Website Privacy Policy

Protecting Your Privacy

Ligtip Limited (‘Ligtip’, the ‘Company’) strongly values the privacy of its clients and is committed to protect your Personal Data (i.e. information that identifies you) as though it were our own. The Company forms part of the Tonybet group of companies (the ‘Group’, ‘we’, ‘our’ or ‘us’). The Company provides online gambling services. We protect your Personal Data in accordance with all applicable law, including Ontario’s Freedom of Information and Protection of Privacy Act (‘FIPPA’), the federal Personal Information Protection and Electronic Documents Act (‘PIPEDA’), Canada’s Anti-Spam Legislation (‘CASL’) and other applicable laws (collectively the ‘Applicable Data Protection Legislation’).

This Website Privacy Policy (the ‘Policy’) describes our practices related to the processing of personal data through the website accessible on www.tonnybet.net (“the Website”) and related mobile applications, and is incorporated into and forms part of the Privacy Policy (‘T&Cs’) regulating the Website. In this regard, the company that’s responsible for your privacy — is Ligtip Limited, a company incorporated in the Republic of Malta, bearing registration code C-86844, and having its registered office at Valletta Buildings, Second Floor, Suite 7, South Street, Valletta VLT1103, Malta.

Our Services, as described in the T&Cs, are provided as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (http://www.igamingontario.ca/en). In the course of providing the services (i) Ligtip collects, uses and discloses Personal Data on behalf of and as agent to iGaming Ontario; (ii) Ligtip Ltd collects Personal Data in accordance with FIPPA and other Applicable Data Protection Legislation, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission, and the operating agreement entered into between Ligtip and iGaming Ontario.

If you have any questions about how we protect your privacy, get in touch here: dpo@tonnybet.net.

One of your rights under Applicable Data Protection Legislation is that you must be informed when your personal data - also known as Personal Dara - is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.

We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this Policy.

Information we collect

Most of the Personal Data which we collect about you is collected through our registration process or in any other manner where you interact with the Website or use any of related services.

Most of the personal data which we may collect about you through the Website, is given to us only if you choose to give it to us. Some personal data and customer lists can also be obtained from other service providers and third party suppliers in a strictly legal manner, and while in complete accordance with all applicable laws and regulations.

Such personal data may be requested from you when you fill in a form (e.g. fill in any other form with your questions and comments, or any other form or application downloaded through or from the Website). If you send us emails, then the personal data we process will depend on what you send us in the email.

The information we collect from you normally includes the following:

• External Data
  • Identifying Data, this is information that uniquely or semi-uniquely identifies you, including your name, username, unique identifiers, government issued identification, picture, etc.
  • Behavioral Data, this is information that describes your activity online, and includes website visit time, pages viewed, language preferences, etc/

 

• Financial Data
  • Account Data, this is information that relates to your financial account, and includes credit card number, etc.
  • Transactional Data, this is information about your spending or income, including information revealing source of wealth and source of funds.

 

• Social Data
  • Communication Data, this is information communicated from or to you, and includes customer support messages.
  • Public Life Data, this is information about an your public life, and includes information of political exposure, criminal activity, etc.

 

• Tracking Data
  • Device Data, this is information about the device that you makes use of in using our services, and includes an IP address, country, etc.
  • Contact Data, this is information that provides a mechanism for contacting you, and includes an email address, physical address, telephone number, etc.

 

How & Why we use your information

We use your information in a number of different ways, the main purpose for the collection, use and disclosure of the Personal Data we process is for complying with our obligations as an Operator within Ontario’s regulated iGaming market. What we do with the Personal Data depends on the information and the purpose for which we collected it.

The tables below set this out in detail, showing what we do, and why we do it.

