Chumba Casino Merchandise Portal Privacy Policy
Table of Contents
1. Data Controller. 2
2. Type of Information We Collect. 2
3. How we collect your information. 3
4. Personal Data Collected via Technology. 3
5. How We Use Collected Information. 4
6. Your Privacy Rights. 5
7. Exercising Your Privacy Rights. 5
8. How We Protect Your Information. 6
9. How Long Will We Retain Your Information. 6
10. Sharing Your Information. 6
11. Other Important Information. 7
12. Changes to this Privacy Policy. 8
13. Contacting Us. 8



Date updated: 26 July 2023

At VGW, we are committed to protecting and respecting your privacy and maintaining the confidence and trust of our customers. This privacy policy ("Privacy Policy") explains how your personal information is collected, why it is collected and how it is kept secure. We are committed to complying with obligations under all applicable global data privacy laws, including the General Data Protection Regulation (‘GDPR’), the California Consumer Privacy Act (‘CCPA’), the Virginia Consumer Data Protection Act (‘VCDPA’), the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) (and any provincial substantially similar law as applicable) and the Australian Privacy Act 1988 (Cth) (the ‘Privacy Act’) (including the Australian Privacy Principles set out in the Privacy Act (the ‘APPs’)).

This Privacy Policy governs the manner in which VGW Holdings Limited and its related entities that form the VGW group ("VGW Group") collect, use, maintain and disclose information collected through https://www.chumbacasino.gifts/ and any subdomains, subpages, successor sites or any application accessible via our website (the "Chumba Casino Merchandise Website"). This Privacy Policy applies to the Chumba Casino Merchandise Website and all merchandise offered through the Chumba Casino Merchandise Website.
 

1. Data Controller

1.1 This Privacy Policy is issued on behalf of the VGW Group so when we mention "VGW", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the VGW Group responsible for processing your data. 

1.2 The data controller responsible for processing data collected through your use of the Chumba Casino Merchandise Website (including any data you may provide through the Website when you obtain any merchandise) is VGW Malta Limited having its registered address at Trident Park, Notabile Gardens, No6 — Level 3, Central Business District, Mdina Road, Zone 2 Birkirkara CBD2010 Malta (the "Data Controller").

2. Type of Information We Collect

2.1 Personal Information is any information about you, whether it is true or not, where your identity is apparent or can reasonably be ascertained from that information.  When anonymous information is directly or indirectly associated with personal information, the resulting information is also treated as Personal Information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.  Aggregate information means information about groups or categories of customers, which does not identify and cannot reasonably be used to identify an individual customer.

2.2 We collect two basic types of information — Personal Information and anonymous information (as defined above at clause 2.1) — and we may use personal and anonymous information to create a third type of information, aggregate information (also defined at clause 2.1).  We collect:

1. contact details such as your first name and surname, email address, residential address and mobile or other phone numbers;
2. personal information such as gender, age, age range or your image; account login details, including your username, password and pictures associated with your profile;
3. transaction information you provide when you redeem a code and obtain merchandise through the Chumba Casino Merchandise Website, such as your postal address and phone number;
4. location information including location information provided by a mobile or other device interacting with one of our Websites, including the Chumba Casino Merchandise Website, or associated with your IP address, where we are permitted by law to process this information;
5. activity, technical and device information about your use of our Chumba Casino Merchandise Website, such as the content you view, the time and duration of your visit on our Chumba Casino Merchandise Website, how often you use our services, your preferences and information about your interaction with the content offered through our Chumba Casino Merchandise Website, your hardware model, device type, other unique device identifiers, operating system version, browser type and IP address; and
6. sensitive information such as geolocation.

 

3. How we collect your information

3.1 We collect information in a variety of ways, as set out below. You confirm that any contact information you provide is true and accurate.

3.2 Information you provide to us directly including when you visit our Chumba Casino Merchandise Website, register an account on the Chumba Casino Merchandise Website, redeem codes on our Chumba Casino Merchandise Website to obtain merchandise, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Chumba Casino Merchandise Website.

3.3 In addition to collecting information via our Chumba Casino Merchandise Website, we collect information from you by telephone or in correspondence (including email and text message). All telephone calls between you and VGW Group representatives may be recorded for training, quality control and compliance purposes and by continuing with any such call you consent to it being recorded.

3.4 Information you provide when using our services
We also collect information about your use of our products and services through a variety of technologies that are present when you visit our Websites, including the Chumba Casino Merchandise Website, or use our applications on third party sites or platforms (whether or not you are logged in or registered) including cookies, flash cookies, pixels, tags and application programming interfaces (“API”). Please see the section entitled “Personal Data Collected via Technology” below for further information. Analytics tools are also used by us to collect information, including when you visit our Chumba Casino Merchandise Website or use our applications or services on third party sites or platforms.

