SUNLAND SOCIAL CASINO PRIVACY STATEMENT

LAST UPDATED: July 15, 2021



PLEASE READ THIS PRIVACY STATEMENT AND THE SUNLAND SOCIAL CASINO TERMS OF SERVICE (sunland-park.net) PRIOR TO USING, ACCESSING OR DOWNLOADING THE SUNLAND SOCIAL CASINO OR ANY RELATED WEBSITE, APPLICATION OR SOFTWARE.


Sunland Social Casino is a business product of My Way Holdings, LLC (“MWH”). As such, this Privacy Statement is separate and different from MWH ’s Privacy Statement sunland-park.net and does not apply to any website, mobile app, or product operated by MWH that has a separate privacy policy, notice, or statement. This Privacy Statement applies to the Sunland Social Casino, as well as any related website, application or software that links to this Privacy Statement, collectively referred to as “the Services.”


This Privacy Statement explains the information we collect, and how we collect, use and, in certain circumstances, share your information in connection with the Service(s) we provide you. If you have any questions, feel free to email us at privacy@sunland-park.net.


Information We Collect and How We Use It.


You may access the Services as a guest without providing any personal information, other than your date of birth and the information described in the “Automatically Collected Information” section below. When accessing the Services as a Players Club member, we will collect your Players Club credentials (Players Club member number or username and associated Players Club online account password). We automatically collect some information when you access or use the Services and collect other information when you voluntarily submit it to us. If you elect not to provide certain information, you may be prevented from participating in some of the Services.


We may also collect information about you from other sources such as publicly available or commercially available information. However, the information collected for Players Club members outside of the Services is governed by the MWH Privacy Statement, located at sunland-park.net When information we collect about you through the Services is combined with other information we have collected about you, please see MWH Privacy Statement for more information on our data handling practices.


Information You Provide.


There is no cost to access the Services. However, Sunland Social Casino and we may collect information from you when you access or use the Services including, for example:


  • • Registration information (identifiers such as your date of birth, Players Club username and Players Club password);
  • • Purchase transaction information and other commercial information if you make a purchase (we use a third-party service provider for these transactions so while we receive information about the transaction, such as what you purchased, we do not receive your billing or payment information);
  • • Demographic information, such as your gender and age;
  • • Social network website user information if you access the Services through our social network community page (including information that is visible on your social network page if you have allowed this through the privacy settings on your social network account);
  • • Loyalty program information if you enroll in or are already enrolled in MWH ’s Players Club loyalty program (identifiers such as name, email or postal address, telephone number, information about your use of the Services and any purchases you have made or rewards you have received);
  • • Information you provide in response to contests, surveys or other marketing outreach (identifiers such as name, email or postal address, telephone number, eligibility information for contests which may include age, images or photographs, hobbies or interests, and occupation);
  • • Information that you may post on the Services through in-game play, comments, reviews, support tickets or other posts (you control the information that you provide in this way and this information may include actions you perform with other players; all such information, excluding support tickets, can be viewed by the general public so please take that into consideration when you post); and
  • • Inferences based on the information described above and other information described in this Privacy Statement.
  • • Other correspondence you send to us, including questions about the Services or communications about this Privacy Statement.


Automatically Collected Information.


We may automatically collect information from you when you access or use the Services. This information is collected through Sunland Social Casino and by third party service providers such as Google and Apple, by placing certain data files on your computer or mobile device. These data files may be cookies, other local storage technologies, or other technologies (collectively, “Cookies”).


We collect information about your use of the Services, including, without limitation, internet or other electronic network activity information about your access of the Services, like playing games via the Sunland Social Casino, and/or your interaction with our Services via other third party websites or applications, such as your device ID, internet protocol addresses, browser type, referring / exit pages and URLs, other browser history, 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, payment events, and related date and time information. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred. This information allows us to improve the Services as well as to communicate with you about customer support and to market and advise you of other products or services that may be of interest to you.


We may collect information about your geolocation, including geolocation information derived from GPS, WiFi, IP address and other device information, with your consent and consistent with your mobile device or app permissions. Also consistent with your mobile device or app permissions, we may send you push notifications.


We also receive the categories of information described above from other sources, including from users of our Services, government entities that make information publicly available, entities that sell data, and third-party services and organizations. For example, if you access any social media or similar services through the Services to login or to share information about your experience on our Services with others, we may collect information from these third-party services.


We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.


Sometimes, we utilize the services of a third party to help us understand this information better. Please see the “Cookies and Tracking” section below for more information.


Use of Information.


