POLICY STATEMENT
This document explains how we collect, use, disclose, retain, secure and
otherwise process personal information in connection with ONLINE CASINO CANADA RANK, made available
through https://onlinecasinocanadarank.com/ and any related pages, features, content, comparison tools,
editorial materials, forms, communications and functionalities that link to it (collectively, the
“Services”).
The Services are operated by VR Studio sp. z o.o., of Jozefa Dietla 50, 31-039
Krakow, Poland (the “Operator”, “we”, “us” or “our”). For the purposes of applicable Canadian privacy
law, we are responsible for personal information under our control, subject to any processing carried
out by authorised service providers on our behalf.
This document is intended to support
compliance with applicable Canadian privacy and electronic communications requirements, including the
Personal Information Protection and Electronic Documents Act (“PIPEDA”), applicable provincial
private-sector privacy laws, and guidance issued by Canadian privacy regulators. It also addresses
relevant transparency expectations relating to cookies, analytics, security, anti-abuse controls,
advertising technologies, consent mechanisms and commercial electronic communications, including
requirements relevant to Google Ads and Microsoft Advertising where such tools are enabled.
It
applies when you:
- visit the Website or any other website or page we operate that links to it;
-
access and use our informational, comparison, review and editorial services relating to online casinos,
casino games, bonuses, payment methods, licensing frameworks, mobile compatibility and responsible
gambling tools; or
- communicate with us in any manner, including by submitting enquiries, feedback,
correction requests, complaints, privacy rights requests, consent withdrawal requests, advertising
preference requests, unsubscribe requests or formal legal correspondence.
THE SERVICES ARE
PROVIDED AS AN INFORMATIONAL, COMPARISON AND REVIEW PLATFORM ONLY. THE SERVICES DO NOT OFFER OR OPERATE
REAL-MONEY GAMBLING, WAGERING, BETTING, DEPOSITS, WITHDRAWALS, PLAYER ACCOUNTS, CASH PRIZES, OR ANY
GAMBLING TRANSACTION FUNCTIONALITY. WE DO NOT PROCESS USER PAYMENTS OR GAMBLING TRANSACTIONS THROUGH THE
SERVICES.
We implement reasonable administrative, technical and physical safeguards designed to
protect personal information and to ensure that our practices are appropriate, proportionate and
transparent, having regard to the sensitivity of the information and the purposes for which it is
processed. We seek to apply data minimisation, purpose specification, limited retention, need-to-know
access controls and appropriate contractual oversight of service providers consistent with applicable
Canadian privacy law.
If you wish to contact us regarding privacy-related matters, including
withdrawal of consent, access requests, correction requests, deletion requests, complaint submissions or
advertising preference requests, you must use the channels specified in Section 12 (CONTACT DETAILS AND
DATA ENQUIRIES).
ADULT-ONLY SERVICES. The Services are intended solely for individuals who are at
least eighteen (18) years of age. Where a higher legal age applies in your province or territory in
relation to gambling services, that higher age requirement applies to those third-party services.
Individuals who do not meet these requirements must not access or use the Services.
CANADA-FACING
SERVICES. The Services are intended for users located in Canada. We may restrict or condition access
from locations outside Canada, or from locations where access presents legal, compliance or operational
risk. We may process limited geolocation information derived from your IP address or similar technical
indicators for compliance, fraud prevention, security, service administration and jurisdictional
tailoring purposes.
By accessing or using the Services, you acknowledge that you have read and
understood this document and our Terms of Service. Where required by applicable law, we will seek your
valid consent before collecting, using or disclosing personal information, or before activating
non-essential cookies and similar technologies. Where we rely on another lawful basis recognised by
applicable Canadian law, we will process personal information as described in this document and in
accordance with that law.
1. INFORMATION WE COLLECT AND STORE
We collect and process personal information that you voluntarily provide
to us, information that is collected automatically when you access or interact with the Services, and
information generated through the operation, protection and administration of the Services. The
categories of personal information we collect are limited to what is reasonably necessary for identified
purposes relating to operation, security, communications, analytics, advertising compliance, legal
compliance and lawful business administration.
