PRIVACY POLICY

Scope of Privacy Policy

This Privacy Policy describes and governs the manner in which COMPASS SYSTEMS LIMITED (“Yay Casino”, “we”, “us”, “our”) collects, uses, shares, disclose and stores customer personal information through its website https://www.yaycasino.us (the “Yay Casino Website”, “Our Website”, “Website”) and any related domains, subdomains, related parties websites, webpages, and third party websites or applications. This Privacy Policy applies to the Yay Casino Website and all products and services offered through Our Website. Please read this Privacy Policy carefully before using Our Website.

This Privacy Policy explains how your personal information is collected, used and stored during and after your use of Our Website. We comply with all applicable privacy laws and regulations, including but not limited to the California Privacy Rights Act (“CPRA”), the Virginia Consumer Data Protection Act (“VCDPA”), and any other applicable privacy laws and privacy regulations.

1. Definitions

1. The following definitions apply to this Privacy Policy:

1. “Account” means your account with us, which you sign up for at www.yaycasino.us;
2. “Covered Information” means information which allows a specific person to be contacted either physically or online, including, without limitation, first and last name, address, email address, phone number, and an identifier which allows a specific person to be contacted either physically or online;
3. “Confidentiality Incident” means any access, use, loss or communication of a Participant’s personal information, including any information relating to a Participant which can directly or indirectly allow them to be identified, which is not authorized by law, or any loss or other breach of the protection of such information;
4. “Data Protection Officer” means a role within a company or organization whose responsibility is to ensure that the company or organization is correctly protecting individuals' personal data according to current legislation;
5. “Event Tagging” means tags that allow us to monitor certain events completed through our Website (e.g., purchases);
6. “Sweeps Coin” means the in-game currency as defined in the Yay Casino Sweepstakes Rules;
7. “Gold Coin” means the in-game currency used to play Games that cannot be redeemed for Prizes;
8. “Marketing Pixels” means pieces of code that allow us to gather information about anyone who visits our Website, including their engagement with our webpage;
9. “Mobile Device Identifiers” means the unique customer identifier on every mobile device which is used to distinguish a mobile device. This unique identifier can be used for the purposes of internet-based advertising;
10. “Participant” means a registered user of the Service who obtains Gold Coins or Sweeps Coins, participates in games using Gold Coins, and/or redeems Sweeps Coins;;
11. “Prize(s)” means the results of the redemption of Sweeps Coins which are eligible to be redeemed by a Participant;
12. “Service” means any of the services available through our Website or mobile applications;
13. “Website” means our website at https://www.yaycasino.us;

2. What We Collect

1. We collect information about you in a number of ways. For example, we collect directly identifiable information - information that you provide to us and it includes:

1. Your email address, physical mailing address, mobile phone number (and any other phone number(s) provided).
2. Personal information such as your first name, last name, age.
3. Account login details, including your unique username, unique password and any photos associated with your account.
4. Transaction information such as your mailing address, phone number, information collected at the time of payment and/or redemption, such as, financial institution information, crypto wallet and credit card information and bank account statements (if ever applicable).
5. Information sent as part of live chat, email, or any other method of customer support.
6. Information we obtain from a third-party (such as, Facebook, Google) regarding your connection to our services.
7. Your location information, including information provided by a device interacting with our platform.
8. Activity and device information about your use of our products or services, including which content you view/use, when and for how long you access our products or services, how often you use our services, how you heard about our services, the specific hardware model you are using, the device type you are using, other unique device identifiers, operating system, browser type and IP address; and
9. Any documentation which we request to verify that you are eligible to have an account and receive payouts.

2. We may also collect information which does not directly identify you, as well as information about groups of customers which does not directly identify you, including, but not limited to, your patterns of use of the Website or the zip code/postal code associated with your device.

3. Your Representations

1. By providing your information to us, you represent that any information you provide is true and accurate. You acknowledge that your contact information, including but not limited to, your phone number and email address, are true and accurate. Further, you admit that you are the subscriber to any telephone number that you provide to us.

4. How We Collect Information

1. Participant information is collected in a number of ways, including when a Participant accesses our Service, registers an Account, makes a purchase, answers a survey (including those sent from a related third-party), and in connection with any other service, feature or resource offered by us.
2. By providing your telephone number(s) to us, you agree to being contacted at the number provided to us. Ways in which you may be contacted include pre-recorded voice messages, autodialed calls, SMS messages and emails from or on behalf of us related to:

1. The Documentation;
2. Any purchases or redemptions related to your Account; and
3. Promotional matters from or on behalf of us, provided you have opted-in or provided your express consent for pre-recorded voice messages, autodialed calls, emails and SMS or text messages. 
4. We may communicate in the ways described above even though a phone number is registered on a state, or federal do not call list. We are not responsible for any charges incurred by Participants from their telephone provider(s) for texts or calls received from or on behalf of us.
5. You may opt-out of these messages by contacting us at [email protected] or by using the unsubscribe feature in the message.

