Last updated: 1st March 2022
safeguard your personally identifiable information and to explain your rights in relation to that information and its use. Please read this
incorporated herein by this reference. If you are a California resident, please be sure to review the section “Additional Information for
California Residents” below for important information, as required by California privacy laws, about the categories of personal information
we collect and disclose, as well as your rights under California privacy laws.
This “Site” (as defined herein) is operated by NSUS Group Inc and its respective subsidiary, parent and affiliated companies
entity responsible for the capture, storage and use of personally identifiable information and is a company incorporated in Canada with
registered office at 2 Sheppard Ave. East Suite 700 North York ON M2N 5Y7 (the “Company Address”).
3. Protecting your Privacy
Protecting your privacy, along with your financial transactions, is at the core of our business. We are committed to
maintaining the confidentiality of the personal information collected by us, utilizing ‘best in class’ information security technology and
procedures, in accordance with applicable standards of data protection and the requirements of regulatory authorities. We will comply
with the terms of applicable data protection regulations through which you access and use our Site (as such regulations may be amended
from time to time) (collectively, “Applicable Law”), when processing personally identifiable information. Personally identifiable information
may be also processed or transferred by us to other members of our group of companies, our affiliates, our agents and third parties
providing services to us. In this event we will comply with the terms of Applicable Law that ensure that personal data is only transferred to
such jurisdictions which comply with the various ‘adequacy’ requirements for data protection set out in Applicable Law.
From time to time, Company may share email addresses and sell or share all other information with our affiliates and with carefully
selected companies who we think can offer you services and products of interest to you. If you no longer wish to have your information
shared, write to us at firstname.lastname@example.org. If you do not wish to receive communications from us, you may opt out at any time, by following
the unsubscribe instructions contained within the email, or write to email@example.com. We also allow access to our database by third
parties that provide us with services, such as technical maintenance or forums software, but only for the purpose of and to the extent
necessary to provide those services. And if you choose to purchase items through features on our site, we may forward your information to
third parties for services such as credit card processing and order fulfillment. There are also times when you provide information about
yourself to us in areas of the Site that are managed or participated in by third parties, such as our featured partners. In such cases, the
information will be used by us and by such third party(ies), each pursuant to its own policies. In certain circumstances, consistent with
applicable law, we also provide your information to our advertisers, so that they can serve ads to you that meet your needs or match your
interests. While Company will seek to require such third parties to follow appropriate privacy policies, Company does not bear any
responsibility for any actions or policies of third parties. Please note that third parties may collect information about your online activities
over time and across different websites when you use the Site. There may also be occasion when we are legally required to provide access
to our database in order to cooperate with governmental agency investigations or other legal proceedings. In those instances, the
information is provided only for that purpose.
In addition, we reserve the right to disclose, share and/or otherwise transfer user information, including without limitation personally
identifiable and account information, in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our
business or the sale of substantially all of Company’s assets, or other fundamental corporate change, whatever form it may take. You will be
notified via email or prominent notice on our Site prior to a change of ownership or control of your personally identifiable information, if
your personally identifiable information will be used contrary to this policy. For clarification and the removal of doubt, Company
from this Site or the Software, off-line or otherwise, to the buyer of that portion of its business relating to that information.
last updated date at the top of this policy. Amendments will come into effect immediately upon such change being notified on the Site.
5. What We collect
Although parts of our Site do not require you to be a subscriber and you can use them without submitting any personally
identifiable information, some areas do require you to register and provide information that enables us to identify who you are. Company
generally collects personally identifiable information with your specific knowledge and consent. For instance, when you enter a
sweepstakes or register for any portion of our services, you are asked to provide information (e.g., your email address, name or phone
number). Additional information such as your age is also requested and will be used to verify your eligibility to win sweepstakes. Providing
us with information about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be
information is personal information about an individual, such as a first and last name, phone number or email address or other individually
identifiable information within the meaning of COPPA and the Federal Trade Commission’s Online Privacy Protection Rule found at 16 CFR
We collect, retain, and use information about you to protect and administer your account and funds; to comply with applicable state,
federal and European Union (EU) laws and regulations; and to help us design, improve and provide products and services in order to better
serve you. When you open an account with us or when you submit a request or electronically pass information to us, you may be asked to
provide certain information, such as your name, e-mail address, mailing address, telephone number(s), identity card/passport number,
identification documents, proof of address documents, date of birth, any other documents that we may require to provide you with our
service as well as certification that you are at least 18 years old or older in jurisdictions in which the minimum age for use of the Site is
greater than 18. In addition, it is important that you complete the account details with valid information, since it will be used for purposes
do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the personally identifiable
information that you have provided to us. We ask for this information in order to facilitate your requests, provide personalized services, and
communicate separately with you. Without your written or electronic consent, we will not collect personally identifiable information over
our system unless it is necessary to provide you with our services or to prevent unauthorized access to our Site or to comply with applicable
laws and regulations.
