PlayNow and Player Privacy Policy

“Aggregate information” – information collected by combining information about an entire group of people

“Non-identifiable information” – information that cannot be associated with an identifiable individual, and cannot be used to distinguish one person from another.

“Personal information” – information about an identifiable individual.

MBLL is required to comply with The Freedom of Information and Protection of Privacy Act (Manitoba) when collecting, using, disclosing, managing and safeguarding personal information. We collect information about you when you register, when you communicate with Customer Support and when you sign in and use the Service. We collect personal information and non-identifiable information. Other information is collected in the aggregate. In some cases the aggregate information may still be personal information, while in other cases it is non-identifiable.

 

Personal information you provide to us

We collect the following types of personal information on the Service:

• Contact: Name, address, telephone number, email address.
• Identity verification and registration: date of birth, gender, user name, government-issued identification, photograph, biometrics – photo of yourself to match with your identification, answers to security questions, password, credit card information.
• Occupation: occupation category and job title.
• Transaction: Bank account information, transaction and play data, play preferences.
• Communication: Customer support questions and requests, in-game chats.
• Winner information: Photograph, name, geographical location of residence of winners.
• Location: IP address, location coordinates.
• Survey and contests: Survey responses, demographic information (such as postal code and age group), feedback, contest entry and contact information.
• Casinos of Winnipeg Club Card membership number (optional): When provided, this number facilitates a link from your PlayNow player record to a Club Card program record.

 

Technical information we collect automatically

We also collect information using technology. This information is collected automatically as you view and use the Sites. In some cases, this information may be considered personal information.

 

Cookies and other Technologies

Cookies

MBLL uses cookies which are small text files that are stored in a folder of your web browser on your device when you visit the Sites to distinguish you from other users accessing the Sites. Information is transmitted between our web server and the browser you are using. Cookies help in identifying a device and the browser that is used to access the Sites. We employ session and persistent cookies. Session cookies expire when you close your browser and are helpful so that you are remembered during a browsing session. Persistent cookies last for an extended period of time (or until you delete these) and are useful to retain your settings.

Cookies are intended to enhance your experience on the Sites and the administration of the Sites. Different types of cookies are used for different reasons, including:

• Personalizing and retaining your settings: If you are remembered as a visitor to the Sites, your settings may be retained whenever you access the Sites e.g. game preferences.
• Log in credentials: We store an encrypted cookie once you have logged in. These cookies allow you to navigate pages on the Sites without repeatedly logging in again.
• Customize content and advertising: Cookies enable us to serve you customized content that is aligned with your browsing habits e.g. if you indicate an interest in Sports products by clicking on Sports related pages, we may make suggestions on new Sports games or serve you advertisements compatible with this interest. It also helps us to manage advertisement frequency;
• Analytics: Information is collected in aggregate to gauge the effectiveness of the Sites and to better understand our visitors, such as which pages of the Sites are visited, how many visitors access the pages on the Sites, which areas of the Sites are clicked on more frequently and the referral websites from which visitors arrive at the Sites. This information helps us to make improvements to the Sites. We use tools such as Google Analytics and Mouseflow for this purpose.

We may also use additional analytics programs from time to time to process non-identifiable information about you.

Non-identifiable information may be permanently archived for future use in any manner whatsoever by MBLL.

MBLL and its partners use cookies or similar technologies described in this document to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Information collected may be personal or non-identifiable, and collected in aggregate or on an individual basis.

You may control and disable cookies using your browser settings. If you disable some or all cookies you may still use the Sites; however, your ability to use the Sites will be limited and you won't be able to log in.

If you'd like to opt out of having your information tracked by Google Analytics, download  If you'd like to opt out of information tracked by Mouseflow, turn on the 'do not track' option in your browser or 

 

Behavioural Targeting

Cookies & eTags

We partner with third-party marketing and advertising organizations, including Facebook, to either display advertising on the Sites or to manage our advertising on other websites. Our third-party partners may use technologies such as cookies and eTags to gather information about your activities on the Sites and other websites in order to provide you with advertising based upon your browsing activities and interests. Information collected may be personal or non-identifiable, and collected in aggregate or on an individual basis. If you do not wish to have this information used for the purpose of serving you interest-based ads,  Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

Web Beacons

Web beacons, also called clear gifs are tiny graphics with a unique identifier that are embedded invisibly on pages on the Sites. We use these tools to help us deliver cookies and to understand the usage on the Sites e.g. which pages are being accessed more frequently. This helps us to better manage content on the Sites. Information is collected in aggregate, and we do not identify individuals when using web beacons on pages on the Sites.