For the purposes of this document, “personal
information” means information about an identifiable individual and includes information that may
reasonably identify an individual either alone or in combination with other information. Information
that has been irreversibly anonymised so that it can no longer reasonably identify an individual is not
treated as personal information. Aggregated, statistical or de-identified information may, however, be
treated as personal information where re-identification remains reasonably possible.
You are
responsible for ensuring that any personal information you provide is accurate, complete and up to date,
and that you are legally authorised to provide it.
1.1 Personal information you disclose to us
You may voluntarily provide personal information when you contact us,
submit a query, request information, report an issue, request a correction, lodge a complaint,
exercise privacy rights, manage consent or advertising preferences, or otherwise communicate with
us.
(a) Personal information provided by you
Depending on the nature of your interaction
with us, we may collect:
- your name;
- your email address;
- your telephone number, if you
choose to provide it;
- your province or territory, where relevant to your request;
- your
communication and marketing preferences;
- the content of your message, correspondence or request,
including attachments, supporting documentation and records of communications; and
- any other
information you voluntarily disclose.
The Services do not operate user gambling accounts,
registration systems, deposit accounts, player wallets or payment processing systems. Accordingly, we
do not ordinarily request or collect usernames, passwords, gambling account credentials, payment card
numbers, bank account details or equivalent transactional financial information through the
Services.
(b) Sensitive personal information
We do not request and do not intend to
collect sensitive personal information unless such collection is strictly necessary, lawful and
proportionate for a specific purpose and, where required, supported by valid consent or another
recognised legal basis.
Without limitation, we do not seek to collect information
revealing:
- racial or ethnic origin;
- religious or philosophical beliefs;
- political
opinions;
- trade union membership;
- health or medical information;
- biometric information
used for identification;
- sexual orientation or sex life; or
- other categories of information
treated as sensitive under applicable law.
Sensitive personal information must not be submitted
unless expressly requested for a specific lawful purpose and, where required, with valid
consent.
Sensitive personal information is not used for personalised advertising, behavioural
profiling or remarketing.
(c) Payment information
The Services do not sell gambling
services, do not accept gambling deposits and do not process payments on behalf of gambling operators.
We therefore do not intentionally collect or store payment card data, bank account details, billing
details or other transactional financial information through the Services, except to the limited
extent such information may be incidentally included by you in a free-text communication submitted
without being requested.
You are responsible for ensuring that any personal information you
provide is limited to what is necessary for your enquiry or request and does not include unnecessary,
excessive or sensitive information. Where personal information is voluntarily submitted beyond what is
required, we may process, retain or securely delete such information in accordance with this Privacy
Policy and applicable law.
1.2 Information automatically collected
When you access, browse or interact with the Services, we may
automatically collect certain technical, device, usage and diagnostic information. Depending on the
circumstances, this information may constitute personal information.
Automatically collected
information may include:
- IP address;
- browser type, browser version and browser
settings;
- device type, device identifiers, hardware model and operating system;
- language
settings, time zone and regional settings, where available;
- referring URLs, entry pages, exit
pages and navigation data;
- pages viewed, content interactions, dwell time and navigation
paths;
- campaign attribution and referral information;
- error reports, crash reports,
performance logs and diagnostic records;
- approximate location inferred from IP address or similar
technical signals; and
- information relating to consent status, advertising preferences or cookie
selections.
This information may be collected for purposes including service delivery, fraud
prevention, security, analytics, debugging, performance optimisation, advertising measurement,
attribution, consent management, legal compliance and auditability.
(a) Log and usage
data
Our systems and service providers may automatically generate server logs and event records
reflecting activity on the Services. Such records may include timestamps, IP address, browser
information, device characteristics, resource requests, page interaction data, referring pages and
system events. We use this information for technical administration, performance monitoring, abuse
detection, incident response, internal reporting and legal compliance.
(b) Device
data
We may collect device-related metadata, such as device type, operating system version,
browser configuration, screen resolution, connection type, language settings and similar technical
information necessary to optimise compatibility, detect abuse, maintain security and improve the
operation of the Services.
(c) Location data
We may process limited geolocation
information derived from IP address or comparable technical indicators in order to determine
approximate geographic region, province or territory for lawful content presentation, compliance,
fraud prevention, security monitoring and service administration purposes. We do not intentionally
collect precise geolocation data through the Services.