The Site is not directed toward children (individuals under thirteen years of age). We do not permit registration or use of the Site by anyone
under the age of 18, and we do not knowingly collect personally identifiable information from children. In particular, if you are under 13
years of age (or under the age of 16 if you reside in the European Union), you should not provide any personally identifiable information to
any site on the Internet without the knowledge and permission of your parent or guardian. If Company discovers that a person under the
age of 18 has provided Company with any personally identifiable information, Company will use commercially reasonable efforts to delete
such person’s personally identifiable information from its system.
6. Where we store your personal information
The Company is based in the ON Canda and the information we collect is governed by
applicable state, federal and European Union (EU) laws and regulations. By accessing the Site and using our services or otherwise providing
information to us, you consent to the processing and transfer of information in and to the United States and other countries listed in this
7. Ongoing Data Capture
When you use the Site, we capture and store certain personally identifiable information including access times,
pages viewed, your IP address and the web page that referred you to our Site. We also use ‘cookies’ and our ‘cookie’ policy is explained
8. Data Retention
includes any period of historic retention that may be required for regulatory purposes. We do not collect any more personal information
from our users than is necessary for our purposes and our data management policies include the deletion of any personal information we
no longer required. Should you close (or if we shut down) your account with us, we will retain personally identifiable information only to the
extent that is necessary to comply with Anti-Money Laundering requirements or with other applicable legal and regulatory obligations and
to allows us to defend ourselves against any claims.
9. Use of Information
We, our affiliates and third parties providing services to us or to you on our behalf will use personally identifiable
information for the purpose of conducting our business and providing the Site to you. Specifically, this includes the following purposes, but
we also reserve the right to use your personally identifiable information for any other purposes that are reasonably ancillary to the business
of providing you with our services: to provide the Site to you; identification, verification and vetting purposes; statistical analysis and
research; research and development; marketing, market research and customer profiling; data analysis; to comply with licensing and
regulatory requirements and other applicable laws; to carry out batch testing of documents prior to the deployment of tools sourced from
or provided by third parties; to combat against security risks and fraudulent activity; and to confirm your geographic location.
10. Consent to Processing
We will process personally identifiable information for a variety of reasons, each of which is prescribed by relevant
data protection laws. Our processing of personally identifiable information is necessary for us to provide you with the Site. On occasion we
may ask for your consent to processing personal information in a discrete manner, in this instance personally identifiable information will
be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
11. Legitimate Interest for Processing
It may also be necessary for us to process personally identifiable information where it is necessary for
the performance of a contract or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not
limited to, complying with any anti-money laundering legislation. Finally, we may also process personally identifiable information where we
deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your
interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (ii) where we identify
certain companies can offer you additional benefits to our services or provide us with valuable information about your use of our Site; (ii)
processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic
communications network; (iii) adhering to regulatory and statutory requirements; (iv) devising a tailored reward scheme for players.
12. Disclosures of Information
We may disclose personally identifiable information to our employees, employees of affiliated companies, our
agents and to third party service providers who use personally identifiable information to provide services to us in respect of you being a
security measures to protect your information. In some circumstances, we may disclose personally identifiable information as follows: to
any recipient if required to do so by law or by regulatory authority; to any regulatory body or licensing body or authority; to third parties for
the purposes of settling or making payment in connection with any staking agreement; to third parties who provide services to us or on our
behalf; to third parties for marketing purposes, provided you have consented or not objected, as the case may be; to any third party that
purchases us or our business or any part of us or our business; if we believe in good faith that such action is necessary: to comply with any
law or comply with legal process served on us; to protect and defend our rights or property.