External Data              

How we use your Identifying Data	Why?
To register you as a player and provide you with access to our services	We’ve got to do this to confirm your eligibility for registration, to perform our contract with you and to be able to comply with our obligations arising under relevant gaming legislation.
To send you service messages by e-mail or through our Website	We’ve got to do this to perform our contract with you or to respond to your queries.
To verify your identity and age whenever you use our Website, and therefore ensure fraud prevention and detection.	We’ve got to do this to perform our contract with you, to comply with our obligations arising under relevant responsible gambling legislation, and to prevent and detect fraud against either you or Us – unfortunate, but absolutely essential. In order to fulfil this purpose, Ligtip shares some of the information you provide at registration with third party identity verification service providers, including credit bureaus, who can access your credit reports. Supplementary personal data is also sourced from these third party identity verification service providers.
To send you information by email about our new products and services.	To keep you up to date. We only send this with your permission – and you can ask us to stop, at any time by opting out without any additional hurdle or cost. (You can read more about how we use your information for marketing below).
Knowing what you, and other customers, like.	To ensure we are giving you what you want and enhance your user experience.
How we use your Behavioural Data	Why?
Improve our Website and set default options for you (such as language preferences)	To give you the best possible user experience
Protect our website	To prevent and detect fraud against either you or us — and to meet our legal obligations about looking after your data

Financial Data

How we use your Account Data	Why?
To register you as a player and be able to offer you access to our services, including ability to deposit funds and withdraw winnings as well as process your transactions.	We’ve got to do this perform our contract with you and to be able to comply with our obligations arising under relevant gaming legislation.
How we use your Transactional Data	Why?
To register you as a player and provide you with access to our services	We’ve got to do this perform our contract with you and to be able to comply with our obligations arising under relevant anti-money laundering and responsible gambling legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (‘PCMLTFA’).
To verify your identity and age whenever you use our Website, and therefore ensure fraud prevention and detection.	We’ve got to do this to be able to comply with our obligations arising under relevant anti-money laundering, including the PCMLTFA, and responsible gambling legislation.

Social Data

How we use your Communication Data	Why?
Provide customer service and support	We’ve got to do this perform our contract with you and offer you high-quality support service.
Train our personnel	For our team to remain up to scratch so that you get the best possible customer service. We believe this would be in our legitimate interest, as well as our players’ legitimate interests.
How we use your Public Life Data	Why?
To register you as a player and be able to offer you access to our services	We’ve got to do this perform our contract with you and to be able to comply with our obligations arising under relevant anti-money laundering legislation, including the PCMLTFA.

Tracking Data

How we use your Device Data	Why?
To verify your identity whenever you use our Website, and therefore ensure fraud prevention and detection.	We’ve got to do this to perform our contract with you, to comply with our obligations arising under relevant responsible gambling legislation, including to confirm that the device you use to register is located within Ontario, as Ligtip’s Services as described herein are only available to persons residing in Ontario and who use the Services while physically located in Ontario, and to prevent and detect fraud against either you or Us – unfortunate, but absolutely essential.
Protect our Website	To prevent and detect fraud against either you or us — and to meet our legal obligations about looking after your data
Knowing what you, and other customers, like.	To ensure we are giving you what you want and enhance your user experience.
How we use your Contact Data	Why?
Provide customer service and support	We’ve got to do this perform our contract with you and offer you high-quality support service.

 

You don’t have to give us any of this personal data  but if you don’t, you may not be able to use our site or make use of all of the services we offer on the site, and we may be unable to provide an optimal customer experience.

We also anonymise and aggregate Personal Data (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site and app, and developing new products and services. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.

The Legal Basis for Processing

The majority of the processing of personal data undertaken in the provision of the Services, is based on your consent, granted by way of affirmative action at registration stage and at any subsequent stage wherein this Policy is updated. You will also have the opportunity to withdraw that consent should you change your mind, in whole or in part, subject to applicable laws, reasonable notice and other restrictions, by contacting our Data Protection Officer on dpo@tonnybet.net.

For some of the other uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent.

This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you, such as to process your order, provide customer-care and support services to you.

We reserve the right to carry out security reviews at our discretion for the purposes of verifying your Personal Data provided upon registration, verifying financial transactions and ensuring proper use of the services provided. This may be done to ensure that there are no violations of applicable laws or our Privacy Policy.