Automatically collected information is
used only for the purposes described in this Privacy Policy and is handled in accordance with
applicable law, including any consent requirements where relevant. Where such information is combined
with other data in a manner that identifies an individual, it is treated as personal information and
subject to the safeguards and protections described in this Policy.
1.3 Cookies, analytics and similar technologies
We may use cookies and similar technologies, including pixels, tags,
local storage objects, software development kits and other comparable tools, to operate the Services,
remember preferences, maintain security, detect abuse, analyse usage, measure advertising performance
and, where enabled and lawful, support remarketing or personalised advertising.
Depending on
configuration, your choices and the tools in use from time to time, such technologies may
include:
- consent management and preference tools;
- analytics tools, including Google
Analytics or equivalent services;
- advertising and attribution tools, including Google Ads
conversion tracking, remarketing technologies and Microsoft Advertising Universal Event Tracking
(UET);
- tag management tools;
- content delivery, security and anti-abuse tools; and
-
performance monitoring and diagnostic tools.
These technologies may collect online identifiers
and technical or behavioural information such as browser and device attributes, session data, content
interactions, click paths, attribution information, event data and aggregated usage
insights.
Where enabled and subject to applicable law and your choices, certain tools may be
used to support personalised advertising, advertising measurement, remarketing or audience
segmentation. We do not knowingly use such tools to target minors and do not knowingly use sensitive
personal information for advertising targeting.
Preferences may be managed through available
mechanisms on the Services and through browser or device settings, subject to Section 4.
1.4 Anti-abuse and automated traffic controls
We may implement technical and operational measures to protect the
Services, contact forms, consent tools and related systems from spam, automated abuse, malicious
submissions, credential-stuffing attempts, scraping and other harmful activity.
Such measures
may include CAPTCHA services, behavioural analysis tools, rate limiting controls, firewall
technologies and similar anti-abuse mechanisms.
These measures may process limited technical
information, including:
- IP address;
- browser and device characteristics;
- submission
patterns;
- behavioural signals; and
- risk scores or similar indicators generated by authorised
tools.
These controls are implemented for security, abuse prevention, fraud mitigation,
operational continuity and protection of the Services and users, in accordance with applicable law.
2. USE AND PURPOSE OF YOUR INFORMATION
We collect, use and disclose personal information only for purposes that a
reasonable person would consider appropriate in the circumstances and only where permitted or required
by applicable Canadian law.
The purposes for which we may process personal information
include:
- To provide and operate the Services Â
We may process technical, device and usage
information to deliver the informational, comparison and editorial content made available, maintain
functionality, and ensure compatibility, continuity and lawful presentation of content.
- To
respond to enquiries and provide support Â
We may process personal information contained in
communications, complaints, correction requests, rights requests, advertising preference requests,
unsubscribe requests or other correspondence in order to review, authenticate, respond to and manage
those interactions.
- To send administrative and service-related communications Â
Where
reasonably necessary, we may use contact information to send operational notices, policy updates,
security notifications, compliance-related messages, responses to user requests and other
non-promotional communications relating to the Services.
- To send marketing communications
(where applicable)Â Â
Where we offer newsletters, updates or other promotional communications, we will
send such communications only in accordance with applicable law, including Canada’s Anti-Spam
Legislation (CASL). Where required, this includes obtaining appropriate consent, identifying the sender,
providing valid contact information, and including an unsubscribe mechanism in each
communication.
- To maintain the security and integrity of the Services Â
We may process
personal information to detect, prevent, investigate and mitigate fraud, abuse, spam, malicious
activity, unauthorised access, technical incidents and other conduct that may affect the security or
availability of the Services.
- To operate analytics, performance measurement and
optimisation Â
Subject to applicable consent requirements, we may process technical and usage
information to understand how the Services are used, identify trends, improve user experience,
troubleshoot issues, optimise performance and support internal reporting.
- To conduct
advertising measurement and, where enabled, personalised advertising Â
Subject to your choices and
applicable legal requirements, we may use online identifiers, device data, interaction data and
attribution data to measure advertising performance, attribute conversions, manage frequency, prevent
fraud and, where permitted, support audience building, remarketing or personalised advertising through
authorised partners.
- To comply with legal and regulatory obligations Â
We may process
personal information to comply with applicable laws, lawful requests, court orders, regulatory
requirements, audit obligations and recordkeeping duties.
