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Privacy Policy

OCEAN RESORT ONLINE CASINO

PRIVACY POLICY

AC OCEAN WALK, LLC (which we may refer to as "Ocean", "us", "we" and "our") respect and are committed to protecting your privacy. That is why we have adopted this Privacy Policy. This Privacy Policy lets you know how and for what purposes your personally identifiable information is being collected, processed and used. Your personally identifiable information will only be used in ways that are in compliance with this Privacy Policy.

 

1. Privacy Policy Limitation

1.1. This Privacy Policy is only in effect for web pages, mobile and device-specific applications, third party social media sites, e-mail lists, as well as any on-line features, programs and services offered, owned or operated by Ocean or on Ocean’s behalf, including but not limited to, by its gaming partner, GAN, LLP., a London, UK-based company (together with any other company within a group of parent, affiliate and subsidiary companies of which GAN, LLP., is a part, being collectively referred to herein as "  GAN") in connection with the principle URL link:  www.oceanonlinecasino.com, any mobile or device specific version and any related applications of the website at such URL (collectively, the "  Website"), and relates to personally identifiable information and non user-specific information collected by Ocean or on Ocean's behalf, including but not limited to, by GAN, through the Website and through a means other than the Website.

 

1.2. This Privacy Policy does   not apply to:

i. any other web pages, mobile applications, mobile device specific applications, online features, services and/or programs,or third party social media sites other than the Website, as defined in 1.1 above; and

ii. any information (including but not limited to e-mail lists, non user-specific information and personally identifiable information) collected and/or owned by any entity other than (a) Ocean or (b) those entities collecting on behalf of Ocean (including, but not limited to, GAN).

 

1.3. This Privacy Policy also does not apply to information collected by or for Ocean through a means other than the Website or in connection with the Website.

 

1.4. Should there be any changes to this Privacy Policy, we will notify you the next time you log into your Patron account (Patron shall have the meaning set forth in the Website Terms) at which point you will be prompted to accept such changes to the Privacy Policy. The date of the most recent revision to this Privacy Policy appears at all times at the end of this Privacy Policy.

 

2. Website Ownership and Operation

2.1. The Website is currently operated for Ocean by GAN, under and pursuant to the Internet Gaming Permit issued to Ocean by the New Jersey Division of Gaming Enforcement ("NJDGE") pursuant to N.J.S.A. 5:12-95.21 of the New Jersey Casino Control Act, as amended, and the regulations promulgated thereunder. As required under the Act, the Website is currently operated from computer servers hosted and maintained by Ocean or its service provider. The terms of this Privacy Policy shall apply to our operation of the Website regardless of what party or parties may act as our service provider for such operations.

 

2.2. Your use of the Website is also governed by the Website Terms.

 

2.3. The Website and the games on such Website are provided and operated by GAN on our behalf.

 

3. Information Collected

3.1. Registration information collected

 

3.1.1. Required information - information which is required by Ocean in order to open a Patron account shall include but not be limited to, your:

i. legal name;

ii. date of birth;

iii. Social Security Number (in its entirety or part of it) or equivalent if you are foreign such as a passport or taxpayer identification number;

iv. mailing address;

v. e-mail address;

vi. cellular telephone number; and

vii. gender.

 

3.2. Information that may be required or requested by Ocean may include but not limited to:

i. credit card numbers, bank account numbers or other personal financial information;

ii. geographical information;

iii. biographical information such as household data, preferences and demographic information;

iv. drivers’ license numbers;

v. credit and debit card information;

vi. purchase information regarding our products and services;

vii. demographic information;

viii. security question responses; and

ix. opt in status for SMS and telephonic marketing.

 

3.3. For training and security purposes, we may record or monitor calls as they relate to wagering communications, geographic location, emails you send to us and chat logs with our Customer Support, among other things.

 

3.4. When you connect to the Website, we may also retrieve information from the computer used to log onto the Website. The information we collect may include (but is not limited to) information about the computer's hardware system and data related to the computer's software or use of the Website.

 

3.5. In addition, when you interact with the Website, our servers keep an activity log unique to you that collects certain administrative and traffic information, including, but not limited to: source Internet Protocol ("  IP") address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used.

 

3.6. You are under no obligation to provide personally identifiable information to us. However, certain personally identifiable information is essential for the provision and quality of the services we offer to you (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information.

 

4. Patron Account, Password, and Security

4.1. For certain features available through the Website, we may require the use of encryption technologies provided for your protection and/or Patron account. We use reasonable precautions to protect the privacy of your username, password and Patron account information. 

 

4.2. You, however, are ultimately responsible for protecting your username, password and Patron account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You agree to: (a) immediately notify Ocean of any unauthorized use of your username, password and/or Patron, and/or any other breach of security; and (b) ensure that you log out from your Patron account at the end of each session. While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.

