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Last Updated: 2022/07/01

Introduction

Cadtree Limited, along with the affiliated online casinos listed below (referred to as "the Group"), delivers digital gaming experiences through websites, mobile platforms, and other digital channels (collectively known as the "Services"). This Privacy Policy is intended to explain how we handle your personal data—how we gather, use, disclose, and protect it.

Our commitment to user privacy is unwavering. We’ve developed this Privacy Policy to clarify how your data is managed, stored, and shared, as well as to outline your rights. Cadtree complies with all relevant privacy laws, including Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA).

This Privacy Policy covers the following topics:

  • Cadtree Limited
  • Types of Information Collected
  • Minors
  • Use of Collected Data
  • Marketing Practices
  • Information Sharing
  • International Data Transfers
  • Tracking Technologies
  • Third-Party Services
  • Data Retention
  • Your Data Rights
  • Data Security
  • Policy Updates
  • Contact Information

We encourage you to review this Privacy Policy thoroughly. By using our Services or creating an account with us, you consent to the terms outlined here.

Contact Information

If you have any questions or comments about this Privacy Policy or your personal data, please contact our Privacy Officer using the provided form or by mail. Note that responses may be subject to applicable legal limitations.

Cadtree Limited

Cadtree Limited operates the following casino websites: spincasino.ca, rubyfortune.ca, jackpotscitys.com, and royalvegas.ca.

The company is incorporated in Guernsey (company number 2031), with its registered office located at La Corvee House, La Corvee, Alderney GY9 3TQ. Cadtree Limited holds a license issued by the Alcohol and Gaming Commission of Ontario (License Number OPIG1236392), effective from June 23, 2022.

What Information Do We Collect?

As a licensed operator under iGaming Ontario (iGO), Cadtree Limited collects and processes personal data in accordance with FIPPA, PIPEDA, and Ontario Regulation 722/21. “Personal Information” refers to any recorded data about an identifiable person. Our data collection can be broken down into two main categories:

1. Personal Data

We collect the following types of personal information, depending on your interaction with our Services:

  • Account Information: Includes your full name, email, gender, date of birth, residential address, government-issued ID number, phone number, and job title.
  • ID Verification: We may request a scan or photo of official ID for identity verification.
  • Payment Details: To enable full service functionality, we collect data such as your credit card and bank account information.
  • Voluntary Input: Any information you provide willingly, such as replies to our messages or data shared through chats and games.
  • Device Data: Technical identifiers like IP address, device ID (IMEI, MAC), geolocation, and browser fingerprints.
  • Call Monitoring: Phone conversations may be recorded for training, support, or security purposes.
  • Social Media Data: If you log in via social platforms (e.g., Facebook), we may access public details from your profile and friends list.
  • Referral Data: If you use features like “Invite a Friend,” we may collect data on referred users.
  • Third-Party Sources: Data such as credit history or fraud checks may be obtained through third-party services.
  • Geolocation: We may use your location to meet legal requirements.

2. Non-Personal Data

This category includes information that cannot directly identify you. It’s typically aggregated or anonymized, and it helps us improve the functionality and analytics of our Services. This includes:

  • Device Specifications: Data about your browser, screen resolution, operating system, etc.
  • Gaming Activity: Includes records of your deposits, bets, bonus use, play duration, and scores.
  • Security Monitoring: We scan your device for known cheating software or proxies/VPNs.
  • Usage Logs: Logs include your navigation paths, clicked items, and session durations.
  • De-Identified Data: Aggregated data that doesn’t reveal your identity may be used freely, including for marketing or statistical purposes.

If at any point non-personal data becomes associated with identifiable personal data, we will treat the combined dataset as personal information.

Minors

Our Services are strictly intended for individuals who are at least 19 years old or have reached the legal age of majority in their respective jurisdiction—whichever is greater (referred to as “Legal Age”). If you do not meet this requirement, you are not permitted to access, use, or download our Services, nor should you submit any personal data to us.

We maintain the right to examine and validate the personal information you provide. If we determine that any data has been submitted by someone under the Legal Age, that information will be deleted. If you suspect a minor has provided us with any data, we urge you to notify us immediately.

