1. Introduction
Konnected Koncepts ("JustKonnect," "we," "us," or "our") operates the JustKonnect platform —
an all-in-one loyalty, SMS marketing, compliance, and player engagement system built for
charity bingo halls and entertainment venue operators.
This Privacy Policy explains how we collect, use, store, share, and protect information about
the operators who use our platform, the players who participate in loyalty programs managed
through it, and visitors to our website at justkonnect.com.
We are committed to handling all personal information with care, transparency, and in
compliance with applicable privacy laws including the California Consumer Privacy Act (CCPA),
Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and other
applicable data protection regulations. This policy also includes specific provisions governing
SMS messaging consent and compliance, which apply to all parties using JustKonnect's
messaging features.
If you have questions about this policy or how your data is handled, please contact us using
the information provided in Section 9 of this document.
2. Information We Collect
JustKonnect collects several categories of information depending on whether you are a platform
operator (a bingo hall owner or manager) or an end user (a player participating in a loyalty
program managed through JustKonnect).
2.1 Information Provided Directly
When operators create an account or configure the platform, we collect:
- Business name, address, and contact information
- Operator name, email address, and phone number
- Billing information (processed securely through a third-party payment processor — we do not store full payment card details)
- Platform configuration settings, including loyalty program rules, reward structures, and SMS campaign preferences
When players enroll in a loyalty program managed through JustKonnect (via an operator's hall), we may collect:
- Full name
- Phone number (required for SMS communications where the player opts in)
- Email address (where provided)
- Date of birth (where used for birthday reward campaigns, with player consent)
- Hall membership or player ID number
2.2 Usage and Engagement Data
We automatically collect certain data when operators and players interact with the JustKonnect platform:
- Login activity and session timestamps
- Platform feature usage — which modules are accessed and when
- Player visit and session attendance records (as logged by the operator)
- Campaign delivery and engagement data — SMS delivery status, opt-outs, and response rates
- Device type, browser, and IP address for platform access security purposes
2.3 Loyalty and Rewards Data
As part of operating a loyalty program, JustKonnect collects and stores:
- Player points balances — points earned, redeemed, and expired
- Reward issuance records — type of reward, date issued, and player attributed
- Redemption activity — when and where rewards were redeemed
- Gamification participation — spin-to-win entries, streak records, challenge completion
- Campaign-specific enrollment data (e.g., birthday campaign opt-ins)
2.4 Compliance Log Data
JustKonnect automatically generates time-stamped activity logs covering player interactions,
reward events, and campaign activity. This data is collected and retained specifically to support
compliance and audit obligations applicable to charity gaming operators. See Section 6 for data
retention details.
3. How We Use Your Data
JustKonnect uses the information we collect for the following purposes:
3.1 Platform Operation
- To create and manage operator and player accounts
- To operate loyalty programs, issue and track reward points, and process redemptions
- To run SMS marketing campaigns and automated communication workflows on behalf of operators
- To generate compliance logs and audit-ready activity reports
- To provide customer support and respond to operator and player inquiries
3.2 Communications
- To send SMS messages to players who have opted in to receive communications from a specific bingo hall operator via the JustKonnect platform
- To deliver automated campaign messages — including game reminders, jackpot alerts, birthday rewards, and re-engagement sequences — based on player activity data
- To send platform-related communications to operators — including service updates, billing notices, and product announcements
- To send missed-call auto-reply SMS messages to players who have previously opted in and contacted a hall via phone
3.3 Compliance and Regulatory Reporting
- To maintain complete, time-stamped activity logs for charity gaming regulatory review
- To generate exportable compliance reports at the request of an authorized operator
- To respond to lawful requests from regulators, auditors, or law enforcement where required
3.4 Platform Improvement
- To analyze platform usage patterns and improve product features
- To monitor system performance and security
- To conduct internal research and development — using aggregated, de-identified data only
4. SMS Consent and Messaging Compliance
This section governs all SMS communications sent through the JustKonnect platform. It applies
to operators using JustKonnect's messaging features and to players who receive messages from
bingo halls operating on the platform.