3. We may also collect information from Participants through telephone, video or correspondence, including email, instant messaging, physical mail, SMS and/or social media platforms. Telephone and video calls with us may be recorded for the purposes of training, quality control and compliance. By partaking in any such call with us as described above, your express consent will be taken and you will be informed prior to your call being recorded.
4. We use a variety of technologies embedded in our Website or in our applications on third party sites and platforms including cookies, pixels, tags and application program interfaces (“API”). For example:

1. In order to enhance your user experience, we use industry standard identifiers, such as cookies or similar technologies. A cookie is a small text file saved locally on your computer or mobile device when you visit our Website. This small text file may include a unique identifier, making it possible to distinguish your device from another device.
2. Examples of similar identifying technologies that we may use are:

1. Marketing pixels;
2. Mobile device identifiers. We may, at times, share your Mobile device identifiers with advertisers; and
3. Event tagging.

5. Analytical tools may also be used to collect information, including when you visit our Website or use our applications or services on third party sites or platforms.

5. How We Use Your Information

1. We may use your information for the purposes set out in this Privacy Policy. Your information may also be accessed by other companies within our group of companies when acting on behalf of us as a data processor as outlined in this Privacy Policy.
2. We retain all customer information collected by means described in this Privacy Policy as long as required by this Privacy Policy or as long as is permitted by law. We may share your information collected with our group of companies or third-party companies providing a service to customers directly or indirectly through us. We may use and/or share your information with third parties, in accordance with applicable law, to offer the best possible experience for you or to offer additional services. Some reasons for which your information may be collected and used/shared are:

1.  To provide services as requested by you, including the establishment and maintenance of your Account and routine security checks to ensure the security of your information.
2.  To provide you with the best customer service experience possible. Information provided and/or collected from you will help us in responding to any customer service requests. Feedback provided by you may be used to improve our products and services.
3.  In the processing of payments, we may use information provided by you in order to comply with various due diligence requirements, including as related to anti-money laundering and to verify payment details. We do not share any payment information with third party payment processors except to the extent necessary in providing transactional services.
4.  Aggregated information may be used to best understand our Participants in order to deliver the most tailored user experience possible.
5.  To contact you about our services, we may contact you by email, live chat, telephone, SMS, physical mail or social media in order to manage promotions and competitions that you elect to enter.
6.  In sending you important notices regarding matters such as purchases you have made or changes to any of our policies.
7.  In complying with all our legal and/or regulatory obligations, we may use the information we collect to ensure compliance with the Documentation and our regulatory obligations.

6. Your Rights Over Your Information

1. By law, you have a number of rights concerning the information about you that we collect and store securely. Please contact our Data Protection Officer if you wish to exercise any of the rights outlined in this Section 7.
2. You have the right to access personal information about you that we securely store, the right to object to the processing of your personal information and the right to withdraw any consent given through this Privacy Policy.

7. How We Protect Your Information

Keeping your personal information secure is our top priority. Through the use of physical, electronic and operational protocols we are able to protect your personal information. We use industry-standard practices for data collection, data storage, and data processing to protect your information against unauthorized access, manipulation, disclosure or destruction. We regularly review our security protocols and make sure that they meet industry-standards. However, no data transmission or storage system is 100 percent secure from unauthorized access or use. If you have reason to believe that your personal information has been compromised while in our care, please immediately notify us at [email protected].  

8. How Long Do We Keep Your Information

1. We may retain your information as long as we require in order to fulfill the practices outlined in this Privacy Policy, in accordance with our commercial needs, or as permitted by law.
2. In the event that you or we close your Account, we may retain your Account information in order to resolve any further disputes or provide clarifications in regards to your Account or as long as permitted by law. If you request your Personal Information to be permanently deleted or erased, we will require your written authorization to do so. Notwithstanding the foregoing, we may be required by law to maintain some or all of your Personal Information for audit purposes.