 

5. Use of Personally Identifiable Information

5.1. Personally identifiable information collected by Ocean may be used for the following purposes:

 

5.1.1. to enable the features of the Website, including, but not limited to:

i. operating any competitions or promotions in which you may participate;

ii. setting up and managing your Patron account, including but not limited to our processing your requests for information, and/or providing support services to you;

iii. if necessary in connection with the management and operation of your Patron account, contacting you at your registered email address or by means of any other contact details that you provide to us;

iv. processing your online financial and wagering transactions;

v. building up your personal profiles; and

vi. confirming that you are physically located in the State of New Jersey when you are Wagering on the Website,

 

5.1.2. to improve the Website by determining, among other things, which of our products, features and services are most popular or effective. We may analyze your personally identifiable information and non-personally identifiable information, such as usage information, to enable us and/or our third party services providers, including but not limited to GAN, to provide products and services to you and develop new features, functionality, products and services:

 

5.1.3. to personalize the experience of the Patrons; and

 

5.1.4. to communicate with you and to inform you about Ocean’s and third parties’ products and services. Unless you have opted in or out as applicable, we and/or any of our third party service providers, including, but not limited to, GAN, may send you information by email, telephone (including, but not limited to SMS), mail or by any other contact details you provide to us or GAN’s and selected third parties': services, products, competitions, prizes and offers.

If you do not wish to receive any information about existing and new services, products, competitions, prizes and offers from us you can tell us not to contact you for marketing purposes at initial registration, by updating your marketing preferences in the My Account section of the Website or by clicking on the unsubscribe link in any marketing email that we or our third party service providers, including but not limited to GAN, send to you. If you opt out or revoke your consent to receive calls and text messages, you acknowledge that such revocation is not instantaneous and will be effective in a reasonable period of time.

 

If you have provided us with your prior express written consent to receive communications via text messaging (which you understand may include the use of an automatic telephone dialing system (auto-dialer)), you may opt out from future text messages by texting STOP. Once you cancel, we will send one additional confirmation message stating that you've opted out.

 

5.2. We may publish some personally identifiable information for promotional purposes, prize or competition winners, including but not limited to winnings and winner’s username. For winnings greater than $100, the winner’s username, first name and initial letter of surname, gender, town, city or county as registered on his or her Patron account may be published. Please see Section   22 of the Website Terms for further information on publicity and the disclosure of winners’ details.

 

5.3. If you submit content and/or participate in the chat facility on the Website, your content and/or communications on the chat facility are not private or confidential, and may be viewed and used by others accessing the Website. Please do not submit any information to the chat facility that you do not want others to see.

 

5.4. When you create a Patron profile, the information that you provide, including, but not limited to, a username and an image (such as a photograph), is not private or confidential, and may be viewed and used by others accessing the Website. We recommend that you choose a username and image that is original and makes no reference to your name and does not contain any personally identifiable information.

 

5.5. When you accept a friend’s invitation to register as a Patron as part of the Refer a Friend program, information relating to your progress in meeting the wagering requirements related to the Refer a Friend program and number of Ocean Premier Rewards Points collected may be viewed by such friend. Please do not participate in the Refer a Friend program if you do not want such information to be seen by your friend.

 

5.6. We may use or make available to you a "strong authentication" process to verify your identity from time to time.

 

5.7. If you reside in, or are a citizen of, a territory within the European Union, we may transfer your personally identifiable information outside the European Union for use for any of the purposes described in this Privacy Policy. By using the Website and providing us with your personally identifiable information, you consent to such transfer of your personally identifiable information.

 

5.8. Information that we may obtain or you submit is subject to the Website Terms, Section   2.

 

6. How Information is Collected

6.1. The means by which Ocean collects such personally identifiable information may include, but is not limited to, when you: (1) purchase, order, or request information about our services through the Website; (2) access an Ocean social media platform; (3) sign up for e-mail notifications, electronic newsletters, mobile messages (including SMS), or social media notifications from, or on behalf of, Ocean; (4) enter or participate in a competition or promotion on the Website, or respond to one of our surveys; (5) provide Ocean with comments, suggestions or other input through the Website; and (6) create a Patron account for use in connection with the Website. Ocean also collects such personally identifiable information in connection with our marketing efforts on third party websites.

 

6.2. Ocean or a partner may sponsor competitions and/or promotions through the Website. Your participation is entirely voluntary. Patrons may be asked to provide personally identifiable information including, but not limited to, their name, email address or home address or to answer questions in order to participate. Ocean may also transfer personally identifiable information to certain advertising or marketing partners from whom you have requested to receive information.

 

6.3. Ocean may engage the services of third party service providers (including, but not limited to, credit reference agencies, customer verification agencies or marketing agencies) and suppliers for certain activities including, but not limited to services to process your information, age, identity location verification, providing technical support, processing your online transactions, maintaining your account and marketing among other things.

 

6.4. Browser Log Files - Our servers automatically log each visitor to the Website and collect and record certain information about each visitor. This information includes or may include your IP address, browser language, browser type, operating system, domain names, browsing history (including time spent at a domain, time and date of your visit), referring/exit web pages and URLs, and number of clicks. The domain name and IP address reveal nothing personal about the visitor other than the IP address from which the user has accessed the Website.

 

6.5. Unique Identifier - We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Website and some of the electronic communications you receive from us.