We also use web beacons in our HTML-based emails and newsletters to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of our marketing campaigns and make improvements where necessary. Information collected is personal information, and may be collected in aggregate or on an individual basis.

Log Files

We gather certain information automatically and store it in log files, such as internet protocol (IP) addresses, location coordinates, operating system, date/time stamp, device make and model, player ID and transaction activities and winnings. This information is only used to monitor activity on our systems for security and fraud investigation purposes and to ensure we comply with applicable laws. Information collected is personal, and may be collected in aggregate or on an individual basis. We do not use or combine this information with other personal information we collect about you without your consent.

Location Information

We acquire location information (i.e. IP addresses and location coordinates) when you log in and periodically while you are logged in to ensure players are accessing their account from within Manitoba due to our legal obligations, and where necessary, to assist in security and fraud investigations. This personal information is collected on an individual basis, but may also be collected in aggregate format for analytical purposes.

In order to access your account (e.g. to view your transactions, play games or purchase lottery tickets), location services on your device must be turned on. You also have the option to turn off location services on your device or deny the permission request for location when logging in. This will result in you not being able to access your account but you will still be able to view the Sites.

We do not use or combine this information with other personal information we collect about you without your consent unless required for security and fraud investigations and to comply with applicable laws.

Flash LSOs

We use local shared objects, also known as Flash Cookies, to store your preferences (such as volume control) or to display content based upon what you view on our site to personalize your visit. Our third-party vendors use LSOs such as HTML 5 or Flash to collect and store information to provide certain features on our Sites or to display advertising based upon your web browsing activity. Information collected may be personal or non-identifiable, and collected in aggregate or on an individual basis.

Various browsers may offer their own management tools for removing HTML5 LSOs. 

Biometrics Verification - Selfie

With your consent we may use facial image scan services provided by our service providers to help verify your identity, to authenticate you as an authorized user of our services, and to investigate, detect and prevent fraud. These biometric identity verification providers compare facial scan data extracted from your photo on your government-issued identification to the facial scan data extracted from a selfie photo you upload, and then report back to us if there is a match. These scans and associated results may constitute biometric information or biometric identifiers (collectively referred to in this Privacy Policy as ‘biometric data’) under applicable laws. Any biometric data will be managed by our biometric identity verification providers.

You may decline to use the biometric verification process and verify your identity with PlayNow through other means, such as contacting PlayNow Customer Support, but this may limit our ability to complete the verification process required to use our Sites in a timely manner.

Links to Other Sites and Social Media Features

Our Sites may contain links to and content of other websites, and social media features (such as the Facebook Like button and the Twitter Tweet button) that are not owned or controlled by MBLL. These third-party websites and social media features may collect information such as your IP address or location co-ordinates, which page you are visiting on the Sites, and may set a cookie to enable the features to function properly. Information collected may be personal or non-identifiable, and collected in aggregate or on an individual basis by those third parties and sites.

These other websites, content and features are governed by the respective third-party's privacy policies and MBLL is not responsible for the privacy practices of such other websites, content and features.

Your personal information is collected and used primarily to enable you to enjoy the Service and to maintain the security of the Service.

