Privacy Notice
Version 1.0
Last updated: February 2025
Introduction
Your privacy and trust are important to Tobix Limited (“Company”, “we”, “our” or “us”). We are committed to handling your Personal Information ("Personal Information") with the utmost care and transparency.
This privacy notice ("Privacy Notice") is designed to inform you about the types of Personal Information we collect, how we use it, and the steps we take to protect it while you enjoy our platforms (website and mobile application; collectively, “Services”). We will also explain your rights regarding your Personal Information and how you can exercise them.
This Privacy Notice applies to all users in Canada, except in the Ontario province. We are committed to protecting your Personal Information in compliance with applicable privacy laws, regulations, and guidelines, including but not limited to the (a) Isle of Man data protection regulation; (b) Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada; (c) any relevant Canadian provincial privacy laws.
Who We Are
Tobix Limited, located at 18-20 North Quay Douglas Isle of Man, IM1 4LE, is responsible for managing how and why your Personal Data is collected, used, and stored when you use our services. As an "organization" under PIPEDA and a "data controller" under Isle of Man data protection regulation, we ensure your data is collected, used, disclosed, and otherwise processed in accordance with all applicable data protection laws.
How To Contact Us
If you have any questions or concerns about how we handle your Personal Information, or if you would like to exercise your data protection rights, please feel free to reach out:
Data Protection Officer
Email: dpo@tooniebet.net
Postal Address: 18-20 North Quay Douglas Isle of Man, IM1 4LE
What Personal Information We Collect
We may collect and process Personal Information about you depending on how you use our platforms. Please note that we do our best efforts to limit our data collection to what is reasonable, as required under applicable laws. This may include:
| Category | Description |
| Account Data | Email address, IP address, password. |
| Gameplay Data | Gameplay history (e.g., games played, session duration), events and outcomes of sessions. |
| Device and Usage Data | Date and time of log-ins/outs, IP addresses, device identifiers, operating system, browser type/version/settings, login location, time zone, cookies and tracking data (including pixels, web beacons, etc.), preferred channels of service access, as well as other information which relates to your activity in the Services. |
| Marketing and Preferences Data | Marketing communication preferences (opt-ins/opt-outs), updates in preferences, and inclusion in marketing lists. |
Why We Process Your Personal Information
We process your Personal Information for the following purposes:
| Purpose of Processing | Description | Lawful Basis |
| Service Provision | To provide and deliver our Services, including creating and maintaining your account and enabling you to access our Services and features. | Performance of a contract; your consent |
| Customer Support and Security Notifications | To provide support, and notify you of security incidents and service availability. | Legitimate interests; your consent; performance of a contract and our legal obligations |
| Service Security and Functionality | To ensure technical availability, conduct data analysis, testing, troubleshooting, and protect against security threats and unauthorised access. To safeguard our rights, systems, and intellectual property and to take legal actions if necessary to protect against claims or disputes. |
Legitimate interests; Legal obligations |
| Analytics and Service Improvement | To analyze usage trends and conduct research for service development, including using statistical analysis to enhance performance, quality, and user experience. | Legitimate interests; your consent |
| Risk Management and Responsible Gambling | To detect, deter, prevent, and report any suspicious or fraudulent activities, such as abnormal gambling patterns, suspected manipulation, or payment fraud. To promote Responsible Gambling practices by administering controls, verifying self-exclusion, detecting pathological behavior, and monitoring for signs of potential gambling addiction. |
Legal obligations Legitimate interests Substantial public interest |
| Legal Compliance | To prevent access by minors and other regulatory obligations. Where necessary, we may also process Personal Information to ensure compliance with internal policies and procedures directly related to these obligations. |
Compliance with legal obligations |
| Marketing and Communications | To send you marketing communications, service updates, and surveys through email, SMS, calls (including robocalls), website/app messages, push notifications, or posts, tailored to your interests and preferences. To allow participation in interactive features, such as competitions, loyalty schemes, promotional events, or engagement surveys. To categorize our audience into segments for more targeted communication based on behavior, demographics, or preferences. To deliver personalized ads and offers, including creating lookalike audiences and targeting similar customer profiles. |
Consent Legitimate interests |
| Social Features | To enable social account linking, referral programs, and content sharing on social media with your consent. | Your consent |
| Legal Actions and Dispute Resolution | To establish, exercise, or defend legal claims, including managing legal disputes, regulatory investigations, or compliance with law enforcement requests. | Compliance with legal obligations Legitimate interests |
Who We Share Personal Information With
We may share with or give access to your Personal Information to the following categories of recipients to provide our Services, enhance your experience, and comply with legal obligations:
1. Internal Teams and Affiliates
Authorised employees, contractors, agents, affiliates, and subsidiaries within our business group or associated with our parent company. Access is strictly limited to those who need it to perform their duties.
