Oneida Innovations Group, LLC and its instrumentalities subsidiaries and affiliates (referred to in this Privacy Policy as “OIG,” “us,” “we,” and/or “our”) value you as a customer and take your personal privacy seriously. In the course of providing you with products and services, we may collect certain information from or about you. We are providing this Privacy Policy to explain our practices and policies for collecting, using and sharing information collected from or about you when you visit, access, or use, or provide information to us in connection with, one of the OIG businesses or OIG Websites, as each term is defined below in Section 1 (referred to together as the “OIG Services”). By visiting, accessing, or using, or providing information to us in connection with, the OIG Services, you expressly consent to our collection, storage, use and sharing of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with OIG Services.
This Privacy Policy does not create a contractual obligation between you and OIG, and it is subject to our Terms of Use located at https://www.oneidainnovations.com/terms-of-use. If you have questions about this Privacy Policy, please contact us at privacy@onenterprises.com.
1. DEFINED TERMS
As used in this Privacy Policy:
(a) “OIG Websites” refers to websites owned or operated by OIG that display this Privacy Policy, including, but not limited to, https://www.oneidainnovations.com/
(b) “Personal information” refers to any information by which you can be personally identified, such as your first name, last name, address, phone number, email address, credit card number, geolocation information, date of birth, purchase information and other similar information.
(c) “Non-personal information” refers to information by which you cannot be personally identified.
2. INFORMATION WE MAY COLLECT.
We collect and use information we believe is necessary to administer and promote our business, provide you with the products and services you request, and to provide a safe and healthy environment to our employees and other customers. We may collect and maintain both personal information and non-personal information needed for these purposes. Your personal information and/or non-personal information will be referred as your “information” in this Privacy Policy.
3. HOW WE COLLECT YOUR INFORMATION.
(a) Information You Directly Provide to Us. You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through OIG Websites, sign up to receive email or text messages from us, sign up to access Wi-Fi at an OIG Property, or provide feedback in a survey.
(b) Information Automatically Collected Through the OIG Websites.
(i) Traffic Data. We automatically track and collect general log information when you visit the OIG Websites, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on the OIG Websites (collectively “Traffic Data“). Traffic Data does not personally identify you, however, if you choose to provide us with personal information, we may store some items of your personal information and use it with the Traffic Data to better personalize your experience on the OIG Websites. We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of the OIG Websites. It enables us:
• to estimate our audience size and usage pattern;
• to learn what information is of most and least interest;
• to speed up your searches; and
• to learn of any possible OIG Website performance problems.
We, or our service providers, may also use Traffic Data to identify your physical location to confirm that you are in a jurisdiction where you can use our online gaming services. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and transparent GIFs.
(ii) Data Collected Using Cookies and Other Technologies. We also automatically collect information from you using cookies and other technologies on the OIG Websites. We may use cookies and similar technologies to identify who you are and may use them when you visit the OIG Websites, click on our ads, or open our emails. Cookies also enable us to remember your user preferences for the OIG Websites. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, serving contextual advertisements, and protecting against fraud and theft. You can block or remove cookies using your Internet browser’s settings. If you block or remove cookies, your ability to perform certain transactions, use certain functionality, and access certain content on the OIG Websites may be affected.
(iii) Information Collected by Third Party Analytics Services. We may work with third party analytics services to help us understand how OIG Websites are being used, such as tracking the frequency and duration of use of the OIG Websites. These analytics services may use cookies and other technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting the OIG Websites, and your system information and geographic information. The information generated by these technologies about your use of the OIG Websites will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of the OIG Websites.
(iv) Information You Share on Third Party Websites or through Social Media Services. The OIG Websites may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services. We may also monitor sentiments regarding OIG that you publicly post on social media services or customer review sites. We may reach out to you regarding these postings to address customer service issues and to otherwise help ensure that you have a positive customer experience.
(c) Information Obtained from Other Sources, including from Service Providers, Third Party Services and Joint Marketing Partners. We may obtain information about you from other sources, including service providers, third party services (such as data brokers or analytics firms), publicly available sources, government agencies or Joint Marketing Partners (defined below), and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third party information with other personal information we have collected, we will treat the combined information as personal information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.
(d) Information We Automatically Collect When You Use Our Wi-Fi Services. If you use Wi-Fi services that we make available at an OIG Property, we might collect information about your use of our Wi-Fi services, including your IP address, Wi-Fi information (such as SSID), mobile carrier, the websites you visit, the type of device and browser you are using, your device identification number, bandwidth used and session time.
