Please review this Privacy Policy (“Policy”) carefully. It applies to all information collected by Old Vegas Classic Slots and its affiliated companies (collectively, the “Company”, “we”, or “us”) through our websites and gaming applications (collectively, the “Services”). The company creates free social casino games for the Facebook platform and the Google, Apple, and Amazon App Stores.
This policy outlines the information we collect, how we collect it, and why, as well as how we use and share it.
- Accessing and updating your information;
- Controlling how we collect, use, and share your information;
- Ensuring information security.
By using the Services, you agree that we will use your information in the United States and any other countries where we operate. Please keep in mind that privacy laws and standards in other countries, as well as government authorities’ rights to access your personal information, may differ from those in your home country. We will only transfer personal information to countries where we are legally permitted to do so, and we will take steps to ensure that your personal information continues to be adequately protected.
1. What is Personal Information?
“Personal Information” means information that specifically identifies an individual, such as a name, address, telephone number, mobile number or email address, or information about an individual that can be directly linked to such identifying information, such as device IP address and geolocation information (“Device Information”). Personal information does not include “usage information” (i.e., anonymous information about website usage such as visit statistics, page views, device type, etc.) unless such information is linked to your personal information.
Under the EU General Data Protection Regulation (GDPR), where applicable, Personal Data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
2. Information Collected Through Our Services
Information you provide to us.
You may choose to provide Personal Information through the Services. The Company may collect Personal Information when you request information from us, contact us or submit comments. If you do not want your Personal Information collected in this way, please do not submit it.
You may also choose to participate in certain activities on our Services that allow you to communicate or share information publicly, such as player profiles, message boards, chat or messaging features, or gifting/invitation features. If you participate in these activities, we may collect some or all of the information you submit, even if it is submitted through a player-to-player messaging system.
We also collect your Personal Information when you access the Services through a social networking site such as Facebook or through the Facebook Connect feature, including any or all of the following: your name; your profile picture; your social network ID number; your friends’ public profile information on the social networking site; your email address; your location; your gender; your birthday or age; and any other information that the social networking site chooses to share with us. If you access the public areas of the Services through a social networking site or application, we may post your profile information and picture as permitted by the social networking site.
Information Collected by Automated Means.
When you use the Services, the Company and any third party advertisers and/or service providers may automatically collect usage and device information. The technologies used on the Services to collect Usage Information and Device Information may include, but are not limited to, web beacons and cookies. Web beacons (also known as Internet tags, pixel tags, tracking beacons and clear GIFs) are clear/transparent graphic images placed on a web page or in an email that collect Usage Information and Device Information. Cookies are data files that are placed on a device when it is used to visit the Services. If you prefer not to accept cookies, most browsers will allow you to: (i) modify your browser settings to notify you when you receive a cookie, giving you the opportunity to decide whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically refuse all cookies. Please note, however, that if you disable or reject cookies, some features of our services may not function properly because we may not be able to recognise you, and the offers we provide may not be as relevant to you.
We use tracking technologies to recognise your logged-in state on the Services, to understand what Service features visitors are interested in, to make the Services work for you, and to make your browsing and use of the Services more personalised. In general, we use tracking technologies for the following purposes.
Security and authentication (strictly necessary)
Some functions of cookies and similar technologies are necessary and essential to ensure that the Services function properly for visitors, such as maintaining the security, safety and integrity of the Services, authenticating and logging into the Services (including remembering permissions and consents you have granted), and ensuring the ability to securely complete transactions.
Account and user preferences
Some technologies are used to remember your account and preferences over time, such as remembering your account or keeping you logged in when you return to the Services, maintaining your choices regarding Service features, and customising content based on how you use the Services.
Social networking
Some technologies help you interact with social networks you are logged into while using the Services, such as sharing content with the social network, logging in with the social network, and other features you use with the social network or that are permitted by the social network’s privacy policy. These may be set and controlled by the social networks and your preferences with those social networks.
Performance and analytics
Some technologies help provide performance data about how the Services work to improve the Services, including, for example, data about site and application functionality and speed to help us optimise the Services, and to detect and collect reports of bugs to help make the Services work better.
The Services also use Google Analytics to help us understand how the Services are used by visitors. For some of the advertising features listed below, such as retargeting, data from Google Analytics may be combined with our first-party data and third-party cookies (such as Google’s advertising cookies).