By continuing to use our Services, thereby accepting our T&Cs in their entirety, you are hereby informed that your Personal Data may be used to conduct such security reviews at our discretion, which may involve transferring your information outside of your country. Security reviews may include (but are not limited to) ordering credit reports and checking the information provided against available third-party databases.

Retention Periods

We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.

We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Privacy Policy.

As a guide:

• we will keep personal data while your account with us is active or until such time as you ask us to stop communications with you, unless we need to keep the data for longer;
• we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute;
• and, we may keep different types of personal data for different lengths of time if required by law, including retention periods arising under the PCMLTFA, the iGO Policies and Directives, amongst others;

The records are maintained in such a manner that they can be provided to FINTRAC within thirty (30) days of a request. You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us here dpo@tonyybet.com. 

Sharing your information

We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. It is not our business to do so – and we don’t want to lose your trust and confidence.

However, in order to achieve the purposes for the processing as set out above, Ligtip may share personal data within the Tonybet Group, and subject to the appropriate agreements to the following categories of third party recipients, for the processing of the personal data on its behalf:

• Software service providers & content providers engaged by Ligtip from time to time to offer its services;
• Payment services providers & banking providers in order to operate players’ payments, deposits and withdrawals;
• Third parties, with which Ligtip partners with, to offer contest entrants a prize, and those third parties may require personal data solely in order to deliver that prize to the rightful contest winners;
• Anti-fraud, risk and compliance providers, including credit bureaus, in order for Ligtip to fulfil its legal requirements;
• Other service providers that help Ligtip create a better user experience, including geo-location providers.

 

In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities. Additionally, if we have a reason to believe someone has committed or is intending to commit something dishonest and illegal, such as

• tampering with games,
• committing payment fraud (which includes using stolen cards),
• requesting payment reversals and cancelations,
• performing prohibited transactions (including money laundering),

We reserve the right to share this information and your personal data with other gaming websites, law enforcement authorities, credit card companies and other relevant regulatory agencies. Your personal data may also be passed on to appropriate institutions to carry out public research and prevent gaming addiction.

When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended. In such cases, the relationship with these third parties is adequately regulated by appropriate data processing contracts in accordance with law.

We may also provide third parties with aggregated but anonymised information and analytics about our players and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous, meaning that it cannot identify you.

Please be advised that since Ligtip is based in Malta, and we operate globally, it may be necessary for the provision of Services and to the extent required for the specific purpose, to transfer your Personal Data to countries outside Canada. As a result, the personal data we collected from you may be stored and processed in any country, based on where gaming services are provided by our affiliates, suppliers, partners or agents. In the cases where we might share personal data with entities that are outside of Canada, we will be sure to do so in a manner that complies with the requirements established under Applicable Data Protection Legislation, including through the implementation of adequate data transfer mechanisms.

Security of your Personal Data

Security of your personal data is very important to us. All Personal Data obtained from you is stored and encrypted in a database protected by password and regularly updated firewall software. Our Services rely on 128-bit encryption SSL Version 3. Once your data is received, Ligtip has the proper procedures and mechanisms in place to ensure its security, including encryption and information access controls.

Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

You may complete a registration process when you sign up to use parts of the websites. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone. Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.

Whenever you create a password, then to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.

Protection of Minors

Our services are not intended for and therefore, should not be used, by minors (those under the age of 19 or under the lawful age based on their jurisdiction). We do not allow individuals under the age of 19 to create accounts, make purchases or enter contests or promotions.

Any person signing up with us and using our services confirms, expressly or by using our services, that they are at least 19 or of lawful age based on their jurisdiction. In accordance with our Policy, security reviews are conducted to uncover any attempts by minors to use our services. Should we become aware of any attempts by minors to submit Personal Data and start using our services, we will take all necessary measures to remove such information from our records.

Your rights

You enjoy several rights relating to your Personal Data:

I. The right to be informed about how your Personal Data is being used;

We need to be clear with you about how we process your personal data. We do this through this Policy, which we will keep as up to date as possible.