2. Business Transactions
In the event of a change in ownership, control, or business structure, such as a merger, acquisition, reorganization, sale of assets, joint venture, or other similar transaction, your Personal Information may be transferred to the relevant parties involved. Any such entity or partner will be required to process your Personal Information in line with this Privacy Notice and applicable data protection laws.
3. Law Enforcement Authorities
We may disclose your Personal Information to law enforcement agencies to comply with legal requirements, court orders, investigations, or regulatory requests.
4. Third-Party Service Providers:
- Game Providers: We share limited data with trusted providers to provide you with a variety of games.
- Customer Support Providers: Third-party support teams for efficient service handling.
- Email & SMS Providers: For service-related and marketing communications.
- Social Media & Digital Platforms: Platforms for social sharing and advertising.
- Analytics Providers: Services like Google Analytics for usage insights.
- Security and IT-Related Providers: Trusted IT and security providers to host, maintain, and protect our systems. This includes data hosting services, cybersecurity providers, and infrastructure support to ensure our platform's availability, security, and performance.
- Other Providers: Supporting services like maintenance, legal, fraud, auditing, and marketing.
5. Advertising and Marketing Partners
We may share your Personal Information with advertising and marketing partners, including third-party advertisers, affiliate networks, and agencies. These partners help deliver personalized ads, remarketing campaigns, and targeted promotions across various platforms. This data sharing enables us to optimize marketing strategies and tailor advertisements based on your preferences.
6. Data Analytics
We work with analytics providers who assist in understanding user behavior, improving platform performance, and refining user experiences. These providers generate insights from data, including usage patterns, engagement metrics, and interaction trends, helping us enhance our Services.
Marketing And Advertising
We will use your Personal Information, such as your name, home address, email address, telephone number etc., collected by ourselves and/or through our third-party subcontractors to provide you with promotional materials via different marketing techniques such as direct email, telephone marketing, SMS and post concerning our Services as well as products, websites and applications that may be of interest to you which relate to: (i) our or other companies within the Company's group; or (ii) the Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Personal Information with our Marketing Affiliates to provide you with different marketing offers, that we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS telephone marketing purposes.
When we send you marketing communications, we will rely on your consent. You may at any time decline receiving further marketing offers from us or from our Marketing Affiliates by either: following the links inserted in the promotional emails (e.g., selecting the opt-out link or “unsubscribe” link) or contacting our customer support of the Privacy Notice. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
International Data Transfers
We store your Personal Information in the EEA. Our partners and providers operate globally, so it may be necessary to transfer and where applicable store your Personal Information outside the country from which you access our services, including outside Canada, Isle of Man or the EEA. If such cross-border data transfer occurs, we ensure that your Personal Information is protected with appropriate technical and organizational safeguards.
To exercise your privacy rights, or know more about cross-border data transfers, you may contact us through email at dpo@tooniebet.net.
Cookies And Third-Party Tracking Technologies
We use cookies and third-party tracking technologies to enhance your experience on our platform, improve website and network security, analyze usage, and deliver personalized content. For detailed information about the types of cookies we use, their purposes, and how you can manage your preferences, please refer to our Cookie Notice.
