Privacy Policy

1. General Information 

Golden Nebula Limited, with company registration number C 115271 of Spinola Park Level 4 South, Triq Mikielang Borg, Sangiljan, SPK 1000, Malta (“We”, “Us”, “Our”) is committed to protecting and respecting the privacy rights of the user (“You”, “Your”) of the Website www.casinodays.com/ab (“Website”), which includes any Personal Information that You may choose to provide Us on this Website. For the purposes herein, We are the Data Controller.  

This Privacy Notice (together with Our Terms and Conditions and Cookie policy) is meant to help You understand what data We collect, why We collect it, and what We do with it. When You share information with Us, We can make our services even better for You. For instance, We can show You more relevant search results and ads, help You connect with people or to make sharing with others quicker and easier. As You use our services, We want You to understand how We are using information and the ways in which You can protect Your privacy.  

Please read the following carefully to understand Our views and practices and where You can find controls to manage Your information and protect Your privacy and security.

Definitions. To help You understand this Privacy Policy, the following terms have the meanings set out below:

"Personal Information" means recorded information about an identifiable individual, such as Your name, contact details, and account and verification information.

"Processing" (and "Process") means any operation performed on Personal Information, including its collection, use, storage, retention, disclosure, de-identification, and destruction.

"AiGC" means the Alberta iGaming Corporation, which conducts and manages the open and regulated internet gaming market in Alberta.

"OA" means the operating agreement between Us and AiGC under which We provide the Website and Our services as agent of AiGC.

"Subcontractor" means a third party engaged by Us to Process Personal Information on Our behalf.

"Privacy Laws" means the Protection of Privacy Act (Alberta) ("POPA") and all other applicable laws governing the collection, use, disclosure, and retention of Personal Information.

We have designated a Privacy Officer who is responsible for overseeing and ensuring Our compliance with applicable Privacy Laws. You may contact Our Privacy Officer, and direct any questions about this Privacy Policy or the collection and other Processing of Your Personal Information, by emailing privacy@rhinoentertainmentgroup.com. We monitor this inbox on Business Days and will respond to privacy questions on a timely basis. 

2. How is Your data collected? 

2.1. Information We collect from You 

Our Website collects data to operate effectively and provide You with the best experiences with Our services. You provide some of this data directly, such as when You create a personal account. As is described in further detail in our Cookie Policy, We get some of it by recording how You interact with Our services by, for example, using technologies like cookies, and receiving error reports or usage data from software running on Your device. We also obtain data from third parties (including other companies). The data We collect depends on the services and features You use. 

In particular, We process personal details such as name and surname, email address, postal address, telephone number and date of birth collected pursuant to legal obligations we are subject to. Personal Information may include, but is not limited to, information that You provide when You register to use Our Website, enter any competition or promotion, complete surveys, communicate with our Customer Support team and/or when You report a problem with Our Websites. The information You provide Us may include Your name, address, e-mail address and phone number, personal description, and photograph. In addition, when You interact with the Websites, Our servers keep an activity log unique to You that collects certain administrative and traffic information including, but not limited to: source IP address, time of access, date of access, device and browser used to access the Website, Your activity on the Website, games played, session times, financial transactions, play limits set, language and other account preferences, and software crash reports. This information is essential for the provision and quality of the services provided by the Website. We do not collect Personal Information about You on the Website without Your knowledge. 

We are, on the basis of the applicable laws and license conditions, legally obliged to monitor Our players in order to identify people who may be experiencing, or at risk of developing, problems with their gambling, and interact with them to offer help or support. To this end, and to fulfil this obligation, by using historic data describing behaviour of players, in particular certain responsible gambling data, transaction and usage data, and other generic communication data (in particular, specific sentiments used in messages or chats) We have established rules regarding who is likely to suffer from gambling addiction and then take relevant action. 

We are also legally obliged to monitor Our players in order to identify potentially suspicious activities regarding AML/CFT. Based on data describing the behaviour of players, in particular transaction and usage data, the algorithm suggests a risk profile. Any decisions on the basis of the prediction are not taken automatically and require human intervention. 

