in the General Terms of Service, you will be required to provide additional information such as your source of funds, your source of wealth, the nature of your connection to the PEP or HIO if you are a family member or close associate of a PEP or HIO, the office or position of the PEP/HIO, the PEP or HIO organization/institution name and, if you are a family member or close associate of a PEP or HIO, the nature of the relationship between the family member and close associate of the PEP or HIO. Such information is collected on behalf of iGO and may be shared with other Operators as part of enterprise level player monitoring.

When you access, participate in, or otherwise interact with our Services, or otherwise engage with us in connection with our Services, such as requesting more information about our Services or communicating with us, we may ask you to provide us with additional personal information. We may require some of this information to meet our legal and/or regulatory obligations. Please note, if you do not provide us with personal information that is required for a particular feature of our Services, such as information we are legally required to collect when you register for a Wagering Account, you may not be able to access, participate in, or otherwise use our Services or certain portions of our Services.

B. Location, Gaming, and Transaction Information. When you use the Services, we and our third-party service providers may collect information about your physical location, gaming activity and all transactions associated with your Wagering Account. 

C. Device Information. When you use the Services, we and our third-party service providers may use cookies (see below), web beacons, tracking pixels, scripts, e-tags, and other technologies (“Tracking Technologies”) to collect and analyze information about you, your device, and your activity. Information collected through Tracking Technologies may include the type of device; browser and operating system you are using; your device identifiers, such as your MAC address; the name you have associated with your device; the unique number associated with your internet connection; your (mobile) telephone number; the websites you visit; your geographic location; and your activities within the Services including the links you click, the pages or screens you view, the bandwidth you use, your session time, the number of times you click a page/screen or use a feature of the Services, the date and time you click on a page or use a feature, and the amount of time you spend on a page or using a feature. Information collected through Tracking Technologies is stored in log files. We respond to “Do Not Track” signals as required by applicable law.

D. Cookies/Session ReplayWe may use cookies to store some information on your computer, laptop, tablet or mobile device when you access and use the Services. Cookies are small text files that are stored on your computer or equipment when you visit certain online pages and record your preferences. Cookies allow us to remember things about your visits across the Services, but cannot access or use other information on your device. We do not use flash cookies to remember or use directly identifying personal information about you such as your name or e-mail address. We use cookies to track use of the Services. We also may use cookies and third-party cookies to monitor traffic to the Services, improve the Services, make it easier and/or more relevant for your use, and help us to show you advertisements which are relevant to your interests based on your use of the Services (“interest-based advertising”). For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioral ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.

We use session replay software on our Online Offerings so we can better understand each individual user’s experiences on our Online Offerings (like how much time users spend on which pages, which links they click, what they like and don’t like) and use that knowledge to fix bugs on our Online Offerings, improve your user experience on our Online Offerings, and improve the functionality of our Online Offerings. Session replay software allows us to record and play back a user’s journey through our website or mobile app. These session replay services use cookies and other technologies to collect data about the behavior of our users and their devices, in particular the IP address of the device, screen size, device type (“Unique Device Identifiers”), information about the browser used, location (country only), preferred language for displaying our Online Offerings, in addition to mouse movement, click information, and text you enter as you navigate through our Online Offerings.

Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also modify your Flash Player settings to prevent the use of flash cookies. 

If you choose to decline cookies, you may not be able to experience all of the interactive features available through the Services. You can visit www.allaboutcookies.org in order to obtain more information on deleting or controlling cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services. You can find additional information about our use of cookies here.

E. Wi-Fi and Location Information. In your use of the Services, we may collect information (directly or through third-party service providers) that includes the web sites you visit, the type of device and browser you are using, your device identification number, bandwidth used, session time, etc. We and our service providers utilize several current technologies, and may use future technologies, that enable us and our service providers to determine the location of devices that engage, or attempt to engage, in any wagering activity through or in connection with our Gaming Operations (collectively, “Location Tracking Technologies”). Location Tracking Technologies allow us to: (i) verify your physical location when you engage, or attempt to engage, in any wagering through or in connection with a specific Gaming Operation; and (ii) improve the location-based services utilized by our Services. Without limiting anything else in this Policy, the Location Tracking Technologies are capable of identifying the near-precise physical location of the computers or Internet-connected devices that engage, or attempt to engage, in any wagering activities through or in connection with our Gaming Operations by accessing the device’s IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates (collectively, “Location Information”). The Location Tracking Technologies will report the Location Information for each any every device you use to engage, or attempt to engage, in any wagering activities through or in connection with our Gaming Operations to us, and as needed our service providers and/or regulatory bodies and other applicable government agencies and related entities to ensure you are located in Ontario.

