EFFECTIVE DATE 24.04.2022

Hotslot is committed to protecting your privacy. We are committed to gaining and maintaining your trust by following a core set of Privacy Principles.

1. Scope

This Privacy Policy applies to information collected by the Hotslot Website. Please review this Privacy Policy carefully. The Privacy Policy describes, among other things, the types of information collected by Hotslot about you when you visit the Website; how your information may be used and disclosed; how you can control the use and disclosure of your information; and how the personal information is protected. In addition, please review the Terms of Use that govern your use of this Website.

2. Information Collected

You are not required to provide information about yourself when you visit a Website and can visit most areas of this Website without doing so. Hotslot may ask you for different types of information only when you log in or directly contact the Hotslot such as contact information (full name and email address) or call our offices or provide feedback, comments, or ask questions about the Website.

When you access the Website, we automatically collect certain information from you, including:

• Your device type and settings, software used and browser type, and operating system;
• Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Websites or other services you visited before and after visiting a Website;
• Web pages and advertisements you view and links you click on within the Website;
• Unique identifiers and connection information, including mobile device identification numbers (e.g. Apple’s Identifier for Advertising IP (IDFA) or Google’s Android Advertising ID (AAID)) and internet connection means (e.g. mobile operator, ISP, WiFi connection) that can identify the physical location of such devices in accordance with applicable law;
• Information collected through cookies, web beacons, and other similar technologies;
• Standard server log information.
• This Privacy Policy does not cover actions of the third parties, including those who disclose information to Hotslot.

In order to improve the Website, we may combine the information we collect about you with information we collect from other sources. This is done to better serve you and help ensure that your experience on our Website is transparent, personalized, and appropriate for you. For example, combining information allows us to make our communications with you more relevant for future visits to our Website and develop richer content on our Website

3. Use of Information

Hotslot uses the personal information that you have given to us for operation purposes, such as to send you news and bonus programs. We may also use your personal information for related purposes that you would reasonably expect from us. If we will decide to use your personal information for direct marketing purposes, we will give you the opportunity to opt-out of receiving any marketing material. We may share the personal information that you have given to us with associates and affiliates. We may also use your personal information for related purposes that you would reasonably expect.

We collect and use certain Personal Information about you that is not necessary for the Website to function, such as information that is used to better understand how we can improve our Website and Content. We generally use this information in order to: fulfill your requests for information, including sending you electronic newsletters that you have requested; analyzing the use of the Website and information about visitors of our Website to understand and improve our Content; whenever permitted by law or otherwise in accordance with our Terms of Use, deny access to the Website or remove content; customize the content you see on the Website; prevent potentially prohibited or illegal activities otherwise in accordance with our Terms of Use and/or any other purpose disclosed to you at the time we collect your information or pursuant to your consent.

4. Data Subject Rights

Data subjects with a residentship in New Zealand have the following rights under the Act:

The right to access information – the right to both:

confirmation as to whether (or not) an agency holds information about that person; and

access to such personal information, where such personal information may be readily retrieved.

The right to correction of information – the right to request correction of information. The agency must, on request or of its own initiative, take steps that are reasonable in the circumstances to ensure (having regard to the purposes for which the information may lawfully be used), that the information is accurate, up to date, and not misleading.

Object to direct marketing – while there is not a specific right to object to direct marketing under the 2020 Act, it is worth noting that the Unsolicited Electronic Messages Act 2007 (‘UEMA’) prohibits the sending of unsolicited electronic messages (such as SMS or e-mail) for direct marketing purposes. Additionally, under the Telecoms Code, telecommunication information may only be used for direct marketing if the individual has been advised that such authorisation may be withdrawn at any time (Rule 10 of the Telecoms Code).

Rights not included in the 2020 Act

There is no express right to object to processing in New Zealand. If the information had yet to be provided by the individual, then she/he may refuse to provide the relevant information (provided it is being collected directly), or otherwise complain of interference to privacy to either the OPC or the agency itself.

Note that there is no broad right to data portability in New Zealand. For completeness, there is ‘number portability’ whereby local and mobile numbers may be transferred, which is regulated under different legislation outside the scope of this Guidance Note (the Telecommunications Act 2001).

Similarly, there is not a ‘right to be forgotten’ or ‘right to erasure’ in New Zealand. It is arguable that an individual may request their information to be corrected (as described above), and such a correction may constitute deletion of information, but this is not typically what is thought of when referring to a right to be forgotten. However, of note in this area is the Harmful Digital Communications Act 2015, which aims to deter, prevent, and mitigate harm to individuals caused by digital communications (often known as ‘cyber-bullying’), and provide victims with efficient means of redress. This can involve a court takedown order, requiring harmful digital communications to be removed.

Data subjects with a residentship in Canada have the following rights under the Privacy Act:

The right to access information – the right to both:

confirmation as to whether (or not) an agency holds information about that person; and

access to such personal information, where such personal information may be readily retrieved.

The right to correction of information – the right to request correction of information. The agency must, on request or of its own initiative, take steps that are reasonable in the circumstances to ensure (having regard to the purposes for which the information may lawfully be used), that the information is accurate, up to date, and not misleading.