 

6.6. Cookies - From time to time, Ocean and/or our advertisers or other third parties may send a "cookie" to your computer. A cookie is a small piece of data that is sent to your Internet browser from a web server and stored on your computer’s hard drive and that can be re-sent to the serving website on subsequent visits. A cookie, by itself, cannot read other data from your hard disk or read other cookie files already on your computer. A cookie, by itself, does not damage your system. We use cookies for a number of different purposes, including, but not limited to:

i. authenticating requests made in our customer help interface;

ii. recognizing a patron and track their actions on subsequent visits;

iii. collecting information about how visitors use the Website;

iv. testing different design ideas; and

v. anonymously tracking visitors to the Website through online advertising.

We, our advertisers and other third parties may use cookies to identify and keep track of, among other things, those areas of the Website and third party websites that you have visited in the past in order to enhance your next visit to the Website.

You can choose whether or not to accept cookies by changing the settings of your Internet browser, but some functionality of the Website may be impaired or not function as intended, if you choose not to accept cookies. See Section   6.8 below.

 

6.7. Web Beacons - Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as "clear gifs"). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third party advertisers. These Web Beacons do not carry any personally identifiable information and are only used to track usage of the Website and activities associated with the Website. See Section   6.8 below.

 

6.8. Third Party Collection Services - We may allow third-party companies to serve advertisements and/or track and collect certain information. Such services include but are not limited to:

i. helping us to improve your use and experience of the Website by tracking your activity on the Website and/or other websites;

ii. measuring the effectiveness of the Website and the effectiveness of our marketing campaigns; and

iii. collecting or receiving information and using that information to advertise to you on other websites.

These companies may use non-personally identifiable information (including, but not limited to, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Website in order to provide advertisements about goods and services likely to be of greater interest to you.

These companies typically use a cookie or third party Web Beacon to collect this information, as further described above. Through these technologies, the third party may have access to and use non-personalized information about your online usage activity.

 

6.9. There are Federal prohibitions and restrictions relating to wagering on the Internet (including, but not limited to, such prohibitions and restrictions set out in 18 U.S.C. §§ 1084 et seq. (The Wire Act) and 31 U.S.C. §§ 3163 through 3167 (UIEGA)). It is a Federal offense for persons physically located outside of New Jersey to engage in Internet wagering through any New Jersey casino, including, but not limited to, placing a Wager (as defined in the Website Terms) on the Website, unless you are explicitly authorized by the Regulator (as defined in the Website Terms). We and our service providers utilize several current technologies, and may use future technologies, in order to verify your physical location while you are placing a Wager on the Website (collectively, the "  Geolocation Technologies"). Geolocation Technologies report your physical location from the computer or Internet-connected device that you choose and from which you are accessing the Website. Geolocation Technologies obtain your physical location by accessing your IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates. The Geolocation Technologies report to us, our service providers and/or the Regulator the physical and geographic location of the computer or Internet-connected device from which you are accessing the Website. It is possible that your precise or near-precise physical location will be reported to us, our service providers and/or the Regulator when you use the Website.

 

7. When Information Is Disclosed By Ocean

7.1. In addition to the other times or occasions on which we might disclose personally identifiable information about Patrons, we might also disclose personally identifiable information when required by law or in the good-faith belief that such disclosure is necessary to: (1) comply with legal process and applicable laws, including but not limited to the requirements of the NJDGE or any other regulatory body having jurisdiction over Ocean or the Website; (2) enforce this Privacy Policy; (3) respond to claims that any materials, documents, images, graphics, logos, designs, audio, video and any other information provided to, from or on the Website violates the rights of third parties; or (4) protect the rights, property or personal safety of Ocean, its Patrons or the public.

 

7.2. We use reasonable precautions to keep the information that is disclosed to us secure. We provide personally identifiable information and non-personally-identifiable information to businesses or persons (including our service provider GAN) for the purposes of processing such information on our behalf and promoting the goods and services of our trusted business partners, some or all of which may store some of your information on servers outside of the United States. We require that these parties agree to process such information in compliance with our Privacy Policy or in a similar, industry-standard manner, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures. The use of your information by one of our trusted business partners may be subject to that party’s own Privacy Policy. Without limiting the foregoing, use of such information by GAN and other business partners shall at all times be subject to the terms of this Privacy Policy.

 

7.3. We may share non-personally identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to demonstrate the usage patterns for Ocean’s advertisements, content, functionality, promotions, competitions, games and/or services on the Website and/or on third party websites.

 

7.4. We may share personally identifiable information with third party service providers and suppliers. For example, without limitation, we may engage the services of third party service providers (including, but not limited to, credit reference agencies) and suppliers for certain activities including, but not limited to, processing your information, age, identity and location verification providing technical support, processing your online transactions, maintaining your account, advertisement and providing prizes and gifts to you. We take steps to ensure that our arrangements with third party service providers protect your privacy by ensuring that these third parties comply strictly with our instructions.

