Legal
Privacy Policy
Last updated: July 14, 2026
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Services and tells you about your privacy rights and how the law protects You. We use your Personal data to provide and improve the Services. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Lastly, various jurisdictions worldwide are adopting general privacy laws that require more specific disclosure and descriptions of your (data subject/consumer) rights with respect to processing your personal information. Carillon Gaming is providing a Specific Privacy Law Addendum (the “SPLA”) that followings this “General Privacy Policy Disclosures” and that may apply to you pursuant to a specific privacy law as the SPLA describes in more detail.
Updates to the Privacy Policy.
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. When we update this Privacy Policy, we will revise the “Last Updated” date at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we will provide notice in a manner reasonably designed to inform you of the changes before they take effect, where required by applicable law. This notice may include, as appropriate, posting a prominent notice on our website or within our services, sending notice to the email address associated with your account, providing an in-app or platform notice, or using another reasonable method of communication.
Unless otherwise stated in the notice, updates to this Privacy Policy will become effective when posted. Your continued use of our Website, products, or Services after the updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy, to the extent permitted by applicable law. If you object to any of the disclosed privacy practices in an updated Privacy Policy, you should stop using our Website, products, or Services and, if applicable, may close your account or contact us using the information provided in the Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, disclose, and protect personal information.
Definitions.
For the purposes of this Privacy Policy:
“Account” means a unique account created for you to access our Services or parts of our Services.
“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
“Business,” for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, and that does business in the State of California.
“CCPA” and/or “CPRA” refers to California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
“Company” (referred to as either the "Company", "we", "us" or "our" in this Privacy Policy) refers to Carillon Gaming, Inc., 6111 128th Avenue NE, Kirkland, WA98033-8510 USA. For the purpose of the GDPR, the Company is the Data Controller.
“Consumer” means a natural person who is a resident of a U.S. state whose consumer privacy law applies to our processing of that person’s Personal Information or Personal Data, including any California resident covered by the CCRA/CPRA. For purposes of state privacy laws that limit the term to individuals acting in a personal, family, or household capacity, Consumer does not include a person acting in an employment, contractor, job-applicant, owner, director, officer, or business-to-business capacity, except where the applicable law requires otherwise.
“Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
“Data Controller,” for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
“Device” means any device that can access the Services such as a computer, a cellphone or a digital tablet.
“Do Not Track” (or “DNT”) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
“GDPR” for the EU refers to EU General Data Protection Regulation and for the UK refers to the UK Data Protection Act 2018.
“Personal Data” is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA/CPRA, Personal Data may be used in the SPLA instead of the defined term in CCPA/CPRA “Personal Information,” although we may also use Personal Information if GDPR is inapplicable to the disclosure we are making. Under CCPA, Personal Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
“Services” means any of our web applications, mobile applications, and our Website(s).
“Service Provider” means any natural or legal person who processes the data on our behalf. It refers to third-party companies or individuals engaged or contracted by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing how the Services are used. For the purpose of the GDPR, Service Providers are considered “Data Processors”.
“Usage Data” refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
“Website” refers to carillongaming.com, pokerwize.com, and any other website owned or controlled by us.
“you” means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. Under GDPR, you can be referred to as the Data Subject or as the User as you are the individual using the Services.
General Privacy Policy Disclosures
Collecting and Using your Personal Data.
Types of Data Collected.
Personal Data: while using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to email address, First name and last name, Phone number, Address, State, Province, ZIP/Postal code, City.
Usage Data:
- Usage Data is collected automatically when using the Services.
- Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- When you access the Services by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
- We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device.
Tracking Technologies and Cookies.
We use Cookies and similar tracking technologies to track the activity on our Services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services. The technologies we use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.
- Web Beacons. Certain sections of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
Use of your Personal Data.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Services.
To manage your Account: to manage your registration as a user of the Services. The Personal Data you provide can give you access to different functionalities of the Services that are available to you as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Services.
To contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
To manage your requests: To attend and manage your requests to us.
For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Services users is among the assets transferred.
For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share your personal information in the following situations:
- With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to contact you.
- For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
- With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With your consent: We may disclose your personal information for any other purpose with your consent.