Sunland Social Casino and we may use the information we collect for our general commercial or business purposes such as to improve and grow our business and to offer you our own, our affiliates’, or third party products or services that we think you may find of interest. Our potential uses of the information which we collect may include:


  • • Providing and improving the Services, including confirming your eligibility to use the Services and verifying you, enhancing your experience on the Services, and resolving service problems and errors.
  • • Communicating with you, including communicating with you about our products, services, events, and promotions, providing you with relevant advertising on our Services and elsewhere, administering satisfaction or other surveys, responding to inquiries and resolving complaints, or notifying you that you have been invited to join Sunland Social Casino or other Services;
  • • For business research and development, including research and development of new products or services, generating usage statistics of our Services and for other analytics purposes, and detecting and preventing fraud or misuse of the Services;
  • • Complying with our legal and regulatory obligations; and
  • • Enforcing our legal rights.


International Transfer of Your Information.


By using the Services and providing us with information, you understand and agree that your information may be accessed and stored outside the country where you reside, including in the United States, where it will be subject to laws that may not be equivalent to those that apply in your country. The information we collect may also be processed by staff operating inside or outside the United States of America, by persons who work for us or for one of our suppliers, related companies or payment processors. Such staff, suppliers or payment processors may be engaged in, among other things, the fulfilment of your order and the processing of your payment.


Access to Your Personal Information and Your Rights and Choices.


In accordance with applicable law, you or your authorized agent may be entitled to request access to or correction of your information. If you are aware of changes or inaccuracies in your information, you should inform us of such changes using the details in the “Additional Questions - Contact Us” section below, so that your information may be updated or corrected. Depending on where you live, you or your authorized agent also may have rights to request that we delete personal information that we hold about you, to request that we provide such information to you in a portable format, or to request additional information about how we collect or disclose your personal information.


We will not discriminate against you for exercising your rights and choices except where permitted by law. For example, some of the functionality and features on the Services may change or no longer be available to you if you have requested that we delete your information.


Once we receive your request, we may verify it through your account or by requesting information sufficient to confirm your identity. If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise rights on your behalf. To designate an authorized agent to exercise your rights and choices on your behalf, please direct a dated and signed request to: My Way Holdings, LLC, Attn: Compliance Officer, 1200 Futurity Drive, Sunland Park, NM 88063.


You can terminate your account at any time. We may, however, keep information about you following termination of your account. In some cases, we may be legally required to maintain certain records of your personal information, in which case we may not be permitted to delete your information. If you wish to terminate your account or if you have any other questions or concerns about your personal information please email Sunland Social Casino at privacy@sunland-park.net.


You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from Sunland Social Casino or by emailing Sunland Social Casino at privacy@sunland-park.net.This will not stop Sunland Social Casino from sending emails about your account or your transactions with Sunland Social Casino.


You can choose to delete or block certain Cookies by setting your browser to either reject all Cookies or to allow Cookies only from selected websites. You may need to take additional steps to refuse or disable other types of technologies, such as Local Shared Objects. If you block Cookies, performance of the Services may be impaired and certain features may not function at all. Deleting cookies may in some cases cancel the opt out selection in your browser.


Some of our third-party partners may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.


If you have previously allowed us to access your geolocation data, you can stop making geolocation information available to us by visiting your mobile device’s “settings” for the Sunland Social Casino application, but this may impact your ability to access and use the Services.


When you install our Services on a mobile device, you can choose to receive push notifications, which are messages an application sends you on your mobile device, even when the application is not active. You can turn off notifications by visiting your mobile device’s “settings” page for external applications.


If you have registered to receive SMS messages, you can opt out of receiving SMS messages (text messages for example) by texting back STOP to the number we send the text from for that particular SMS Message program. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.


If you have been invited to join Sunland Social Casino you are provided with the option not to receive further invitations from Sunland Social Casino. If you choose to opt-out at any time after granting approval you can email us at privacy@sunland-park.net.


Sharing Your Information.


We may reveal or share the categories of information listed above to unaffiliated third parties:


If you request or authorize it;


If the information is provided to help complete a transaction for you;


If the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Service or other agreements, or to protect our or our affiliates’ rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.);


If the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);


If the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., billing, email deployment, advertising and marketing (including counting ad impressions, verifying positioning and quality of ad impressions, ensuring compliance with industry standards and specifications, ad delivery, reporting, personalization, audience segmentation, and analytics), security and performance monitoring, maintaining or servicing accounts, research, and auditing, providing customer service, processing orders, etc.); or


As otherwise described in this Privacy Statement.


We may share your information with our affiliated companies.


If you access third-party services -- such as social media services or mobile game centers for high scores and leaderboards -- through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.


We do not sell your information to third parties. We do permit third parties to collect the information described above through our Service and disclose such information with third parties for business purposes as described in this Privacy Statement, including but not limited to providing advertising on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”). The information practices of these third parties are not covered by this Privacy Statement.


Cookies and Tracking.