The normal operation of the Location Tracking Technologies and our Gaming Operations transmit Location Information via Transport Layer Security (TLS) technology and Location Information is stored in secure servers managed by us and our geolocation and operating partners. Neither we nor our partners will disclose, transfer or resell your Location Information to any additional third parties except:

  1. where required by law, including, without limitation, as necessary to satisfy any law, regulation or government agency request.
  2. as necessary or appropriate to investigate, respond to and defend against legal claims, including, without limitation, to protect us against liability.
  3. to protect our property and rights.
  4. for the safety of the public or any person.
  5. to stop any unfair, illegal, unethical, fraudulent, abusive or legally actionable activity.
  6. to protect the security and integrity of our Gaming Operations and any equipment used to make our Gaming Operations available.
  7. in the event of a proposed or completed merger, acquisition, bankruptcy or other sale of all or a portion of our assets.

You may opt out of, or otherwise withdraw your consent to, our use of the Location Tracking Technologies to collect Location Information at any time by turning off the location settings on your applicable devices or by notifying us in writing that you would like to opt-out or otherwise withdraw your consent. If you turn off the location settings or opt-out or otherwise withdraw your consent, you may be able to access your account and view our webpages, but you will not be able to place any internet wagers or access real money games and tournaments via the applicable Gaming Operations.

Location Information may be retained for up to ten (10) years as required by applicable regulatory bodies and other government agencies and related entities, or for other retention periods that are consistent with applicable laws.

F. Affiliate and Third-Party Information. We may obtain information about you from MGM and casinos, resorts, platforms, and properties that are owned, operated, managed by or affiliated with MGM (collectively “MGM Affiliates”), from our other parent and affiliated companies, including, but not limited to, Entain plc (collectively, with the MGM Affiliates, our “Affiliates”) and from third parties, including our business partners and other companies and individuals that refer you to our Services. This information may include, among other things, information to set up your Wagering Account and to assist us in meeting our legal and regulatory obligations and ensuring the fairness, security and safety of our Services.

II. HOW WE USE THE INFORMATION WE COLLECT AND OPT-OUT OPTIONS

A. Use by BetMGM

Marketing Purposes. With your consent, we may use the information we collect for our own marketing purposes, including notifying you of special promotions, offers, and events via push notifications, e-mail, and other means. We may also link personal information (including your name, mobile phone number, and e-mail address) with other information (including information collected through Tracking Technologies and Wi-Fi services) and use such information for our own marketing purposes. We and our marketing providers may also use identifiers derived from a hashed or encrypted version of personal information, such as your e-mail address or phone number, to tailor advertising to you or to measure the performance of our advertising. If you do not want us to use your personal information for marketing purposes, you may opt-out in accordance with the “How to Opt Out” section below.

Non-Marketing Purposes. We may use the information we collect for non-marketing purposes (collectively “Non-Marketing Purposes”) including:

  1. validating your identity.
  2. providing and facilitating our Online Offerings.
  3. sending you push notifications or e-mails to provide you with alerts and updates about your Account and the Services.
  4. monitoring, accessing, and recording gaming-related activity.
  5. conducting internal research, statistical or demographic analysis.
  6. processing and tracking gaming and non-gaming transactions.
  7. complying with legal and regulatory requirements, including, without limitation, responding to subpoenas, search warrants and other inquiries from our regulators.
  8. providing you with the Services and customizing your experience with the Services.
  9. protecting and defending the rights and property of BetMGM, MGM, and all other MGM Affiliates against legal actions or claims.
  10. preventing fraud.
  11. debt collection.
  12. tracking usage of the Services.
  13. assessing and improving the Services.
  14. creating and updating customer profiles.
  15. responding to customer inquiries.
  16. conducting background checks.
  17. satisfying contractual obligations.
  18. responsible gambling assessments.
  19. responding to Customer Care requests.
  20. safety, security and fairness purposes, including cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest.

B. Sharing with Affiliates 

We may share the information we collect with Affiliates for marketing purposes and for Non-Marketing Purposes. If you do not want us to share your personal information with Affiliates for marketing purposes, you may opt-out in accordance with the “How to Opt Out” section below.

C. Sharing with Business Partners, Market Access Partners and Other Third Parties

We may share the information we collect with our business partners and other third parties for joint marketing purposes and/or our business partners’ (or our own) marketing purposes. Specifically, when we are permitted to operate in a jurisdiction based on our relationship with a third party (“Market Access Partner”), we may be required to share information with that third party. We may share information with third-party providers for rewards redemption or to provide prizes to promotion winners. Even if you opt out of permitting us to share your personal information with our business partners and other third parties for marketing purposes, we may still share the information we collect with them for Non-Marketing Purposes such as processing transactions, fulfilling your requests, responding to your inquiries, etc.

