Privacy Policy

Betmingo Privacy Policy

Last Modified: January 1, 2019

Xennial Corporation and our subsidiaries and affiliates (“Betmingo”) provides a mobile application that will help you search for current betting minimums and rules for popular casino table games in Las Vegas.  We care about protecting the personal information of our visitors who use our application, products or services (collectively, our “Users”). This privacy policy (“Privacy Policy”) provides details about how your personal information is collected, shared and used by us.  If you have any questions about this Privacy Policy or the practices described herein, you may contact us at privacy@betmingo.com.

The purpose of this Privacy Policy is to inform you what personally identifiable information or personal information we may collect from you when you use our application or visit our website, how we use such information, and the choices you have regarding our use of, and your ability to review and correct, the information.

For purposes of this Privacy Policy, the terms “we,” “us” and “our” refer to Betmingo. “You” or “your” refers to you, as a user of our services or visitor to our website, as applicable and to people that you contact through our Services (or that we contact on your behalf), or a person who you might choose to contact (or that we contact on your behalf) at some point in the future through the use of our Services. Capitalized terms not defined in this Privacy Policy have the meanings set forth in the Terms of Service.  This Privacy Policy is effective as of the date last modified, as listed in above.

This Privacy Policy covers personal information, including any information we collect, use and share from you, as described further below. This Privacy Policy applies to our application, our products and services (collectively, the “Services”). This Privacy Policy does not cover how our Users may use or share data that they collect using our Services. When you use our Services, your personal information may be collected, used, and shared consistent with the provisions of this Privacy Policy.

INFORMATION WE RECEIVE

In the course of your use of the Services, we obtain the following information about you as described below. We may need to collect this information to provide you with services or information you request, or to facilitate commercial engagements with you. If you do not provide such information, we may not be able to provide services or information to you, or enter commercial engagements with you.  We will only collect information about you that is necessary for one or more of our legitimate business purposes, or is required by law.

Signing Up for Services; User Information

  • Information you provide prior to any registration process, such as your email when you provide it to us;
  • Information that you provide during any registration process (such as your name and email address), including in connection with a co-branded offer, when you email us (for support or otherwise) or when you use our Services.

Use of Services, Application Visits and Support

  • Data relating to your online activity on our application with respect to our Services, including the following:
  • IP address (on an anonymized basis)
  • browser type and version
  • geographic location
  • pages you view on our application
  • how you accessed our Services and any links you click on to leave our Services
  • when you update your information, communicate with us, or order new Services
  • metadata about your use of our Services and the communication that you send in-app
  • your interactions with any videos we offer
  • issues you encounter requiring our support or assistance
  • any device or other method of communication you use to interact with our Services
  • We use various technologies to collect and store information when you use our Services, and this may include sending one or more cookies or anonymous identifiers to your device. We may store the data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.

Other Sources

  • Information that is publicly available; and
  • Information you consent to us receiving from third parties.

HOW WE USE YOUR INFORMATION

We will never sell your personally identifiable private information to others. We have a legitimate interest in running a successful and efficient business and in providing you with our Services and useful content, and we use the information you provide, both on its own and combined with any other information we collect about you, for the following purposes:

  • To provide the requested Services to you;
  • To provide you with useful content;
  • To ensure the proper functioning of our Services
  • To offer and improve our Services;
  • To provide you with requested information or technical support;
  • To facilitate your movement through our application or your use of our Services;
  • To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);\
  • To diagnose problems with our servers or our Services;
  • In connection with our security and compliance programs;
  • To administer our application;
  • To communicate with you;
  • To target prospective customers with our Services (such targeting is only performed with your permission where your consent is required by applicable law);
  • To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
  • As otherwise described in this Privacy Policy.

We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or accessed, our application or used our Services.

We do not collect payment information, including but not limited to credit card data.  You will be directed to a third-party site to process any payments you make to Betmingo.

We do not use your personal data for the purposes of automated decision-making or profiling.  If we do so in the future, we will inform you of any such processing and provide you with an opportunity to object.