The Services use Cookies to improve the quality of our Services, make recommendations, and make the Services easier to use for our users. A cookie is a small text file recorded on your hard drive that identifies you as a unique user and contains certain information about your particular login session and/or your use of the Services. There are other local storage and similar technologies that allow us to collect similar information. We use Cookies to collect information about Service usage by all of our visitors and to help us remember you and your preferences when you revisit the Services. These Cookies may persist until they expire or you delete them. We may also use Cookies to allow the Services to function properly. These Cookies usually are erased when you close your browser window. Further general information about Cookies and how they work is available at www.allaboutcookies.org.


We allow selected third parties to place Cookies through our Services to provide us with better insights into the use of our Services. These third parties may collect information about a consumer’s online activities over time and across different websites and devices when he or she uses our Services. You consent to third party service providers placing Cookies through our Services to perform analytic or marketing functions.


In addition, advertisers and/or ad networks may use other third-party advertising technology (including single and multiple tracking technologies) to target advertising on the Services. In the course of advertisements being served to you, a unique third-party cookie or other Cookies may be placed on your device. Similarly, third-party advertising companies may provide us with pixel tags (also called “clear gifs” or “beacons”) to help manage and optimize our online advertising. Beacons enable us to recognize a browser’s cookie when a browser visits the website on which the beacon is located, and to learn which banner ads bring users to a given website. These third-party Cookies and other technologies are governed by the privacy policy respective to each third-party advertising company or network. We cannot be held responsible for the privacy policies or practices of any such third parties. Please see below for more information about how to opt out of receiving targeted advertisements from companies that participate in industry self-regulatory programs.


To learn about how Google processes your information and what choices you may have, visit their site here.


Data Retention, Security, and Integrity


Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.


We use reasonable technical, administrative and physical measures to protect information contained in our Services against misuse, loss or alteration. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current.


Do not share your log-in information with others.


Email and instant messaging are not recognized as secure communications, so we request that you not send private information to us by email or instant messaging services. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. If you have any questions about the security of the Services, please contact us via email at privacy@sunland-park.net


Links to Other Sites.


We may permit others to link to our Services or to post a link to their site or services on our Services. We are not responsible for third-party sites or their privacy practices. Please read their privacy policies before submitting information.


Children’s Privacy.


The Services are designed and intended for users who are 21 and older only. Children and teens are not permitted to use the Services and we do not knowingly collect or solicit personal information from anyone under the age of 21 or knowingly allow such persons to register for use of the Services. If you are under 21, please do not attempt to register for, or otherwise use, the Services or send or submit any information about yourself to us and/or through the Services, including your name, address, telephone number, or email address.


If you are a parent or guardian of a child under 13 who has sent or submitted his or her personal information to us and/or through the Services, please email us at privacy@sunland-park.net to request deletion of your child’s information, making sure to include the name and password that your child submitted.


Territorial Restrictions and Consent by North American Users.


The Services are designed and intended for users within North America, excluding those users within the State of Washington. Players outside North America or within the State of Washington are not permitted to use the Services and we do not knowingly collect or solicit personal information from anyone outside of North America or in the State of Washington or knowingly allow such persons to register for use of the Services. If you are located outside of North America or in the State of Washington, please do not attempt to register for, or otherwise use, the Services or send or submit any information about yourself to us and/or through the Services, including your name, address, telephone number, or email address. We may update this Privacy Statement to exclude users in additional jurisdictions at any time, in our sole discretion, in accordance with the “Changes to the Privacy Statement” section below.


By accessing or using the Service, all users fully understand and consent to this Privacy Statement. By using our Services, participating in any of our Services and/or providing us with your information, you consent and agree to the collection, transfer, storage and processing of your information as described in this Privacy Statement.


Changes to the Privacy Statement


We may modify this Privacy Statement from time to time. When we update the Privacy Statement, we will revise the “Last Updated” date above and post the new Privacy Statement. We recommend that you review the Privacy Statement each time you visit the Services to stay informed of our privacy practices.


Additional Jurisdictional Rights


California Residents: Your California Privacy Rights.


California residents may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. Our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval you can do so by emailing us at privacy@sunland-park.net, by telephoning the MWH Legal Department at 575/874-5200 or by writing to us at:


My Way Holdings, LLC
Attn: Legal Department
1200 Futurity Drive
Sunland Park, NM 88063


We do not treat the ways we share your personal information as “sales” of personal information under California law, although you have certain choices about our sharing. Please see the relevant sections of this Privacy Statement for information about how your information is shared with third parties and the choices that may be available to you. As described above, we allow third parties to access information about your use of the Services through Cookies. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from participating companies. To learn more, please click here or here. California consumers may also use the Digital Advertising Alliance’s tool, accessible here, to send requests to opt out of the sale of personal information by some or all of the participating companies.


Nevada Residents:


Additional Information Regarding Nevada – We do not sell Covered Information as defined under Nevada law. If you are a Nevada resident and have any questions about this, please contact us at privacy@sunland-park.net.


Additional Questions - Contact Us


Feel free to contact us at any time by submitting an email to privacy@sunland-park.net if you have further questions about our Services or this Privacy Statement.