PRIVACY POLICY

PRIVACY POLICY

Last Updated: December 12, 2017

  1. GENERAL
    Game Play Network, Inc. (“b spot” or “We” or “we”) operates an advance deposit wagering service that it makes available to eligible consumers in certain authorized states by way of: (i) the web site located at https://www.bspot.com (the “Website”); (ii) the b spot mobile application (the “Mobile Application”); and (iii) b spot's proprietary application programming interface that integrates with certain trusted third party applications. As used herein, the term “Service” refers collectively to all means and methods by which a consumer may: (i) become an approved user of b spot's advance deposit wagering service; and/or (ii) utilize the advance deposit wagering service to place wagers and/or use other features and functionalities offered via the Service.
    This Privacy Policy applies to the Service and discloses what information we gather, how we use it, to whom we disclose personal information and other information you have provided, and how to correct or change personal information that you have provided to us. We urge you to read the complete Privacy Policy set forth below as well as our Terms of Use posted on the Service, which is available here

  2. WHAT INFORMATION DO WE COLLECT ABOUT YOU? 

    • Personal Information. We collect personally identifiable information, such as names, mailing and current physical addresses, e-mail addresses, age, social security number, driver's license information, and other demographic information from consumers who elect to provide this information to us in order to: (i) apply for an advance deposit wagering account via the Service; and/or (ii) receive promotional e-mails about the Service and our business. We also may collect additional personal information to verify a user's identity, age, state of residence, and geographic location. Further, we may collect credit card information, bank account information, and similar financial information from users of the Service when such users fund their wagering accounts that such users have set up via the Service. The foregoing categories of personally identifiable information are referred to collectively in this Privacy Policy as “Personal Information.” 

    • Non-Personal Information Collected Automatically. The Service may collect or receive automatically certain types of non-personal information (collectively “Non-Personal Information”) when you use the Service, including without limitation the following categories of Non-Personal Information: (i) Internet Protocol (IP) address; (ii) browser type; (iii) device type and operating system on which the user has accessed or used the Service; (iv) location services data associated with the device you have used to access or use the Service; (v) physical location data; (vi) information relating to the user's usage of the Service and mobile, social, or casual games in our mobile games network (such as games played, playing time, sessions data, and related activity data); (vii) functional and download data received by the Service from third party application stores (e.g., Apple's App Store); and (viii) information relating to your referral or redirection to the Service, including information pertaining to the originating parties (e.g., third party game developers, advertising platforms, etc.) and your use of the originating party's platform, service, or game at the time you were referred or redirected to the Service. The Service's automatic collection of the foregoing categories of Non-Personal Information helps us to enhance and upgrade our products and services and to tailor our products and services to better serve our customers. 

  3. THIRD PARTY COLLECTION AND SHARING OF INFORMATION 

    • Third Party Integrated Service Providers. The Service contains certain features and functionalities that interact with certain third parties and/or integrate third party application programming interfaces in furtherance of the Service and/or the promotion of the Service. These third parties include, but are not limited to: (i) smart phone operating system providers and device providers; (ii) mobile analytics providers; (iii) advertising platform providers and advertising networks; (iv) regulatory, compliance, and telecommunications vendors; (v) game developers in b spot's games network; (vi) totalizator services; and (vii) payment services, payment processors, and payment gateways (collectively “Third Party Integrated Service Providers”). b spot's Third Party Integrated Service Providers may collect various forms of Non-Personal Information from b spot's account holders and share such Non-Personal Information with b spot in connection with the Service. 

    • In the event that you provide personal information to any third party via our Service or any offer made available to you by b spot, you understand that we are not responsible for such third parties' use or misuse of your personal information. You should review the privacy and information sharing practices of such third parties. We may offer links to third party sites so that you can conveniently visit our vendors or locate other content likely to be of interest. We are not responsible for the content, practices, or policies of sites operated by third parties and urge you to inquire about them before providing any personally identifiable information. 

  4. WHAT DO WE DO WITH COLLECTED INFORMATION? 

    • Personal Information. We use the Personal Information you provide to us in the following ways: (i) to verify your age, identity, state of residence, and geographic location in connection with your interest in setting up a wagering account with GPN; (ii) to administer your wagering account with GPN; (iii) to facilitate deposits into and withdrawals from your wagering account; (iv) to communicate with you about your wagering account and/or other GPN products and services; (v) to facilitate your use and enjoyment of mobile, social, or casual games in our games network; and (vi) to comply with GPN's regulatory licenses and other legal requirements. 

