TwinSpires Internet Gaming and Sports Betting
Last updated: June 7, 2021
(i) Any other web pages, mobile applications, mobile device specific applications, online features, services and/or programs, or third party social media sites other than the Website, as defined in 1.1 above.
(ii) Any information (including but not limited to e-mail lists, non user-specific information, and personally identifiable information) collected and/or owned by any entity other than (a) TwinSpires, or (b) those entities collecting on behalf of TwinSpires.
- WEBSITE OWNERSHIP AND OPERATION
3.2. Your use of the Website is also governed by the Website Terms and Conditions.
- WHAT INFORMATION WE COLLECT:
4.1 Personal Information (which you provide to us)
You may register or open an account on the Website if you are at least twenty-one (21) years old and are eligible to open an account.
We will collect some or all of the following "Personal Information" voluntarily provided by you to the Website:
- Full legal name
- Date of birth
- Phone number
- Email address
- Social Security Number or equivalent if you are foreign such as a passport or taxpayer identification number
- Bank and/or credit card account number
- Biographical information such as household data, preferences and demographic information
- Profile picture
- Social media account ID
- Loyalty program account number
- Driver's license number
- Security question responses
- Opt in status for SMS and telephonic marketing
TwinSpires does not give out your Personal Information to any third party for uses not described as normal business operations.
For training and security purposes, we may record or monitor calls as they relate to wagering communications, geographic location emails you send to us and chat logs with our Customer Support, among other things.
4.2 Other Information (which we collect about you)
TwinSpires and our service providers may collect Personal Information and the following other Personal Information about you when you interact with our online services:
- Your computer IP address, and browser history on our sites
- Your e-mail address
- Information volunteered by you, such as survey information and/or site registrations, user ID, and passwords
- Purchases made by you on the Website
- Your wagering activity (identified by your account number and name)
- If you choose to connect to the Website through a social network such as Facebook or Twitter, we may collect your profile information
- The physical location of the computer from which you are accessing the Website and the Services
4.3 You are under no obligation to provide personally identifiable information to us. However, certain personally identifiable information is essential for the provision and quality of the Services (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information.
- HOW WE MAY COLLECT PERSONAL INFORMATION:
5.1 We and our service providers may collect Personal Information in a variety of ways, including:
Through the Website and the Services: We may collect Personal Information through the Website and the Services, for example, when you create or log into your account or make a reservation or purchase.
Offline: We may collect Personal Information from you offline such as when you visit one of our casinos or contact customer service.
From Other Sources: We may receive Personal Information from other sources such as public databases or social media platforms, or from people with home you are friends or otherwise connected on social media platforms.
- HOW WE USE YOUR INFORMATION:
(a) To enable the features of the Website and fulfill the purpose for which you provided it to us, including, but not limited to verifying your identity, to fulfill your online financial and wagering activity or to build your Patron profile.
(b) To ensure that wagering activity on our sites meets various legal and regulatory requirements, such as confirming that you are physically located in the state of New Jersey when you wagering on the Website.
(c) To operate any competitions or promotions in which you may participate or to contact you regarding promotions and marketing offers that we believe may be of interest to you. Some of these activities have additional rules, terms and conditions, which could contain additional information about how we use and disclose your Personal Information. Read these rules carefully.
(d) To respond to your inquiries and fulfill your requests.
(e) To send administrative information to you, for example, information regarding the Website and the Services and changes to our terms, conditions, and policies, or information regarding your gaming activity.
(f) To complete and fulfill your transactions and provide you with related customer service.
(g) To personalize your experience with us by presenting products and offers tailored to you.
(h) For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying the Website and the Services, enhancing our marketing efforts, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
(i) We may publish some personally identifiable information for promotional purposes, prize or competition winners, including but not limited to winnings and winner’s username. For winnings greater than $100, the winner’s username, first name and initial letter of surname, gender, town, city or county as registered on his or her Patron account may be published.
(j) If you submit content and/or participate in the chat facility on the Website, your content and/or communications on the chat facility are not private or confidential, and may be viewed and used by others accessing the Website. Please do not submit any information to the chat facility that you do not want others to see.
