Privacy Policy

Last revised on: August 16, 2019

1. INTRODUCTION

1.1 Betmo (“Betmo,” , “we,” or “us”) recognizes that people who use Betmo’s Service (“you” or “users”) value their privacy. This Privacy Policy details important information regarding the collection, use and disclosure of User information collected on Betmo’s sports entertainment website located at betmo.com (the “Site”), the related mobile app, and any other features, tools, materials, or other services (including co-branded or affiliated services) offered from time to time by Betmo or its affiliate companies (the “Service”). Betmo provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Service.

1.2 This Privacy Policy should be read in conjunction with our Terms of Use. By accessing the Service, you are consenting to the information collection and use practices described in this Privacy Policy.

1.3 Your use of the Service and any information you provide through the Service remains subject to the terms of this Privacy Policy and our Terms of Use, as each may be updated from time to time.

1.4 Any questions, comments or complaints that you might have should be emailed to privacy@betmo.com or forwarded in writing to:

Betmo, Inc.
100 Wilshire Blvd., Suite 1270
Santa Monica, CA 90401

2. INFORMATION WE COLLECT

By using our Service and by submitting information to us through your use of our Service then this Privacy Policy will apply. You provide certain personal information to Betmo when choosing to participate in the various activities on the Service such as registering for an account, participating in contests, posting messages, taking advantage of promotions, responding to surveys or subscribing to newsletters or other mailing lists. The personal information we collect from you generally may include:

2.1.1 your name;

2.1.2 email address;

2.1.3 date of birth;

2.1.4 PayPal or credit card billing information;

2.1.5 contacts you choose to submit;

2.1.6 profile photo;

2.1.7 username;

2.1.8 location;

2.1.9 your preferences;

2.1.10 submissions to various competitions and promotions;

2.1.11 responses to surveys;

2.1.12 communications sent to us by you;

2.1.13 your subscriptions to newsletters and services offered by us; and

2.1.14 any other information you submit to Betmo when choosing to participate in various activities on the Service.

2.2 In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you (for compliance reasons, provision of this information, when requested, is a mandatory condition of using our Service):

2.2.1 passport information;

2.2.2 driving license information;

2.2.3 other identification documents;

2.2.4 permanent and temporary address;

2.2.5 tax-related information; and

2.2.6 other information as may be required to verify you in accordance with applicable laws and regulations.

2.3 When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.

2.4 In addition, if you choose to log in, access or otherwise connect to Betmo, or contact Betmo, through a social networking service (such as Facebook), we may collect your user ID and user name associated with that social networking service, as well as any information you make public using that social networking service. We may also collect information you have authorized the social networking service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have “liked”).

2.5 Cookies Information: When you visit the Betmo.com website, we may send one or more cookies – small files – to your computer or other device, which may enable us or others to uniquely identify your browser. Betmo uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept cookies is disabled.

2.6 Log File Information: When you use our Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.

2.7 Clear GIFs Information: When you use our Service, we may employ technology such as “clear GIFs” (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

2.8 Betmo may also collect information about you from third parties, such as marketing partners, identity verification services, anti-fraud services and other service providers.

3. THE WAY BETMO USES YOUR PERSONAL INFORMATION

3.1 We use your personal information to operate, maintain, and provide to you the features and functionality of the Service, including but not limited to the following:

3.1.1 providing you with our products and services, including our games;

3.1.2 processing and responding to enquiries;

3.1.3 personalizing your use of the Service,

3.1.4 alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;

3.1.5 enforcing the legal terms that govern your use of the Service; and

3.1.6 investigating and protecting the integrity of Betmo’s contests.

3.2 We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company, such as a sports team, a sports venue, or a other entity.

3.3 We may use your information to communicate with you about:

3.3.1 our products and services in which you may be interested provided that you have not requested otherwise;

3.3.2 newsletters and information for which you have signed up; and

3.3.3 non-marketing or administrative purposes (such as notifying you of major changes to the Service or for customer service purposes).

3.3 We use your information to improve the quality and design of our Service and to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends.

3.4 We also use cookies, clear gifs, log file information, and mobile app information such as device identifiers for purposes such as (a) remembering information so that you will not have to re-enter it during your visit or the next time you visit our Service; (b) providing custom, personalized content and information; (c) monitoring the effectiveness of our marketing campaigns; (d) monitoring aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) tracking your entries, submissions, and status in promotions, sweepstakes, and contests. You can learn more about how these technologies are used in the Section below, Third Party Advertising and Analytics.

3.5 We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting and research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your mobile device, based on your web-based activity.

3.6 We will retain personal information as long as necessary to fulfill these purposes unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described here, we make backups of certain data, which we may retain for longer than the original data.

4. WHEN BETMO DISCLOSES INFORMATION

4.1 We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf in order to provide or operate the Service. For instance, these entities may have access to your information for purposes including (but not limited to) billing and accounting, hosting, marketing, promotional and email services, customer and technical support, and for the purpose of accepting deposits and paying withdrawals and processing such information on our behalf, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.

4.2 When you choose to share information with social media services about your activities on Betmo by, for example, connecting your social media account to our Service, then Betmo may share your personal information and information about your use of the Service with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Service in this way.