Retention of your Personal Data
The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
The Company will take all steps that are reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Delete your Personal Data
You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you.
Our Services may give you the ability to delete certain information about you from within the Services.
The Services will be developed either so that you may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your personal information or by contacting us to request access to, correct, or delete any personal information that you have provided to us.
Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of your Personal Data
Business Transactions. If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement. Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements. The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Services or the public
- Protect against legal liability
Security of your Personal Data
The security of your Personal Data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Services in accordance with their Privacy Policies.
Analytics
We may use third-party service providers to monitor and analyze the use of our Services.
Google Analytics
We use Google Analytics, a web analytics service provided by Google, to help us understand how users interact with our Services. Google Analytics collects information such as usage data, device and browser information, and interactions with our Services, and uses that information to provide analytics services to us. Depending on our Google Analytics settings, linked Google services, and your consent choices where applicable, Google may also use Analytics data to improve Google products and services or for advertising-related purposes, including ads personalization. You can learn more about how Google uses information from sites and apps that use Google services at https://policies.google.com/technologies/partner-sites, and you can review Google’s Privacy Policy at https://policies.google.com/privacy. You may also be able to opt out of Google Analytics measurement by installing the Google Analytics opt-out browser add-on, available from Google.
Email Marketing. We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may use Email Marketing Service Providers to manage and send emails to You. Email marketing is often included in Customer Relationship Management (CRM) solutions, and email marketing therefore may be disclosed under the CRM category, below.
Usage, Performance and Miscellaneous. We may use third-party Service Providers to provide better improvement of our Services.
Google Places
Google Places is a service that returns information about places using HTTP requests. It is operated by Google. Google Places service may collect information from you and from your Device for security purposes. The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/
Customer Relationship Management and Website Analytics
Attio
We use Attio as our customer relationship management platform to help us manage business contacts, prospective customer relationships, communications, sales and marketing activities, and related interactions with users of our website and Services. When you interact with our website or Services, submit a form, request information, subscribe to updates, book a meeting, or otherwise communicate with us, we may collect and process information such as your name, contact details, communication preferences, inquiry details, and related correspondence. We may also associate this information with website analytics data, such as pages viewed, referral source, approximate location derived from IP address, device and browser information, timestamps, and interactions with our website or emails. We use this information to respond to inquiries, manage our relationship with you, understand how visitors use our website or Services, improve our Services and marketing, maintain internal records, and measure the effectiveness of our outreach and communications.
Specific Privacy Law Addendum (the “SPLA”)
Last updated: July 14, 2026
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following legal bases authorized under GDPR:
- Consent: You have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
What Categories of GDPR Personal Data do we collect and process?
The following hyperlink is to a table disclosing more specifically the categories of Personal Data that we collect and process, including the legal bases for processing each such category: [INSERT HYPERLINK TO TABLE HERE]
Your Rights under the GDPR
We respect the confidentiality of your Personal Data and guarantee you can exercise your rights. You have the right under this SPLA, and by law if you are within the EU or UK when we collect and Process your Personal Data, to:
- Request access to your Personal Data. The right to access, update or delete the information we have on you. We may provide notice of and capabilities for you to access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
- Request correction of the Personal Data that we hold about You. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
- Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Services.
Exercising your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
UK GDPR Local Representative Contact:
EU GDPR :Local Representative Contact:
CCPA/CPRA Privacy Notice
This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
What Categories of CCPA/CPRA Personal Information do we collect and process?
The following hyperlink is to a table disclosing more specifically the categories of Personal Information that we may collect or may have collected for processing from California residents or households within the last twelve (12) months, including other information the disclosure of which CCPA/CPRA requires: [INSERT HYPERLINK TO TABLE HERE]. Under CCPA/CPRA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA/CPRA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from the forms you complete on the Services, preferences you express or provide through the Services.
- Indirectly from you. For example, from observing your activity on the Services.
- Automatically from you. For example, through Cookies we or our Services Providers set on your Device as you navigate through the Services.
- From Service Providers. For example, third-party vendors to monitor and analyze the use of the Services, or other third-party vendors that we use to provide the Services to you.
