My Player Perks Program – Privacy Notice (For Website & Mobile)

Last Updated July 12, 2023

 

This Privacy Notice describes the information collection, use, retention and sharing practices of Eureka Entertainment, LLC d/b/a Universal Gaming Group (“UGG”, “we”, “us”, “our”) when you interact with us through the My Player Perks website, https://www.myplayerperks.com/ (the “Website”), the My Player Perks app (the “App”), or other digital products on which this Privacy Notice appears (collectively, the “Services”). This Privacy Notice also applies to when you interact with us offline, such as when you visit participating UGG video gaming locations, a full list of which can be found by visiting https://www.myplayerperks.com/ (each, a “Participating Location”).

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG

We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you, when you engage with the Services. We collect personal information from a variety of sources and in a variety of ways, including when you:

  • Enroll in the My Player Perks reward program. When you enroll in the My Player Perks reward program (the “Program”), we collect, from you, your personal identifiers (name, telephone number, email address, physical address, date of birth). We use this information to enroll you in the Program, set up your Program account (“Account”), communicate with you about your Account, and facilitate your access to your Account in the future (i.e., you can log in using your telephone number). If you choose to provide this, we also collect your protected classifications (gender) in order to better understand our market and build programs and communications that are better tailored to the relevant gender. We also use this information to: (i) verify your identity and the identification information you provide; (ii) confirm your state of residence; (iii) comply with our legal and regulatory obligations of allowing gambling only from persons who have been properly identified, , and are twenty-one (21) years or older at the time of enrollment; (iv) prevent fraud and illegal activity; and (v) determine your eligibility to participate in the Program. If you opt in during the enrollment process (or later decide to opt in) to receive marketing or promotional emails from us, we will use this information to send you marketing or promotional emails. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email. However, we will continue to send you transactional or service-related messages. Our emails include a tracking pixel that tracks whether you open the email, whether you click banners in the email, and your subsequent clicks and usage of the Website. We use this information to send you additional email communications which may be of interest to you, as based on your interaction with our emails and/or the Services. You can avoid downloading the pixel by rejecting the download of images in the email. If you opt in during the enrollment process (or later decide to opt in) to receive marketing or promotional text messages (e.g., SMS or MMS) from us, we will use this information to send you marketing or promotional text messages through an automated telephone dialing system. Consent is not a condition of any purchase. Reply STOP to cancel. Message frequency varies. Message and data rates may apply. For additional information, please see our Terms of Use http://myplayerperks.com/terms-of-use/ . We retain this information until you delete your Account or is otherwise terminated.

  • Sign-in to your Account. When you sign-in to your Account, we collect, from you, your personal identifiers (username and password). We use this information to authenticate you and grant you access to your Account. We retain this information until you delete your Account or is otherwise terminated.

  • Check-in at a Participating Location. When you perform a Location Check-in (as defined in the Terms of Use http://myplayerperks.com/terms-of-use/ ) at a Participating Location via the App, we collect, through our third-party provider, your precise geolocation data (determined through a web beacon) during when you are in close proximity to a Participating Location. We use this information to confirm your presence at a Participating Location and to determine whether to allocate you UGG Points for your Location Check-in. If you choose to perform a Location Check-in using the Program Tablet (as defined in the Terms of Use http://myplayerperks.com/terms-of-use/ ), we collect, from you, your personal identifiers (telephone number). We use this information to authenticate you and grant you access to your Account to determine whether to allocate you UGG Points for your Location Check-in and offer you the ability to see your transaction history. If you disable the location beacon you will not be able to check in at any Participating Location. We retain this information until you delete your Account or is otherwise terminated.

  • Redeem a reward. When you redeem a reward, we will collect, from you, your personal identifiers (username, password, telephone number) If you redeem UGG Points for a reward that cannot be electronically fulfilled (e.g., e-gift card), we will collect, from you, your physical address. If you redeem UGG Points for an e-gift card, we will collect, from you, your email address. We use this information to administer your reward. If we suspect fraud, we may ask you to provide your sensitive identifiers (driver’s license or government-issued ID). We retain this information until you delete your Account or is otherwise terminated.