4.1 Opt-In Requirement
JustKonnect does not send SMS messages to any individual who has not expressly consented
to receive them. Consent must be obtained prior to any message being sent and must be:
- Freely given — the player must not be required to consent to SMS communications as a condition of receiving a service
- Specific — consent must clearly identify who will be messaging the individual and for what purpose
- Informed — the player must be told they are signing up for recurring automated messages and what types of messages they will receive
- Documented — all opt-in records are logged in the JustKonnect platform with a timestamp and attribution
Operators are responsible for obtaining valid consent from players before enrolling them in any
SMS campaign through JustKonnect. Operators must not import or upload phone number lists
without confirmed prior consent from each individual on the list.
4.2 Message Disclosures
All SMS campaigns sent through JustKonnect must include or reference the following at the point of opt-in:
- The name of the bingo hall or organization sending messages
- The nature of the messages (e.g., "You will receive game reminders, jackpot alerts, and loyalty updates from [Hall Name]")
- Frequency disclosure (e.g., "Message frequency may vary")
- Data rate notice: "Message and data rates may apply"
- Opt-out instructions (see Section 4.3)
- A link to this Privacy Policy
4.3 Opt-Out Instructions
To stop receiving SMS messages: Reply STOP to any message at any time. You will
receive a single confirmation message and no further messages will be sent. To re-subscribe,
reply START or follow the sign-up process at your bingo hall.
JustKonnect honors opt-out requests immediately and permanently. When a player sends
STOP, their number is flagged in the system and excluded from all future campaign sends.
Operators cannot manually override a player's opt-out status. Help instructions are available by
replying HELP to any message.
4.4 Short-Code Messaging Compliance
JustKonnect uses carrier-approved short codes for all broadcast SMS communications.
Short-code messaging complies with:
- The Telephone Consumer Protection Act (TCPA) in the United States
- CTIA Messaging Principles and Best Practices
- Canada's Anti-Spam Legislation (CASL) where applicable
- Carrier messaging guidelines for A2P (application-to-person) SMS
JustKonnect maintains delivery logs, opt-in records, and opt-out histories for all messaging
activity conducted through the platform. These records are available to operators for compliance
review and are retained in accordance with Section 6 of this policy.
4.5 Missed-Call Texting
JustKonnect's missed-call-to-text feature sends an automated SMS reply when a player calls a
hall and the call goes unanswered. This feature is only activated for players who have
previously opted in to receive SMS communications from that hall. Players who have not opted
in do not receive missed-call auto-replies. Operators may configure the content of missed-call
reply messages within platform guidelines.
5. Data Sharing and Disclosure
5.1 We Do Not Sell Personal Data
Clear statement: JustKonnect does not sell, rent, or trade personal data about operators or
players to any third party for any commercial purpose. This applies to all categories of personal
data we hold.
5.2 Internal Access
Access to personal data within JustKonnect is restricted to:
- Platform engineering and operations staff — for system maintenance, support, and security purposes
- Customer success and support teams — when responding to operator or player inquiries
- Compliance and legal personnel — when required for regulatory obligations
All internal access is governed by role-based permissions, and staff with access to personal data
are subject to confidentiality obligations.
5.3 Operator Access to Player Data
Operators who use JustKonnect to manage their player loyalty programs have access to the
player records associated with their hall. This includes visit history, points balances, redemption
records, and contact information for players enrolled in their program. Operators are responsible
for handling this data in accordance with applicable privacy laws and their own privacy
obligations to their players.
5.4 Service Providers
JustKonnect may share limited data with trusted third-party service providers who assist us in
operating the platform. These providers include:
- Cloud hosting and infrastructure providers
- Payment processing partners (billing information only, handled under their own PCI-compliant processes)
- SMS delivery carriers and short-code management providers
- Customer support and communication tools
All third-party service providers are contractually required to handle data only as directed by
JustKonnect, maintain appropriate security standards, and not use data for any purpose beyond
fulfilling their service obligations.
5.5 Legal and Regulatory Disclosure
JustKonnect may disclose personal data when required to do so by law or in good faith belief
that disclosure is necessary to:
- Comply with a legal obligation, court order, or government request
- Respond to a lawful request from a charity gaming regulator or audit authority
- Protect the rights, property, or safety of JustKonnect, our operators, players, or others
- Investigate fraud, security incidents, or violations of our terms of service
6. Data Security and Storage
6.1 Security Measures
JustKonnect implements industry-standard technical and organizational security measures to
protect personal data against unauthorized access, disclosure, alteration, and destruction.