 

7.5. We also reserve the right to disclose personally identifiable information and/or non-personally-identifiable information in connection with the enforcement of our Website Terms, take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Website, to ensure or increase regulatory compliance, and/or to protect the rights, property, or personal safety of Ocean, our Patrons or others. For example, without limitation, if you self-exclude from the Website, we may disclose information about you to our gaming regulators, relevant employees and other casino licensees in accordance with applicable laws and regulations.

 

7.6. We reserve the right to transfer your personally identifiable information, as well as any other information, in connection with the sale or other disposition of all or part of  Ocean’s business and/or assets. We also cannot make any representations regarding the use or transfer of your personally identifiable information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors. Furthermore, we cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties (including other users of the Website) that receive any of the information that is disclosed to us. The Website may also link to other websites and contain advertisements of third parties. We are not and cannot be responsible for the privacy policies of those websites of third parties or for how they treat information (including, but not limited to personally identifiable information) about their users.

 

7.7. The Website may contain links to other websites, including, but not limited to, links to websites of various third party service providers. Ocean is not and cannot be responsible for the privacy practices or the content of any other websites. Other than under agreements with certain reputable organizations and companies, and except for third party service providers (as described in this Privacy Policy), we do not share any of the personally identifiable information that you provide to us with any of the websites to which the Website links, although we may share aggregate, non-personally identifiable information with those other websites. Please check with those websites in order to determine their privacy policies and your rights under them.

 

7.8. California’s "Shine the Light" Law

 

7.8.1. California residents who provide personally identifiable information in connection with obtaining products or services for personal, family or household use are entitled to request, and obtain from us once each calendar year, information about the Patron information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities).

 

7.8.2. To obtain this information on behalf of Ocean, please send an email message to privacy@oceancasino.com with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

 

7.8.3. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

 

8. Information From Persons Under 21 Years of Age

8.1. It is a criminal offense to allow a person who is under the age of twenty-one (21) to participate in Internet wagering. The Website is not for use by any person under the age of twenty-one (21) and we do not knowingly accept as a Patron anyone under the age of twenty-one (21).

 

8.2. Furthermore, the Website is not intended or designed to attract individuals under the age of twenty-one (21). We do not collect personally identifiable information from any person that we know to be under the age of twenty-one (21) You affirm that you are at least twenty-one (21) years of age and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Policy, and to abide by and comply with this Privacy Policy.

 

8.3.   THE WEBSITE IS NOT INTENDED FOR CHILDREN. Parents should be aware that Ocean’s Privacy Policy will govern our use of personally identifiable information, but also that information that is voluntarily given by children - or others - in e-mail exchanges, bulletin boards or the like may be used by other parties to generate unsolicited communications.  Ocean encourages all parents to instruct their children in the safe and responsible use of their personally identifiable information while using the Internet.

 

9. Access and Correction

9.1. To access your personally identifiable information in the possession of Ocean and correct inaccuracies of that information in our records, please contact us in the manner specified at the end of this Privacy Policy. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances as permitted by applicable privacy legislation.

 

10. Choices with your Personally Identifiable Information

10.1. Whether you submit any personally identifiable information to Ocean is entirely up to you. You are under no obligation to provide personally identifiable information. However, this information is essential for the provision and quality of the services we offer to you (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information. 

 

10.2. You may choose to prevent Ocean from disclosing or using your personally identifiable information under certain circumstances ("opt out"). You may opt out of any disclosure or use of your personally identifiable information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Policy, or by following the procedures set forth in an electronic communication from us, if applicable. Furthermore, even where your personally identifiable information is to be disclosed and used in accordance with the stated purposes in this Privacy Policy, you may elect to opt out of such disclosure to and use by a third party that is not acting as an agent of Ocean. There are some uses from which you cannot opt-out, such as our use of your personally identifiable information in connection with regulatory compliance and/or reporting.

 

10.3. If Ocean collects personally identifiable information, such information will not be disclosed or used by Ocean for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization unless you affirmatively consent to such disclosure and use.

 

10.4. You can opt-out of online behavioral services through any one of the ways described below (you do not need to go to each opt-out site, one is sufficient). After you opt-out, you will continue to receive advertisements, but those advertisements will no longer be as relevant to you.

  • You can opt-out via the Network Advertising Initiative industry opt-out at www.networkadvertising.org.
  • You can opt-out via the Consumer Choice Page at www.aboutads.info.
  • You can configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser. It is at your discretion whether you use the opt-out described above or manage cookies via the browser.

Note: If you opt-out as described above, you should not delete your cookies. If you delete your cookies, you will need to opt-out again.

 

11. Your Consent To This Privacy Policy

11.1. By using the Website, you consent to the collection and use of your information (including personally identifiable information) by us as identified herein, in compliance with this Privacy Policy, unless you inform us otherwise by means of the procedure identified herein. If we make changes to this Privacy Policy or any part of it, you will be notified of such changes and asked for your acceptance. So that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Website following such publication of any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

 

11.2. If you have additional questions or comments of any kind, wish to opt-out of this Privacy Policy or if you see anything on the Website that you think is inappropriate or incorrect, please let us know by e-mail or by sending your comments or requests to:

 

Ocean Resort Casino

500 Boardwalk

Atlantic City, New Jersey 08401

Attn: Customer Support support@oceancasino.com

Copyright © 2020. AC Ocean Walk, LLC. All Rights Reserved.

