SI Sportsbook Privacy Policy

Last modified: August 3rd, 2021

Introduction

VHL Colorado, LLC (“Company”, “we”, “our” or “us”) offers online gambling services through the website sisportsbook.com, its subdomains and its related features ("Website") and the SI Sportsbook mobile application ("App", collectively the “Services”).

We are dedicated to protecting your privacy rights and making our practices regarding your data more transparent and fair. This Privacy Policy (“Policy”) describes how we collect, store, use and share your personal data, and it applies whenever you visit, use or access our Services.

Specifically, it describes our policy regarding –

What types of data we collect?
Tracking Technologies
Why we process your Personal Data?
With whom we share your Personal Data?
Marketing
Your rights
Transfer of data
How we protect your data?
Minors
Retention
Updates to this Policy
Data protection officer
Further information

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy at any time.

You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services.

This Policy is integrated into and forms part of the Company's Terms of Use, which are currently available here.

What types of data we collect?
We collect two types of data from you: Personal Data ("Personal Data") and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (e.g. email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out the typed of data we collect and how and when we collect those types of data from you.
1. Account information. When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, gender, birth date, Social Security Number or other personal identifier (e.g. passport number), age, physical address, phone number and occupation. In addition, we may collect certain information as required under various gambling regulations, as well as Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements, such as your source of funds.
2. Gaming information. We automatically record different information related to your account and use of our Services, including with respect to your transactions, deposits, balances, bets, withdraws, bonuses and winnings. We also collect information regarding potential gambling problems or addictions, based on your patterns of gambling across our Services, in order to ensure a responsible gaming environment and as required by law.
3. Payment information. In order for you to enjoy all of the functions of the Services (e.g. place bets, perform purchases, play in tournaments, etc.), payment information will be collected from you, such as your currency, credit card number, payment method and bank account details.
4. Usage information. When you use our Services, we collect technical information about your interaction with our Services and your device. Such information may include geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) as well as other information which relates to your activity in the Services.
5. Communication information. When you send us an email or contact us in any other way, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.
Tracking Technologies
When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Service's performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.
1. What types of Tracking Technologies do we use?
  When you use or access our Services, we use the following categories of Tracking Technologies:
  1. Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed on your computer or device when you access or take certain action in our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
  2. Tracking and Advertising Tracking Technologies – these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which the Company does not control;
  3. Functionality Tracking Technologies – these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
  4. Performance Tracking Technologies – these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
2. How and by whom Tracking Technologies are stored on your device?
  We store Tracking Technologies on your device when you visit or access our Services (for example, when you are visiting our Website) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
  There are various ways in which you can manage and control your Tracking Technologies settings. You can manage your Tracking Technology preferences by changing your browser settings to send a “Do-Not-Track” signal; in such case, your browser will send us a special signal to stop tracking your activity. You may also install third party browser extensions, to block third party tracking cookies on our Website.
  To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:
  You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

Why we process your Personal Data?
This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.

Purpose	Legal basis
Provision of our Services; support. We use your Personal Data, such as your name and email address, for consumer services purposes. This includes, for example, managing your account and responding to your inquiries.	The legal bases for processing this data are the performance of our contractual obligation towards you; your consent (for example, when you provide Personal Data); compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.
Improve our Services. We collect and analyze information about you and your usage of our Services to improve the usability and effectiveness of our Services.	The legal bases for processing this data are our legitimate interests, in this case – providing and improving our Services.
Marketing, advertising and analytics. We use your Personal Data and Tracking Technologies in order to provide you with personalized advertisements when you visit our Services, to market our Services and to gather aggregate usage information.	The legal basis for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests and to promote our Services.
Compliance with applicable laws.	We may be required to collect, retain, or share your Personal Data, under applicable laws.

With whom we share your Personal Data?
We may share your Personal Data as described below:
1. Affiliated companies: we may share Personal Data internally within our family of companies, for the purposes described in this Policy.
2. Service providers: we share your information with our service providers for the purpose of providing the Services.
3. Third party advertisers: we may partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. Our third party advertisers may use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you with advertising based upon your browsing activities and interests.
4. Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
5. Auditors and advisers: we may share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards.
6. Mergers and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via the contact details you provided and/or prominent notice on our Services.
Marketing
Company may, on its own or through third party subcontractors, use your Personal Data, such as your name, home address, email address, telephone number etc. for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other affiliated company; (ii) white label brands; or (iii) Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Personal Data with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. We and our Marketing Affiliates may use this Personal Data for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to support-co@sisportsbook.com. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Your rights
This section addresses the specific rights you may have concerning your Personal Data.
You may request to:
1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Request erasure of your Personal Data.
5. Object to the processing of Personal Data by us.
6. Request to restrict processing of your Personal Data by us.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions, requests or complaints through our contact details below.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the competent supervisory authority.
Tansfer of data
We may transfer your Personal Data to third parties, as set out in this Policy. Such third parties may reside in various jurisdictions around the world. In such circumstances and where required by law, we have put in place contractual measures to ensure that the recipients of your Personal Data provide appropriate safeguards for your data (for example, by training its staff and implementing effective technological and organizational security measures) and are only using it for the purposes of performing their services, or otherwise for those purposes for which we have disclosed your information to them.
How we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.
Minors
We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
Retention
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
Data protection officer
The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following email address: support-co@sisportsbook.com.
Further information
If you have any further questions regarding the data collects, or how we use it, please contact us by:
email at: support-co@sisportsbook.com.

By mail:
Attn: Data Protection Officer
VHL Colorado LLC 400 Plaza Drive, Secaucus, New Jersey 07094.