13. Legally Required Disclosures
Due to the legal, regulatory and security environment in which we operate, we may be required, under
certain circumstances, to disclose personally identifiable information about our Users and we may not be permitted to inform you that we
have done so. We will use reasonable endeavors to limit such disclosure to the following: (a) where we believe in good faith that we are
required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to
identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights. Further, we can, and you authorize
us to disclose your User identification, name, date of birth, street address, city, county, post code, country, phone number, email, account
activity, transactions, communications with other Users, to our third party agents or official government bodies as we, in our sole
discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property
infringement, piracy or other unlawful activity or activity that may expose us to legal liability.
14. Group Marketing
We may use your email address and phone number for the purpose of providing you with news, promotions and other
marketing offers from us. If you no longer wish to receive these promotional communications, newsletters and marketing offers, you may
opt-out of receiving them either when you register with us initially, or subsequently by following the ‘opt-out’ instructions included in each
communication. You are also, in addition, entitled at any time to notify us that you do not wish to receive any promotional communications
15. Third Party Offers of Goods and Services
Where you have provided us with your consent to do so, we may also share your email address
and phone number with third parties so that they may send you offers of their goods and services. You may request at any time not to
receive such offers. If you request not to receive these offers, we will remove your details from our marketing distribution lists and from any
future lists we may share with our marketing partners. However, you will need to unsubscribe separately from marketing communications
sent by partners who have received your contact details from us prior to your request to be removed from these lists.
We will only use your name and details in publicity materials with your written consent.
17. Protecting Information
We have undertaken substantial efforts to protect the confidentiality of the identity, preferences and other
information we have collected about Users and we will not knowingly allow access to this information to anyone outside of P5 other than to
and encryption technologies to protect the information that we collect and process. These technologies are deployed as part of
state-of-the-art security architecture. However, you should also play your part in protecting personally identifiable information. Your login
credentials are confidential and you are obliged to keep your login credentials secret and confidential at all times and to use your best
efforts to protect their secrecy and confidentiality. You should also be aware that the transmission of data via email is not secure and
therefore we ask you not to send personal data such as identification documents via email but to upload these documents via links
provided by us or our service providers, which utilize SSL protocols to securely transmit data over the internet.
18. Right to request information about you
We aim to keep our information about you as accurate as possible. You can contact us at any time
to review, change, obtain a copy of your information or have your details altered, corrected or deleted in accordance with your rights under
Applicable Law. In this event we may require evidence of and be satisfied as to your identity before we take any requested action. We may,
in certain circumstances, levy a small charge to cover the cost of administration regarding any request made by you in this regard or deal
with your query in accordance with Applicable Law.
19. Additional Rights
You have the following rights in relation to personally identifiable data: (i) a right to object to processing that is likely to
cause or is causing damage or distress; (ii) a right to object to decisions being taken by automated means; (iii) a right in certain
circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and (iv) a right to claim compensation for damages
caused by a breach of Applicable Law. If you contact us in relation to your rights, we will do our best to accommodate your request or
objection. Please note, however, that not all rights are absolute.
20. The Right to Lodge Complaints
You may lodge a complaint directly by sending an email to: firstname.lastname@example.org or by post to the
Company Address referenced above. Alternatively, you have the right to lodge a complaint with the Federal Trade Commission at
21. How to Contact Us
In order to exercise your rights, you may contact us by email on email@example.com. We will acknowledge receipt of
your email at the earliest possible and will ask you to provide proof of your identity before proceeding with processing your request. We will
try to provide a reply to your request within 30 days. If we encounter circumstances that will not allow us to reply within this time-frame we
will notify you as soon as reasonably possible to inform you of the reason that we require additional time to reply to your request.
22. Third Party Web Sites
The Site may contain links to other sites. P5 cannot be responsible for the privacy practices or the content of other
sites. When linking to other sites, please review their security and privacy policies.