- To protect legal rights and manage
disputes Â
We may process personal information where reasonably necessary to establish, exercise or
defend legal claims, enforce our Terms of Service, investigate misconduct and manage disputes or
complaints.
- To maintain records and accountability Â
We may process personal information to
maintain records of consent, correspondence, complaints, decisions and compliance measures as reasonably
required for governance, audit and accountability purposes.
We do not process personal
information for gambling account creation, gambling transactions, payment processing or financial
account administration, as no such functions are provided through the Services.
Lawful basis and
consent
We collect, use and disclose personal information in accordance with applicable Canadian
privacy laws. In most cases, this is done with your consent, or as otherwise permitted or required by
law.
Consent may be express or implied, depending on the sensitivity of the personal information
and the reasonable expectations of the individual. For example:
- express consent may be required for
certain uses of personal information, including where information is sensitive or where required by
law;
- implied consent may be relied upon where the purpose of processing is reasonably apparent and
the information is provided voluntarily in that context.
Where we rely on consent:
- consent
is obtained in a manner appropriate to the circumstances;
- you may withdraw your consent at any
time, subject to legal or contractual restrictions and reasonable notice; and
- withdrawal of consent
does not affect the lawfulness of processing carried out prior to withdrawal.
In certain
circumstances, we may collect, use or disclose personal information without consent where this is
permitted or required by applicable law. This may include situations such as:
- compliance with legal
or regulatory obligations;
- responding to lawful requests from public authorities;
- detecting,
preventing or investigating fraud, abuse or security incidents; or
- other purposes permitted under
applicable legislation.
We do not use personal information for purposes that are materially
different from those described in this Privacy Policy without providing additional notice and, where
required, obtaining further consent.
3.  DISCLOSURE OF COLLECTED INFORMATION
We may disclose personal information to third parties only where
reasonably necessary for the lawful operation of the Services, for compliance with applicable law, for
protection of our rights and legitimate interests, for administration of user requests, or where you
have directed or authorised such disclosure.
We do not sell personal information, and we do not
rent or trade personal information to third parties for monetary consideration.
Disclosure may
occur to the following categories of recipients:
(a) Infrastructure, hosting and technical
service providers
We may disclose personal information to third parties that provide
infrastructure, hosting, cloud storage, content delivery, security, anti-abuse, backup, monitoring,
software maintenance, communication handling, consent management, analytics implementation and other
technical or operational support services reasonably required to operate the Services.
(b)
Analytics and measurement providers
Subject to applicable consent requirements and your choices,
we may disclose technical and usage information to analytics, diagnostics and measurement providers for
purposes such as site analytics, performance reporting, troubleshooting, service optimisation,
aggregated insights and operational monitoring.
Where appropriate and reasonably practicable, we
seek to minimise the identifiability of information shared for analytics purposes through aggregation,
truncation, de-identification or similar controls.
(c) Advertising, attribution and marketing
technology partners
Where enabled and subject to applicable law and your choices, we may disclose
limited technical and online identifier information to advertising, attribution and marketing technology
partners for purposes including:
- conversion tracking and attribution;
- ad measurement and
campaign reporting;
- fraud prevention and traffic validation;
- remarketing and audience
creation; and
- personalised advertising.
We do not knowingly disclose sensitive personal
information for advertising targeting. We do not knowingly target minors with personalised advertising
or gambling-related promotional messaging.
(d) Legal, regulatory and governmental
authorities
We may disclose personal information where required or permitted by law, including in
response to subpoenas, court orders, warrants, lawful requests, regulatory inquiries, law enforcement
requests, or other processes issued by competent authorities.
We may also disclose personal
information where reasonably necessary to detect, investigate, prevent or address actual or suspected
unlawful conduct, fraud, security incidents or threats to safety.
(e) Professional
advisers
We may disclose personal information to our legal advisers, privacy advisers, auditors,
accountants, insurers, compliance consultants and other professional advisers where reasonably necessary
to obtain advice, manage legal and operational risk, protect our rights, conduct audits or respond to
claims, complaints, investigations or proceedings.