How We Use Your Personal Data

The information we collect is utilized for a variety of purposes, all aimed at improving your experience and maintaining the integrity of our platform. These purposes include:

  • Creating, maintaining, and managing your user account;
  • Delivering our Services, including processing payments and placing bets;
  • Communicating with you regarding updates, service enhancements, and promotional content;
  • Carrying out marketing activities (see more under “Marketing”), including personalized advertising strategies;
  • Conducting research, analysis, and statistics to tailor and optimize our Services based on user behavior and preferences;
  • Offering customer service, troubleshooting technical issues, and managing user inquiries;
  • Developing new features and refining existing ones to better match user needs;
  • Promoting safe and responsible gaming practices;
  • Processing user requests to exercise data-related rights;
  • Authenticating user access to secured parts of the platform;
  • Detecting and preventing fraud, illegal use, or any activity that could undermine the integrity of our systems;
  • Investigating breaches of our Terms of Use or other internal policies;
  • Resolving disputes or issues related to your use of the Services;
  • Complying with legal obligations, including Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, or responding to official government requests or legal processes.

Marketing

We, along with selected third-party service providers, may use your personal details—such as name, email, phone number, and mailing address—to deliver promotional content related to our Services. This includes offers from:

  • Other brands within our corporate group;
  • White-label services operated under our umbrella;
  • Affiliated business partners and marketing associates ("Marketing Affiliates").

We may also share your information with these Marketing Affiliates so they can contact you directly with tailored offers. These may be delivered through various methods including emails, text messages, phone calls, or physical mail.

You can update your communication preferences anytime via our Customer Support team (where available). If you download our software, it may include a component that allows us to send push notifications directly to your device. These alerts may inform you of new features, updates, or promotional content.

By downloading the software, you agree to receive such notifications. If you change your mind, you can remove this feature manually—either by following the instructions linked in the notification itself or by changing the notification settings on your device.

At any time, you may opt out of future marketing communications—either from us or our affiliates—by contacting our Live Chat support. Please note that even if you unsubscribe from marketing messages, we may still send you essential service-related updates.

Who We Share Your Information With

We do not rent, sell, or otherwise trade your Personal Information to third parties (“Recipients”), except in situations explicitly outlined in this Privacy Policy. Any information shared is strictly limited to the extent necessary for fulfilling specific, legitimate business purposes.

We may disclose your Personal Information to the following categories of recipients:

  • White Label Partners: This includes any substitute operators or service providers managing the White Label platforms.
  • Affiliated Entities: Other companies within our Group, related businesses, contractors, and approved third-party service providers such as hosting services, marketing partners, identity verification providers, and fraud detection services.
  • Credit Agencies: For credit verification and financial background checks.
  • Payment Processors: Banks and financial institutions involved in processing deposits and withdrawals.
  • Third-Party Promoters: Vendors assisting in the operation or marketing of our brands, both in-house and White Label (if applicable).
  • Event Partners: External organizers of events or tournaments affiliated with our brands.
  • Travel Providers: Airlines, hotels, or transport companies used for promotional events or travel-based prizes.
  • Auditors and Consultants: Professional advisers or reviewers of our business practices and compliance.
  • Fraud and Crime Prevention Bodies: This may include banks, law enforcement, governmental bodies (e.g. FINTRAC), and other investigative authorities.
  • Regulatory Authorities: Licensing bodies and government regulators, including those enforcing legal compliance.
  • Business Transfers: Potential investors or acquirers in case of a merger, sale, asset transfer, bankruptcy, or reorganization of the Group or any of its brands. The receiving party will be bound by this Privacy Policy.
  • Gaming Regulators: Including but not limited to iGaming Ontario and the Alcohol and Gaming Commission of Ontario.

In addition to the reasons above, we may share Personal Information with these Recipients for the following purposes:

  • To store your data securely, for instance via cloud storage solutions;
  • To assist in business operations like deposit handling, user authentication, system audits, and fraud prevention;
  • To carry out diagnostics, analytics, or service improvements;
  • To deliver promotional content or personalized advertising, in line with our marketing practices;
  • To protect legal rights, enforce our policies (including this Privacy Policy and Terms of Use), or respond to security threats and fraud investigations.

Transfer of Information

As an international operator, we may transfer your Personal Information to jurisdictions outside of Ontario. These locations may not offer the same legal protections as those available under Ontario’s Freedom of Information and Protection of Privacy Act.

Nonetheless, we implement robust measures to safeguard your data, which may include approved legal agreements or ensuring that data transfers only occur to regions with adequate privacy frameworks.

If you suspect your information has been mishandled or you observe behavior that violates this Privacy Policy, we encourage you to reach out to us via Live Chat support.

Third-Party Tracking Technologies

When you use or visit our Services—including our websites—we and authorized third parties use various digital tools such as cookies, location identifiers, beacons, pixels, tags, scripts, and similar technologies (“Tracking Technologies”).