Marketing Services
We work with third party service providers who may use various tracking technologies to enable us and them to learn which ads you see and click on when you visit the Services or to serve ads to you on and off the Services. These may include things like
- Frequency capping, which limits the number of times a user’s browser or mobile device displays the same ad;
- Attribution tracking, which estimates which advertising or marketing source brought someone to the Services, or determines which marketing source led to actions such as a visit or purchase;
- Remarketing, which shows relevant ads to an audience based on previous browsing patterns on the Services;
- Audience targeting, which refers to targeting advertisements to a large audience based on the audience’s known or inferred demographics; and
- Cross-device recognition, which recognises actions across multiple devices or browsers.
Some third-party service providers may provide information such as demographics, cross-device information or interest categories from a combination of sources that does not personally identify you but enables us to provide you with more relevant and useful advertising. In some cases, this information may also be used for non-marketing performance analysis.
These technologies allow a partner to recognise your computer or mobile device each time you visit the Services based on data such as a cookie, your IP address or device ID, but do not allow access to other personal information from us. However, these technologies may allow us or a third party to recognise you over time, either from a single device or across devices. These third parties are required to comply with applicable laws, self-regulatory programmes and our privacy policy, where applicable. However, we have no control over these third parties, which have their own privacy policies and practices.
Information we receive from third parties.
We may also supplement and combine the information we collect about you through the Services with other information we receive from third parties in order to improve our ability to serve you, tailor our content to you, and market products and services to you. In these cases, we will apply this policy to all personal information received, unless we have disclosed otherwise.
3. How we use information
When you access or use the Services, we will collect, use, disclose and otherwise process your Personal Information as described in this Policy. We will use Personal Information and other information we collect through the Services to
- To provide you with the services and information you request;
- Process your transactions through the Services;
- To contact you about your use of the Services;
- respond to your emails, questions, comments and complaints and otherwise provide customer service;
- to personalise and improve the Services and to provide advertisements, content or features that match the interests of our users;
- Monitor and analyse usage information and otherwise measure the effectiveness of the Services;
- send you confirmations, updates, security alerts, support and administrative messages, detect and prevent fraud, and otherwise facilitate your use of the Services and our administration and operation of the Services; and
- to notify you of important changes to the Services.
We rely on a number of legal bases to use your information in these ways. These legal bases include where
- necessary to perform the contractual obligations set out in our Terms and Conditions;
- necessary to provide the Services to you;
- you have consented to the processing, which you can withdraw at any time;
- is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
- is necessary to protect our legitimate interests or those of third parties, such as other visitors or our suppliers;
- You have published the information;
- is necessary in the public interest; and
- is necessary to protect your vital interests or those of others.
4. What personal information do we disclose to third parties?
We will not share the personal information we collect from you through the Services with third parties except as described in this Policy or in the Services. We may share non-personal information, such as usage information, with third parties. We may share your information with third parties in the following circumstances
Third parties who provide services on our behalf.
We may share your personal information with third parties who perform services on our behalf (or on behalf of our partners), such as companies that host or operate our services, provide customer service, manage payments, and provide marketing services to us. These third parties are required to maintain the confidentiality of your personal information and only use it to provide services on our behalf in accordance with our instructions.
Your consent to share your personal information.
While using our Services, you may be given the opportunity to opt-in to receive information and/or marketing offers from someone else or otherwise consent to the sharing of your information with a third party. If you consent to your personal information being shared in this way, your personal information may be disclosed to the third party and the personal information you disclose will be subject to that third party’s privacy policy and business practices.
Business Transfers.
We may also share your personal information with our subsidiaries and affiliates, and those entities may use your information in accordance with this Policy. As we continue to develop our business, we may sell or acquire assets. If another entity acquires us or all or a portion of our assets, Personal Information and any other information we have collected through the Services may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. In addition, if any bankruptcy or reorganization proceeding is commenced by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties. In the event of such a transfer, the acquiring entity will remain obligated to treat your personal information in accordance with this Privacy Policy.
Legal Disclosures.