    • Non-Personal Information. We may use Non-Personal Information to: (i) enhance and upgrade our products and services and to tailor our products and services to better serve our customers; (ii) troubleshoot problems relating to the Service and/or a consumer's interaction with or use of the Service; (iii) market and advertise our Service and/or games in our games network; (iv) take advantage of certain advertising solutions made available by advertising platforms with whom we have a commercial relationship; and/or (v) undertake certain regulatory and compliance obligations (e.g., we use location services data to determine your geographic location at the time you access the Service and/or any game in our games network).
      In connection with the foregoing uses of Non-Personal Information, we may disclose Non-Personal Information to: (i) Third Party Integrated Service Providers and other third party vendors who will provide services to us; (ii) third party advertising platforms and advertising affiliates; and/or (iii) game developers in b spot's games network. 

  5. HOW DO WE SHARE PERSONAL INFORMATION?
    We share your Personal Information only as described below. 

    • Sharing Within the GPN Corporate Family. We may share your Personal Information with any parent company, subsidiary, or affiliate in the GPN corporate family. All entities within the GPN corporate structure may have access to your Personal Information as well as Non-Personal Information. 

    • Service Providers. We may engage third parties to perform services in connection with the Service. We may share your Personal Information with such third party vendors to enable such vendors to render services to us. Such third party vendors may include (but are not limited to) the following functions or services: (i) age verification; (ii) identity verification; (iii) state of residence and geographic location determination or verification; (iv) financial credit check and assessment; (v) customer service support and call center operation; and (vi) legal compliance and reporting. The third party vendors with whom we share Personal Information will not be permitted to disclose or use such Personal Information except as directed by us in connection with the services provided to b spot. 

    • Required Disclosures of Information. We reserve the right to use or disclose any information (including Personal Information) without notice or consent to: (i) comply with any court order, regulatory order or requirement, lawfully propounded discovery request, and/or other compulsory legal process; (ii) conduct investigations of consumer complaints or possible breaches of law; (iii) protect the integrity of our Service and assure adherence to our Terms of Use; (iv) protect the safety of our users or others; (v) payment processors, collection agencies, and other third parties in the payment industry in connection with payment disputes, insufficient funds situations, chargeback disputes, and similar disputes with account holders; and (vi) comply with a request from an account holder. 

    • Tax Reporting. We reserve the right to disclose Personal Information to the Internal Revenue Service and other taxing authorities to comply with our legal obligations under applicable federal, state, and local tax laws and regulations. 

    • Changes in Corporate Structure. In developing our business, we might sell certain assets, or the company, or parts of it may be sold, merged or otherwise transferred. In such transactions, user information, whether personally identifiable or otherwise, may be one of the transferred assets. 

  6. HOW CAN YOU CONTROL YOUR PERSONAL INFORMATION?
    We believe that choice in how and when you are contacted is key to customer satisfaction, so we offer a few ways for you to update your contact information, change your preferences, or opt out of receiving future promotional communications. 

    • If you have an advance deposit wagering account with us, you may be able to log on and update or change your contact or account information. Check the account settings feature in the Service for further information. 

    • You may unsubscribe to any of our promotional e-mails by following the unsubscribe instructions in the body of any promotional e-mail message. 

    • You also may write to us directly if you wish to: (i) update or delete your contact information; (ii) ask that we not share your personal information with third parties; or (iii) request that we cease sending you promotional or other information via mail or e-mail. Such written requests should be sent to b spot, 10866 Wilshire Blvd., Suite 700, Los Angeles, CA 90024, Attention: General Counsel.
      If you request in writing to opt out of future promotional communications, we will retain your information in a “do not promote” file in our database, and you will receive no further promotional communications from us. If you have opted out of receiving future promotional e-mails from us, we will implement your opt-out request within 10 business days of receiving the opt-out request (b spot's promotional e-mail vendor processes unsubscribe requests). If you have opted out of receiving future promotional materials by regular mail, we will implement your opt-out request within a commercially reasonable time. However, your opting out of promotional communications from b spot will not impact b spot's continuing right to send transactional-related communications to you regarding your use of the Service. 

