VERSION 2.0 - Heuston Gaming Privacy Policy

Welcome to the Privacy Policy (the “Policy”) of Heuston Gaming Limited, and its related, affiliated or subsidiary companies (“Heuston Gaming”).  

The purpose of this Policy is to inform you the type of information we collect from you, how we collect, use and share such information when you provide it to us or when you visit and/or use Heuston Gaming’s website available at www.sweeptastic.com (the “Website”), as well as other related Heuston Gaming’s webpages, mobile applications and products or services accessible through the Website (individually or collectively, the “Services”). 

When we refer to “you/your/user(s)” in this Policy we mean any individual who interacts or uses our Services. By accessing the Services, you acknowledge that you understand this Policy and agree to be bound by the terms hereof, the Terms of Use, the Sweeps Rules for Sweeptastic and any other terms or policies we post on the Services, and consent to the collection, use, and sharing of information as described in this Policy. If there is anything you do not understand, please email any inquiry to [email protected]. If at any time you do not agree to this Policy, please do not use the Services or provide us with any information.  

Privacy Policy Changes. We reserve the right to change or update this Policy at any time by posting such changes or updates to the Website without further notice. Amendments to this Policy will be posted at this URL and will be effective when posted. You can tell if this Policy has changed by checking the last modified date that appears at the end of this Policy. Your continued use of the Services following the posting of any amendment, modification or change shall constitute your acknowledgement of the modified privacy policy and agreement to abide and be bound by that privacy policy. Therefore, it is important that you periodically check this page for changes made to this Policy.  

CATEGORIES OF INFORMATION WE COLLECT

We collect information in three ways. First, we collect information that you provide to us. Second, we collect certain information when you use our Website and/or Services. Third, we may collect information from public sources or from third parties who have obtained such information in compliance with applicable laws and have the legal authority to provide such information to us. 

Information You Provide to Us

Heuston Gaming collects information about you when you interact with our Services including information that you voluntarily provide when you use the Services. Information that we collect may depend on how you interact with Heuston Gaming and use the Services. A description of the types of information we may collect is described in detail below. 

• Account Information such as unique user ID, password, and user settings. 
• Contact Information such as email address, telephone number, shipping address and billing address
• Personal Identifiers such as first and last name, gender, address and date of birth.
• Marketing and Communications Information such as marketing campaign data, click-throughs, your game play history and preferences, marketing preferences, email, phone calls and text communications preferences. 
• Commercial Data such as purchase history, including, purchase amount, details about the products and/or services you have purchased through our Services, transaction records, bonuses attributed to you and availed of, participation in competitions and promotions, life-time value and/or other details of products and/or services you have acquired from us in the past. 
• Usage Data such as information about how you use our Services, such as statistics regarding the opening and clicking on emails, and other activities on the Services, including game play, player stats, referring/exit pages, responsible social gaming data, life-time value and clickstream data.
• Financial Information such as credit or debit card information, bank account information, payment details, or other payment information. 
• Biometric Information such as a faceprint (i.e. your face geometry). See Biometric Information Policy below for additional details.

We collect information directly from you when you provide it to us. This typically occurs when you: 

• sign up for our email list
• arrive on our Website via an affiliate or a marketing platform / social platform
• send us an email or other communication
• create an account with us for any of the Services
• make a purchase on our Services
• obtain free coins (either Lucky Coins or Sweeps Coins) associated with completing certain actions on our Services that do not include purchases
• add or update your account information
• participate in our promotions, surveys, and/or contests
• play our games offered via the Services
• purchase our products and/or services
• complete any survey, questionnaire or forms of information request that may appear on our Services
• send us an email or other communication that contains any Personal Information
• submit a Contact Us inquiry or contact our Customer Support team
• log into the Website or use the Services from one or more of your devices or otherwise interact with the Services
• complete an alternative method of entry (AMOE)

It is optional for you to engage in such activity, however, if you choose to do so, we may require that you provide us certain information. Depending upon the activity, some of the information we ask you to provide is required and some is voluntary. If you do not provide required information for a particular activity, you may not be permitted to engage in that activity.

Information We Collect When You Use the Services

Automated technologies or interactions. Certain information can be collected through automated means to help us personalize your Heuston Gaming’s experience as you navigate around the Website and/or use the Services, such as: 

• the internet protocol (IP) address of the device you use to connect to the internet (which may include information about your geographic location)
• internet service provider (ISP)
• the unique identifiers of your device 
• your browser characteristics 
• your device characteristics
• your operating system 
• your language preferences
• the websites you visited before coming to our Website or through which you were referred to our Website and/or Services 
• information on actions taken by you on our Website and/or Services
• dates and times of your visits to our Website and/or Services
• the pages you accessed on our Website and/or Services
• any transactions completed on our Services including but not limited to purchases, obtaining free Sweeps Coins or Lucky Coins and participating in promotions including Sweeptastic’s Loyalty Club
• when you change your preferences on our Services including but not limited to changing responsible social gaming preferences or contact preferences 

Cookies and Tracking Technologies. We and our service providers use cookies, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our Services with the purpose of delivering customized and personalized services.

Cookies. A cookie is a small text file that is saved on your web browser when you visit a website. Most web browsers automatically accept cookies. However, you can view and delete existing cookies through your browser. If you do not wish to have cookies on your system, you can set your browser to refuse them or to alert you when cookies are being sent. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Services unavailable or difficult to view or use. You may opt-out of receiving targeted advertisements from other companies that perform interest-based advertising services, including some that we may work by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/, the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/, or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/. When using the ad industry opt out tools described above, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third-parties. If you use any of the third-party opt-out tools listed above, we do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.