These tools help us automatically collect data regarding your behavior online and information about the device you’re using (e.g., smartphone or computer). This information is utilized for several key functions, including:

  • Confirming your physical presence in Ontario to comply with regulations;
  • Enhancing your browsing experience and navigation speed;
  • Improving Service performance and responsiveness;
  • Customizing features and content to match your interests;
  • Running analytics and generating user behavior reports;
  • Supporting advertisers, publishers, and business partners with relevant data.

Additionally, we allow certain third parties to collect data through these Tracking Technologies. For more information on how we use cookies and related tools, please refer to our Cookie Policy.

Third-Party Services

While interacting with our Services, you may come across links that lead to third-party websites, external platforms, or independent applications. Please note that our Privacy Policy does not govern these third-party services, even if you can access, download, or use them via our platform.

These third-party sites and services operate independently of our Group. We are not responsible for the content, privacy policies, or legal practices of such external entities. We highly recommend that you review their privacy policies and terms of use before engaging with them, as your interactions will be governed by their terms—not ours.

You are solely responsible for any decisions you make regarding these third-party services and accept all risks involved. By using them, you agree that we bear no responsibility or liability for any aspect of your interaction with those services.

Retention of Personal Information

When you create an account through our Services, we will retain your personal information as long as your account remains active. Additionally, we may store your information beyond the life of your account in order to fulfill our legal and regulatory responsibilities—such as obligations under gambling laws, Know-Your-Customer (KYC) protocols, Anti-Money Laundering (AML) standards, and our agreement with iGaming Ontario (iGO).

If you wish to have your personal data removed, you can email your request to [email protected]. We will take reasonable steps to honor your request, subject to any applicable legal limitations.

Your Data Rights

Under the Freedom of Information and Protection of Privacy Act (FIPPA), you have the right to access and ensure the accuracy of your personal data. Similarly, under the Personal Information Protection and Electronic Documents Act (PIPEDA), you may withdraw consent you’ve previously given for data collection, use, or sharing. However, revoking consent may affect our ability to provide certain Services.

You can reach out to us via email to request any of the following:

  • Access or deletion of your personal data held by us.
  • Correction or update of inaccurate or outdated information (unless we are required by law to retain the original data).
  • Restriction or suspension of further use of your data.
  • Provision of your voluntarily submitted data in a portable, machine-readable format.

Please note that these rights are not absolute. We may be legally required to retain certain information, particularly under gambling and financial regulations. Additionally, we reserve the right to correct or remove incomplete or incorrect data in line with our internal data policies.

If you believe your privacy rights have not been upheld, you are entitled to file a complaint with the appropriate regulatory authority. You may also escalate your complaint to iGaming Ontario (iGO). We are committed to cooperating fully with iGO in any investigations, following the Customer Care and Player Disputes Resolution (CCDR) guidelines.

How We Protect Your Information

We are committed to safeguarding your personal information and securing our Services. To do this, we implement a variety of physical, technical, and procedural security measures designed to prevent unauthorized access, ensure data integrity, and handle the information you share with us responsibly. The level of protection applied depends on the type and sensitivity of the data being processed.

We follow widely recognized industry standards and practices to keep your information safe. Our security infrastructure includes:

  • A secure network architecture with firewalls and intrusion detection systems;
  • Encrypted communications across all sensitive channels;
  • Authentication mechanisms and controlled access to systems and data;
  • Regular internal and external security audits.

While we take all reasonable precautions to secure your data, no system can offer a 100% guarantee. We cannot accept responsibility for unauthorized access resulting from malicious activity and do not guarantee that such breaches can be entirely prevented.

Security, Breach Management & Cooperation

Cadtree places the highest importance on maintaining the security of your personal data. Our security framework incorporates multiple layers of protection—technical, organizational, and procedural—to prevent misuse, unauthorized access, alteration, or loss of information. These controls are updated regularly to align with industry best practices and are scaled based on the level of risk and sensitivity of the information.

Despite our efforts to protect your data, it’s important to recognize that no online transmission is ever completely secure. Sharing your personal information over the internet involves some level of risk. While we can’t fully guarantee immunity from security breaches, we are prepared to act quickly in case of an incident.

If your personal data is involved in a security breach that could lead to significant harm, we will notify you promptly. We are also obligated to inform relevant authorities, such as the Office of the Privacy Commissioner of Canada, and maintain appropriate records in accordance with the law.