23. Non-Personally Identifiable Information
When your computer or mobile device contacts our web servers (for example, when you visit the
Site or view an HTML e-mail), our web servers automatically collect usage information. Such usage information includes information about
how our visitors use and navigate the Site. It can include the number and frequency of visitors to each web page and the length of their
stays, browser type, and referrer data that identifies the web page visited prior and subsequent to visiting the Site. We also may determine
the applicable technology available in order to serve you the most appropriate version of a web page, e-mail, or advertising or promotional
announcement or similar service. This information is used to analyze and improve the Site and to provide you with a more fulfilling and
24. Browser Cookies
Like many websites, we use browser “cookies.” Cookies are a website’s way of remembering who you are. We use
maintain information about your use of the Site. You can delete cookies manually or set your browser to automatically delete cookies on a
pre-determined schedule. If you decline to accept cookies, you may not be able to take advantage of or participate in certain features of the
25. Web Beacons
Our web pages or e-mail messages may contain a small graphic image called a web beacon, which is sometimes also called
a "clear gif," which allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the
web beacon and the time the web beacon was viewed. We may use web beacons to count visitors to our web pages or to monitor how our
users navigate the Site, and we may include web beacons in e-mail messages in order to count how many of the messages we sent were
actually opened or acted upon. We use web beacons to compile aggregate statistics about the Site and our marketing campaigns.
26. Third Party Cookies
We allow third-party companies to collect anonymous information when you visit the Site and to use that
information to serve ads for products or services or for products or services of other companies when you visit the Site or other websites.
These companies may use anonymous information (e.g., navigational, non-personally identifiable information; click stream information;
browser type, time and date; subject of advertisements clicked or scrolled over, etc.) during your visits to the Site and other websites in
order to provide advertisements about our goods and services likely to be of interest to you. These parties may use a cookie or a third-party
web beacon, or other technologies, to collect this information.
27. International Transfers
Personally identifiable information collected on the Site may be stored and processed in any country in which we
or our affiliates, suppliers, or agents maintain facilities. By using the Site, you expressly consent to any transfer of information outside of
your country. Where personally identifiable information that we collect is transferred to and processed in the United States or anywhere
else outside the European Economic Area (“EEA”) for the purposes described in this policy, we will take steps to ensure that the information
receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU
Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - US Privacy Shield. You may
have a right to details of the mechanisms under which your data is transferred outside the EEA.
28. Additional Information for California Residents
In this section, we provide information for California residents, as required under
California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain
specific information about how we handle their personal information, whether collected online or offline. This section does not address or
apply to our handling of:
* Information subject to an exemption from the CCPA.
* Publicly available information made lawfully available by state or federal governments.
* Personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and
temporary employees and staff, officers, directors or owners of Company.
* Personal information about individuals acting for or on behalf of another company, to the extent the information relates to our
transactions with such company, products or services that we receive from or provide to such company, or associated
communications or transactions.
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a
California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table
below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and
disclose to others for a business purpose. We do not sell this personal information.
California Residents’ Rights. California law gives consumers the right to make the following requests, up to two (2) times every 12-months:
* The right to request a copy of the personal information that we have collected about you in the prior 12 months.
* The right to request details about the categories of personal information we collect, the categories of sources, the business or
commercial purposes for collecting information, and the categories of third parties with which we share information.
* The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
You can submit a copy, deletion and right-to-know request by emailing us at firstname.lastname@example.org.
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on
any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of
goods or services are reasonably related to the value of the consumer’s data. We do not discriminate against consumers when they exercise
their CCPA rights.
Your California Privacy Rights under Shine the Light:
California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal
information to third parties for their direct marketing purposes during the immediately prior calendar year. As set forth in this Privacy
Policy, we comply with this law by offering our visitors the ability to tell us not to share your personally identifiable information with third
parties for their direct marketing purposes. To make such a request, consistently exercise your opt-out choice whenever you provide
personally identifiable information to us or send us a message at email@example.com. You must include this Site as the subject line, and
your full name, email address, and postal address in your message.