Use of Personal Information
We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
- To operate the Services and provide you with the Services.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve the Services.
- To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about the Services, we will use that personal information to respond to your inquiry.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
- Other one-time uses.
Please note that the examples provided above are illustrative and not intended to be exhaustive. Please refer to table disclosing more specifically the categories of Personal Information that we may collect or may have collected for processing from California residents or households within the last twelve (12) months, including how we use such Personal Information and other information the disclosure of which CCPA/CPRA requires: [INSERT HYPERLINK TO TABLE HERE].
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update the table for this SPLA identified above.
Share of Personal Information
We may share, and have shared in the last twelve (12) months, your personal information identified in the above categories with the following categories of third parties:
Service Providers
our affiliates
our business partners
Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to You
Please refer to table disclosing more specifically the categories of Personal Information that we may collect or may have collected for processing from California residents or households within the last twelve (12) months, including how we share such Personal Information: [INSERT HYPERLINK TO TABLE HERE].
Sale of Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We may allow Services Providers to use your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
Personal Information of Users Under 18 Years of Age
We do not knowingly collect personal information from users who are under the age of 18 through the Services, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission. If you have reason to believe that a child under the age of 18 has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.
Your Rights under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to know/access. Under CCPA/CPRA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information.
- The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct us not to sell your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact us.
- The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our Service Providers to correct) your personal information, unless an exception applies.
- The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information we collected about you, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact us.
- The right to delete Personal Data. You have the right to request the deletion of your Personal Data under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights.
Exercising your CCPA/CPRA Data Protection Rights
Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact Us:
By email: legal@carillongaming.com
Only You, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to us must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
We cannot respond to your request or provide you with the required information if we cannot:
- Verify your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from You, we will stop selling your personal information. To exercise your right to opt-out, please contact us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Services that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
Website
As provided in by the Website, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Services to review your privacy preferences and opt out of Cookies and other technologies that we may use. Please note that you will need to opt out from each browser that you use to access the Services.
Mobile Devices
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Limit the Use or Disclosure of My Sensitive Personal Information
If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide the Services. For more information on how we use your personal information, please see the "Use of your Personal Data" section or contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
The Services do not respond to Do Not Track signals.
However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If You'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Categories of Personal Data/Information Collected, Processed and shared.
| Category of Personal Information | Examples | Sources | Purposes of Processing | GDPR Lawful Basis | Recipients / Categories of Recipients | Sold or Shared (CCPA) | Retention Criteria / Period | Required or Optional |
|---|---|---|---|---|---|---|---|---|
| Identifiers | Name, username, account ID, customer number | User, employer, reseller, customer administrator | Account creation, authentication, account administration, customer support | Contract; Legitimate Interests | Hosting providers, customer support providers, CRM vendors | No | Duration of account plus 3-7 years for legal compliance | Required |
| Contact Information | Email address, phone number, mailing address | User, employer, reseller | Services delivery, notifications, support, billing, security communications | Contract; Legitimate Interests; Consent for marketing where required | Email service providers, CRM vendors, support vendors | May be Shared for cross-context advertising if applicable | Duration of relationship plus legal retention period | Required for account; optional for marketing |
| Commercial Information | Subscription history, purchases, invoices, payment status | User, customer organization | Billing, contract administration, revenue recognition, audits | Contract; Legal Obligation | Payment processors, accounting providers, auditors | No | Tax and accounting retention periods | Required |