  • Request for information or ask a question. When you contact us to request information or ask a question, we collect, from you, your personal identifiers (name, email address, and telephone number) and any information you choose to include in your message. We use this information to respond to your question(s) or provide the information you requested. We retain this information until you delete your Account or is otherwise terminated.

  • Complete a survey. When you complete a survey, we collect, from you, your personal identifiers (name and email address) and your survey responses. We aggregate the survey results and use this information to identify market trends. If, however, you request to discuss your survey responses with us in greater detail, we will review your survey responses on an individual level and contact you using the email address you provide. We retain this information until you delete your Account or is otherwise terminated.

  • Enter sweepstakes. When you enter a UGG sweepstakes, we collect, from you, your personal identifiers (name, telephone number, email address, physical address). We use this information to manage your entry, communicate with you about your entry, and to conduct the sweepstakes. We retain this information until you delete your Account or is otherwise terminated.

  • Interact with us at in-person events. When you interact with us at in-person events, we will collect, from you (if you choose to provide), your personal identifiers (name, email address, and telephone number). We use this information to enroll you in the My Player Perks program. We retain this information until you delete your Account or is otherwise terminated.

  • Interact with us on social media. When you interact with our fan page on social networking websites, such as Facebook, Twitter, Instagram, TikTok, and/or YouTube (each a “Fan Page”) (collectively “Fan Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Facebook, Twitter, Instagram, TikTok, and/or YouTube use your personal information, please see: Facebook’s Privacy Policy , Twitter’s Privacy Policy, Instagram’s Privacy Policy, TikTok’s Privacy Policy , or YouTube’s Privacy Policy.
  • Fan Pages. When you interact with our Fan Pages, we collect, from you, your personal identifiers (Fan Page username/alias and profile picture) as well as any information that you provide when interacting with our Fan Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. If you directly message us or comment on our Fan Pages, with a suggestion, question, or an assistance request, we will collect your identifiersand information about your request and will reply either via the same channel or via the email address you provided in order to assist you.

Because our Fan Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments, or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.

The content posted on our Fan Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to rewards@myplayerperks.com.

  • Community Management. With the help of a third party, we collect, from you, your contact, including "likes", shares, messages, and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. We use this information to create advertisements that match our Fan Page and to disseminate them via Facebook based on demographic data.

  • Facebook Messenger. When using Facebook messenger, Facebook collects, automatically, your internet or other electronic network activity information (IP address, date and time of the server request, time zone, specific browser or app function, access status, amount of data transferred, browser or app from which the Request comes, device type, operating system used, and its interface (e.g. Android or IOS), language, version of the operating system, and device identifiers). We do not use this information; its use is governed by Facebook’s Privacy Policy.

  • Events and Photos. When you register for an event on our Fan Pages, we collect, from you, your personal identifiers (Fan Page username/alias) and the attendance preference you indicate. We use this information to create and manage the event (e.g., to create the guest list, accreditation and admission control, room and personnel planning, planning the catering) as well as to send you your invitation and notifications about the event.

At events for which you have registered, photos and video recordings may be made (possibly by a photographer commissioned by us), in which you may also be shown. If you are the central subject of a recording or photograph, the photographer will ask you before the recording/taking the photo whether you agree and consent.

We use the photos for our public relations and marketing on our various media/digital media outlets.

  • Facebook Page Insights. When you visit our Facebook Fan Page, Facebook records your IP address and other information about your usage behavior on our Facebook Fan Page. Facebook collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Facebook app through your mobile device (e.g., smartphone or tablet). Facebook uses this information to create statistical evaluations for us of the use of the Fan Page. We receive this information, from Facebook, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age, gender, city/country, device, inquiries from fans about other Facebook fan pages, region and language settings of the users, proportion of men and women, the number of people reached, clicks on posts, "Likes” and reactions, comments and shared content, and total video views. We do not collect or process any other personal data in connection with the page insights.

We do not retain this information independently. For information on data protection and the storage period on Facebook in relation to the "Page Insights" function see here and Facebook’s Privacy Policy. It has been contractually agreed with Facebook that Facebook is responsible for providing you with information about the processing for Page Insights.

