Privacy Policy

1. Who We Are

This Privacy Policy applies to Cadtree Limited (2031), a Guernsey-registered company with registered address at La Corvee House, La Corvee Alderney, GY9 3TQ ("Cadtree," "we," "us," or "our"). Cadtree Limited is the operator of spincasino.ca, rubyfortune.ca, jackpotcity.ca, and royalvegas.ca (collectively, the "Casino Websites"). Cadtree Limited is licensed by the Alcohol and Gaming Commission of Ontario (AGCO) under License No. OPIG1237906 (issued 23 June 2022) and operates under the iGaming Ontario (iGO) Operator Agreement. Cadtree Limited collects, processes, and discloses personal information in compliance with Ontario's Freedom of Information and Protection of Privacy Act (FIPPA), the Personal Information Protection and Electronic Documents Act (PIPEDA), and Ontario Regulation 722/21. For privacy enquiries, contact Cadtree Limited via the Help Centre at help.spincasino.ca.

2. What Data We Collect

Information You Provide Directly

Registration data (full legal name, date of birth, email address, phone number, physical address, government ID number, occupation), copies of government-issued photo ID submitted for KYC verification, voluntary communications (chat messages, email correspondence, customer support interactions), and social network profile data if you register via a social login (name, birthdate, profile picture, friends list, publicly available profile content).

Transaction and Activity Data

Payment information (credit card numbers, bank account details) collected for deposit and withdrawal processing, gameplay data (deposits, bets, bonuses, session durations, game-specific activity, high scores), and tournament participation records.

Technical Data

Device identifiers (UDID, IMEI, MAC address), IP address, geolocation data (collected to verify Ontario location compliance), browser fingerprinting, operating system and browser type, click-stream activity, pages viewed, time-on-page, log files, connection type, and VPN/proxy detection data.

Telephone Call Data

Cadtree Limited records and monitors telephone calls with Player Services for training, quality assurance, and security purposes. Players consent to recording by using these services.

3. How We Use Your Data

To create, manage, and maintain your Casino Account, including identity verification and KYC compliance.
To provide, operate, and improve the casino gaming services.
To process deposits, withdrawals, and payment transactions, including anti-money-laundering checks in compliance with FINTRAC.
To verify that each player is physically located in Ontario at login and during play sessions.
To communicate with players regarding account activity, promotions, and service updates.
To conduct analytics, performance research, and statistical reporting to improve the Services.
To detect and prevent fraud, money laundering, bot usage, and other prohibited conduct.
To administer the Loyalty Club, bonuses, tournaments, and responsible gaming tools.
To respond to player support requests, complaints, and regulatory enquiries.
To comply with AGCO requirements, iGO Operating Agreement obligations, FIPPA, PIPEDA, Ontario Regulation 722/21, and applicable Canadian law.

With affiliated Cadtree Limited companies within the Casino Group for operational and compliance purposes.
With third-party service providers (cloud computing, identity verification, fraud prevention, payment processors, credit reporting agencies) engaged to support the operation of the Casino Websites.
With iGaming Ontario (iGO) and the Alcohol and Gaming Commission of Ontario (AGCO) as required by the Operating Agreement and applicable regulations.
With FINTRAC and other governmental authorities for anti-money-laundering compliance.
With eCOGRA as Cadtree Limited's approved Alternative Dispute Resolution (ADR) provider.
With the Alderney Gaming Control Commission (AGCC) as required by Cadtree Limited's international licensing obligations.
With marketing affiliates and White Label Brand operators, where applicable, in accordance with the player's marketing consent preferences.
With auditors, legal advisers, and insurers as required for business operations.
With law enforcement or courts when required by law or to defend legal claims.
Cadtree Limited does not rent or sell personal data to unaffiliated third parties for their own independent marketing purposes.

5. Your Rights

Access: You may request a copy of the personal data Cadtree Limited holds about you.
Correction: You may request correction of inaccurate or incomplete personal data.
Deletion: You may request deletion of your personal data, subject to Cadtree Limited's legal retention obligations under gambling regulations, FINTRAC, and the iGO Operating Agreement.
Restriction: You may request that Cadtree Limited restrict further processing of your data in certain circumstances.
Objection: You may withdraw consent to marketing communications at any time by contacting Player Services via live chat.
Portability: You may request your personal data in a machine-readable format where technically feasible.

Rights requests are subject to applicable legal exceptions under FIPPA, PIPEDA, and gambling regulations. Not all data can be immediately deleted due to mandatory retention obligations. Submit rights requests via the Help Centre at help.spincasino.ca or by email to the Privacy Executive contact form on the Casino Website. Ontario players may also file a Freedom of Information Request (FOI Request) directly with iGaming Ontario under Part II of FIPPA.

6. How We Protect Your Data

256-bit SSL encryption on all data transmissions between players and the Casino Websites.
Secure network topology including firewall and intrusion prevention systems.
Multi-Factor Authentication (MFA) available for all player accounts.
Access controls restricting data access to authorised personnel categories: Customer Support, Customer Welfare, Technology and IT Operations, Risk and AML, Data Analytics, Compliance, Legal, and Privacy Teams.
External and internal security audits.
Incident response procedures aligned to Cadtree Limited's Incident Management Process, with breach notification to players, iGO, and the Office of the Privacy Commissioner of Canada within applicable timeframes.

7. Cookies

Cadtree Limited uses Tracking Technologies — including cookies, web beacons, pixel tags, scripts, and similar tools — on the Casino Websites and in the mobile app. Four categories of cookies are used: strictly necessary (essential for login and security), functionality (remembering player preferences and language settings), performance (analytics and usage statistics), and marketing/advertising (delivering targeted offers based on derived interests). Players can manage cookie preferences through their web browser settings or via the cookie preference centre on the Casino Website. Disabling strictly necessary cookies will impair login and account functionality. For detailed information, see the Cadtree Cookie Policy (last updated 1 July 2022) on the Privacy Policy page at spincasino.ca.

8. Data Retention

Financial data and gameplay data: retained for a minimum of six years from the date of each transaction.
Telephone call recordings and correspondence: retained for a minimum of three years, or longer where legitimate legal interests require.
AML-related data: retained for a minimum of five years from the end of the customer relationship.
Marketing data: retained for a maximum of three years.
Inactive Account data: Cadtree Limited may deactivate Inactive Accounts (no login for six or more consecutive months) after 30 days' notification to the player. A C$10 monthly administration fee applies to positive cash balances in deactivated Inactive Accounts until the balance reaches zero or the account is reactivated.

9. Minors

The Services are not directed at persons under 19 years of age. Cadtree Limited conducts age verification checks during registration. If Cadtree Limited identifies or is notified that an account has been registered by a person under 19, that account will be closed immediately and all funds forfeited. Players who suspect a minor has accessed the Services should report this via help.spincasino.ca.

10. Changes to This Policy

Cadtree Limited reserves the right to amend this Privacy Policy at any time. Material changes will be communicated by notice on the Casino Website or by email to the player's registered address. Material changes take effect seven days after publication. Non-material changes take effect on the published "Last Updated" date. Continued use of the Services after any change constitutes acceptance of the updated Privacy Policy.

11. Contact Us

For privacy enquiries, rights requests, or complaints regarding data handling: contact the Cadtree Limited Privacy Executive via the contact form on the Privacy Policy page at spincasino.ca or via live chat at help.spincasino.ca. Players who are unsatisfied with Cadtree Limited's response may escalate to iGaming Ontario at [email protected] or to the Office of the Privacy Commissioner of Canada.