Stars Affiliate Club Program Privacy Policy

Identity of Data Controller. For the purposes of this privacy policy (“Privacy Policy”), the “data controller” (i.e. the person responsible for the capture, storage and use of your personal information) is TSG Interactive Services Limited (“TSG”), who can be contacted at Douglas Bay Complex, King Edward Road, Onchan, Isle of Man, IM3 1DZ or via email at support@starsaffiliateclub.com. In this Privacy Policy, when we say “TSG”, “we” or “us”, we are referring to this company. References to “Group” means TSG together with its subsidiaries and any holding company of TSG and any subsidiary of such holding company and any company associated with the group of companies known as The Stars Group.

Our Commitment to Our Players’ Privacy. We are the owner and operator of the website located at www.starsaffiliateclub.com (the “Site”). We are committed to maintaining the confidentiality of the personal information collected by us, utilising ‘best in class’ information security technology and procedures, all in accordance with European Union standards of data protection and the requirements of the applicable regulatory authority for data protection.

Purpose of this Privacy Policy. The purpose of this Privacy Policy is to enable you to understand how we collect, store, use and safeguard your personal information and to explain your rights in relation to that information and its use.

Our Legal Obligations. We will comply with the terms of the Isle of Man’s Data Protection Act 2002 (as may be amended or updated from time to time) (the “Act”) when processing your personal information. Your personal information may be also processed or transferred by us to other members of or our group of companies, our affiliates, our agents and third parties providing services to us, in jurisdictions outside of the Isle of Man and the European Economic Area. In this event, we will comply with the terms of the Act which ensure that personal data is only transferred to such jurisdictions which comply with the various ‘adequacy’ requirements for data protection set out in the Act.

What do the Capitalised Terms Mean? Unless we give them a specific meaning in this Privacy Policy, capitalised terms shall have the meaning given to them in our Stars Affiliate Club Program Terms of Service which takes precedence over any conflicting provision of this Privacy Policy.

• Your Agreement to the Privacy Policy
• What information is collected and for what purpose
• Conditions for Processing Personal Information
• Information Sharing, Disclosures and Recipients
• Confidentiality
• Limits of Confidentiality
• Legally Required Disclosures
• Your Rights in Relation to Your Information
• Cookies
• Further Information to facilitate financial transactions for any amounts due to you; to analyse your credit and fraud risk and verify your credentials using third parties, including financial institutions, identification verification agencies and credit reference agencies;

1. Agreement: By using the Service, you (“User” or “you”) agree to the terms of this Privacy Policy as may be amended by us from time to time, save that we will ask you separately, when you provide us with your details whether you consent to receiving promotional communications from: (a) us; and also (b) from third party providers of goods and services with whom we may share your details. Amendments: We reserve the right to amend this Privacy Policy from time to time. Amendment will come into effect immediately upon such change being notified on the Sites. We therefore encourage you to visit this Privacy Policy from time to time to make sure that you are aware of the current version and any changes that we may make.

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2. Registration Details: As part of the Stars Affiliate Club Program registration process, we will ask you to provide us with certain personal information, including but not limited to your name, postal address, telephone number and email address. The name you register with us must be your own name. In addition, it is important that you complete the account details with valid information in order for us to verify your identity, carry out adequate background checks and set up any payments that may be due to you as well as for the other purposes described in this Privacy Policy. You must advise us of any relevant changes to your personal information as provided to us and we do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the personal information that you have provided to us. Ongoing Data Capture. Please note that we also use ‘cookies’ and our ‘cookie’ policy is explained below. Data Retention: We retain your personal information for as long as necessary for the purposes set out in this Privacy Policy which includes any period of historic retention that may be required for regulatory purposes. We do not collect any more personal information from our users than is necessary for our purposes and our data management policies include the deletion of any personal information we no longer require. Should you close (or if we shut down) your Stars Affiliate Club Program account with us, we will retain your personal data for a period of 6 (six) years following such closure in order for us to meet our regulatory and legal obligations and defend ourselves against any claims. Personal information which is not needed for these purposes will be deleted after this period. Purposes: We, members of our Group of companies, our affiliates and third parties providing services to us or to you on our behalf, will use your personal information for the purpose of conducting our business and in relation to the services you provide to us. Specifically, this includes the following purposes, but we also reserve the right to use your personal information for other purposes that are reasonably ancillary to our primary business:

• identification, verification and vetting purposes;
• statistical analysis and research;
• research and development;
• marketing, market research and customer profiling;
• data analysis;
• to comply with licensing and regulatory requirements;
• to carry out batch testing of documents prior to the deployment of tools sourced from or provided by third parties;
• to combat against security risks and fraudulent activity; and
• to confirm your geographic location.

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3. Conditions: We will process your personal information for a variety of reasons, each of which is prescribed by relevant data protection laws.

Consent

Our processing of your personal information will primarily be necessary for the purpose of carrying out administrative functions using your information as well as to assist with the affiliate services you provide to us. We may ask for your consent to processing personal information in a discreet manner; in this instance, your personal information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time. By way of example, your consent will be needed in order to send you marketing and promotional communications.

Fulfilment of a contract, compliance with a legal obligation

It may also be necessary for us to process your personal information where it is necessary for the performance of a contract (such as you entering into the Stars Affiliate Club Program or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licences and complying with any anti-money laundering legislation.