The collection, storage, use and disclosure of Your personal information, is undertaken pursuant to, and in accordance with Section 4 of the Protection of Privacy Act (Alberta) ("POPA"), the iGaming Alberta Act, the Gaming, Liquor and Cannabis Act (Alberta), and the operating agreement between Us and AiGC (the "OA").

In order for the Company to provide gaming services to you, certain employees of the organization may require limited access to your personal information. This access is strictly role-based and granted only where necessary to perform their duties. The categories of employees includes: Customer support and tech teams.

Customer support team: To verify your identity, assist with transactions and resolve account- related inquiries.

Tech team: To provide technical solutions and assist with any errors and issues You might have with our Website.

We operate and make our services available via the Website as part of Our participation in the open and regulated internet gaming (iGaming) market in Alberta, which is conducted and managed by the Alberta iGaming Corporation ("AiGC"). We collect, use, and disclose Your Personal Information on behalf of, and as agent to, AiGC.  

2.2. Registration and Account Activation 

Upon registering an account with Us, We will collect certain identity, demographic, and contact information from You. This information will be used to administer Your account throughout Your use of Our products and services, to confirm Your eligibility for registration, and for anti-fraud and legal compliance purposes.

Notice at the time of collection: Personal information is collected through the site by Us under the authority of Sections 4(a) and (c) of the Protection of Privacy Act (Alberta), the Gaming, Liquor and Cannabis Act (Alberta), and the iGaming Alberta Act, and the operating agreement entered into between Us and the Alberta iGaming Corporation. Your personal information will be used or disclosed for the administration of Our iGaming site, and as otherwise described in this Privacy Policy. Automated systems may be used by Us to generate content, and to make decisions, recommendations or predictions about You. You may direct any questions about the collection and other processing of Your personal information to Our Privacy Officer at privacy@rhinoentertainmentgroup.com.   

Prior to activating Your account, We will seek to verify Your identity. To do so, We may share some of the information You provide at registration with reputable third-party identity verification service(s). In the event that Your identity cannot be verified with the information You provided at registration, We may require that You submit additional information or proof of identity prior to the completion of registration and the activation of Your account. Access to any such additional information will be strictly controlled and only those of our personnel who require access to the same to complete the identity verification process will be granted access. The information will be retained in a manner consistent with this Privacy Policy and Our internal retention and information security procedures. 

2.3. Children’s Privacy

Our products and services are not intended for, or directed at, individuals under the age of 18 ("Minors"). We do not knowingly collect Personal Information from minors. As part of Our registration and account activation process, We verify each player’s age and identity using reputable third-party identity verification services, and We may request additional proof of age before an account is activated or at any time during the account lifecycle. Accounts that cannot be age-verified, or that We have reason to believe belong to a minor, will be suspended and any associated Personal Information handled in accordance with Our retention obligations. If a parent or guardian becomes aware that their Minor child has provided Personal Information to Us, or if You otherwise believe that a person under the age of 18 has accessed Our Website or provided Personal Information to Us, please contact Our Privacy Officer at privacy@rhinoentertainmentgroup.com so that We may promptly investigate, delete such Personal Information, and take appropriate action.

3. How We Process Your Information      

When You create an account, You are giving Us Your Consent to collect and process Your personal information as explained in this Privacy Notice.   

We use the information that we hold about You, including Personal Information, to: 

• carry out Our obligations pursuant to the contract entered into between You and Us in accordance with the Terms and Conditions and to provide You with the information, products and services that You request from Us; 
• provide You with information about other services We offer that are similar to those that You have already used, enquired about and/or shown an interest in; 
• permit and assist the Website’s compliance with applicable law and regulatory obligations, including the performance of Our Operator Obligations under the OA, and to maintain the integrity of Our business; 
• notify You about changes to Our service; 
• to ensure that content from Our Websites is presented in the most effective manner for You and for Your device. 
• We may monitor, record, store and use any telephone, email or other communication with You in order to confirm any instructions given to us, for training purposes, for fraud and/or crime prevention and to improve the quality of our customer service. 