4. Personal Data Collected via Technology

4.1 When you interact with our Chumba Casino Merchandise Website, we try to make that experience simple and useful. We and our partners use industry standard identifiers, such as cookies or other similar technologies.

4.2 Our Chumba Casino Merchandise Website may use technologies to enhance your experience. These technologies are small files that are placed on your computer, tablet, mobile phone or other devices when you visit a website. They allow us to record certain pieces of information whenever you visit or interact with the Chumba Casino Merchandise Website. Usage information may include, in part, browser type, operating system, device type, an estimate of your geographic location associated with your IP address, the location of your mobile device, the page served, the time, referring URLs and other information normally transmitted in HTTP requests.  This statistical data provides us with information about your use of the services, such as general engagement with a page, the type of content on that page and how long you stay on that page.  Usage information is generally non-identifying but if VGW associates it with you as a specific and identifiable person, VGW will treat it as Personal Information.

4.3 The following are examples of these types of technologies:

1. APIs. APIs work by allowing different types of software to communicate with each other. They make life a lot easier for programmers and provide a better experience for end users.
2. Cookies. These are small text files placed in your device browsers to store your preferences. Most browsers allow you to block and delete cookies. However, if you do that, the service may not work properly.
3. Event tagging. Event tagging allows us to track actions that occur on the Chumba Casino Merchandise Website.
4. Mobile device identifiers. We may share the advertising identifier associated with your mobile device or tablet (such as the Apple IDFA and Google Advertising ID) with advertisers. It is used to identify your device for internet-based advertising. For instructions for using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI’s Mobile Choices page here.
5. Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on a website that collects information about your engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in e-mails to understand whether messages have been opened, acted on or forwarded.

5. How We Use Collected Information

5.1 We use the information collected to operate our Chumba Casino Merchandise Website, to provide merchandise and to respond to your questions.

5.2 In accordance with applicable laws and any elections made available to you, VGW may collect and use your information for the following specific purposes:

1. To provide and manage the services you request — This includes, for example, processing your registration, setting up and looking after your account.
2. To improve customer service and our services — Information you provide helps us respond to your customer service requests more efficiently; we may use feedback you provide to improve our products and services.
3. To personalize user experience — We may use information which has been aggregated to understand how our users as a group use the services and resources provided on our Chumba Casino Merchandise Website.
4. To contact you about our services including marketing — For example by email, telephone, text message, or mail. We may periodically contact you with offers and information about our products and services, including in connection with your accounts,  merchandise, and other important information. Please see the section entitled ‘Your Privacy Rights for your opt out rights.
5. To comply with our legal and regulatory obligations — We may use information we collect about you to comply with any legal or regulatory obligations (including the detection, investigation and prevention of activity that violates our terms and conditions or that may be illegal).
6. To conduct market research and analysis — to analyse how you interact with our products and services; to monitor and analyse usage and activity trends; and for other research, analytical and statistical purposes.

5.3 Automated Decision Making
We do not use automated decision making within the definition of global data protection laws.

6. Your Privacy Rights

6.1 Marketing Communications
If we process your personal information for the purpose of direct advertising, you have the right to object at any time to this processing; this also applies to profiling, where appropriate, insofar as it is associated with such direct advertising.

6.2 You may opt out of receiving commercial messages from us by following the instructions contained in those messages or by contacting Customer Support. In the event of your objection to processing for the purpose of direct advertising, we will no longer process your personal information for these purposes.

6.3 Cookies
You can change your preferences with regards to cookies and other trackers at any time by clicking on the Your Privacy Choices link provided at the bottom of our Chumba Casino Merchandise Website.
 

7. Exercising Your Privacy Rights

7.1 We appreciate that by law and subject to certain conditions, you have a number of rights concerning the personal information we hold about you. These rights include the right to access the personal information we hold about you, the right to object to the processing of your data, the right to update and correct the information we hold about you, and the right to withdraw any consent provided. In some circumstances, you can ask us to delete the personal information we hold about you.

7.2 To exercise the rights described at clause 7.1 please complete the Chumba Casino Merchandise Portal Customer Request Form here [embed this link in “Chumba Casino Merchandise Portal Customer Request Form” https://www.chumbacasino.gifts/contact_us.php], or alternatively email dataprivacy@vgw.co.