D. Service Providers

We engage service providers to provide certain services to us or to perform certain services on our behalf including analytics, marketing, fulfillment, identity verification and to meet our other business needs. In some cases, service providers may collect or be provided with access to your information as reasonably necessary to perform such services on the condition that they not use or disclose your personal information for other purposes.

Our service providers may be located in the USA or other foreign jurisdictions. In the event personal information is transferred to the USA or other foreign jurisdiction, the storage and other processing maybe be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

We also engage service providers to provide identity verification services; in some cases, these service providers may use biometric information to perform such services. Your consent will be requested before your biometric information will be collected; you may choose not to participate in such collection and we may be able to verify your identity in another way. The collection, use, disclosure, retention and other processing of the biometric information collected will be subject to the service provider’s retention policies, which will be available to you prior to processing. 

E. Fraud Prevention and Security

We are committed to taking all reasonable measures to ensure the fairness, security and safety of our Services. Where permitted or required by applicable law, we share information with our Affiliates, service providers, regulators and other government agencies, governing bodies, and other similar third parties to detect, discourage and report fraud, unsafe gambling, and other potentially unethical or illegal betting-related activity.

F. Certain Business Transactions

We may share all information we collect with any prospective or actual successor to all or part of our business in connection with a transaction involving a proposed or completed sale, purchase, reorganization, merger, or transfer of any our assets or the assets of Affiliates.

G. How to Opt Out of Marketing from Us and How to Opt Out of Having Your Personal Information Shared with Others for Marketing Purposes

If you wish to opt out of receiving marketing communications from us via postal mail, e-mail and telephone, you can opt out within the ‘Communication Preferences’ tab of your account Settings or via e-mail. If you do not want us to share your personal information for marketing purposes with our business partners, third parties or Affiliates, please e-mail us at optout@betmgm.com or write to us at:

BetMGM

Attn: WOF Privacy Policy

Harborside Plaza 2, Suite 700

200 Hudson Street

Jersey City, New Jersey 07311

United States

Alternatively, you can unsubscribe from e-mails at any time by clicking the “unsubscribe” link included at the bottom of each e-mail.

Although you may opt out of the use and sharing of personal information for marketing purposes, you may continue to receive transactional or account-related communications from us.

H. Your Consent or Instructions

We may share your personal information with any third party to whom you consent or instruct us to provide your personal information.

I. No Additional Disclosures

We will not share the information we collect with third parties, other than as described in this Policy.

III. HOW LONG WE KEEP YOUR PERSONAL INFORMATION/PRIVACY RIGHTS

The length of time we retain personal information depends on the reason the personal information was originally collected, how we use the personal information in connection with our operations, and requirements applicable to the personal information. This may include, without limitation, retaining personal information to:

  • complete the transaction for which the personal information was collected,
  • continue our ongoing business relationship with you,
  • ensure the security and integrity of our Services, and
  • satisfy applicable legal, regulatory, tax, accounting, or reporting requirements.

To determine the appropriate retention period for individual categories of personal information we collect, we consider the nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process that personal information and whether we can fulfill those purposes through other means, and applicable legal, regulatory, tax, accounting, reporting or other requirements.

Requests to close or delete your account may be made by logging into your account and selecting Service Closure. Due to regulatory requirements under jurisdictional gaming laws, federal tax laws and other legal obligations, and as necessary to complete certain transactions, we are required to retain your account information for a certain period of time, which may vary by jurisdiction. We may also retain your account information to engage in ongoing fraud prevention and detection and to exercise and defend against legal claims. Provided you do not re-open your account in the future, we will delete your account information once we no longer need to retain it for the purpose(s) for which it was collected, or as required by applicable law.

1. Requests to Access and to Correct Your Personal Information

You have the right to request access to any personal information we have about you in our custody and under our control, and to request we update or correct any inaccuracies in such personal information. While we will use reasonable efforts to ensure your personal information is up to date and accurate, we ask that you update your information whenever your information is incomplete, out of date or otherwise changes. You can update and correct any inaccuracies in your personal information by contacting Our Customer Care team via e-mail and providing the required personal information and identity verification documents. If you request that we correct inaccurate personal information about you, we will use commercially reasonable efforts to correct it. If necessary, we may ask that you provide documentation showing that the information we retained is inaccurate. All requests are subject to verification of your identity to protect the privacy and security of your personal information.

2. Withdraw Consent to Process Your Personal Information

You have the right to withdraw your consent to our processing of your personal information, subject to certain legal or contractual exceptions such as our need to process your personal information to comply with legal obligations, fulfill orders, complete transactions, etc. All such requests are subject to verification of your identity. If we verify your request and cease processing your personal information pursuant to the request, we will also instruct our service providers (if any) to cease processing your personal information, subject to applicable legal requirements. 