Personal Information that are automatically collected about You and/or received from third parties will be used to operate Our Websites as well as to ensure that content from Our Websites is presented in the most effective manner for You and Your device. To give a few examples this includes: 

• administration of Our Website and internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 
• keeping Our Website safe and secure; 
• combining Personal information from third parties with the information We hold to personalize and enhance Your experience on Our Websites.

4. Disclosure of Your Information 

For the purposes described above, Your personal information may be shared with any third party and any associated company within the Rhino Entertainment Group to which GNL belongs. We share Your personal information with Your consent or as necessary or provide any service You have requested or authorized. We also share personal information with vendors or agents working on Our behalf for the purposes described in this statement. For example, companies We contract with to provide customer service support or assist in protecting and securing Our systems and services may need access to personal information in order to provide those functions. In such cases, these companies must abide by Our data privacy and security requirements and are not allowed to use personal information they receive from Us for any other purpose. We may also disclose personal information as part of a corporate transaction such as a merger or sale of assets. 

Additionally, we may disclose Your Personal Information to any regulatory authority, law enforcement agencies or if so required by any legal obligations. 

5. Data Storage and Data Retention 

Personal Information We collect is retained and disposed of in accordance with applicable law, the OA, and Our retention and disposition policy and schedule, which complies with the Systems, Data, and Record Retention Policy. Personal Information used to make a decision that directly affects You, including a decision made using an automated system, is retained for at least one (1) year after it is used. After any applicable retention period for records containing Personal Information has elapsed, the records are securely destroyed in accordance with Our information security policies, unless and to the extent required to be retained by any ongoing legal and/or regulatory obligations. Throughout the retention period, We will make reasonable efforts to ensure personal information in Our custody, or under Our control, is kept accurate, complete, and up to date. You are responsible for keeping the Personal Information associated with Your account accurate and current, and for updating it through Your account settings or by contacting Us where Your details change. Please contact privacy@rhinoentertainmentgroup.com to advise Us of any updates or corrections You would like to make regarding Your Personal Information. 

We have implemented industry-standard physical, procedural, and technological security measures to protect any personal information in Our custody and under Our control. By submitting Your personal Information, You agree to Our storing and processing Your Personal Information. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy including, but not limited to, the entering into of written data processing agreements, as appropriate, with any third party which may be requested to process data on Our behalf. 

To help protect Your account and personal information, we require You to create a strong password when registering for our Services. Passwords must meet our internal security requirements designed to reduce unauthorized access. Users should avoid using easily guessable information and should not reuse passwords used for other accounts. You are responsible for maintaining the confidentiality of your login credentials.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect Your personal information, We cannot guarantee the security of Your data transmitted to the Website; any transmission is at Your own risk. Once We have received Your information, We will use strict procedures and security features to try to prevent unauthorised access. We will notify You and any applicable regulator of a suspected data security breach where We are legally required to do so. 

6. Your Rights 

You can view or edit Your personal information online for many of Our services. You can also make choices about Our collection and use of Your data. How You can access or control Your personal information will depend on which services You use.  

• Right of access 

You have the right to access Your personal information and to receive Your personal information which You have provided to Us in a structured, commonly used and machine-readable format. 

• Right to correction 

You have the right to require Us to correct any mistakes and/or changes to Your information in Our possession. 

• Right of erasure 

You have right for Your personal information to be deleted if there is no other legal basis that justify their retention. 

• Right to data portability 

You have the right to transmit Your personal information to a third party. 

• Right to object 

You have the right to object at any time to processing of Your personal information for direct marketing and to object to processing of Your personal information in a situation where such processing is based on tasks carried out in public interest or based on legitimate interest. 

• Right to restrict 

You have the right to ask for Your data not to be processed for the period of deciding about Your complaint in regard of challenging legality of processing of data, punctuality of data, if legitimate interest is outweighing Your rights and in situations where You want Your data to be kept for potential legal claims. 

