Conference proceedings, Zurich 2023

but in general, there are obviously marketing and advertising allowances in the US. And I think that’s really taking a step forward. A couple months ago, I was at another conference and there was a gentleman from AWS, speaking about how they are getting into the operator marketing casino rewards app business. Hopefully, they’re not going to compete with us but he was talking about basic geolocation. So they’re talking about integrating with a casino loyalty app or casino rewards app to actually start locating users when they’re on the casino floor, or on the property anywhere: what restaurants are they eating at? Where are they shopping? You know, how long are they on the floor? Things like that and probably they could even expand that with a multi property operator, like Caesars or MGM. If they’re in a different state, and they’re logged into their app, and they see that they’re at another property. So its more about the player, the user data outside of gambling, what else are they doing? What are they interested in? Can we push them, you know, a $10 gift certificate to a particular restaurant that we know that they like I think it’s expanding from that perspective, as well. But if we’re also talking about out, integrating like a rewards app with a betting app they’re still tracking those things as well. We don’t have as many restrictions on bonus offers and things like that like, as they do in Europe. So there are technologies coming in to bring that all together, and maybe start pushing out different marketing or make a bigger marketing push. JK: This may sound a little provocative, but based on what you just described, what AWS is doing, that isn’t really omnichannel. Isn’t it really all about getting granular information to push promotions. And we’re hiding behind monitoring player behavior from a Responsible Gambling point of view and increased AML protections and these kinds of things. But it’s really all about the marketing. Anyone else out there agree or disagree? GA: I agree. I think especially based on what I heard from AWS a couple months ago, that’s kind of the intent of it. And I’m sure at some point a regulator will reel them in. But that’s the point we’re getting to. We have the technology, so if you’re on the rewards app, and you’ve got it open then anonymity is gone. The casinos wants to know where you’re going, what you’re doing on their property, so that they know how they can basically keep you as a customer. What things to push out to you, what incentives to give for customer loyalty. JK: Okay, let’s shift gears now and talk about regulation and the regulatory challenges. We’ve talked about technology, we all know what it is, how it works, what the intent is, the benefits of it, the downsides, but let’s talk about as a practical matter, how to implement it in different markets, and whether the regulatory frameworks that exist account for omnichannel. We talked about geolocation quite a bit. Gabrielle, give us your thoughts on whether, in the US at least, existing regulation accounts for what you’ve described as two different levels of geolocation: one set of rules for targeted marketing, the other for geolocating and geofencing people when they’re placing bets? GA; I think that is going to be a challenge, if not, from a regulatory perspective, from a technology perspective to integrate that kind of geolocation. Geolocation is very heavily regulated. In the betting and online gaming market, marketing is different. But if you’re on an online casino or betting app, there are very strict geolocation regulations, there are very detailed technical standards around what the geolocation system has to do, when it has to do it, what data the operator has to keep and provide to the regulator. And then you’ve got the marketing perspective where there’s no regulatory framework for that type of geolocation right now. There are obviously marketing rules and regulations, but that tends to be around what you can market, not how you’re tracking customers. I think, if you’re an omnichannel, if you’ve got the betting app integrated with the casino rewards or loyalty app, you have to lean towards the more heavily regulated geolocation requirements. You’ve got to figure out how to have those geolocation checks when someone’s logged in, to look at a place to bet, perhaps to deposit or withdraw money from their betting account. First, how are the regulators going to look at that. If you’re all in one, you’re saying I’ve got to track them for this from a compliance perspective, but we also want to track them from a marketing perspective. And the regulators need to consider whether we just make them run all the same checks. Do we allow them to try to integrate two different types of checks depending on where they are? When you’re combining the less regulated with the heavily regulated it’s a challenge. Where do you find that balance?

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