3. Verification Procedures

In order to verify requests made pursuant to applicable laws, we may require two (2) or more pieces of identifying information that match information maintained by us or, if you have a Wagering Account, to verify your identity through your Wagering Account. In some cases, we may require additional identifying information and a signed declaration attesting to your identity. 

In certain circumstances, we may decline a request to exercise the ‘Requests to Access and Correct’ or ‘Withdraw Consent’ described above, particularly where we are unable to verify your identity or are permitted or required to maintain the personal information we have collected about you. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

4. How to Submit a Privacy Request

If you wish to submit one of the above requests, please click here and provide the identifying information requested. All requests are subject to verification of your identity to protect the privacy and security of your personal information.

IV. SECURITY

We store certain non-gaming information and non-live gaming data collected through the Services on secure servers located in the United States. Internet wagering data and live game play data collected by us through the Services is stored in Canada, the United States and other foreign jurisdictions and, pursuant to applicable laws, may be subject to access by US or foreign courts, law enforcement or other government authorities. 

We have measures in place to prevent the unauthorized or unnecessary disclosure of the personal information we collect. Our servers are protected by firewalls and other industry standard security measures. These security measures are intended to protect our servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. We have controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach. We maintain a BetMGM ‘Information Security Policy/Information Security Standards’ document, which contains Data Breach security standards. We will provide you notice in the event of an incident that materially impacts your personal information (a “Data Incident”). We will notify you, iGO, the Alcohol and Gaming Commission of Ontario (“AGCO”), and any other applicable regulatory authority about the Data Incident, and we will aid iGO, AGCO and any applicable authorities in the management and handling of the Data Incident.

Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information. Personnel who violate our privacy practices are subject to disciplinary action, up to and including termination of employment.

We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you may use to send e-mails and submit information to us over the internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of information that you send us before we receive it.

As a standard security practice, we will take reasonable steps which are generally recognized in the industry to ensure that the communication methods used to support the Services do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using the Services, it may be an indication that you need to upgrade your internet browsing tool or application to a newer version that supports more secure communication methods. In order to protect your account, we strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or e-mail messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately. For general information on how to protect your information online, please refer to the resources posted by the Information and Privacy Commissioner of Ontario.

In situations where your personal information is collected by third parties under contract with us for performance of their contractual duties and other purposes, we require such third parties to exercise reasonable care to protect that information and restrict the use of your personal information to the purposes for which it was provided. When we share your personal information with third parties in accordance with this Policy, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them.

V. ACCESS TO AND DELETION OF PERSONAL INFORMATION

With respect to personal information associated with your Wagering Account (“Wagering Account Personal Information”), we will retain such Wagering Account Personal Information as long as your Account is active. When your Wagering Account is terminated, we will retain applicable Wagering Account Personal Information for as long as necessary to comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements.  Once we determine that we no longer need to retain such Wagering Account Personal Information, pursuant to applicable law, all such Wagering Account Personal Information will be securely erased from hard disks, magnetic tapes, solid state memory, and other devices, as applicable. If erasure is not possible, the device will be destroyed. 

For all other personal information that we collect in connection with our Services, we will retain such personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements.

VI. OTHER WEBSITES

We are not responsible for the information collection or privacy practices of other websites, including websites accessible through the Services. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any personal information on them.

VII. INTERNATIONAL TRANSFERS

Information collected on the Services may be stored and processed in any country in which we or our affiliates, suppliers, third-party electronic payment processors and/or financial institutions or agents maintain facilities. By using the Services, you expressly consent to any transfer of information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.

VIII. PERSONS UNDER 19

The Services are for use by persons 19 or older. If you are under 19, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of personal information via the Services from persons under 19. If you are a parent or guardian and become aware that your child under the age of 19 has provided us with personal information, please contact us via the information below in the “Contact Us” section.

IX. CHANGES TO THIS POLICY

We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions by placing notice of the revised Policy on the Services or any place through which you access the Services, by sending you an email, or by communicating with you in any other legally permissible manner. For material changes to the Policy, you may be required to acknowledge acceptance of such changes. It is your sole responsibility to review the Policy and any revisions thereto each time you use the Services.

X. CONTACT US

If you have any questions about this Policy or would like to request any additional information, please contact our Data Protection Team. Additionally, if you wish to make a complaint, you can make one through our complaints process, which can be found here. If you need information on how to exercise your rights in an alternative, accessible format due to a disability, please send us an e-mail with your name and contact information, or contact us via our Customer Care portal (chat feature is included).