In greater detail, your personal information is used for the following purposes:

• to register you for the Service, which includes: ensuring you meet the age (18+) and residency (Manitoba residents only) requirements and accessing your credit file (only for identity verification and not as a credit check. This will not affect your credit rating or credit score);
• identifying you when you first register, subsequently log in or make queries about your account;
• to administer your account, complete transactions and provide you with information and access to the Service and the products you have requested;
• to facilitate deposits into your PlayNow account and to facilitate withdrawals from your bank account (if you request this);
• to provide assistance and support to you when using the Service, such as when you initiate a live chat session;
• to communicate with you about your account, including providing you with security information, transaction information and to respond to your requests;
• to send you electronic promotional communications (if you consent);
• to administer promotions and contests that you enter (including, contacting you if you win);
• for conducting and inviting you to participate in research and surveys (including, compiling research and survey results to better understand our players so that we may enhance the Service);
• to administer responsible gambling programs (if you enroll in the program);
• for winner publicity purposes including publishing winners' names, photographs, amounts won and geographical location of residences in accordance with the terms of the PlayNow.com Player Agreement and other rules governing games available through the Service. Winners' stories, videos, additional photographs and additional information are also published for marketing purposes with additional consent;
• to customize the content and delivery of our products, services and marketing;
• to maintain the security of the Service, including ensuring only you access your account and for investigating fraudulent activity;
• to determine your location to ensure you are accessing your account from Manitoba as we are required by law to ensure you are playing within Manitoba;
• to enforce our agreements, to comply with applicable laws (for example, the and legal processes, including, providing information as required by our regulators, law enforcement or quasi-enforcement agencies, or other government agencies; and
• to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you.

 

Access to Information

MBLL has access to information collected by the Sites. MBLL staff are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Personal information will only be collected and used by authorized staff in a manner consistent with the activities of MBLL.

We will only disclose your personal information to those individuals and organizations who need to access your information in relation to the Service. This includes our primary service provider, British Columbia Lottery Corporation (BCLC), as well as third-parties who we contract with including an online betting platform provider, identity verification provider, payment processor, email/mail service solutions, marketing service providers, a mobile services vendor, and research companies. We will not sell your personal information. These companies are authorized to use your personal information only as necessary to provide these services to us. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal information they receive from us for any other purpose.

We may also disclose winner information and/or winner stories with Western Canada Lottery Corporation (WCLC) for the purposes of publishing lottery wins.

We may also disclose your personal information to any other third-party with your prior consent.

In addition, we may be required to disclose your personal information to specific parties when required by law, such as to comply with a subpoena or a request by public authorities to meet national security or law enforcement requirements, to protect our rights, protect the security of the Service and the security of our players, protect your safety and the safety of others, and to investigate fraud. In these limited cases, we may be unable to, or are not permitted to, provide prior notice of such disclosure.

Aggregate personal and non-identifiable information is disclosed to our marketing and advertising partners as described in the Behavioural Targeting section of this document.

We may also disclose your personal information in connection with a corporate re-organization, a merger or amalgamation with another entity, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

The authorized third-party service providers and the third-party services we use are located inside and outside of Canada and/or store and access information both inside and from outside Canada. Your consent is obtained for the disclosure, access from and storage of personal information outside of Canada when you register for the Service and agree to the PlayNow.com Player Agreement.

Your personal information may be stored and processed in any country where we engage third party service providers (e.g. Canada, United States). While such information is outside of your country of residence, it is subject to the law of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices will at all times continue to be governed by this Privacy Policy.

MBLL has measures in place to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. These measures typically include contractual safeguards stipulating the confidentiality of the information and the purposes for which it is to be used.

If you have questions or concerns relating to the location of your personal information, please contact .

You may log in to your account at any time to access your personal information.

To update your information, such as your email address, telephone number and communication preferences, simply log in to your account. For address updates, after logging in, you must also provide your credit card information which will help us to verify that only the correct person is updating these details. For all other updates, viewing, deleting or other questions about accessing your personal information, please contact .

Upon request, MBLL will provide you with information about whether we hold any of your personal information.

Also upon request, MBLL will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information.

If you wish to access additional records containing your personal information, you may be required to submit a formal request by following the steps on the  Information provided using this personal information request process will be provided at a minimal or no cost to you.

We follow generally accepted industry standards to protect the personal information submitted to us against unauthorized access, use, copying, modification, disclosure, destruction, and any other lawful form of processing of your personal information in our possession regardless of the format in which it is held. When you enter sensitive information (such as a credit card number), the transmission of that information is encrypted using transport layer security (TLS) and our payment processor is required to handle the data in a manner consistent with the Payment Card Industry's Data Security Standards (PCI-DSS).

We ensure there are access controls in place to restrict the viewing and access of your personal information to those individuals who need-to-know the information and to protect the confidentiality of your personal information.