9. Sharing Your Information

1. We may share your information within our group of companies or with a third party who will provide services to you for us. We may also share your information with other third parties in order to stay compliant with our legal obligations. We will only share the minimum amount of your information required to fulfil these purposes.
2. We reserve the right to use a Participant’s information to announce the winning of any Prize through use of our products or services, including username or your partial name, the amount of won Sweeps Coins, state, zip code, profile picture or any other Personal Information collected as described in this Privacy Policy for marketing purposes including on social media platforms, affiliated marketing channels and through physical media channels (radio, television, print media).
3. We may also share your personal information in connection with the sale, merger, acquisition (or similar transaction) of the company to a third party and/or the transfer of substantially all of the assets of the company to a third party.

10. Information for Specific Groups located in the United States

1. Our Services are restricted to individuals who have attained the age of majority in their jurisdictions. Accordingly, we will never knowingly collect or maintain information from minors. If you believe that a minor may have provided us with personal information and you would like for us to delete that information, please contact us at [email protected].

2. For Nevada Residents

1. Under Nevada law, Nevada residents who have made purchases related to the Services may opt out of the “sale” of “Covered Information” (as such terms are defined under Nevada law) for financial consideration to a person for that person to license or sell such information to additional persons. While we may share your information with third parties we believe can provide you with offers and promotions for goods and services of interest to you, we do not believe this sharing would qualify as a sale under Nevada law. Regardless, if you are a Nevada resident who has made purchases related to the Services, you may submit a request to record your preference to opt out by emailing the Data Protection Officer at [email protected].  We may take reasonable steps to verify your identity and that the request came from you.

3. For California Residents

1. As a California resident, you have the right to request that we disclose what personal information we collect from you, to delete that information, and, subject to certain restrictions, to opt out of the sale of your personal information.
2. You may exercise your California privacy rights by contacting the Data Protection Officer by opening a ticket on our customer support portal at [email protected]. We will verify your identity when you request to exercise your rights. Logging into your Account may be sufficient, however if we have reason to suspect that your Account has been compromised, or if you do not have an Account, we may request additional verification information from you.
3. You have the right to designate an agent to exercise your rights on your behalf. Your agent must verify authorization to make a request on your behalf by providing us with a signed written authorization or a copy of a power of attorney.
4. You have the right to request, up to two times in a 12 month period, that we disclose what categories of your personal information that we collect, use, and share, including the specific pieces of personal information we have collected from you and which information is shared with third parties for direct marketing purposes.
5. You have the right to request that we delete personal information that we collect from you. Some information may be exempt from such requests under California law.
6. You will not be denied access to the Services or provided with a modified version of the Services if you choose to exercise these rights.
7. We may sell information that directly identifies you such as your name, telephone number, mailing address or email address. You may opt out of the sale of your personal information. If you would like to opt-out, please contact the Data Protection Officer by opening a ticket on our customer support portal at [email protected].
8. If you are a California resident under the age of 19, you may view, correct, or delete information provided by you or publicly posted by you by sending us an email asking us to delete certain posted content. Please note that our products and services are restricted to individuals who have attained the age of majority in their jurisdictions. Accordingly, we will never knowingly collect or maintain information from minors.
9. You have the right to be informed as to how we respond to “Do Not Track” settings. We do not currently take actions to respond to “Do Not Track” settings and instead we adhere to the standards set out in this Privacy Policy.
10. California Collection Notice. We may share information described below with third parties for the following purposes: (i) with our group companies for the purposes described in this Privacy Policy; (ii) with vendors and partners we engage in order to provide you with the Services; (iii) if required to do so by applicable law or legal process; (iv) if necessary to exercise, establish, or defend our legal rights; (v) if necessary to protect the vital interests of any person; and (vi) in connection with the sale of our business. We may collect categories of information. The table below describes how we collect and use such categories of information:

We will maintain records of all Confidentiality Incidents in the form and for as long as required by applicable law.

11. Changes To This Privacy Policy

1. This Privacy Policy may be updated from time to time to reflect changes in the law   and changes to our customer data handling practices and internal policies. We will notify you of any material changes and, where required by law, we will obtain your consent. Notice for any material change (or changes) to this Privacy Policy may be made by posting of such change (or changes) to the Yay Casino Website or by other means in accordance with the applicable laws.
2. Any changes to the Privacy Policy will become effective when the updated Privacy Policy is posted on our Website.
3. Participants are responsible for staying up to date on the changes to our Privacy Policy posted on our Website. We recommend checking this page regularly for updates. We will post the “date updated” at the top of the Privacy Policy.
4. This Privacy Policy is effective as of the ‘date updated’ which appears at the top of this webpage, and supersedes and replaces any and all privacy policies previously in effect.

12. Contacting Us

1. If you have questions regarding this privacy policy, how we use or handle your personal information, please contact our privacy team at legal@yaycasino.us.  Alternatively, you may also contact our customer service department at [email protected].