  7. HOW DO WE USE COOKIES AND WEB BEACONS?

    • Cookies. Your Web browser offers “cookies” which, if you allow their use, store small amounts of data on your computer when you visit a web site. Cookies do not contain any personally identifiable information about you and therefore cannot be used to identify you personally. Cookies assist us in tracking which of our features you like best, and also enable us to customize our content according to your preferences. You have the ability to accept or decline cookies by modifying your browser and the Site is viewable even if you disable the cookie function on your browser. However, if you disable cookies, some advanced and customized features or offerings on our Site will not be available to you. In addition to collecting cookies, b spot may distribute, sell, and/or transfer such cookies to third parties with whom b spot has a commercial relationship. If you do not wish your cookies to be used in this manner, you can modify your browser to disable the collection of cookies. 

    • Web Beacons. A number of technologies exist to assess consumer behavior both on-line and off-line. We may employ some of these technologies, including web beacons (see below), web analytics techniques, and other behavior marketing technologies, to assess consumer behavior and to understand how we can better serve our customers. Some of these technologies are provided to us via third party vendors. In the course of using these technologies, we automatically collect non-personal information from you, including but not limited to the following types of information: Internet protocol (IP) address used to connect your computer to the Internet; login, e-mail address; computer and connection information such as browser type and related browser data; content viewed; and purchase history, which may be aggregated with other information for analytic purposes. Some of our web pages and/or promotional e-mail messages may contain electronic images known as web beacons, which are also called single-pixel gifs. Web beacons are not used to access your personally identifiable information, but they are a technique we use to compile aggregated statistics about the usage of our web sites and to track the number of users who have opened and acted up our promotional e-mail messages. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. 

  8. SECURITY OF YOUR PERSONAL INFORMATION
    We use HTTPS technology to encrypt important information, such as your credit card data, in an effort to prevent unauthorized access during transmission of your Personal Information over the Internet. We incorporate standard industry practices suitable to the degree of sensitivity of the information involved to maintain the security of your Personal Information and to avoid its disclosure except as described in this Privacy Policy. Although we take measures to protect the security of your Personal Information, security during Internet transmissions or within any system cannot be assured. We limit access to personal data only to our employees or agents with a specific need to access or retrieve this information. We store data on multiple service systems, in controlled, secure environments. Remember, however, that we cannot guarantee the security of your Personal Information, and we are not responsible for the privacy or security practices of any third party. 

  9. YOUR CALIFORNIA PRIVACY RIGHTS

    • Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send us a letter at the address set forth below and please include your name, address, and email address. We will respond to you within thirty days of receiving such a request.
      Game Play Network, Inc.
      10866 Wilshire Blvd.
      Suite 700
      Los Angeles, CA 90024
      Attention: General Counsel

    • Do Not Track. The Service does not utilize technology to track your behavior after you leave the Site or to serve you with advertisements after you leave the Service and visit third party web sites. Therefore, the Service does not respond to Do Not Track Signals. Additionally, we do not allow third parties to deploy tracking technology on our Service that would enable such third parties either to: (i) track your behavior or otherwise collect personally identifiable information about you after you leave the Site; or (ii) serve you with advertisements after you leave the Service and visit third party web sites. 

  10. GENERAL TERMS

    • By using our Service and providing us with your Personal Information, you agree to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you should not use or access the Service. We will occasionally update this Privacy Policy as necessary to protect our users and to comply with a changing environment. We recommend that you check the posted Privacy Policy when you visit the Service to be sure you are aware of and understand our current policy. Your continued use of the Service means you accept the updated Privacy Policy. 

    • Visitors and Subscribers Outside the United States. All matters relating to the Service are governed by the laws of the State of Oregon in the United States. Persons visiting the Service from outside the United States will not be permitted to sign up to use the Service. 

    • Children's Privacy. The Service contains age verification functionality that prohibits minors from accessing or using the Service. We do not collect any Personal Information from children under the age of eighteen (18). 

    • Contact Information. If you have any questions about this Privacy Policy or our privacy practices or wish to opt out of receiving future communications from us, please contact us by mail at:
      Game Play Network, Inc.
      10866 Wilshire Blvd.
      Suite 700
      Los Angeles, CA 90024
      Attention: General Counsel