To safeguard personal information within our network, we have implemented and employ network security controls, intrusion detection and intrusion prevention systems, logging and monitoring, and vulnerability management. We also employ anti-malware programs, use industry standard encryption, firewalls, store data in secure servers and physically restrict access to our buildings to ensure our systems are reasonably secure.

All employees undergo mandatory privacy and security training and must comply with privacy and information security policies.

MBLL’s contracts with third-party service providers who handle personal information contain privacy protection provisions to ensure our service providers protect your personal information in an appropriate manner.

To maintain the security of your account, there are also some measures you can take, such as keeping your password and security questions confidential, not sending any sensitive personal information by email (you may use the Site's  to securely send information to us), maintaining up-to-date virus protection software and regularly monitoring your account activity.

Still, no system can be guaranteed to be 100% secure.

We cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you do so at your own risk. We also cannot guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, and in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.

 MBLL takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.

If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately pursuant to Section 9 of this Privacy Policy.

Upon registration, you can choose whether or not you wish to receive promotional communications about our products and services. You are able to change this preference at any time under Edit Profile on your My Account page or by following the unsubscribe instructions included in these emails.

If you require assistance to change your preferences, please contact 

If you choose to play lottery games on PlayNow.com, we will send you a courtesy email notification if you win with instructions on how to verify your prize and how to claim winnings. We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.

We will retain your information for as long as your account is active and as needed to provide services to you. If you decide to cancel your account or if we need to cancel your account (e.g. if you are not complying with the terms of the PlayNow.com Player Agreement), we will retain and limit use of your information as necessary to comply with the applicable retention periods, our legal obligations, to resolve disputes and to enforce agreements.

MBLL will only retail personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy Privacy, to comply with MBLL and its third-party service providers’ legal and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may also retain aggregated non-identifiable personal information indefinitely after your account has been closed for research or statistical purposes.

Please note, if you are a registered user of the Sites and your account becomes inactive, MBLL may choose not to retain your User Content, personal information associated with your MBLL account, or any other records associated with your MBLL account, for a period longer than three years after your MBLL account becomes inactive, in which case such information may be destroyed. If your MBLL account becomes inactive, you are solely responsible for exporting any such information from your MBLL account that you may wish to retain.

Contact Customer Support by:

• Completing the  on PlayNow.com
• Telephone: 1-877-706-6789
• Using the  feature on PlayNow.com
• Mail: PlayNow Customer Support at 74 West Seymour Street, Kamloops, BC V2C 1E2

If we are unable to resolve your privacy concerns, you may contact MBLL’s Privacy Coordinator at:

• Mailing Address: Privacy Coordinator, A - 1555 Buffalo Place, Winnipeg, MB R3T 1L9
• Email: privacy.compliance@mbll.ca
• Telephone: 204-957-2500 ext. 2552

MBLL will promptly investigate all complaints concerning our compliance with the Privacy Policy and our dealings with your personal information. If a complaint is found to be justified, MBLL will take appropriate measures to resolve the complaint, including, if necessary, amending our policies and procedures. You will be informed of the outcome of the investigation regarding your complaint.

We may update this Privacy Policy to accommodate changes in our services, changes in technology and legal developments. If we make significant changes to this Privacy Policy, such as using personal information for a new purpose or disclosures to new third parties, we will provide notice through our Services, or by other means. For example, we may issue an account message to you through the Service or email you to let you know of an updated Privacy Policy. We encourage you to periodically review the latest information on our privacy practices.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your personal data without your knowledge or consent where this is required by law.

You acknowledge that your continued use of the Service after we modify this Privacy Policy, publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

If you object to any changes to the Privacy Policy you may close your account.

 

Withdrawing Consent

You may withdraw your consent to the collection, use or disclosure of your personal information by MBLL and its service providers at any time, subject to legal or contractual restrictions and reasonable notice. In most circumstances, your withdrawal of consent may result in the inability of MBLL to continue providing aspects or optimization of the Service to you.

Whenever we update the Privacy Policy, we will change the date below to indicate when the changes were made.

This Privacy Statement was last updated on December 14, 2023.