(f) Corporate transactions and business
continuity
We may disclose personal information in connection with an actual or proposed merger,
acquisition, financing, sale, reorganisation, restructuring, insolvency proceeding, investment
transaction or transfer of all or part of our business or assets, where such disclosure is reasonably
necessary for due diligence, transaction completion, continuity planning or post-transaction
integration, provided appropriate confidentiality and security safeguards are used.
Service
provider controls and contractual safeguards
Where we disclose personal information to service
providers acting on our behalf, we take reasonable steps to ensure that such service providers:
-
process personal information only for authorised purposes consistent with the services they provide to
us;
- protect personal information by reasonable security safeguards appropriate to the sensitivity
of the information;
- provide assistance in relation to security incidents, rights requests and
compliance obligations where appropriate;
- do not use the information for their own unrelated
purposes except as lawfully permitted and disclosed; and
- remain subject to contractual or
comparable restrictions and oversight appropriate in the circumstances.
Cross-border processing
and international transfers
Personal information under our control may be stored, accessed or
processed outside the province or territory in which you reside, including outside Canada, by us or by
authorised service providers acting on our behalf. Such jurisdictions may have privacy laws that differ
from those in your place of residence and may permit access by courts, law enforcement, national
security authorities or regulators in accordance with their laws.
Where personal information is
processed across borders, we take reasonable steps to ensure that comparable protection is in place,
having regard to the sensitivity of the information, the purposes of processing, the destination
jurisdiction, the identity and role of the recipient, and the contractual, organisational and technical
safeguards available.
For individuals in Quebec, where applicable, we will take such steps as are
required by applicable law before communicating personal information outside Quebec, which may include
an assessment of privacy-related factors and implementation of appropriate contractual and operational
protections.
We remain responsible for personal information under our control, including where it
is transferred to third parties for processing on our behalf. However, to the extent permitted by
applicable law, we are not responsible for the independent acts, omissions or policies of third parties
where personal information is disclosed to them in accordance with this Privacy Policy or at your
direction.
4. USE OF COOKIES AND TRACKING TOOLS
The Website may use cookies and similar technologies, including pixels,
tags, scripts, local storage objects and software development kits, to support the operation, security,
performance and administration of the Services and, where enabled and lawful, to support analytics,
advertising measurement and personalised advertising.
Cookies are small files or code elements
stored on or accessed through your device that allow systems to recognise a browser or device, maintain
session integrity, remember preferences, detect abuse and measure interactions.
Cookies and
similar technologies used through the Services may include:
- strictly necessary technologies, used
for core site functionality, security, fraud prevention, load balancing, consent management or
accessibility;
- analytics and performance technologies, used to understand usage patterns, diagnose
errors and improve the Services;
- advertising and attribution technologies, used to measure campaign
performance, attribute visits or conversions, manage ad frequency and, where enabled, support
remarketing or personalised advertising; and
- preference technologies, used to remember settings and
choices, including consent preferences where implemented.
We may use:
- session-based
technologies, which remain active only for the duration of a browsing session; and
- persistent
technologies, which remain on your device for a specified period or until deleted.
Consent and
lawful use
Strictly necessary technologies are used automatically where required for the
operation, security and integrity of the Services and do not require consent where permitted by
applicable law.
All other cookies and similar technologies are used only where:
- you have
provided valid consent through an appropriate consent mechanism; or
- their use is otherwise
permitted under applicable Canadian law.
Where consent is required:
- non-essential
technologies are not activated until consent has been obtained;
- consent is obtained in a clear,
granular and informed manner;
- you are able to accept, reject or customise categories of
technologies; and
- you may withdraw or modify your consent at any time through available
controls.
Consent preferences may be recorded and retained for compliance, audit and
accountability purposes.
User control and choice
You may manage cookies and similar
technologies through:
- any consent or preference controls made available through the Website;
-
your browser settings, including blocking or deleting cookies;
- device-level privacy settings, where
available; and
- opt-out tools provided by relevant third-party providers, where
applicable.
Refusal or restriction of non-essential technologies may reduce the functionality,
availability or performance of certain features and may limit analytics, advertising measurement or
personalisation.
Third-party technologies
Authorised third parties may place or access
cookies and similar technologies through the Services for purposes including:
- website analytics and
traffic reporting;
- advertising conversion tracking, attribution and remarketing;
- consent and
preference management;
- anti-abuse, security and fraud prevention; and
- content delivery and
technical optimisation.
