Introduction

Caddttree Limited and its affiliated brands (collectively, “the Group”) provide online gaming services via websites, mobile apps, and other digital platforms (“Services”). This Privacy Policy explains what personal information we collect, how we use and protect it, and the rights you have under Canadian law regarding your privacy.

We strictly comply with Canadian legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial statutes (such as FIPPA in Ontario), ensuring robust protection of your data.

Caddttree Limited

Caddttree Limited (registration number: 2031, La Corvee House, Alderney GY9 3TQ, Guernsey) owns and operates the following online casinos:

• Spin Casino
• Ruby Fortune
• Luckysdayscasino
• Royal Vegas

The company is licenced and regulated by the Alcohol and Gaming Commission of Ontario (AGCO licence number OPIG1236392 dated June 23, 2022).

What Information We Collect

We collect two categories of information:

• Personal Information: When you register an account, we request your first and last name, email address, date of birth, residential address, telephone number, and other details necessary for identity verification (e.g., a copy of government-issued ID). For transactions, we collect payment details such as credit card or banking information. We may also request voluntary information for surveys or feedback, plus device information like IP address, geolocation, and device identifiers.
• Non-Personal Information: This is aggregated, anonymized data about your interaction with our Services: browser type, operating system, date and time of visits, pages viewed, and your gaming activity (deposits, wagers, wins, session durations, etc.). When data cannot be linked directly to an individual user, it is considered non-personal.

Minors

Our Services are intended for individuals aged 19 and over (or older if required by your jurisdiction’s law). If you are under the required age, please discontinue using our Services and do not provide us with any personal information. If we become aware that we have collected personal information from a minor, we will promptly delete it.

How We Use Your Information

We use collected information for the following purposes:

• Account creation, maintenance, and updates.
• Operational purposes, including processing payments, placing bets, and facilitating tournaments.
• Communication with you for important notifications, updates, and special offers.
• Marketing communications (email, SMS, or push notifications) if you have provided consent.
• Analytics and research to improve and personalise our Services.
• Ensuring responsible gaming, problem gambling prevention, and self-exclusion tools when required.
• Customer support and dispute resolution.
• Identity verification and fraud prevention (KYC/AML procedures).

Marketing

We may use your contact and other personal information to send you marketing materials related to our Services and partner products. You can withdraw your marketing consent at any time by contacting customer support or via your account settings. However, we reserve the right to send you service-related communications necessary for the provision of our Services.

With Whom We Share Information

We do not sell or rent your personal information to third parties. However, we may disclose information to:

• Affiliated companies within the Group and White Label brands for operational purposes.
• Payment processors, banks, and financial institutions to handle transactions.
• Compliance organisations and auditors for regulatory reviews and audits.
• Credit bureaus and verification services for identity checks (KYC/AML).
• Government and regulatory authorities (e.g., AGCO, iGaming Ontario) as required by law.
• Customer support partners to respond to inquiries and resolve disputes.
• Potential investors or in the event of a corporate transaction (merger, acquisition, or sale of assets).

International Transfer of Information

Since we operate in multiple jurisdictions, your information may be transferred outside Canada. We take all reasonable measures to protect your data, including contractual safeguards with data recipients and verifying that their jurisdiction provides adequate protection (e.g., standard contractual clauses).

Third Party Tracking Technologies

We use cookies, pixels, web beacons, and other tracking technologies to enhance our Services and analytics. Specifically:

• Session cookies to maintain preferences and login state.
• Analytics tools (such as Google Analytics and internal tools) to analyse user behaviour.
• Advertising pixels for retargeting and personalised ads.
• Fraud prevention technologies (IP filtering and device verification).

You can manage your cookie preferences through your browser settings or use built-in opt-out options in our Services.

Third Party Services

We partner with external providers, including payment processors, email and chat platforms, identity verification services, and fraud prevention tools. Each of these partners has its own privacy policy. Please review their policies on their respective websites.

Retention of Personal Information

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by law. After the retention period ends, data will be securely deleted or de-identified.

Your Rights

Under Canadian law, you have the following rights regarding your personal information:

• Access your personal information and request a copy.
• Request correction of inaccurate or incomplete information.
• Request deletion or transfer of your data (except where retention is required by law).
• Object to processing of data for marketing purposes.
• Withdraw consent to processing of personal information.
• Lodge a complaint with the Office of the Privacy Commissioner of Canada.

How We Keep Your Information Secure

We implement technical and organisational security measures, including data encryption (SSL/TLS), restricted server access, regular security audits, and employee training. Our policies and procedures are reviewed periodically to align with industry best practices.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time. All changes will be posted on this page with an updated “Last Updated” date. If changes are significant, we will notify you by email or when you next log in to your account.

How to Contact Us

If you have questions or concerns about this Privacy Policy, you can contact our Privacy Officer:

Email: [email protected]
Address: Caddttree Limited, La Corvee House,
La Corvee, Alderney GY9 3TQ, Guernsey