We may transfer and disclose information, including your Personal Information, to third parties to comply with any legal obligation; at the request of governmental authorities conducting an investigation or otherwise requiring disclosure (including, without limitation, to meet law enforcement requirements and for purposes of national security); to verify or enforce our Terms of Service; or to otherwise protect the rights, property, safety or security of us, the public and/or other users of our Services.
5. How long we keep your information
The length of time we keep your personal information depends on why we collected it and how we use it. We will never retain your personal information for longer than is permitted by applicable law, and otherwise we will generally not retain your personal information for longer than is necessary to fulfil our business purposes and to protect our legal rights.
6. Your rights as a data subject; your access and choices
At any time while we hold or process your personal information, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information we hold about you.
- Right of rectification – you have the right to correct any information we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be removed from our records.
- Right to restrict processing – where certain conditions apply, you have the right to restrict processing.
- Right to portability – you have the right to transfer the data we hold about you to another organisation.
- Right to object – you have the right to object to certain types of processing, such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to object to the legal effects of automated processing or profiling.
- Right to judicial review: if we refuse any of your above requests, we will provide you with a reason for doing so. You have the right to complain in accordance with this policy.
All of the above requests will be passed on where a third party is involved in the processing of your personal data.
7. Links to other sites
The Services may provide links to other websites that we do not own or operate. We do not control, recommend, endorse or are responsible for these websites or their content, products, services or privacy practices.
8. How we protect personal information
We maintain certain administrative and technical safeguards to help protect against loss or unauthorised access to or disclosure of your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us and your use of the Services is at your own risk.
9. International operations; transfer of information outside the EU
The Services are operated in the United States and other countries outside the EU. Please be aware that the information we collect will be transferred to and processed in the United States and other countries outside the EU. By using the Services, providing us with any information, or opting into this Policy through any mechanism we provide, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other territories that may not have data protection laws equivalent to those of the country in which you reside and/or are a citizen.
We store information about players and visitors to our Services on servers located in the United States and other countries outside the EU. Personal information collected within the EU may be transferred to and stored outside the EU. The data we hold may also be processed by employees located outside the EU who work for us or one of our affiliates or suppliers. These employees may be involved in, among other things, (i) processing transactions and your payment details and (ii) providing support services. When we transfer your personal information internationally, we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner described here. Please note that laws vary from jurisdiction to jurisdiction and therefore the data protection laws applicable to the places to which your information is transferred or stored, used or processed may be different from the data protection laws applicable to the place where you are located.
To the extent that we are considered to be transferring personal data outside the EU, we rely separately, alternatively and independently on the following legal bases to transfer your data:
Model clauses
The European Commission has adopted standard contractual clauses (also known as model clauses) that provide safeguards for personal information transferred outside of Europe. We often use these model clauses when transferring personal information outside of Europe.
Necessary for the performance of the contract between you and us
We provide optional services and you can choose whether or not to use the services. However, if you choose to use the Services, you must agree to our Terms and Conditions, which set out the contract between us and the users of our Services. Because we operate in countries around the world (including the United States) and use technical infrastructure in the United States to provide the Services to you, the contract between us requires us to transfer your personal information to the United States and other countries as necessary to provide the Services.
Privacy Shield
Old Vegas Classic Slots abides by the EU-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Old Vegas Classic Slots has certified to the Department of Commerce that it abides by the Privacy Shield Principles. In the event of any inconsistency between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
10. Liability of Old Vegas Classic Slots
- Old Vegas Classic Slots may be liable for onward transfers to third parties of personal data received under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield.
- Old Vegas Classic Slots shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless Old Vegas Classic Slots proves that it is not responsible for the event giving rise to the damage.
- In the context of an onward transfer, Old Vegas Classic Slots is responsible for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Old Vegas Classic Slots will remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organisation proves that it is not responsible for the event giving rise to the damage.
11. Children
The Services are not directed to children under the age of 18. We do not knowingly collect information from anyone under the age of 18. If we discover at the time of collection that a user is under that age, we will not use or maintain their personal information.
12. Updates to our privacy policy
This policy may be updated periodically without prior notice to you, and any changes will be effective immediately upon posting of the revised policy on the Services. However, we will use your Personal Information in a manner consistent with the Policy in effect at the time the information was collected, unless you consent to its use in accordance with a new or different version of the Policy. We will always indicate at the top of this Policy when it was last updated.