These third parties may collect technical information such as IP address,
browser details, device information, session data, interaction events and attribution data, subject to
applicable law and your choices.
Where third-party technologies are used:
- we take reasonable
steps to ensure they are integrated in a manner consistent with this Privacy Policy and applicable
law;
- we seek to limit data sharing to what is reasonably necessary for the relevant purpose;
and
- we do not knowingly permit the use of sensitive personal information for advertising
targeting.
However, third parties operate under their own terms and privacy policies, and we do
not control their independent data processing practices.
Accordingly, to the extent permitted by
applicable law, we are not responsible for the independent acts, omissions or data handling practices of
such third parties once information is collected through their technologies.
You acknowledge that
certain technologies may rely on browser or device-level storage and that disabling or restricting such
technologies may affect the proper operation, security or availability of parts of the Services.
5.  RETENTION PERIOD FOR INFORMATION
We retain personal information only for as long as is reasonably necessary
to fulfil the purposes for which it was collected, or as otherwise required or permitted by applicable
Canadian law, including for compliance, dispute resolution, enforcement and accountability
purposes.
We do not retain personal information indefinitely. Retention is limited to what is
necessary, proportionate and appropriate in the circumstances, having regard to the nature of the
information, the purposes of processing and applicable legal requirements.
Retention periods are
determined based on the following criteria:
(a) Operational necessity Â
Personal information
may be retained as required to respond to enquiries, maintain records of correspondence, manage
requests, administer consent preferences, ensure service continuity, investigate misuse, and maintain
appropriate internal records necessary for the operation of the Services.
(b) Legal and
regulatory obligations Â
We may retain personal information where necessary to comply with statutory
obligations, regulatory requirements, lawful requests, audit requirements or recordkeeping duties under
applicable federal or provincial law.
(c) Limitation periods and legal risk Â
We may retain
personal information for periods reasonably necessary to establish, exercise or defend legal claims,
taking into account applicable limitation periods and legal risk considerations in relevant
jurisdictions.
(d) Security and fraud prevention Â
We may retain technical logs, identifiers
and related data for a limited duration to detect, investigate and mitigate fraud, abuse, unauthorised
access, security incidents or policy violations, and to preserve the integrity and security of the
Services.
(e) Consent and compliance records Â
Where consent is relied upon, including for
cookies, tracking technologies or commercial communications, we may retain records of consent,
timestamps, preference settings and associated metadata for compliance, audit, accountability and
dispute resolution purposes.
When personal information is no longer required for the purposes for
which it was collected, and no legal, regulatory or operational requirement justifies continued
retention, we will take reasonable steps to securely delete, anonymise or irreversibly de-identify the
information, subject to technical feasibility and applicable law.
Certain information may persist
in encrypted or access-restricted backup systems for a limited period for disaster recovery, continuity
and compliance purposes. Access to such archived information is strictly limited and subject to
appropriate safeguards, and such data is not actively processed except where required for legitimate
recovery, audit or legal purposes.
Retention decisions are periodically reviewed to ensure that
personal information is not retained longer than necessary and that retention practices remain
appropriate, proportionate and compliant with applicable law.
By using the Services, you
acknowledge that retention periods may vary depending on the nature of the information, the purpose for
which it was collected, and the legal and operational requirements applicable at the time.
6.  INFORMATION SECURITY MEASURES
We implement and maintain reasonable administrative, technical and
physical safeguards designed to protect personal information against loss, theft, unauthorised access,
disclosure, copying, use or modification.
These safeguards are designed having regard to:
-
the sensitivity of the personal information;
- the purposes for which it is used;
- the nature of
the risks associated with the processing; and
- generally accepted industry standards and
practices.
Our security measures may include, where appropriate:
- encryption of data in
transit using secure communication protocols;
- secure hosting environments with network
segmentation, firewalls and intrusion detection systems;
- access control mechanisms limiting access
to authorised personnel and authorised service providers;
- role-based or least-privilege access
controls;
- authentication and identity verification procedures for administrative access;
-
logging, monitoring and audit mechanisms designed to detect unusual or unauthorised activity;
-
regular review and updating of security practices;
- contractual safeguards with service providers
regarding security obligations; and
- incident response procedures designed to identify, contain,
investigate and remediate security incidents.
