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Here is the Privacy Policy

Privacy Policy

Valuedynamx, Inc. on behalf of PENN Entertainment, Inc., (collectively, "we") are committed to protecting and respecting your privacy. With respect to the collection and processing of your data, as described below, PENN Entertainment, Inc. is the controller and Valuedynamx, Inc. is the processor/service provider. This Privacy Policy together with our Terms of Use explains how we treat any personal data we collect and process when you use our website, services or products.

1. Collection and processing of your personal data

We only collect and process your personal data if:

  • You have consented to it (e.g., while logging into the website); or
  • It is necessary in order for us to be able to provide our service or product, which you have consented to; or
  • It is necessary for compliance with our legal obligations as service providers of PENN Earn Marketplace; or
  • We have legitimate reason to do so, such as for fraud prevention or debt collection.

2. What types of personal data we handle

We collect and process the personal data that you provide when interacting with us (e.g., via Single Sign On (SSO) integration, log-in integration, during your use of the website or by the data subject directly either online or via email, such as for customer service purposes or enquiries.

Such personal data includes the following:

  • Unique identifier information (PENN Entertainment membership number, first and last name and email address);
  • Click history;
  • Payment card data for card linked offers
  • Some details provided by your device such as IP address, device ID, device type, and location data.

3. How we use your personal data

We may use the personal data we collect and process to:

  • Provide you with access to our website
  • Provide the services or products you request
  • Provide you with information you have requested, including without limitation, service emails concerning your purchase (e.g., cancelled purchases, miles crediting status, missing transactions etc.)
  • Respond to any enquiries from you regarding our products and services (e.g., points tracking requests)
  • Where you have agreed, provide you with information about certain other goods and services which we believe may be of interest to you (e.g., newsletters, favorite merchant notifications)
  • We may collect information on your activity on our website through monitoring your navigation and use of tools and functions available on our website. This non-personal information may be used in aggregated format to enable us to analyze the use of the website and to enhance the services offered (e.g., navigation experience, selection of merchants in our website)
  • Meet our legal and regulatory obligations
  • Detect and prevent fraud

4. Personal data sharing and transferring

We will not share your personal data with anyone else unless you agree to this, or such sharing is necessary to fulfil our contract with you, or we are legally allowed or required to do so. Moreover, your personal data will only be shared with selected organizations which comply with our security procedures and policies.

Organizations we may share your personal data with include:

  • Another member of our group of companies where they help provide our services to you.
  • Our service providers and subcontractors, where they help us provide our services to you.
  • To a regulating body or other authority where we need to comply with a regulatory or legal obligation, respond to a request.
  • Fraud prevention or debt collection organizations when required to protect our legitimate interests.

Some of those organizations may be based in a country outside the European Economic Area or where different data privacy laws apply. We will only transfer your personal data to that country if they ensure an adequate level of protection of your rights and freedoms, or you have given us your consent, or that transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and Decision 2010/87/EU as appropriate.

We will not sell your personal data to anyone.

5. Personal data protection and storage

Personal data collected and processed in accordance with this Privacy Policy is stored on secure servers located in the United Kingdom (primary servers) and United States, Hong Kong and Australia (replicas).

We handle your personal data in accordance with adequate and reasonable procedures and technologies in order to maintain and protect its security, availability, confidentiality and integrity, and prevent its unlawful or unauthorized processing, accidental loss or damage, from its collection until its destruction.

Where personal data is transmitted across the internet, it will be encrypted.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of your personal data, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6. Personal data disposal and retention

We will only keep your personal data for as long as it is needed for the purposes for which it was collected, and we will remove from our systems all personal data which is no longer required.

We will only retain your personal data for 36 months since you last used our services; and/or for a period longer than 36 months where we are required to do so by a regulatory or legal obligation.

7. Tracking

Online Affiliate

Transactions are electronically tracked and reported back by the participating merchant. We cannot be held responsible if for any reason merchants are not correctly reporting sales to us or reporting back at all. We will, however, use commercially reasonable efforts to ensure correct reporting by participating merchants. However, we do not accept liability if merchants fail to do so.

All participating merchants’ transactions are tracked through the use of cookies. It is your responsibility to ensure that cookies are enabled with your browser and ensure that any security software on your computer does not block cookies.

8. Use of cookies

We use cookies on our website in order to improve your user experience by enabling our website to “remember” you, either for the duration of your visit (using a “session cookie”) or for repeat visits (using a “persistent cookie”).

We may also use cookies to enable us to target our services or products based, for example, on your location and/or browsing habits.

Please click here to read our Cookie Policy which explains what we do and how you can alter your cookie settings.

9. Your rights

Subject to your place of residency, you may be entitled to exercise your consumer privacy rights at any time by:

  • Requesting a copy of the personal data we hold about you. We may charge a reasonable fee to provide further copies and can refuse to give you this information if your requests are clearly unjustified or excessive.
  • Have your personal data corrected if it is inaccurate or incomplete.
  • Request the deletion of your personal data where it is no longer necessary for us to keep it for the purpose for which it was originally collected or processed, unless we have a legal or regulatory obligation to retain the personal data.
  • Limit use/processing of your sensitive personal data. Where you have previously entered into a contracted service or product with us, this may imply cancelling the contracted service or product.
  • Opt-out of targeted advertisement, including profiling.
  • Obtain and reuse your personal data for your own purposes subject to certain conditions of portability.

10. How to contact us

If you have questions about our Privacy Policy, the operation or configuration of the PENN Earn Marketplace site, please contact us in the following ways:

Valuedynamx, Inc., Registered Office:

Cutlers Exchange
123 Houndsditch
London, EC3A 7BU UK

To exercise your rights, or if you wish to make a complaint about the use of your personal data, please contact PENN Entertainment at privacy@pennentertainment.com or by mail at:

PENN Entertainment, Inc.
825 Berkshire Blvd.
Wyomissing, PA 19610
Attn: Legal

For more information on PENN Entertainment Inc. privacy practices, you may access PENN Entertainment Privacy Policy here.

11. Other websites

Our website may contain links to other websites. This Privacy Policy only applies to our website, services and products so when you link to other websites, you should read their own privacy policies.

12. Changes to our policy

We keep our Privacy Policy under regular review and we will make any new versions available on our website.