 

EFFECTIVE AS OF: June 29, 2018

LAST UPDATED: March 4, 2020

Protecting your privacy. That is why we have adopted this Privacy Policy. This Privacy Policy lets you know how and for what purposes your personally identifiable information is being collected, processed and used. Your personally identifiable information will only be used in ways that are in compliance with this Privacy Policy. 1. Privacy Policy Limitation 1.1. This Privacy Policy is only in effect for web pages, mobile and device-specific applications, third party social media sites, e-mail lists, as well as any on-line features, programs and services offered, owned or operated by Ocean or on Ocean’s behalf, including but not limited to, by its gaming partner, GAN, LLP., a London, UK-based company (together with any other company within a group of parent, affiliate and subsidiary companies of which GAN, LLP., is a part, being collectively referred to herein as " GAN") in connection with the principle URL link: www.oceancasino.com, any mobile or device specific version and any related applications of the website at such URL (collectively, the " Website"), and relates to personally identifiable information and non user-specific information collected by Ocean or on Ocean's behalf, including but not limited to, by GAN, through the Website and through a means other than the Website. 1.2. This Privacy Policy does not apply to: i. any other web pages, mobile applications, mobile device specific applications, online features, services and/or programs,or third party social media sites other than the Website, as defined in 1.1 above; and ii. any information (including but not limited to e-mail lists, non user-specific information and personally identifiable information) collected and/or owned by any entity other than (a) Ocean or (b) those entities collecting on behalf of Ocean (including, but not limited to, GAN). 1.3. This Privacy Policy also does not apply to information collected by or for Ocean through a means other than the Website or in connection with the Website. 1.4. Should there be any changes to this Privacy Policy, we will notify you the next time you log into your Patron account (Patron shall have the meaning set forth in the Website Terms) at which point you will be prompted to accept such changes to the Privacy Policy. The date of the most recent revision to this Privacy Policy appears at all times at the end of this Privacy Policy. 2. Website Ownership and Operation 2.1. The Website is currently operated for Ocean by GAN, under and pursuant to the Internet Gaming Permit issued to Ocean by the New Jersey Division of Gaming Enforcement ("NJDGE") pursuant to N.J.S.A. 5:12-95.21 of the New Jersey Casino Control Act, as amended, and the regulations promulgated thereunder. As required under the Act, the Website is currently operated from computer servers hosted and maintained by Ocean or its service provider. The terms of this Privacy Policy shall apply to our operation of the Website regardless of what party or parties may act as our service provider for such operations. 2.2. Your use of the Website is also governed by the Website Terms. 2.3. The Website and the games on such Website are provided and operated by GAN on our behalf. 3. Information Collected 3.1. Registration information collected 3.1.1. Required information - information which is required by Ocean in order to open a Patron account shall include but not be limited to, your: i. legal name; ii. date of birth; iii. Social Security Number (in its entirety or part of it) or equivalent if you are foreign such as a passport or taxpayer identification number; iv. mailing address; v. e-mail address; vi. cellular telephone number; and vii. gender. 3.2. Information that may be required or requested by Ocean may include but not limited to: i. credit card numbers, bank account numbers or other personal financial information; ii. geographical information; iii. biographical information such as household data, preferences and demographic information; iv. drivers’ license numbers; v. credit and debit card information; vi. purchase information regarding our products and services; vii. demographic information; viii. security question responses; and ix. opt in status for SMS and telephonic marketing. 3.3. For training and security purposes, we may record or monitor calls as they relate to wagering communications, geographic location, emails you send to us and chat logs with our Customer Support, among other things. 3.4. When you connect to the Website, we may also retrieve information from the computer used to log onto the Website. The information we collect may include (but is not limited to) information about the computer's hardware system and data related to the computer's software or use of the Website. 3.5. In addition, when you interact with the Website, our servers keep an activity log unique to you that collects certain administrative and traffic information, including, but not limited to: source Internet Protocol (" IP") address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. 3.6. You are under no obligation to provide personally identifiable information to us. However, certain personally identifiable information is essential for the provision and quality of the services we offer to you (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information. 4. Patron Account, Password, and Security 4.1. For certain features available through the Website, we may require the use of encryption technologies provided for your protection and/or Patron account. We use reasonable precautions to protect the privacy of your username, password and Patron account information. 4.2. You, however, are ultimately responsible for protecting your username, password and Patron account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You agree to: (a) immediately notify Ocean of any unauthorized use of your username, password and/or Patron, and/or any other breach of security; and (b) ensure that you log out from your Patron account at the end of each session. While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error. 