We may allow third-party companies to serve ads and/or collect certain anonymous information when you visit our Site. These companies
may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements
clicked or scrolled over) during your visits to this and other websites in order to provide advertisements about goods and services likely to
be of interest to you. These companies typically use a cookie or third-party web beacon to collect this information. Our Site does not
recognize browser “Do Not Track” signals but several of our service providers who utilize these cookies or beacons on our websites enable
you to opt out of this behavioral advertising.
29. Notice to European Economic Area (EEA) Residents / Your Privacy Rights: We collect, use, and share your
personally identifiable information where we are satisfied that we have an appropriate legal basis to do this.
This may be because
* You have provided your consent to us using the personally identifiable information (for example in relation to our electronic direct
* Our use of your personally identifiable information is in our legitimate interest as a commercial organization (for example in order to
make improvements to our products and services and to provide you with information you request); in these cases we will process
your personally identifiable information at all times in a way that is proportionate and respects your privacy rights, and you have a
right to object to processing as explained herein;
* Our use of your personally identifiable information is necessary to perform a contract or take steps to enter into a contract with you
(for example when you register and create an account or play in one of our tournaments); and/or
* Our use of your personally identifiable information is necessary to comply with a relevant legal or regulatory obligation that we have
(for example, where we are required to undertake vetting to comply with safety and security regulations or where we are required to
disclose personal information to a court or tax authority).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details
Your legal rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in
relation to your personally identifiable information:
Right to access Personally Identifiable Information
You have a right to request that we provide you with a copy of your personally identifiable information that we hold and you have the right
to be informed of; (a) the source of your personally identifiable information; (b) the purposes, legal basis and methods of processing; (c) the
data controller’s identity; and (d) the entities or categories of entities to whom your personally identifiable information may be transferred.
Right to rectify or erase Personally Identifiable Information
You have a right to request that we rectify inaccurate personally identifiable information. We may seek to verify the accuracy of the
personally identifiable information before rectifying it.
You can also request that we erase your personally identifiable information in limited circumstances where:
* it is no longer needed for the purposes for which it was collected; or
* you have withdrawn your consent (where the data processing was based on consent); or
* following a successful right to object; or
* it has been processed unlawfully; or
* to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personally identifiable information if the processing of your personally
identifiable information is necessary:
* for compliance with a legal obligation; or
* for the establishment, exercise or defense of legal claims
* Right to restrict the processing of your Personally Identifiable Information
You can ask us to restrict your personally identifiable information, but only where:
* its accuracy is contested, to allow us to verify its accuracy; or
* the processing is unlawful, but you do not want it erased; or
* it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
* you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personally identifiable information following a request for restriction, where:
* we have your consent; or
* to establish, exercise or defend legal claims; or
* to protect the rights of another natural or legal person.
Right to transfer your Personally Identifiable Information
You can ask us to provide your personally identifiable information to you in a structured, commonly used, machine-readable format, or you
can ask to have it transferred directly to another data controller, but in each case only where:
* the processing is based on your consent or on the performance of a contract with you; and
* the processing is carried out by automated means.
Right to object to the processing of your Personally Identifiable Information
You can object to any processing of your personally identifiable information which has our legitimate interests as its legal basis, if you
believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to
demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your Personally Identifiable Information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personally identifiable information to unaffiliated third parties for the purposes of direct
marketing or any other purposes. If you would like us to stop sending promotional communications to your email address, you may opt out
of receiving them by following the "unsubscribe" instructions at the bottom of each communication.
You may opt out of the use of your information for online interest-based advertising by following the steps detailed herein.
Right to obtain a copy of personal Personally Identifiable Information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA. We
may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your
personally identifiable information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact
your supervisory authority at any time. If you would like to exercise any of the rights described above, please send us a request at
firstname.lastname@example.org. In your message, please indicate the right you would like to exercise and the information that you would like to
access, review, correct, or delete. We may ask you for additional information to confirm your identity and for security purposes, before
disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your
request is manifestly unfounded or excessive.
You can exercise your rights by emailing us at email@example.com. Subject to legal and other permissible considerations, we will make
reasonable efforts to honor your request promptly or inform you if we require further information in order to fulfil your request.