Data Security
We take the security of your Personal Information seriously and have implemented robust technical and organizational measures to protect it against unauthorised access, alteration, loss, or misuse. While no method of data transmission or storage is completely secure, we have taken adequate steps to safeguard your information. Our security measures include advanced encryption protocols, access controls, regular security audits, and employee training on data protection practices. These measures are reviewed and updated regularly to align with industry standards and address evolving security threats. However, please note that we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Information you choose to disclose. If you feel that your privacy was treated not in accordance with this Privacy Notice, or if any person attempted to abuse the Services or acts in an inappropriate manner, please contact us directly via our contact details available above.
Data Retention
We retain your Personal Information while your account is active and as long as necessary to fulfill the purposes for which it was collected, including compliance with regulatory, legal, accounting, or reporting obligations. If your account is closed, we determine the appropriate retention period based on several factors, such as:
- The volume, nature, and sensitivity of the data;
- The potential risk of harm from unauthorised use or disclosure;
- Applicable legal, jurisdictional, and regulatory requirements;
- Our internal policies and industry best practices;
- The purposes for processing your data and whether those purposes can be achieved through other means.
Upon expiration of the retention period, we will securely delete or anonymize your data and ensure it can no longer be associated with you, in which case we may retain and use this anonymized data indefinitely.
Your Data Protection Rights
Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights:
1. Right to Access
You have the right to request a copy of the Personal Information we hold about you.
2. Right to Rectification
If your information is inaccurate or incomplete, you may request corrections or updates.
3. Right to Erasure
You may request the deletion of your Personal Information. We will delete your data if it is no longer needed for the purposes it was collected and there is no business or legal requirement to keep it.
4. Right to Restrict Processing
You can request that we limit the processing of your data under certain conditions, such as while we verify the accuracy of your data or resolve an objection.
5. Right to Data Portability
You have the right to request the transfer of your data to you or another service provider in a structured, commonly used, and machine-readable format.
6. Right to Object
You may object to the processing of your Personal Information, including for direct marketing purposes or based on our legitimate interests.
7. Right to Withdraw Consent
If you have given consent for specific processing activities, for example, direct marketing, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
8. Right to Lodge a Complaint
If you have concerns about how we handle your Personal Information, we encourage you to contact us first to resolve the issue. You can reach us at dpo@tooniebet.net.
If you are not satisfied with our response, you have the right to file a complaint with –
- the Information Commissioner of Isle of Man at: https://www.inforights.im/
- the Office of the Privacy Commissioner of Canada (OPC) at https://www.priv.gc.ca/ ; or
- the relevant supervisory authority governing data subject’s rights-related matters in your province. For example, Quebec residents may file a complaint with the Commission d'accès à l'information du Québec (CAI) at https://www.cai.gouv.qc.ca/.
9. Right to Cease dissemination (for Quebec residents only)
If you are a resident of Quebec, you have the right to cease dissemination of your Personal Information if it is outdated, inaccurate, or if its continued disclosure causes harm or is not justified by public interest. You may request that we remove this data from public access or our databases, subject to applicable legal limitations.
How to Exercise Your Rights: To exercise any of these rights, please contact us through email at dpo@tooniebet.net or support@tooniebet.net. For verification and security purposes, we may ask you to provide proof of identity before fulfilling your request.
Minors
We do not knowingly collect or solicit Personal Information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event we learn that we have collected Personal Information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
Language Control
This Privacy Notice has been drafted in the English language. In the event of any discrepancies or conflicts between different language versions, the English version will take precedence and be considered the authoritative version for legal and interpretative purposes.
Changes To This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our practices and legal requirements, or for other operational or regulatory reasons. Any significant changes will be communicated to you through our website, email, or other direct means, as appropriate.
Each version of this Privacy Notice will include the effective date at the top. We encourage you to review this Privacy Notice periodically to stay informed about how we are protecting your Personal Information. Your continued use of our Services after any changes take effect indicates your acceptance of the updated terms.