Here are a few general principles to keep in mind as you read through this Policy:
- The Oneida Nation amended its Gaming Compact with the State of Wisconsin to expand into sports betting services within the Oneida Reservation. The services currently operate pursuant to permit issued by the Oneida Gaming Commission and the Oneida Gaming Compact executed with the State of Wisconsin and approved by the United States Department of Interior, Bureau of Indian Affairs, in accordance with Indian Gaming Regulatory Act (IGRA).
- The Oneida Nation is a federally recognized tribal government possessing sovereign powers and rights of self-government. Nothing in this Policy waives the Oneida Nation’s sovereign immunity.
- Advertisements displayed to you on the Services and elsewhere may be customized to your interests and preferences based on your Personal Information and Web site and mobile application usage information collected over time across our Services and other online properties.
- We are not responsible for the information collection or privacy practices of other web sites, including web sites accessible through the App. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any personal information on them.
What Personal Information Do We Collect?
“Personal Information” is any information that can be used to identify you as an individual. We collect different categories of Personal Information from different sources, including Personal Information you provide directly to us (“User-Provided Information” described below) and Personal Information we collect through your use of our Services (“Service Usage Information” described below). Specifically, in order to use the App, you must register for a wagering account (“Wagering Account”). When you register for a Wagering Account, we may access and collect the information you provide (including your name, postal address, e-mail address, and date of birth) by which you can be personally identified. We may also ask you for additional information including your mobile phone number, social security number, and a government-issued photo identification such as your driver’s license, state identification card, or passport. We will also verify whether you have a current Players’ Club Account. If you do not have a current Players’ Club Account, you will be required to create a Players’ Club Account as part of the registration process, which will require you to register in person at a designated Oneida Casino location. The App is intended for persons 21 or older. If you are under 21, you may not access or attempt to access or use the App. We do not knowingly collect or allow the collection of personal information from persons under 21.
When Do We Collect User-Provided Information?
We collect User-Provided Information when you create an account on the Services; login to your account; place a wager or conduct any other transaction on the Services; sign up for our communications; enter contests or sweepstakes; complete surveys; contribute to our online forums; communicate or transact with other users; or submit a comment or question to us using a “contact us” or similar feature on the Services.
Unless otherwise noted on an online form, you are required to provide to us all Personal Information requested to register your account, complete your transaction, or make your request. If you do not provide the required Personal Information, you will not be able to place your wager or conduct your transaction or we may not be able to respond to your request. An example of this is your payment card information, billing address and mailing address when you make a transaction, or your email address when you sign up to receive emails from us.
A referral or similar tool may be provided on the Services and/or in our emails that allows you to send information about our offerings to another person. When you use these offerings, we may ask you for the name and information of the other person, and that information will be handled pursuant to this Policy.
When Do We Collect Service Usage Information?
In addition to User-Provided Information, we collect other Personal Information about you and your online activities related to the Services (“Service Usage Information”), including as described below.
- Location, Gaming, and Transaction Information. When you use the App, we and our third-party service providers may collect information about your precise physical location, your gaming activity, and all transactions associated with your Account. We may share this information, and any other information we collect about you for purposes maintaining the integrity of our services and with parties that share enforcement responsibilities related to sports wagering including the State of Wisconsin, state and local law enforcement and applicable sports organizations.
- Wi-Fi and Location Information. In order to use the App for on-premises mobile gaming, you may be required to use designated Wi-Fi services that will be made available to you at no cost on premises. When you use these Wi-Fi services, we might collect information (directly or through third party service providers) that includes the web sites you visit, the type of device and browser you are using, your device identification number, bandwidth used, session time, etc. We might also collect information about your precise physical location on premises for marketing purposes.
- Affiliate and Third-Party Information. We may obtain information about you from Oneida Nation and casinos, resorts, platforms, and properties that are owned, operated, managed by or affiliated with Oneida Nation (collectively “Oneida Nation”) and from third parties, including our business partners and other companies and individuals that refer you to the App. This information may include, among other things, information related to your Wagering Account that we need to make the App available to you, information to set up your Wagering Account and information necessary to connect your Wagering Account to your account with one or more of our business partners, including, but not limited to, your Players’ Club Account.
Do We Share Personal Information About You with Others?
Yes. We may share the Personal Information we collect on the Services with others for a variety of reasons. Due to the legal, regulatory and security environment in which we operate, we may be required to disclose information about you under certain circumstances, and we may not be permitted to inform you that we have done so.
- Use by Oneida Casino. Marketing Purposes. We may use the information we collect in connection with the App for our own marketing purposes including notifying you of special promotions, offers, and events via push notifications, e-mail, and other means. We may also link personal information (including your name, mobile phone number, and e-mail address) with non-personal information (including information collected through Tracking Technologies and Wi-Fi services) and use such information for our own marketing purposes. If you do not want us to use your personal information for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.
If you provide a cell phone number and expressly consent to receive text messages form us, you expressly consent to receive recurring informational and transactional texts – including texts made using an auto dialer – from or on behalf of us to the number you provided. By providing a cell phone number expressly consenting to receive SMS messages from us, you warrant and represent that you are either the account owner of the cell phone number you provide to us, or you have the express permission of the account holder to provide the number and to consent to automated texts to that number.
Although there is no fee associated with this service, your carrier may charge you for each message you receive in accordance with your calling plan. You agree that we are not responsible in any way for such charges. You can stop receiving text messages from Oneida Sportsbooks at any time. Just text “stop” in response to any SMS message you receive from us. After you send this SMS message “stop” to us, we will send you a single message to confirm that you have been unsubscribed. After this, you will no longer receive text messages from us. If you want to join again to receive messages, just sign up as you did the first time, and we will start sending messages to you again.