These measures include:
- Encryption of data in transit using TLS (Transport Layer Security)
- Encryption of sensitive data at rest
- Access controls and role-based permissions for all platform users and staff
- Regular security monitoring and vulnerability assessments
- Incident response procedures for security events
No system can guarantee absolute security. In the event of a data breach that affects personal
data, JustKonnect will notify affected operators and, where required by law, relevant authorities
within applicable notification timeframes.
6.2 Data Retention
JustKonnect retains personal data for the following periods:
- Active operator account data: retained for the duration of the operator's subscription plus a reasonable period to facilitate account recovery or transitions
- Player loyalty and rewards data: retained for the duration of the operator's active program plus the period required to support audit and compliance obligations
- SMS messaging logs and opt-in/opt-out records: retained for a minimum of four years to support TCPA, CASL, and carrier compliance requirements
- Compliance and audit logs: retained for a minimum of five years, or longer if required by applicable charity gaming regulations in the operator's jurisdiction
- Operator billing records: retained in accordance with applicable accounting and tax retention requirements
Upon account termination, operators may request export of their data before deletion.
JustKonnect will delete or anonymize personal data when retention is no longer required, except
where retention is mandated by law.
7. Your Rights
Depending on your location and applicable privacy law, you may have the following rights
regarding your personal data:
7.1 Right to Access
You have the right to request a copy of the personal data JustKonnect holds about you,
including how it is being used. Operators can access most of their account data directly through
the platform dashboard. Players may submit an access request through the contact information
in Section 9.
7.2 Right to Correction
You have the right to request correction of inaccurate or incomplete personal data. Operators
can update most account information directly in the platform. Players should contact the
operator managing their loyalty program for updates to loyalty-related records, or contact
JustKonnect directly where the request concerns data held at the platform level.
7.3 Right to Deletion
You may request deletion of your personal data where it is no longer necessary for the purpose
for which it was collected, or where you withdraw consent and there is no other legal basis for
continued processing. Note that certain data — particularly compliance logs and messaging
records — may be subject to mandatory retention requirements that take precedence over
deletion requests.
7.4 Right to Opt Out of Communications
Players may opt out of SMS communications at any time by replying STOP to any message
(see Section 4.3). Operators may opt out of non-essential platform communications by updating
their notification preferences in their account settings or by contacting support.
7.5 Right to Data Portability
Where applicable under law, you have the right to receive your personal data in a structured,
machine-readable format. Operators may request a data export through the platform or by
contacting JustKonnect support.
7.6 Exercising Your Rights
To exercise any of the rights described above, please contact JustKonnect using the information
provided in Section 9. We will respond to verified requests within 30 days. In some cases,
we may need to verify your identity before processing a request. We will not discriminate against
any person for exercising their privacy rights.
8. Changes to This Privacy Policy
JustKonnect may update this Privacy Policy from time to time to reflect changes in our practices,
platform features, legal obligations, or applicable regulations.
When we make material changes, we will:
- Update the "Last Updated" date at the top of this policy
- Notify active operator account holders by email at least 14 days before changes take effect, where the changes materially affect how we handle their data or that of their players
- Post a notice on the JustKonnect platform dashboard for a period following any significant update
Continued use of the JustKonnect platform after the effective date of any updated policy
constitutes acceptance of the revised terms. If you do not agree with a material change, you
may terminate your account prior to the effective date and request deletion of your data in
accordance with Section 7.3.
For non-material updates — such as clarifications, formatting changes, or corrections that do
not affect how data is handled — we may update the policy without separate notice beyond the
updated effective date.
9. Contact Information
If you have questions, concerns, or requests related to this Privacy Policy or JustKonnect's data
practices, please contact us:
Privacy Contact
Company: Konnected Koncepts
Platform: JustKonnect (justkonnect.com)
Email: [INSERT PRIVACY CONTACT EMAIL]
Mailing Address: [INSERT COMPANY ADDRESS]
[ Note to dev: replace bracketed placeholders with real contact email and company address before publishing. ]
For SMS-related opt-out requests, players do not need to contact us directly — replying STOP
to any message will immediately remove you from all JustKonnect-powered SMS
communications from the sending operator.
For compliance log access requests from regulatory authorities, please contact us using the
email above and include your regulatory authority identification and the specific data or records
being requested. We will respond within applicable legal timeframes.
© Konnected Koncepts. All rights reserved. justkonnect.com
This Privacy Policy was last reviewed on [INSERT DATE]. Please check this page regularly for updates.