5. Use of Personally Identifiable Information 5.1. Personally identifiable information collected by Ocean may be used for the following purposes: 5.1.1. to enable the features of the Website, including, but not limited to: i. operating any competitions or promotions in which you may participate; ii. setting up and managing your Patron account, including but not limited to our processing your requests for information, and/or providing support services to you; iii. if necessary in connection with the management and operation of your Patron account, contacting you at your registered email address or by means of any other contact details that you provide to us; iv. processing your online financial and wagering transactions; v. building up your personal profiles; and vi. confirming that you are physically located in the State of New Jersey when you are Wagering on the Website, 5.1.2. to improve the Website by determining, among other things, which of our products, features and services are most popular or effective. We may analyze your personally identifiable information and non-personally identifiable information, such as usage information, to enable us and/or our third party services providers, including but not limited to GAN, to provide products and services to you and develop new features, functionality, products and services: 5.1.3. to personalize the experience of the Patrons; and Anchor5.1.4. to communicate with you and to inform you about Ocean’s and third parties’ products and services. Unless you have opted in or out as applicable, we and/or any of our third party service providers, including, but not limited to, GAN, may send you information by email, telephone (including, but not limited to SMS), mail or by any other contact details you provide to us or GAN’s and selected third parties': services, products, competitions, prizes and offers. If you do not wish to receive any information about existing and new services, products, competitions, prizes and offers from us you can tell us not to contact you for marketing purposes at initial registration, by updating your marketing preferences in the My Account section of the Website or by clicking on the unsubscribe link in any marketing email that we or our third party service providers, including but not limited to GAN, send to you. If you opt out or revoke your consent to receive calls and text messages, you acknowledge that such revocation is not instantaneous and will be effective in a reasonable period of time. If you have provided us with your prior express written consent to receive communications via text messaging (which you understand may include the use of an automatic telephone dialing system (auto-dialer)), you may opt out from future text messages by texting STOP. Once you cancel, we will send one additional confirmation message stating that you've opted out. 5.2. We may publish some personally identifiable information for promotional purposes, prize or competition winners, including but not limited to winnings and winner’s username. For winnings greater than $100, the winner’s username, first name and initial letter of surname, gender, town, city or county as registered on his or her Patron account may be published. Please see Section 22 of the Website Terms for further information on publicity and the disclosure of winners’ details. 5.3. If you submit content and/or participate in the chat facility on the Website, your content and/or communications on the chat facility are not private or confidential, and may be viewed and used by others accessing the Website. Please do not submit any information to the chat facility that you do not want others to see. 5.4. When you create a Patron profile, the information that you provide, including, but not limited to, a username and an image (such as a photograph), is not private or confidential, and may be viewed and used by others accessing the Website. We recommend that you choose a username and image that is original and makes no reference to your name and does not contain any personally identifiable information. 5.5. When you accept a friend’s invitation to register as a Patron as part of the Refer a Friend program, information relating to your progress in meeting the wagering requirements related to the Refer a Friend program and number of Ocean Premier Rewards Points collected may be viewed by such friend. Please do not participate in the Refer a Friend program if you do not want such information to be seen by your friend. 5.6. We may use or make available to you a "strong authentication" process to verify your identity from time to time. 5.7. If you reside in, or are a citizen of, a territory within the European Union, we may transfer your personally identifiable information outside the European Union for use for any of the purposes described in this Privacy Policy. By using the Website and providing us with your personally identifiable information, you consent to such transfer of your personally identifiable information. 5.8. Information that we may obtain or you submit is subject to the Website Terms, Section 2. 6. How Information is Collected 6.1. The means by which Ocean collects such personally identifiable information may include, but is not limited to, when you: (1) purchase, order, or request information about our services through the Website; (2) access an Ocean social media platform; (3) sign up for e-mail notifications, electronic newsletters, mobile messages (including SMS), or social media notifications from, or on behalf of, Ocean; (4) enter or participate in a competition or promotion on the Website, or respond to one of our surveys; (5) provide Ocean with comments, suggestions or other input through the Website; and (6) create a Patron account for use in connection with the Website. Ocean also collects such personally identifiable information in connection with our marketing efforts on third party websites. 6.2. Ocean or a partner may sponsor competitions and/or promotions through the Website. Your participation is entirely voluntary. Patrons may be asked to provide personally identifiable information including, but not limited to, their name, email address or home address or to answer questions in order to participate. Ocean may also transfer personally identifiable information to certain advertising or marketing partners from whom you have requested to receive information. 6.3. Ocean may engage the services of third party service providers (including, but not limited to, credit reference agencies, customer verification agencies or marketing agencies) and suppliers for certain activities including, but not limited to services to process your information, age, identity location verification, providing technical support, processing your online transactions, maintaining your account and marketing among other things. 6.4. Browser Log Files - Our servers automatically log each visitor to the Website and collect and record certain information about each visitor. This information includes or may include your IP address, browser language, browser type, operating system, domain names, browsing history (including time spent at a domain, time and date of your visit), referring/exit web pages and URLs, and number of clicks. The domain name and IP address reveal nothing personal about the visitor other than the IP address from which the user has accessed the Website. 