Non-Marketing Purposes. We may use the information we collect in connection with the App for non-marketing purposes including (1) validating your identity; (2) sending you push notifications or e-mails to provide you with alerts and updates about your Account and the App; (3) monitoring, accessing and recording gaming-related activity; (4) conducting statistical or demographic analysis; (5) processing and tracking gaming and non-gaming transactions; (6) complying with legal and regulatory requirements; (7) customizing your experience with the App; (8) protecting and defending us and our affiliates against legal actions or claims; (9) preventing fraud; (10) debt collection; (11) satisfying contractual obligations; and (12) safety and security purposes including cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest (collectively “Non-Marketing Purposes”).
B. Sharing with Oneida Casino Affiliates. We may share the information we collect in connection with the App with Oneida Affiliates for marketing purposes and for Non-Marketing Purposes. If you do not want us to share your personal information with Oneida Affiliates for marketing purposes, you may opt-out in accordance with the “How to Opt-Out section below.
C. Wagering Account and Players’ Club Account Information. Regarding sharing of information with International Gaming Technology, PLC, (IGT) and our affiliates about your Wagering Account and your Players’ Club Account, by registering for a Wagering Account and using the App, you expressly acknowledge that you understand and agree that (subject to compliance with applicable laws and with your express consent where required) we will provide IGT with certain information related to your gaming activity that is necessary for IGT to provide its services to us with respect to your Wagering Account and your use of the App, including but not limited to: (1) the amount of money credited to, debited from or present in your Wagering Account; (2) the amount of money you wagered on any game or gaming device; (3) your Wagering Account account number and secure personal identification method that identifies you; (4) the identities of particular entities on which you are wagering or have wagered on in the past; and (5) your name, address or other information that we possess that would identify you to anyone other than us or applicable gaming regulators (“Account Information”). The Account Information we will provide to IGT represents the information that IGT needs to operate and manage certain functions of the App. We will also provide certain affiliates with certain Account Information that is necessary for those affiliates to administer your Players’ Club Account, including, but not limited to, information those affiliates needs to provide you with certain benefits and rewards as more fully described in the terms applicable to your Players’ Club Account. For opt-out information specific to your Players’ Club Account and its connection with your Wagering Account, please see the “How to Opt-Out” section below.
E. Service Providers. We may engage service providers to provide certain services to us or to perform certain services on our behalf including analytics, marketing, fulfillment, etc. In some cases, service providers may collect or be provided with access to your information related to the App as reasonably necessary to perform such services on the condition that they not use or disclose your personal information for other purposes.
F. Certain Business Transactions. We may share all of the information we collect in connection with the App with any successor to all or part of our business in connection with a transaction involving a sale, purchase, reorganization, merger, or transfer of any our assets or the assets of Oneida affiliates.
How Can You Opt-Out of Marketing from Us and Having Your Personal Information Shared with Others for Marketing Purposes?
You may tell us that you do not want to receive our promotional messages or that you do not want us to share your Personal Information with third parties for their marketing and other purposes by:
- Logging into your App Wagering Account and changing your communications preferences in settings.
- Writing to us with your name, address, email and phone number and indicating whether you are asking us to: (1) stop sharing your information with third parties for their marketing and other purposes, or (2) using your information for our marketing purposes, including whether you would like us to stop sending you a particular media notification via email or, if applicable, text message. Send your communications to: Oneida Casino P.O. Box 365 Oneida, WI 54155
- Clicking on the opt-out link in any promotional emails you may receive.
We may take a few days to process an opt-out request. Although you may opt-out of the use and sharing of personal information for marketing purposes, we may still use and share information we collect for Non-Marketing Purposes.
How Can You Access Your Information and How Long Do We Retain Your Information?
We will retain the information we collect about you as long as your Wagering Account is active. When your Wagering Account is terminated, we will retain your personal information for as long as necessary to comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements. You may access, update, and correct inaccuracies in your personal information which is in our custody and control by visiting the location where you registered for your Wagering Account or another Oneida Casino designated location.
How Do We Protect Your Information?
Information collected by us through the App is stored on secure servers located in the United States. The United States may not offer a level of privacy protection as great as that offered in other jurisdictions. We make no representation that the practices described in this Policy are compliant with laws outside of the United States.
Our servers are protected by firewalls and other industry standard security measures. These security measures are intended to protect our servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. We have controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach.
Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information. Employees who violate our privacy policies are subject to disciplinary action, up to and including termination of employment.
We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you may use to send e-mails and submit information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of information that you send us before we receive it.
As a standard security practice, we will take reasonable steps which are generally recognized in the industry to ensure that the communication methods used to support the App do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using the App, it may be an indication that you need to upgrade your internet browsing tool or application to a newer version that supports more secure communication methods.
In situations where your personal information is collected by third parties under contract with us for performance of their contractual duties and other purposes, we require such third parties to exercise reasonable care to protect that information and restrict the use of your personal information to the purposes for which it was provided. When we share your personal information with Oneida Affiliates or third parties in accordance with this Policy, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them.
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date”. In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an email to the email address we have on file for you. In some cases, we may request your consent to the changes.
If you have any questions or comments regarding our privacy practices, you may contact us at: Postal Address: P.O. Box 365, Oneida, WI 54155
Effective Date: October 14, 2021