(k) When you create a Patron profile, the information that you provide, including, but not limited to, a username and an image (such as a photograph), is not private or confidential, and may be viewed and used by others accessing the Website. We recommend that you choose a username and image that is original and makes no reference to your name and does not contain any personally identifiable information.
(l) When you accept a friend’s invitation to register as a Patron as part of the Refer a Friend program, information relating to your progress in meeting the wagering requirements related to the Refer a Friend program may be viewed by such friend. Please do not participate in the Refer a Friend program if you do not want such information to be seen by your friend.
(m) We may require you to verify your identity by entering a pin code on the Website that we provide to you by SMS (text message) or by email.
(o) As we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and governmental authorities; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates (including through surveillance); (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
- HOW PERSONAL INFORMATION MAY BE USED AND DISCLOSED:
7.1 Your Personal Information may be used and disclosed:
(a) To judicial or other government agencies in response to warrants, subpoenas or other governmental orders. You are hereby advised that in the event of a criminal investigation by state or federal authorities or regulatory inquiry, you specifically authorize us to disclose said data and information to law enforcement authorities and you release us from any and all liability related to such disclosures.
(b) To our affiliates for the purposes described in this policy.
(c) To third parties to permit them to send you marketing communications, consistent with your choices.
(d) With other third parties in order to assist with marketing or other normal business activities, such as website hosting, data analysis, payment processing, customer service, email delivery, auditing and other services.
(e) To third party sponsors of sweepstakes, contents, and similar promotions.
(f) To identify you to anyone to whom you send messages through the Website or the Services.
(g) By you, on message boards, chat, profile pages, blogs, and other services to which you are able to post information and materials (including, without limitation, our social media pages). Please note that information you post in a chat room, a message board, a forum, or another public posting area on our websites or social media can be viewed by anyone with internet access. Use extreme caution prior to disclosing your Personal Information, or any other information, in these areas. We are not responsible for a third party's use of information which you post in a public area.
(h) To your friends associated with your social media accounts, to other Website users and to the providers of your social media accounts, in connection with your social sharing activities. By connecting your Website or Services account(s) and your social media account(s), you authorize us to share information with your social media account provider(s), and you understand that the use of the information we share will be governed by the social media sites’ privacy policies. If you don’t want this information shared, do not connect your social media account(s) with your Website or Services account.
(i) To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock.
(j) As we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and governmental authorities; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
7.2 We reserve the right to transfer your personally identifiable information, as well as any other information, in connection with the sale or other disposition of all or part of the TwinSpires business and/or assets. We also cannot make any representations regarding the use or transfer of your personally identifiable information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. Furthermore, we cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties (including other users of the Website and the Services) that receive any of the information that is disclosed to us.
- OTHER INFORMATION
8.1 Other Information We May Collect:
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an individual, such as: browser and device information, app usage data, information collected through cookies, pixel tags, and other technologies, demographic information and other information provided by you and aggregated information.
8.2 How We May Collect Other Information:
Other information may be collected by us and our third party providers in a variety of ways, such as:
(a) Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (e.g., Windows or Macintosh), screen resolution, operation system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Website and the Services (such as the App) you are using.
(b) Through your use of the App, , including but not limited to App usage data and what files have been downloaded to the App based on your device number.
8.3 We also use:
At this time, we do not respond to browser “Do-Not-Track” signals.
(d) Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Website and some Services to, among other things, track the actions of users of the Website and the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Website and the Services and response rates.
(e) IP Address: Your IP Address is a number that is assigned to your computer by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log fields whenever a user accesses the Website and the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP Addresses for purposes such as calculating usage levels of the Website and the Services, helping diagnose server problems, and administering the Website and the Services.
(f) Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content, including specific information about our Website and Services if you are in physical proximity to one of our properties and have opted into receiving text messages from us. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
(g) From You: Other information, such as your preferred means of communication, is collected when you voluntarily share it with us.
(h) By Aggregating Information: Aggregated Personal Information does not personally identify you or any other user of the Website and the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
- HOW WE MAY USE AND DISCLOSE OTHER INFORMATION
9.1 We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
9.2 In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
9.3 We are not responsible for the information collection, usage, disclosure, or security policies and practices of other organizations, such as Facebook, Apple, Google, Microsoft, Twitter, Pinterest, and FourSquare, or any other app developer, app provider, social media platform provider, operation system providers, wireless service provider, or device manufacturer.