6.5. Unique Identifier - We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Website and some of the electronic communications you receive from us. 6.6. Cookies - From time to time, Ocean and/or our advertisers or other third parties may send a "cookie" to your computer. A cookie is a small piece of data that is sent to your Internet browser from a web server and stored on your computer’s hard drive and that can be re-sent to the serving website on subsequent visits. A cookie, by itself, cannot read other data from your hard disk or read other cookie files already on your computer. A cookie, by itself, does not damage your system. We use cookies for a number of different purposes, including, but not limited to: i. authenticating requests made in our customer help interface; ii. recognizing a patron and track their actions on subsequent visits; iii. collecting information about how visitors use the Website; iv. testing different design ideas; and v. anonymously tracking visitors to the Website through online advertising. We, our advertisers and other third parties may use cookies to identify and keep track of, among other things, those areas of the Website and third party websites that you have visited in the past in order to enhance your next visit to the Website. You can choose whether or not to accept cookies by changing the settings of your Internet browser, but some functionality of the Website may be impaired or not function as intended, if you choose not to accept cookies. See Section 6.8 below. 6.7. Web Beacons - Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as "clear gifs"). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third party advertisers. These Web Beacons do not carry any personally identifiable information and are only used to track usage of the Website and activities associated with the Website. See Section 6.8 below. 6.8. Third Party Collection Services - We may allow third-party companies to serve advertisements and/or track and collect certain information. Such services include but are not limited to: i. helping us to improve your use and experience of the Website by tracking your activity on the Website and/or other websites; ii. measuring the effectiveness of the Website and the effectiveness of our marketing campaigns; and iii. collecting or receiving information and using that information to advertise to you on other websites. These companies may use non-personally identifiable information (including, but not limited to, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Website in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party Web Beacon to collect this information, as further described above. Through these technologies, the third party may have access to and use non-personalized information about your online usage activity. 6.9. There are Federal prohibitions and restrictions relating to wagering on the Internet (including, but not limited to, such prohibitions and restrictions set out in 18 U.S.C. §§ 1084 et seq. (The Wire Act) and 31 U.S.C. §§ 3163 through 3167 (UIEGA)). It is a Federal offense for persons physically located outside of New Jersey to engage in Internet wagering through any New Jersey casino, including, but not limited to, placing a Wager (as defined in the Website Terms) on the Website, unless you are explicitly authorized by the Regulator (as defined in the Website Terms). We and our service providers utilize several current technologies, and may use future technologies, in order to verify your physical location while you are placing a Wager on the Website (collectively, the " Geolocation Technologies"). Geolocation Technologies report your physical location from the computer or Internet-connected device that you choose and from which you are accessing the Website. Geolocation Technologies obtain your physical location by accessing your IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates. The Geolocation Technologies report to us, our service providers and/or the Regulator the physical and geographic location of the computer or Internet-connected device from which you are accessing the Website. It is possible that your precise or near-precise physical location will be reported to us, our service providers and/or the Regulator when you use the Website. 7. When Information Is Disclosed By Ocean 7.1. In addition to the other times or occasions on which we might disclose personally identifiable information about Patrons, we might also disclose personally identifiable information when required by law or in the good-faith belief that such disclosure is necessary to: (1) comply with legal process and applicable laws, including but not limited to the requirements of the NJDGE or any other regulatory body having jurisdiction over Ocean or the Website; (2) enforce this Privacy Policy; (3) respond to claims that any materials, documents, images, graphics, logos, designs, audio, video and any other information provided to, from or on the Website violates the rights of third parties; or (4) protect the rights, property or personal safety of Ocean, its Patrons or the public. 7.2. We use reasonable precautions to keep the information that is disclosed to us secure. We provide personally identifiable information and non-personally-identifiable information to businesses or persons (including our service provider GAN) for the purposes of processing such information on our behalf and promoting the goods and services of our trusted business partners, some or all of which may store some of your information on servers outside of the United States. We require that these parties agree to process such information in compliance with our Privacy Policy or in a similar, industry-standard manner, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures. The use of your information by one of our trusted business partners may be subject to that party’s own Privacy Policy. Without limiting the foregoing, use of such information by GAN and other business partners shall at all times be subject to the terms of this Privacy Policy. 7.3. We may share non-personally identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to demonstrate the usage patterns for Ocean’s advertisements, content, functionality, promotions, competitions, games and/or services on the Website and/or on third party websites. 7.4. We may share personally identifiable information with third party service providers and suppliers. For example, without limitation, we may engage the services of third party service providers (including, but not limited to, credit reference agencies) and suppliers for certain activities including, but not limited to, processing your information, age, identity and location verification providing technical support, processing your online transactions, maintaining your account, advertisement and providing prizes and gifts to you. We take steps to ensure that our arrangements with third party service providers protect your privacy by ensuring that these third parties comply strictly with our instructions. 7.5. We also reserve the right to disclose personally identifiable information and/or non-personally-identifiable information in connection with the enforcement of our Website Terms, take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Website, to ensure or increase regulatory compliance, and/or to protect the rights, property, or personal safety of Ocean, our Patrons or others. For example, without limitation, if you self-exclude from the Website, we may disclose information about you to our gaming regulators, relevant employees and other casino licensees in accordance with applicable laws and regulations. 