4.3 In the event that you win a prize we may use your personal information (such as your name and photo) in connection with publicity purposes.

4.4 In the event that you win a promotion run by us we may be required to either publish or make available upon request your name and county in accordance with applicable legislation.

4.5 We may publish a profile page that includes your username, the date you became a member, your stats from previous contests and, if you uploaded one, your profile picture. Where you post personal information about yourself through our Service to public areas of our Service, you acknowledge and agree that this personal information will be publicly available.

4.6 When you participate in a contest, we may publish your username on a list of the contest participants, along with a link to your profile page.

4.7 Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with Betmo or as part of a specific program or feature.

4.8 In addition, we may disclose to third parties various types of your information for targeted online or mobile advertising, as further described in the Section titled “Third Party Advertising and Analytics.”

4.9 We also may share personal information in other situations with your consent.

4.10 Betmo also reserves the right to disclose personal information that Betmo believes, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to court orders or official requests, to comply with state and federal regulations, including but not limited to sharing with appropriate tax authorities, to protect the security or integrity of our Service, to report violations of Betmo’s eligibility rules to third parties, including employers of inpiduals affiliated with other daily fantasy sites, and to protect the rights, property, or safety of Betmo, our users or others.

4.11 In the event that Betmo is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.

4.12 Recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as your country.

5. LEGAL BASES FOR PROCESSING PERSONAL DATA

5.1 Some laws require companies to tell you about the legal grounds they rely on to process your personal information. To the extent those laws apply, we process your personal information:

5.1.1 Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests’ in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected inpiduals:

(a) Customer service

(b) Marketing

(c) Protecting our players, personnel and property

(d) Analyzing and improving our business

(e) Processing job applications

(f) Managing legal issues

5.1.2 We may also process personal data for the legitimate interests of our affiliates or business partners, such as to offer special events or contests or assist with marketing.

5.1.3 Processing for the contract: Some of our processing of personal data is to meet our contractual obligations with our players.

5.1.4 Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.

5.1.5 Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

6. YOUR CHOICES

6.1 Betmo will process your personal information in accordance with this Privacy Policy, and as part of that Betmo provides you with certain choices about how we process your personal information. These choices are set out below.

6.2 You can access and update certain personal information Betmo holds about you at any time by logging into your account via the Service. You can update your marketing preferences and whether or not you would like us to receive marketing emails in your account. You can also unsubscribe to marketing emails and other communications by using the ‘unsubscribe’ feature in the communication.

6.3 We may occasionally send display media to you, in a targeted way, whether through web or mobile browsers or mobile applications. You may opt out of many third parties that support and send this type of targeting advertising by going to www.aboutads.info, and you may learn more about this type of advertising in the below Section titled “Third Party Advertising and Analytics.” You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms, i.e., Google (here) and Apple (here). (Please note that these companies may change either the way these settings operate, the content or the availability of these pages.)

6.4 We may occasionally send you push notifications to your mobile device. You can turn off certain push notifications in the account settings of your Betmo mobile app. You can also turn off push notifications specific to our Service in the settings on your iOS device, or through the application manager in your Android device.

6.5 You can reach us as described below with any other concerns, requests or complaints regarding our data collection, data use or data transfer. You also have a right to file a privacy complaint with the relevant privacy regulator, but we respectfully invite you to allow us to try to resolve the matter directly. We will attempt to answer your questions and satisfy your concerns in a timely and complete manner.

7. THIRD PARTY ADVERTISING AND ANALYTICS

7.1 Certain ads appearing on our Service are delivered by our advertising partners. Our advertising partners may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the ad companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each ad. This information allows ad companies to deliver targeted advertisements that may be of increased interest to you, both on our Service and elsewhere online. Just as these technologies may be used to target ads on our websites and apps, we, or our advertising partners, may use these same technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through our Service or through other services, to target advertising (for ourselves or other companies) on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

7.2 To learn more and to opt out of the collection of data on our website by third parties (including those described above) for interest-based advertising purposes, please visit www.aboutads.info/choices or www.youronlinechoices.com. Note that because this opt out method may be cookie-based, you will need to opt out again if you update or change your browser, or delete your cookies. You can also control interest-based advertising on apps on your mobile device with the AppChoices app, available for iOS and Android. Note that opting out will not affect the quantity of ads you see online but likely will cause the ads to be less relevant to you.

7.3 We also that we also work with third-party analytics companies to collect data on our Service through cookies and other automated means. In some cases, the third parties mentioned in this section may maintain the information they collect in personally identifiable form.

8. INFORMATION SECURITY

8.1 We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.

8.2 While neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.

8.3 To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.

8.4 Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.

9. YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either e-mailing us a request at privacy@betmo.com; or mailing us a request at:

Betmo, Inc.
100 Wilshire Blvd. – Suite 1270
Santa Monica, California 90401

Attention: Legal

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

10. CHANGES AND UPDATES

10.1 This Privacy Policy may be revised periodically and this will be reflected by the “Last update posted” date above. Please revisit this page to stay aware of any changes. If a revision to this Privacy Policy, in our sole discretion, is material, we will notify you by contacting you through the email address associated with your account.

10.2 Contact Information: Please contact Betmo with any questions or comments about this Privacy Policy by emailing privacy@Betmo.com.