  • Information Processed Solely by Facebook. We do not know how Facebook uses personal information for its own purposes, how long the personal information is stored on Facebook or whether Facebook data is passed on to third parties.

If you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g., smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Fan Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered. You can find more information about the personal information collected by Facebook, how it is used and how long it is stored by visiting Facebook’s Privacy Policy.

  • When you interact with the Services. In addition to the personal information you provide directly to us, we also collect information automatically via cookies, trackers, SDKs, web beacons, and similar technologies as you use the Services. This information includes the following internet or other electronic network activity information .

We use essential and performance cookies, and similar technologies such as SDKs to collect your usage, device, and location (determined through a proximity beacon) information when you interact with the Services. We use this information to: (i) provide the Services; (ii) remember your preferences; (iii) prevent fraudulent use of the Services and detect unlawful activity; (iv) diagnose and repair Services errors, and, in cases of abuse, track and mitigate the abuse; (v) verify your Account and eligibility; and (vi) facilitate your Location Check-ins.

We use a proximity beacon to facilitate your Location Check-ins. When you arrive at a Participating Location and activate the App, the App connects to a nearby proximity beacon that confirms your presence at the Participating Location. In doing so, the proximity beacon relies on an app-specific identifier that is used to identify a unique app user. This identifier is associated only with the App and is not tied to your mobile device. If you do not want the proximity beacon to identify your mobile device, you can delete the App or turn “off” your Bluetooth through your device’s Settings feature. However, if you delete the App or turn “off” your Bluetooth, you will not be able to perform a Location Check-in using the App.

  • Aggregate data. We aggregate the data we collect for benchmarking purposes and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

UGG will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in SHARING OF YOUR INFORMATION.

We may need to use and retain your personal information for longer than the periods indicated above for purposes of:

  • Compliance with our legal obligations. For example, we may retain contract and transaction information for the purpose of accounting, dispute resolution, and compliance with tax, escheatment, anti-money laundering, and other financial regulations.

  • Meeting our safety and security commitments. If a user has been reported or flagged for violations of our Terms of Use, we may retain information longer than the periods indicated above. This information helps us keep our Services and properties secure, prevent fraud, and deter behavior that violates our policies.

  • Exercising or defending legal claims. When you contact us directly (such as for customer support inquiries), we retain relevant information for as long as is necessary to exercise or defend our legal rights. We also may need to retain information for longer than the periods indicated above to meet with legal process or enforceable governmental requests, or to enforce our applicable Terms of Use, including investigation of potential violations.

SHARING OF YOUR INFORMATION

General Sharing

UGG shares personal information in the following instances:

  • Within UGG. We may share your personal information with our subsidiaries and affiliates for legitimate business purposes, general business management, and as permitted by law.

  • For legal purposes.We share your personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.

  • In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

  • With service providers. We share your personal information with service providers that assist us in providing the Services. These service providers assist us with the following: information technology support; email delivery; text messaging; cloud storage; beacon tracking and similar services.

  • With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect going forward by emailing us at rewards@myplayerperks.com .

 

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information:

  • Correct or View Your Information. You may log-in to your Account or email us at rewards@myplayerperks.com to correct or view your personal information.

  • Opt Out of Other Cookies. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/ Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

o Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/

o Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp

o Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info

o European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu

o In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent.

  • Opt Out ofEmail Tracking.You can disable this tracking by blocking automatic loading of images in your email.
  • Opt Out of Marketing Communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Reply STOP to opt out of receiving promotional text messages from us. Please note that we will continue to send you transactional or service-related messages.

  • Opt Out of Proximity Beacon. If you delete the App or turn “off” your Bluetooth, the proximity beacon will not work but you will not be able to perform a Location Check-in using the App.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

 

INFORMATION FROM PERSONS UNDER TWENTY-ONE (21) YEARS OF AGE

The Services are not for use by any person under the age of twenty-one (21). We do not knowingly accept or collect information from anyone under the age of 21.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US

If you have any questions or concerns regarding this Privacy Notice, please contact us via email at rewards@myplayerperks.com .