- HOW WE PROTECT YOUR PRIVACY:
10.1 Security. We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us through the Contact Us page on the Website.
10.2 Patron Account, Password, and Security. For certain features available through the Website and the Services, we may require the use of encryption technologies provided for your protection and/or Patron account. We use reasonable precautions to protect the privacy of your username, password, and Patron account information.
10.3 You, however, are ultimately responsible for protecting your username, password, and Patron account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You agree to: (a) immediately notify TwinSpires of any unauthorized use of your username, password and/or Patron, and/or any other breach of security; and (b) ensure that you log out from your Patron account at the end of each session. While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.
- GEOLOCATION TECHNOLOGIES
11.1 There are Federal prohibitions and restrictions relating to wagering on the Internet (including, but not limited to, such prohibitions and restrictions set out in 18 U.S.C. §§ 1084 et seq. (The Wire Act) and 31 U.S.C. §§ 3163 through 3167 (UIEGA)). It is a federal offense for persons physically located outside of New Jersey to engage in Internet wagering through any New Jersey casino, including, but not limited to, Wagering on the Website and the Services, unless you are explicitly authorized by the Regulator. We and our service providers utilize several current technologies, and may use future technologies, in order to verify your physical location while you are Wagering on the Website (collectively, the "Geolocation Technologies"). Geolocation Technologies report your physical location from the computer or Internet-connected device that you choose and from which you are accessing the Website. Geolocation Technologies obtain your physical location by accessing your IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates. The Geolocation Technologies report to us, our service providers and/or the Regulator the physical and geographic location of the computer or Internet-connected device from which you are accessing the Website. It is possible that your precise or near-precise physical location will be reported to us, our service providers and/or the Regulator when you use the Website.
- CHOICES AND ACCESS
12.1 Your choices regarding our use of your Personal Information. We give you choices regarding our use of your Personal Information for marketing purposes. You may out out from:
(a) Receiving electronic communications from us: If you no longer want to receive marketing related e-mails from us on an ongoing basis, you may opt out by clicking on the unsubscribe link in these emails.
(b) Receiving SMS text messages from us: If you no longer want to receive SMS marketing text messages at a telephone number that you have provided to us for purposes of receiving such offers, by following the instructions provided you can remove your phone number from any future marketing alerts or offers.
(c) Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we do not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by contacting us through the Contact Us page on the Website and the Services, and specifying that you want to opt out of affiliate sharing.
12.2 How you can access, change, or suppress your Personal Information. If you would like to review, correct or update Personal Information that you have previously provided to us, you may contact us through the Contact Us page on the Website and the Services. In your request, please make clear what Personal Information you would like to have changed or updated. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address you use to send us your request, and we may need to verify your identify before implementing your request. Subject to applicable laws, including but not limited to our obligations regarding anti-money laundering laws, we will try to comply with your request as soon as reasonably practicable.
12.3 In addition, please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transaction that you began prior to requesting such change. There may also be residual information that will remain within our databases and other records, which will not be removed.
- USE OF THE WEBSITE AND THE SERVICES BY INDIVIDUALS UNDER THE APPROPRIATE AGE
13.1 Information from Persons Under 21 Years of Age. It is a criminal offense to allow a person who is under the age of twenty-one (21) to participate in Internet wagering. The Website and the Services are not for use by any person under the age of twenty-one (21) and we do not knowingly accept as a Patron anyone under the age of twenty-one (21).
- CALIFORNIA'S "SHINE THE LIGHT" LAW
14.1 California residents who provide personally-identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request, and obtain from us once each calendar year, information about the Patron information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2019 sharing activities).
14.2 To obtain this information on behalf of TwinSpires, please send an email message to compliance@TwinSpires.com with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you at your email address in response.
14.3 Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
Churchill Downs Interactive Gaming, LLC d/b/a TwinSpires
Attn: Customer Support - Website
Copyright © 2021. Churchill Downs Interactive Gaming, LLC. All Rights Reserved.