4. HOW WE MAY USE YOUR INFORMATION.
We will use the information you provide to us for the specific purposes for which you provided the information, as stated at the time of collection, and as otherwise described in the Privacy Policy or permitted by law. The following are some other ways in which we may use your information to administer or promote our business and provide you with the products and services you request or may be of interest to you;
• to improve the products and services we provide you and develop new products and services;
• to improve the OIG Websites;
• to track your use of the OIG Websites for our internal market research and analytics;
• to create a more accurate and complete customer profile for you to better understand and predict the products and services you want to use and to provide a more personalized level of service;
• to notify you about promotions and special offers regarding products and services provided by us or our affiliates or other associated third parties, including our Joint Marketing Partners (defined below);
• to ask for your participation in our internal market research;
• to generate aggregate statistical studies about our customers to better understand how our customers use our services;
• to contact you in response to your inquiries, comments and suggestions;
• to provide a healthy, secure, and safe environment for our customers or employees;
• to protect and defend our rights or property or enforce our agreements with you;
• administer general recordkeeping for financial statements and audits;
• comply with our internal records management policy and retention rules;
• to contact you otherwise when necessary; and
• otherwise with your consent or as permitted or required by applicable law.
5. HOW WE SHARE YOUR INFORMATION WITH OUR AFFILIATES.
For business purposes, we may share certain information we receive from you, and about your transactions with us, with our affiliates, including other Nation instrumentalities, corporate entities or affiliates. Doing so allows us to provide the products and services you have requested.
6. HOW WE SHARE YOUR INFORMATION WITH NON-AFFILIATED THIRD PARTIES.
As permitted by law, we may share the information we collect from and about you with non-affiliated third parties as follows:
(a) Third Party Service Providers. Your information may be shared with or collected by third party service providers who provide us with services. We require these providers to exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them.
(b) Response to Lawful Requests for Information or Court Orders or to Protect Rights and to Comply with Our Policies and Applicable Law. To the extent permitted by law, we will disclose your information to government authorities or third parties: (i) if required to do so by applicable law, or in response to request for information that would otherwise be the subject of a lawful subpoena or court order if not for the Oneida Indian Nation’s sovereign immunity, search warrant or other valid legal process, (ii) to comply with legal, regulatory or administrative requirements of any governmental authorities having authority or jurisdiction, including but not limited to gaming regulators, (iii) in connection with any legal action, claim or dispute, including but not limited to the collection of debts, (iv) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large, or (v) we believe that you have abused a OIG Website by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
(c) Aggregate Information. We may share your information with affiliated or non-affiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
7. ONLINE ADVERTISING; TRACKING.
(a) Online Advertising. OIG and third parties may use the information collected through the OIG Websites using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable advertising services to track the actions of users online over time and across different web sites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience.
(b) Do Not Track. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, at the present time we do not disable tracking technology that may be active on the OIG Websites in response to any “do not track” requests that we receive from your browser.
8. SALE OF PERSONAL INFORMATION.
OIG will not sell your persoonal information.
9. SECURITY.
We maintain physical, electronic and organizational safeguards that reasonably and appropriately protect against the loss, misuse and alteration of the information under our control. With regard to information that you transfer to us through one of the OIG Websites, please be aware that no data transmission over the Internet or a wireless network can be guaranteed to be 100% secure. As a result, OIG cannot guarantee or warrant the security of any information you transmit on or through the OIG Websites and you do so at your own risk.
10. HOW TO ACCESS, UPDATE AND CORRECT PERSONAL INFORMATION.
You can update and correct your personal information by emailing privacy@onenterprises.com
11. CHANGES TO OUR PRIVACY POLICY.
Over time, it may be necessary to modify or supplement our Privacy Policy. When we make changes, we will post the changes to the OIG Websites and change the effective date at the top of the Privacy Policy. We encourage you to visit the OIG Websites from time to time to review our Privacy Policy in the event it has changed. Your continued provision of information to us or use of the OIG Services following the posting of changes to the Privacy Policy means that you accept the changes and our use of your personal information in accordance with the revised Privacy Policy. If you have provided us with your email address, we will also notify you of material changes to this Privacy Policy by sending an email at least thirty (30) days before the effective date of the changes to the email address you most recently provided to us. We encourage you to keep the email address you provide to us current, and to promptly notify us of any changes to your email address, so that you may receive any notices we send to you regarding material changes to this Privacy Policy. If you do not agree to the changes, you should discontinue your use of the OIG Services prior to the time the modified Privacy Policy takes effect.
12. NON-U.S. RESIDENTS.
Unless otherwise specified, the OIG Websites and material provided on or through the OIG Websites are solely intended for users located in the United States and for promoting products, programs, and business operations within the United States. If you do not reside in the United States and you choose to access or use the OIG Websites and provide your personal information to us, it may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should not use the OIG Websites.
13. CONTACT INFORMATION.
Should you have additional questions, comments or concerns regarding this Privacy Policy or how we collect and use your information, you may send an email or contact us by writing to:
Oneida Innovations Group, LLC
ATTN.: Joseph Cavano
579A Main Street Suite 5
Oneida, NY 13421