Legitimate interests

Finally, we may also process your personal information where we deem such processing to be in our legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your personal information to companies in our Group following a restructure or for internal administrative purposes; (ii) where we identify certain companies that can offer you additional benefits to our services or provide us with valuable information about your use of our Service; (iii) processing for the purposes of ensuring network and information security, including preventing unauthorised access to our electronic communications network; and (iv) adhering to regulatory and statutory requirements.

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4. Specific Disclosures. We may disclose your personal information as follows:

• to any recipient if required to do so by law or by regulatory authority;
• to any regulatory body or licensing body or authority;
• to third parties for the purposes of making payments to you in connection with the services you provide;
• to third parties who provide services to us or on our behalf in relation to our agreement with you;
• to third parties for marketing purposes, provided you have consented or not objected, as the case may be, as described in clause 9 below;
• to any third party that purchases us or our business or any part of us or our business;
• to credit reference agencies;
• if we believe in good faith that such action is necessary:
  1. to comply with any law or comply with any legal process served on us;
  2. to protect and defend our rights or property;
• with your consent;
• for the purposes of disaster recovery; or
• as set out in Section 5 below.

5. General Disclosures: In addition to the specific examples of disclosures listed above, we may disclose your personal information to our employees, employees of other companies in our Group, our agents and to third party service providers who use your personal information to provide services to us.

6. Combined Personal Data: We may combine your personal information with other information collected from your use of other services operated by TSG any other company in our corporate group as well as all products which are related or ancillary thereto, including mobile and social networking services. We will treat this combined information in accordance with, and will use it for the purposes set out in, this Privacy Policy.

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7. What Do We Do? We have undertaken substantial efforts to protect the confidentiality of the identity, preferences and other information we have collected about individual members of the Stars Affiliate Club Program and we will not knowingly allow access to this information to anyone outside of our Group, other than to the relevant Stars Affiliate Club Program member or as described in this Privacy Policy. We have made a substantial investment in our server, database, backup, firewall and encryption technologies to protect the information that we collect and process.

8. What Can You Do? You should also play your part in protecting your personal information. Your login information is confidential and you are obliged to keep your password secret and confidential at all times and to use your best efforts to protect its secrecy and confidentiality.

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9. Legally Required Disclosures. Due to the legal, regulatory and security environment in which we operate, we may be required, under certain circumstances, to disclose personally identifiable information about members of the Stars Affiliate Club Program and we may not be permitted to inform you that we have done so. We will use reasonable endeavours to limit such disclosure to the following: (a) where we believe in good faith that we are required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights. Further, we can, and you authorise us to, disclose your, name, date of birth, street address, city, county, post code, country, phone number, email, account activity, transactions and communications, to our third party agents or official government bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.

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10. Group Marketing. We may use your email address and phone number for the purpose of providing you with news, promotions and other marketing offers from us. If you no longer wish to receive these promotional communications, newsletters and marketing offers, you may opt-out of receiving them either when you register with us initially, or subsequently by following the ‘opt-out’ instructions included in each communication. You are also, in addition, entitled at any time to notify us that you do not wish to receive any promotional communications from us and you may do this by emailing us at here.

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11. Third Party Offers of Goods and Services. Where you have provided us with your consent to do so, we may also share your email address and phone number with third parties so that they may send you offers of their goods and services. You may request at any time not to receive such offers by sending a blank message with the word ‘Remove’ in the subject area to Support. If you request not to receive these offers, we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you will need to unsubscribe separately from marketing communications sent by partners who have received your contact details from us prior to your request to be removed from these lists.

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12. Right to request information about you. We aim to keep our information about you as accurate as possible. You can contact us at any time to review, change, obtain a copy of your information or have your details altered or corrected in accordance with your rights under the Act. In this event, we may require evidence of and be satisfied as to your identity before we take any requested action. To contact us, so as to exercise any of your rights as set out in this Clause 12, please e-mail Stars Affiliate Club. We may, in certain circumstances, levy a small charge to cover the cost of administration regarding any request made by you in this regard or deal with your query in accordance with the Act.

13. Additional Rights. You have the following rights in relation to your personal data:

1. a right to object to processing that is likely to cause or is causing damage or distress;
2. a right to object to decisions being taken by automated means;
3. a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
4. a right to claim compensation for damages caused by a breach of the Act.

If you are unsure about your rights or are concerned about how your personal information may be processed, you should contact the Isle of Man Information Commissioner (details set out in clause 14 below). If you contact us in relation to your rights, we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.

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14. Cookies are text-only strings of information that are downloaded to your personal desktop, laptop computer or mobile device (each a “Device”) when you visit a website. They are then sent back to the originating website on each subsequent visit, or to another website that recognises those cookies. Please see: www.allaboutcookies.org for information about what cookies are and what they do.

Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences, and generally improving user experience. Sometimes, cookies are used to help ensure that adverts you see online are relevant to you and your interests. We use cookies in order to track referrals to our Site, to remember your preferences, and to generate anonymised statistical data, which we use to improve the user

experience on our sites. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited a website, and to provide advertisements that are more relevant to your interests.

Detailed information about cookies and how we use them on the Site may be found in our Cookie Policy, which also describes how you can turn off cookies or control which cookies are set on your Device (see in particular, the section headed “How to manage your cookie settings”).

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15. We are happy to provide you with further information on how we protect and use your personal information. Please contact Stars Affiliate Club. You can also obtain much useful information on data protection and privacy from the office of the Isle of Man Information Commissioner www.inforights.im .

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Privacy Policy last revised: August, 2018