SHARING OF INFORMATION

We will only share certain personal information as further described below.

Sharing with Third Party Service Providers and Vendors

Occasionally, we enter into contracts with carefully selected third parties so that they can assist us in servicing you (for example, providing you with customer service, fraud detection and deterrence or access to advertising assets and providing us with information technology and storage services) or to assist us in our own marketing and advertising activities (including providing us with analytic information and search engine optimization services). Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

We also share non-personal information with certain third parties, including the media, industry observers, marketing and advertising partners, vendors, customers, potential customers or partners. For example, we disclose mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or accessed, our application or used our Services.

Corporate Reorganizations

If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our application of any such transfer and any choices you may have regarding your information.

Authorized Users

All users authorized by you to have access to your account can view personal information stored in the account.

Legal Process

Lastly, if legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, law enforcement authorities and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be:

  • violating our Terms of Service;
  • causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
  • violating federal, state, local, or other applicable law.

This disclosure may include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.

SECURITY

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through our Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

CHOICE/OPT-OUT

Email

You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at optout@betmingo.com. Some communications from us are considered transactional or service communications (for example, important account notifications), and your account for our Services is provided to you upon the condition that you receive these communications from us. You must cancel your account for our Services, as applicable, if you do not wish to receive any transactional or service communications. To cancel your account, please follow the instructions found in our Terms of Service. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.

Information from Third Parties

To manage the information we receive about you from a social networking site or other third parties (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this Privacy Policy and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Services.

Unauthorized Accounts

If an account or profile was created without your knowledge or authorization, please contact customer support to request removal of the account or profile.

RETENTION OF PERSONAL INFORMATION

We retain your personal information to provide our Services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than one month following the date on which you terminate your use of our Services, unless we are otherwise required by law or regulation to retain your personal information for a longer period of time.

YOUR RIGHTS

Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. While we are a US-based service and not generally subject to GDPR, we endeavor to materially follow the guidelines of GDPR.  We set out below an outline of those rights and how to exercise rights under GDPR. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request, and in such instances we will let you know if that is the case.

Access

You have the right to know whether we process personal information about you and, if we do, to access data we hold about you and certain information about how we use it and who we share it with.

Correction

You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you is inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

Erasure

You may request that we erase the personal information we hold about you in the following circumstances:

  • where you believe it is no longer necessary for us to hold the personal information;
  • we are processing it on the basis of your consent and you wish to withdraw your consent;
  • we are processing your data on the basis of our legitimate interest and you object to such processing;
  • you no longer wish us to use your data to send you marketing communications; or
  • you believe we are unlawfully processing your data.

Please provide as much detail as possible regarding your reasons for the request to assist us in determining whether you have a valid basis for erasure.  Please send your request to us by e-mail at rightsrequest@betmingo.com.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:

  • You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
  • We wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
  • We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
  • You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.

Objection

You have the right to object to our processing of data about you and we will consider your request. Please provide us with as much detail as possible regarding your reasons for the request so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process such data in relation to legal claims.

You also have the right, at any time, to object to our processing of data about you in order to send you marketing communications, including where we build profiles for such purposes and we will stop processing the data for that purpose.

Please send any objections to us by e-mail at rightsrequest@betmingo.com.

Withdrawal of Consent

Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by e-mailing us at rightsrequest@betmingo.com.

THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS

Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.

CHILDREN

Our Services are not directed to persons under 21. We do not knowingly collect personal information from persons under 21. If we become aware that a person under 21 has provided us with personal information, we will delete such information from our files.

DATA TRANSFER

In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in the United States. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

For transfers of personal information within our corporate family, such transfer will be under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.

For transfers of data to third parties, such transfers will either (i) be under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework.

COMPLAINTS

In the event that you wish to make a complaint about how we process your personal information, please contact us at privacy@betmingo.com.

NOTIFICATION OF CHANGES

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we decide to change this Privacy Policy in any material way, we will notify you here, by email, or by means of a notice on https://betmingo.com prior to the change becoming effective. In all cases, your continued use of our Services constitutes acceptance to any such changes.