7.3 We will not discriminate against you (e.g., through denying products and services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

7.4 If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf.

7.5 Right to Complain to a Supervisory Authority
You also have the right to complain to the relevant data protection supervisory authority about VGW’s processing of your personal information. Please complete the Customer Request Form here [embed this link in “Chumba Casino Merchandise Portal Customer Request Form” https://www.chumbacasino.gifts/contact_us.php] or alternatively email dataprivacy@vgw.co.
 

8. How We Protect Your Information

8.1 We have in place physical, electronic and operational procedures to protect the information that we collect. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password and data stored on our Chumba Casino Merchandise Website. Our security measures are reviewed regularly and updated in keeping up with technological advances.

8.2 We use reasonable means to protect your personal information from misuse, interference, or loss, as well as any unauthorised access, modification or disclosure.

8.3 If we believe that a notifiable data breach has occurred, we will comply with the legislative requirements to notify you of the data breach and any steps taken by VGW to contain and investigate the data breach.

9. How Long Will We Retain Your Information

9.1 We will retain your information for a period of time to reasonably fulfil the purposes specified in this Privacy Policy, unless a longer retention period is required by law.

9.2 We will take reasonable steps to destroy or permanently de-identify any Personal Information where:

1. we no longer need the Personal Information for any purpose for which the Personal Information was collected or for a related purpose; and
2. we are not required by law, a regulator or a court/tribunal order, to retain the Personal Information.

10. Sharing Your Information

10.1 We do not sell, trade, or rent your personal information. However, there are circumstances when we share your personal data with the following categories of third parties:

1. Affiliates — other companies in the VGW Group;
2. Service providers — other companies who provide services to you on our behalf; and
3. Third parties that interact with us in connection with the services we perform.

10.2 If data will be shared with a third party, we require them to maintain the same protections over your data that we provide directly to you and to only perform services on our behalf. Simply put, they are prohibited from using your personal information for purposes other than those requested by us or required by law.

10.3 With Third Parties
We only share information with third parties in limited circumstances including the following:

1. when you allow us to share your information with third parties;
2. when providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
3. with our service providers who enable us to provide our services, such as companies that help us with technology services, storing and combining data, processing codes and delivery services. These service providers will have access to your personal information only to perform services on VGW’s behalf and are prohibited from using your personal information for purposes other than those requested by us or required by law. Where service providers use personal information for their own purposes, where permitted by law, such service providers will act as the data controller of that data;
4. in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law of a particular jurisdiction; and
5. to enforce our terms and conditions set out on our Chumba Casino Merchandise Website, to protect our rights and property and the rights and property of our customers and third parties, to detect fraud or other illegal activities, and to comply with law or legal processes.

10.4 We make available an API provided by Google Maps in order to allow you to have access to an address auto-complete function on our Chumba Casino Merchandise Website. The use of Google Maps for this purpose by you is subject to the then current Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html and Google Privacy Policy at https://www.google.com/policies/privacy.

10.5 We may also share generic aggregated demographic information not linked to any personal identification information regarding visitors to and users of our Chumba Casino Merchandise Website with our business partners, affiliates and advertisers for the purposes outlined above.

10.6 Transfers
The VGW Group operates in several international jurisdictions and personal information we collect may be transferred to, and stored and processed by, individual companies in the VGW Group or third parties in the European Union, the United States, Canada, Australia, the Philippines or any other country in which we or our service providers maintain facilities. We will ensure that transfers of personal information to any country or organization are subject to appropriate safeguards. Additionally, when transferring personal information from the European Union, we may use standard contractual clauses approved by the European Commission or otherwise adopt other means in accordance with European data protection laws for ensuring adequate safeguards.

11. Other Important Information

11.1 Minors
Protecting the privacy of children is especially important to VGW. For that reason, we never knowingly collect or maintain information from individuals under the age of 18, and no part of our Chumba Casino Merchandise Website is structured to attract anyone under the age of 18.  VGW does not offer or direct any of its services or products, including Chumba Casino merchandise to individuals under the age of 18.
 

12. Changes to this Privacy Policy

12.1 This Privacy Policy may be updated from time to time to reflect changes in the way we work or the way our work is regulated. Notice may be by the posting of such changes on our Chumba Casino Merchandise Website or by other means in accordance with applicable laws.

12.2 Any changes to the Privacy Policy will become effective when the updated policy is posted on our Chumba Casino Merchandise Website.

12.3 This Privacy Policy, in effect as of the last modified date stated below, supersedes and replaces any and all Privacy Policies previously in effect.
 

13. Contacting Us

If you have specific questions regarding your personal information or how we use it, please email dataprivacy@vgw.co or alternatively please complete the Customer Request Form [embed this link in “Customer Request Form” https://chumbacasino.zendesk.com/hc/en-us/requests/new].



Published: 16 August 2023