7.6. We reserve the right to transfer your personally identifiable information, as well as any other information, in connection with the sale or other disposition of all or part of Ocean’s business and/or assets. We also cannot make any representations regarding the use or transfer of your personally identifiable information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors. Furthermore, we cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties (including other users of the Website) that receive any of the information that is disclosed to us. The Website may also link to other websites and contain advertisements of third parties. We are not and cannot be responsible for the privacy policies of those websites of third parties or for how they treat information (including, but not limited to personally identifiable information) about their users. 7.7. The Website may contain links to other websites, including, but not limited to, links to websites of various third party service providers. Ocean is not and cannot be responsible for the privacy practices or the content of any other websites. Other than under agreements with certain reputable organizations and companies, and except for third party service providers (as described in this Privacy Policy), we do not share any of the personally identifiable information that you provide to us with any of the websites to which the Website links, although we may share aggregate, non-personally identifiable information with those other websites. Please check with those websites in order to determine their privacy policies and your rights under them. 7.8. California’s "Shine the Light" Law 7.8.1. California residents who provide personally identifiable information in connection with obtaining products or services for personal, family or household use are entitled to request, and obtain from us once each calendar year, information about the Patron information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities). 7.8.2. To obtain this information on behalf of Ocean, please send an email message to privacy@oceancasino.com with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. 7.8.3. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response. 8. Information From Persons Under 21 Years of Age 8.1. It is a criminal offense to allow a person who is under the age of twenty-one (21) to participate in Internet wagering. The Website is not for use by any person under the age of twenty-one (21) and we do not knowingly accept as a Patron anyone under the age of twenty-one (21). 8.2. Furthermore, the Website is not intended or designed to attract individuals under the age of twenty-one (21). We do not collect personally identifiable information from any person that we know to be under the age of twenty-one (21) You affirm that you are at least twenty-one (21) years of age and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Policy, and to abide by and comply with this Privacy Policy. 8.3. THE WEBSITE IS NOT INTENDED FOR CHILDREN. Parents should be aware that Ocean’s Privacy Policy will govern our use of personally identifiable information, but also that information that is voluntarily given by children - or others - in e-mail exchanges, bulletin boards or the like may be used by other parties to generate unsolicited communications. Ocean encourages all parents to instruct their children in the safe and responsible use of their personally identifiable information while using the Internet. 9. Access and Correction 9.1. To access your personally identifiable information in the possession of Ocean and correct inaccuracies of that information in our records, please contact us in the manner specified at the end of this Privacy Policy. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances as permitted by applicable privacy legislation. 10. Choices with your Personally Identifiable Information 10.1. Whether you submit any personally identifiable information to Ocean is entirely up to you. You are under no obligation to provide personally identifiable information. However, this information is essential for the provision and quality of the services we offer to you (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information. 10.2. You may choose to prevent Ocean from disclosing or using your personally identifiable information under certain circumstances ("opt out"). You may opt out of any disclosure or use of your personally identifiable information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Policy, or by following the procedures set forth in an electronic communication from us, if applicable. Furthermore, even where your personally identifiable information is to be disclosed and used in accordance with the stated purposes in this Privacy Policy, you may elect to opt out of such disclosure to and use by a third party that is not acting as an agent of Ocean. There are some uses from which you cannot opt-out, such as our use of your personally identifiable information in connection with regulatory compliance and/or reporting. 10.3. If Ocean collects personally identifiable information, such information will not be disclosed or used by Ocean for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization unless you affirmatively consent to such disclosure and use. 10.4. You can opt-out of online behavioral services through any one of the ways described below (you do not need to go to each opt-out site, one is sufficient). After you opt-out, you will continue to receive advertisements, but those advertisements will no longer be as relevant to you. You can opt-out via the Network Advertising Initiative industry opt-out at www.networkadvertising.org. You can opt-out via the Consumer Choice Page at www.aboutads.info. You can configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser. It is at your discretion whether you use the opt-out described above or manage cookies via the browser. Note: If you opt-out as described above, you should not delete your cookies. If you delete your cookies, you will need to opt-out again. 11. Your Consent To This Privacy Policy 11.1. By using the Website, you consent to the collection and use of your information (including personally identifiable information) by us as identified herein, in compliance with this Privacy Policy, unless you inform us otherwise by means of the procedure identified herein. If we make changes to this Privacy Policy or any part of it, you will be notified of such changes and asked for your acceptance. So that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Website following such publication of any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you. 11.2. If you have additional questions or comments of any kind, wish to opt-out of this Privacy Policy or if you see anything on the Website that you think is inappropriate or incorrect, please let us know by e-mail or by sending your comments or requests to: Ocean Resort Casino 500 Boardwalk Atlantic City, New Jersey 08401 Attn: Customer Support support@oceancasino.com Copyright © 2020. AC Ocean Walk, LLC. All Rights Reserved. EFFECTIVE AS OF: June 29, 2018 LAST UPDATED: March 4, 2020

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