II. The right to access the Personal Data we hold about you;

You can access the personal data we hold on you by contacting us dpo@tonnybet.net.  

To process your request, we may ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person.

We will carry out our best efforts to process your request within thirty (30) days or, if the request is particularly complex, within an additional thirty (30) days. We can provide you with a copy of your personal data in electronic format.

If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the relevant data protection authority – in Ontario, the Ontario  Privacy Commissioner (the ‘OPC’), whilst in Malta, this relevant data protection authority would be the Malta Information and Data Protection Commissioner (the ‘IDPC’).

III. The right to request the correction of inaccurate Personal Data we hold about you;

We appreciate feedback from you to ensure our records are accurate and up-to-date. Please be reminded that you are also responsible to keep your Personal Data accurate and up-to-date.

If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by sending an email to dpo@tonnybet.net.

IV. The right to request that we delete your data, or stop processing it or collecting it;

You can ask us to delete your personal data; however, this is not an absolute right.

In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.

When you ask us to delete your personal data, we assume that you do not want to hear from us again. To ensure that we do not contact you in the future, we will retain just enough of your personal data solely for suppression purposes.

Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.

V. The right to stop direct marketing messages;

We would normally communicate to you about products or services in which you have shown interest or which you are already buying from us – we understand that you would be interested in receiving this information as it is of use with the product or service. But rest assured, you can ask us to stop whenever you want by hitting the “UnSubscribe” button.

How to stop marketing messages from us

You can stop receiving marketing messages from us at any time through any of the following methods:

• By clicking on the ‘UnSubscribe link in any email we send you
• By opting-out in your account settings available on our sites or via our services;
• By contacting our Customer Support Team

Once you do this, we will update your account to ensure that you don’t receive further marketing messages. Please note that, it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.

If you ask us to stop marketing messages this will not stop service communications. This may be necessary of us to communicate to you as part of our services from our contract.

VI. The right to object to certain processing based on legitimate interest;

You have a right to object to our use of your Personal Data including where we use it for our legitimate interests or where we use your Personal Data to carry out profiling using automated means. You can do this by sending an email to dpo@tonnybet.net.

VII. The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;

 

VIII. The right to withdraw consent for other consent-based processing at any time;

Where the processing of personal data, you will also have the opportunity to withdraw that consent should you change your mind through inbuilt measures on our Website, including through changing your settings into the relevant section of your account, however if you have any questions or comments in this regard, please send an email to dpo@tonnybet.net.

IX. The right to request that we transfer or port elements of your data either to you or another service provider;

You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help.

If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.

Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide.

When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.

X. The right to complain to your data protection regulator

If you want to exercise your rights, have a complaint, or just have questions, please send an email to dpo@tonnybet.net.  

Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

If your complaints and concerns are not resolved to your satisfaction, you can complain to the relevant data protection authority – in Ontario, the Information &  Privacy Commissioner (the ‘IPC’), whilst in Malta, this relevant data protection authority would be the Malta Information and Data Protection Commissioner (the ‘IDPC’). You also have the opportunity to complain to the regulatory authority, iGaming Ontario. Further details can be found here. 

Links to Other Websites

This Website Privacy Policy does not cover the links within the Website linking to other websites which are not controlled by us. We are not responsible for the collection or use of your Personal Data from these third-party websites.

Please exercise caution when providing your Personal Data to any third parties and be informed that the use of this information will be governed by the applicable policies of those parties. Therefore, we encourage you to read the privacy statements on the other websites you visit.

How to contact us

We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.

If you have any questions about this Website Privacy Policy, or if you wish to make a complaint about how we have handled your Personal Data, please contact us at:

Ligtip Limited, Valletta Buildings, Second Floor, Suite 7, South Street, Valletta VLT1103, Malta

We have appointed a Data Protection Officer who may be contacted here: dpo@tonnybet.net  

We welcome your feedback and questions. If you wish to contact us, please send an email to dpo@tonnybet.net.  

Changes to how we protect your privacy

Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our Website Privacy Policy may be required from time to time.

We therefore encourage you to check our privacy policy on a frequent basis.