| Payment Information | Credit card token, billing details | User, finance contact | Payment processing and fraud prevention | Contract; Legitimate Interests | Payment processors and banks | No | Retained only as necessary for billing and legal compliance | Required if paid service |
| Internet or Network Activity | IP address, browser type, device identifiers, log data | User device | Security, troubleshooting, Services performance, fraud detection | Legitimate Interests; Contract | Hosting providers, security vendors | May be Shared if advertising technologies are used | As reasonably necessary for analytics and security | Automatically collected |
| Device Information | Device ID, operating system, app version | User device | Services optimization, compatibility, analytics | Legitimate Interests; Contract | Analytics providers, cloud providers | May be Shared if advertising technologies are used | As reasonably necessary for analytics and security | Automatically collected |
| Geolocation Data | Approximate location derived from IP address | User device | Localization, fraud prevention, Services delivery | Legitimate Interests; Contract; Consent where required | Cloud providers, analytics providers | Usually No | Limited period necessary for stated purpose | Optional |
| Usage Information | Feature usage, clicks, session activity, interaction history | User activity | Product improvement, customer support, analytics | Legitimate Interests; Contract | Analytics providers, cloud providers | May be Shared if advertising technologies are used | As reasonably necessary for analytics and security | Automatically collected |
| Communications Data | Support tickets, chat messages, feedback, survey responses | User | Customer support, Services improvement, dispute resolution | Contract; Legitimate Interests | Help desk providers, communication providers | No | Duration of relationship and applicable limitation periods | Optional |
| Marketing Preferences | Subscription status, communication preferences | User | Marketing communications, preference management | Consent; Legitimate Interests where permitted | Email marketing providers | May be Shared if advertising activities occur | Until withdrawn or no longer needed | Optional |
| Customer Content | Data uploaded, entered, or submitted through the service | User, customer organization | Providing the Services requested by the customer | Contract; Controller's lawful basis where provider acts as processor | Cloud providers, subprocessors acting on customer instructions | No | As directed by customer and contract terms | Optional depending on Services use |
| Audio, Electronic or Visual Information | Call recordings, video submissions, photographs | User | Customer support, quality assurance, Services delivery | Consent; Legitimate Interests; Contract | Communication providers | No | Defined retention schedule | Optional |
| Inferences | Preferences, interests, behavioral patterns | Derived from user activity | Personalization, Services optimization, analytics | Legitimate Interests; Consent where required | Analytics providers, marketing providers | May be Shared if advertising activities occur | As necessary for personalization purposes | Optional |
| Gameplay / Hand History Data | Hand histories, betting actions (bet/call/raise/fold), hole and board cards, pot sizes, table and seat data, training-game answers, win/loss results, timestamps | Subscribing User gameplay activity | Training feedback, performance analytics, personalized coaching, progress tracking, product improvement | Contract; Legitimate Interests | Hosting providers, analytics providers, ML/solver subprocessors | No | Duration of account plus a to be determined period to allow a user to re-subscribe to the Services | Automatically collected during gameplay |
| Player Session & Activity Logs | Session start/stop times, play duration, frequency of play, time at table, login patterns, self-imposed play limits | Subscribing User activity and device | Services delivery, responsible-play features and limits, fraud detection, analytics | Contract; Legitimate Interests; Legal Obligation where responsible-gaming rules apply | Hosting providers, analytics providers, security vendors | No | Duration of account plus a to be determined period to allow a user to re-subscribe to the Services. Security and analytics retention schedule; responsible-play records as required | Automatically collected |
| Virtual Currency / Bankroll Data | WizeCoin balances, virtual-currency transactions, in-app purchase history, bankroll-tracking entries (play money, non-redeemable) | Subscribing User; Subscribing User activity | Operating the in-app currency and store, bankroll-management features, fraud prevention | Contract; Legitimate Interests | Payment processors (for purchases of virtual currency), cloud providers | No | Duration of account; tax and accounting periods apply to any real-money purchases | Automatically collected; purchase records only if user buys |
| Player Communications & Coaching Queries | In-app chat messages, coaching and AI-assistant queries, hand-review notes, feedback and survey responses | Subscribing User | Customer support, AI-assisted coaching, community features, Services improvement | Contract; Legitimate Interests; Consent where messages are used to train models | Help-desk providers, communication providers, AI/model providers, cloud providers | No | Duration of relationship and applicable limitation periods | Optional |
| Age & Eligibility Verification Data | Date of birth, age/eligibility confirmation, jurisdiction checks, government ID where KYC applies (real-money only) | Subscribing User | Verifying minimum age and jurisdiction eligibility, legal compliance, fraud prevention | Legal Obligation; Contract; Explicit Consent for ID documents | Identity-verification providers, compliance vendors | No | Minimal; only as long as required by law | Required for eligibility |