Incident Management Process

Cadtree has developed a structured “Incident Management Process” to ensure a consistent and effective response to any security events. This process involves three key phases:

1. Identification and Assessment

If a cyber incident occurs, we immediately work alongside critical partners, internal departments, and oversight functions to evaluate its severity and potential consequences. We intensify system monitoring, investigate the extent of any compromise, and coordinate with internal teams to begin response and recovery procedures.

2. Containment, Resolution, and Recovery

Our teams, in collaboration with key suppliers and stakeholders, run forensic checks to assess the integrity of critical systems and user data. If any information has been compromised, it is isolated, cleaned, and restored. Player account balances and failed transactions are thoroughly reviewed, and relevant reports are submitted to regulatory bodies. Following verification, user balances are corrected or refunded, and systems are validated before being restored online.

3. Communication and Notification

Affected players will be notified via email or direct messaging on our platform regarding the incident. This includes which personal data may have been exposed and recommended actions like password updates. We will also notify iGaming Ontario (iGO), the Office of the Privacy Commissioner of Canada, and any other relevant agencies. Cadtree fully supports and cooperates with these bodies to manage the breach and mitigate any further impact.

Updates to This Privacy Policy

We may revise this Privacy Policy from time to time, so we encourage you to check this page regularly. If significant changes are made, we will notify you either by posting an update on our Services or by sending an email to the address you provided. Major revisions will take effect seven (7) days after such notice is given. For other changes, the policy becomes effective as of the “Last Updated” date shown. Continued use of our Services after that date means you accept the revised policy.

How to Contact Us

If you have any questions about this Privacy Policy, the information we collect, or how we use it, please get in touch with us through the live chat option available on our Contact Us page.

We aim to respond within a reasonable period. If you’re not satisfied with our reply, you may contact the relevant data protection authority for further assistance.

Cadtree Cookie Policy

Last Updated: 2022/07/01

Overview

When you access our Services—whether through websites, apps, or by interacting with our content—we and authorized third parties use cookies and other tracking tools like web beacons, pixel tags, scripts, APIs, and more (collectively referred to as “Tracking Technologies”).

These technologies help us gather data about your online behavior and the device you're using (computer, phone, etc.), allowing us to improve your experience, personalize features, and enhance the performance of our Services. We also use this data for analytics, tailored content, advertising, and user engagement tracking.

In addition, we permit third parties to collect data through these Tracking Technologies as part of our platform ecosystem.

What Are Cookies?

Cookies are small text files made up of letters and numbers that are saved to your device when you visit a website. These files store preferences (such as language) and improve user experience by making navigation easier and more personalized. You can learn more at www.allaboutcookies.org.

Cookies are commonly used to support efficient page loading, remember preferences, and deliver relevant advertising based on your interests.

Types of Tracking Technologies

Tracking Technologies used on our Services fall into two main categories:

  • First-Party Technologies: Set by us directly when you interact with our Services.
  • Third-Party Technologies: Set by external partners such as advertisers or analytics providers.

These technologies may be temporary (used only during your visit) or persistent (used across multiple sessions).

Categories of Tracking Technologies We Use

  • Essential Technologies:

    These are required to access and navigate the platform securely and efficiently. They help with login, maintain session integrity, and enable basic platform functions. These do not require your consent.

  • Functional Technologies:

    These remember your choices (like language or region) and provide enhanced features. For example, they help keep you logged in or enable accessibility options.

  • Performance Technologies:

    These gather behavioral data, such as time spent on pages or clicks. This information is aggregated and used for analytics, improving Services, and performance optimization.

  • Marketing & Advertising Technologies:

    Used to serve personalized ads and marketing content based on your interactions. They help limit repeated ads and measure ad campaign effectiveness. These are usually managed by advertising partners. Features like Facebook’s “Like” and “Share” buttons also fall under this category and follow the policies of their respective third-party providers.

Examples of Tracking Technologies Used

Technology Type Purpose
Analytics Cookies First-Party Track user interaction, usage behavior, referral sources, and aid in performance reporting and service improvement.
Other Cookies First & Third-Party Support basic platform functionality by storing login credentials and remembering user settings.

Managing Your Cookie Preferences

Please note that we do not currently recognize automated browser signals such as “Do Not Track” requests. However, you can control cookie behavior in the following ways:

Browser Settings

Most browsers allow you to view and manage cookies, delete existing ones, and block or allow cookies on specific websites. You can usually find these options in your browser’s “Help” or “Settings” menu.

Here are links for common browsers:

Managing Third-Party Cookies

You can opt out of certain targeted advertising cookies by visiting the Network Advertising Initiative.

Please be aware that disabling cookies may affect the functionality and user experience of our Services.