• Right to lodge complaint  

You may adjust Your preferences in the “My Account” section of the Website and You may also exercise these rights at any time by contacting us at privacy@rhinoentertainmentgroup.com. Withdrawal of consent does not affect the lawfulness of the processing of data which was carried out by Us or on Our behalf, before consent was withdrawn.  

Our Website may, from time to time, contain links to and from the websites of Our partner networks, suppliers, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before You submit any personal information to these websites. 

When exercising your rights by contacting us, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

7. International transfers 

Your Personal Information may be Processed by Us or Our Subcontractors outside of Alberta, including by individuals operating outside of Alberta who work for Us or for one of Our suppliers, engaged in (among other things) the fulfilment of Your requests and the provision of support services. Where We Process Personal Information outside of Alberta, We will provide security coverage equivalent to that required for Personal Information located in Alberta, and We will ensure that any Subcontractors Processing Personal Information outside of Alberta are held to privacy and security standards equivalent to Our own.  

We will take all steps reasonably necessary to ensure that, at all times, Your data is treated and handled securely and in accordance with this Privacy Policy and all applicable laws and agreements including, but not limited to, the entering into of written data processing agreements, where appropriate, which oblige Our suppliers to comply, in all material respects, with the protections afforded to Your personal information by the applicable laws. 

8. Complaints and Enquiries 

You may address any complaints or enquiries that You may have regarding Our handling of Your information by following the below process: 

In the first instance, please submit Your complaint/enquiry via email to privacy@rhinoentertainmentgroup.com, providing as much detail as possible. Our Customer Support team will endeavour to respond to You within 7 days of receiving Your complaint/enquiry. 

In the event that You feel that Your complaint/enquiry has not been dealt with satisfactorily by Our Customer Support team, You may request that the matter be escalated to Our Privacy Officer, who will review Your case and endeavour to respond to You within 30 days, which period may be extended by two months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within 30 days of receipt of the request, together with the reasons for the delay. Please note that the Privacy Officer may elect not to respond directly to complaints/enquiries which have not first been submitted to Our Customer Support team. 

Should You not be satisfied with the response You receive from Our Privacy Officer, You may request a copy of Your case file and elect to escalate Your complaint/enquiry to the Alberta iGaming Corporation. This complaints process aligns with the Customer Care and Dispute Resolution Policy. Nothing in this process prevents You from making a complaint directly to the Office of the Information and Privacy Commissioner of Alberta ("OIPC AB"). 

9. Privacy breach 

The protection of Your personal information is of the utmost importance to Us, and We are committed in Our efforts to prevent and/or restrict third parties from being able to gain access to Your Personal Information and other data (“Privacy Breach”).  

No systems are entirely infallible and it is possible that Privacy Breaches may occur, in which case if we become aware of any breach, we will investigate, contain, remediate and initiate recovery measures in accordance with our security procedures. We are also committed to cooperating and working with the necessary regulatory bodies, and law enforcement agencies, to minimise the extent of any such Privacy Breach, as well as its potential impact on those affected. 

Should you become aware of, or suspect, a breach of Your, or any other person’s privacy, you should immediately report the same to Us by emailing privacy@rhinoentertainmentgroup.com.  

10. Changes 

We reserve the right to make changes and corrections to this Privacy Policy from time to time. Where We materially amend this Privacy Policy, We will require You to actively accept the amended Privacy Policy before You may continue to access the Website or Our services. Each version of this Privacy Policy is identified by its effective date. 

11. Contact  

This Privacy Policy and all related matters are governed solely by the laws of Alberta and the applicable federal laws of Canada.

Our Privacy Officer can be contacted by emailing privacy@rhinoentertainmentgroup.com. 

This Privacy Policy is presented to, and must be actively accepted by, every Player (for example, through the use of a tick-box) before the Player may access the Website or Our services, and We retain evidence of each Player's acceptance. This Privacy Policy is readily accessible at all times through the Website and any of Our applications.