In addition to the access and correction rights, you may be entitled to exercise the right to:

• we process your personal information for the purposes of providing our services, administering the Website and mobile applications, and complying with legal or regulatory requirements.
• request the restriction of processing of your personal data (for instance, if the data is not accurate and needs to be updated). This can also be done for data where the purposes of processing no longer apply, but you still need the data and do not want us to erase it.
• you have the right to ask us to erase your personal data where: (a) it may no longer be necessary for the purpose for which it was collected or processed; (b) you have withdrawn consent; (c) you have successfully objected to processing but wish to exercise this right in future; and/or (d) we have no legitimate interest in continuing our processing. Certain data may not be erased if we have a legal requirement to keep it.
• in order to ensure that individuals are not unjustifiably prevented from exercising their rights, you must establish a mechanism for the portability of personal data. The applicant can request that their information be transferred from one controller to another (e.g. from Facebook to Twitter) if such transfer is technically possible.

To exercise these rights, please Contact Us and we will respond to your request within 30 days, subject to any legal exceptions, and otherwise in accordance with the law.

You also have the right to file a complaint with the data protection authority in your country.

5. Disclosure of Information

We may share information collected about you as disclosed at the time of collection, as otherwise disclosed in this privacy policy, and in the following circumstances: 1. With vendors and other service providers who need such information to carry out their duties. 2. To comply with any legal obligation or for other legal purposes. 3. Where appropriate, within Hotslot.

• With your consent. Hotslot may share your contact information with third-party marketing partners. You acknowledge that when you disclose personal information on the Website and you allow your information to be shared with third parties that can contact you in different ways. Sometimes Hotslot may give you the option to receive further communications from one of our advertising partners. If you do choose to opt-in by expressly providing consent to receive communications from that third-party advertiser, your personal information will be managed by that third party’s own privacy policy.
• Transfers. Hotslot may share your information in connection with a transaction of the corporate rights, such as the sale of a Website, a merger, consolidation, asset sale, or in the event of bankruptcy.
• Legal requirements. Hotslot may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations. There may be circumstances where the law requires Hotslot to disclose the information, or where disclosure is required for law enforcement purposes.
• Protect our Website and users. We may disclose information to protect and defend the legal rights, interests, and safety of the Website; to protect the safety and security of visitors of the Website and members of the public; and as otherwise disclosed in our Terms of Use.

Finally, we also may share aggregated or anonymized information with third parties, to help us develop content that, we hope, will be interesting to you or to help these third parties develop their service offerings.

6. Your Choices

You can choose to view content and features on the Website without providing us directly with any information about you; however, as described above, some information may be collected automatically. There may be times when we ask for personal information from you and you do not wish to provide it. You can opt-out of receiving commercial email or text messages from a particular Website or other services by following the instructions contained in any such message or by contacting us directly. You also have choices about whether cookies and other similar technologies are placed on your computer or mobile device. You also may choose to opt-out of the use of data that our authorized third-party service providers or we collect about your visits to our business partners’ websites that may be used to deliver advertisements tailored to your interests. Finally, you also have choices about the collection and use of your information by third parties to display relevant advertisements.

7. Protection of Information

We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, unauthorized access, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Website but we cannot ensure or warrant the security of any information you transmit to us.

8. Transfer of Data Internationally

Please be aware that information you provide to us or that we obtain as a result of your use of the Website may be collected in your country. The privacy and data protection laws in the country to which your information is transferred may not be equivalent to such laws in your country of residence. Your personal information may be subject to the laws of the country to which it is transferred and may be accessible without notice to you by the courts, law enforcement and national security authorities of that country. By using and visiting the Website or providing us with your information, you consent to the collection, international transfer, storage, and processing of your information.

9. Legal Basis

The key legislation in New Zealand in relation to data protection that we use is Privacy Act 2020 (‘the 2020 Act’). The 2020 Act empowers the Office of the Privacy Commissioner (‘OPC’) to issue codes of practice, which comprise part of the privacy law in New Zealand. The intention of these codes is to modify the operation of the act for specific types of information, or for certain industries. Separate to the 2020 Act, privacy principles can be found within New Zealand’s common law. The New Zealand courts have developed a tort of privacy (i.e. the right of one person to sue another for breach of privacy). The tort of privacy relates to the public disclosure of private facts, where such disclosure would be considered to be highly offensive to a reasonable person of ordinary sensibilities, balanced against the wider public interest (Bradley v. Wingnut Films Ltd [1993] 1 NZLR 415).

Also, according to Canadian legislation and specifically under both the Privacy Act (R.S.C., 1985, c. P-21) and the Personal Information Protection and Electronic Documents Act (PIPEDA) (S.C. 2000, c. 5, Assented to 2000-04-13), We collect personal information as defined by section 3 of the Privacy Act.

10. Information for members in the EEA, UK, and Switzerland

If you are a member of the EEA, UK, and Switzerland, you can find detailed information about your rights by following this link.

11. Changes to This Privacy Policy

Hotslot may update its Privacy Policy to reflect changes in legal basis and Content offerings. If Hotslot modifies Privacy Policy, we will update the “Last Modified Date” and such changes will be effective upon the next posting of such Privacy Policy. If we make any changes in the way Hotslot uses your information, we will notify you in advance by email through the email address you most recently provided to us or by prominently posting a prominent notice of the changes on the Website.

12. Questions

If you have questions regarding this Privacy Policy, please contact us and we will be happy to respond to your request within a reasonable period of time. You may also submit questions using the information on the “Contacts” page.