Pixel Tags (aka clear gifs). These are tiny graphics with a unique identifier, similar in function to cookies, which allow us to monitor the use of our Services, for example, to count users who have visited those pages and for other related website statistics. Pixel tags generally work in conjunction with cookies, registering when a particular device visits a particular page. You cannot decline pixel tags; however, if you turn off cookies the pixel tag will simply detect an anonymous visit. In addition, we use pixel tags in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you prefer not to be tracked through our emails, most email services will allow you to turn off pixels by disabling external images in settings.  

Google Analytics. Our Website uses Google Analytics. Google Analytics employs cookies that are stored on your browser in order to facilitate an analysis of your use of the Website. The information generated by these cookies, such as time, place and frequency of your visits to our Website, including your IP address, allows us to offer better user experiences, perform analytics, analyze traffic, personalize content and serve / offer ads that match your interest. For more information about how Google Analytics collects and uses information from our Website visit: www.google.com/policies/privacy/partners. To opt out of Google Analytics Features, please visit Google support page  or, alternatively, you may access the Google Analytics Opt Out Browser Add-on, currently located here.  You can also opt out of advertising cookies using the Google Ad Settings.  

Google Advertising. Our Website uses Google Advertising. Google Advertising employs cookies that are stored onto your browser in order to facilitate an analysis of marketing campaigns run in the Google platform. The information generated by these cookies, such as time, place and frequency of your visits to our Website, including your IP address, allows us to serve / offer more relevant content towards you that match your interest. To opt out of Google Advertising Features, please visit Google support page or, alternatively, you may access the Google Opt Out Browser Add-on, currently located here. You can also opt out of advertising cookies using the Google Ad Settings. 

Information We Obtain From Third Parties

We may obtain information about you from third parties in a number of ways:  

• We may obtain information from third parties for marketing and business purposes. If we obtain information from third parties for any of these purposes, we will require that any third parties from whom we may obtain such information represent to us that they have acquired the information in compliance with all applicable laws and have the right to provide us such information for our marketing purposes. 
• We may collect information from publicly available sources, including but not limited to, review sites, social media platforms etc. 

BIOMETRIC INFORMATION POLICY

Heuston Gaming uses third-party technology through its vendors to collect, store, and use biometric and other personal information, such as your faceprint, a selfie, and government issued identification. 

By using our Services, you consent to Heuston Gaming, our identity verification vendor, and each of our contracted service providers, collecting, storing, and using your biometric information for the purposes identified below.

Purpose for Collection of Biometric Information

Heuston Gaming and its vendors may use biometric information for the following purposes.

• To verify your identity

• To prevent fraud

• To improve products and services

• To comply with legal obligations  

Biometric information will be securely deleted no later than 3 years after your last interaction with our vendor.

HOW WE USE THE INFORMATION WE COLLECT  

Our primary purpose for collecting your information is to provide you with the services you request. We may also use your information for the following purposes: 

• to provide you with our Services and to operate our business, including to facilitate purchases of Lucky Coins packages, permit game play in freemium mode and entrance to sweepstakes, participation in promotional activity including the Loyalty Club and to permit the award of prizes or redemptions; 
• to provide you with required notices, updates about our products and services as well as other important information, including but not limited to your activity on our Services such as sending you confirmation of your purchases or prize redemptions and your game play activity; 
• to verify your identity and account information in connection with our Services you request; 
• to communicate with you and provide you with recommendations about products, services, updates, promotions, or other topics from us or our partners or third parties that we believe may be of interest to you either directly or via third party partners;
• to personalize, measure and improve our Services, online content and experiences to you;
• to administer your account, including, assist you with setting up and managing your account; 
• to resolve disputes and/or questions about our Services;
• to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, cooperate with law enforcement and regulatory authorities, investigations of banks or payment service providers or prosecute those responsible for such activities;
• for problem troubleshooting, data analysis, testing, system maintenance, support, reporting and to facilitate hosting data;
• for our own internal business purposes; 
• where you have asked us to do so, or consented to us doing so;
• where we need to do so in order to perform a contract we have entered into with you, including to enforce our Terms of Use, Sweepstakes Rules, the terms of this Policy, as well as any other policy applicable to the Services;
• where it is necessary to protect our legitimate interests (or those of a third party) including establishing, exercising and defending legal rights, disputes and claims;
• where we need to comply with a legal or regulatory obligation, including in publicly available winners lists; 
• to promote the results of a promotion, competition or win via the public disclosure of your username, use of your name, likeness, photograph, voice, opinions and/or hometown and state/province/territory for promotional purposes in any media, worldwide, without further payment, notice or consideration; and
• for purposes disclosed at the time you provide/we request your information or as otherwise set forth in this Policy.

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE YOUR INFORMATION 

We want you to understand when and with whom we may share information collected about you. We do not share your information with any third parties except as set forth herein.

Service Providers

We may use third-party service providers to perform certain business services and may disclose your information to such service providers as needed for them to perform these business services. Business services provided include, but are not limited to: 

• customer database management services;
• IT service providers;
• hosting services;
• marketing, promotional (including affiliate providers) and e-mails services;
• billing and accounting services;
• payment processing services; 
• direct marketing and data collection services;
• data storage services and data analysis and reporting services;
• customer and technical support services and the corresponding platform;
• account authentication and user verification services;
• fraud prevention services;
• quality assurance testing and back-office support services;
• gaming platform aggregators and gaming service providers; and
• other services designed to assist us in developing and running our Services and maximizing our business potential.