Despite these measures, no system or method of
transmission over the internet can be guaranteed to be completely secure. Accordingly:
- we do not
guarantee absolute security;
- unauthorised access, interception or misuse of information cannot be
entirely prevented; and
- transmission of information to or from the Services is undertaken at your
own risk.
Security incident response
Where required by applicable Canadian law, we will
assess, document and respond to security incidents involving personal information. This may
include:
- containing and mitigating the incident;
- assessing the risk of harm to
individuals;
- notifying affected individuals where there is a real risk of significant harm, as
required by law;
- notifying applicable regulators, including the Office of the Privacy Commissioner
of Canada or relevant provincial authorities, where required; and
- maintaining records of breaches
in accordance with applicable legal requirements.
We review and update our security measures on
an ongoing basis to ensure that they remain appropriate having regard to evolving risks, technologies
and legal requirements. However, you acknowledge that no security framework can eliminate all risks, and
that the effectiveness of safeguards depends in part on factors outside our control.
7.  COLLECTION OF DATA FROM MINORS
The Services are intended solely for adult users. We do not knowingly
collect personal information from individuals who are under the age of eighteen (18) or, where a higher
legal age applies in their province or territory, below that higher age.
The Services do not
include user accounts, messaging systems, social features or transactional functions, and we do not
actively verify age in all cases. However, we do not intentionally solicit or collect personal
information from minors.
If we become aware, or have reason to believe, that personal information
has been collected from or relates to a minor, we will take reasonable steps to:
(a) cease
further processing of such information, except where required for legal compliance or security
purposes;
(b) delete, anonymise or otherwise render the information non-identifying, to the
extent feasible; and
(c) take any additional steps required under applicable law.
If you
believe that a minor has provided personal information to us, you must notify us using the contact
details provided in Section 12 so that appropriate action can be taken.
We take the protection of
minors seriously and apply reasonable safeguards to minimise the risk of unintended collection. The
handling of any information relating to minors is carried out in accordance with applicable legal
requirements and this Privacy Policy.
8. YOUR DATA RIGHTS AND CHOICES
Subject to applicable Canadian privacy law, including federal and
provincial legislation, individuals may have certain rights in relation to their personal information.
The scope, availability and manner of exercising these rights may vary depending on the jurisdiction in
which you reside, the nature of the information, and the context in which it is processed.
We do
not apply a single uniform rights framework across all users. Instead, rights are interpreted and
applied in accordance with the laws that govern the personal information in question, including, where
applicable, provincial requirements such as those in Quebec.
Nothing in this Section is intended
to grant rights beyond those required under applicable law.
8.1 Your rights
Depending on applicable law, you may have the following
rights:
(a) Right of access Â
You may request confirmation as to whether we hold personal
information about you and request access to that information, together with information about how it
has been used and disclosed.
(b) Right to correction Â
You may request correction of
personal information that is inaccurate, incomplete or outdated. We may require appropriate
information or documentation to support such corrections.
(c) Right to withdraw
consent Â
Where personal information is processed based on your consent, you may withdraw that
consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of
consent may affect the availability or functionality of certain aspects of the Services.
(d)
Right to request deletion, anonymisation or de-indexing Â
In certain circumstances, and subject to
applicable law, you may request that personal information be deleted, anonymised or, where relevant,
de-indexed from publicly accessible results. These rights are not absolute and may be limited where
retention or continued processing is required for legal, regulatory, security, evidentiary or
legitimate business purposes.
(e) Right to restrict or object to certain processing Â
Where
provided by applicable law, you may request that we limit, suspend or object to certain processing
activities, including where the accuracy of the information is contested or where processing is no
longer necessary for the identified purposes.
(f) Right to data portability (where
applicable)Â Â
Where required under applicable law, including Quebec legislation where applicable
and technically feasible, you may request to receive certain personal information in a structured,
commonly used technological format and to have it communicated to another organisation.
(g)
Right to complain Â
You may lodge a complaint with a competent privacy regulator, including the
Office of the Privacy Commissioner of Canada or an applicable provincial authority, if you believe
that your personal information has been handled in a manner that is not consistent with applicable
law.
These rights may be subject to limitations, conditions or exceptions as provided under
applicable law.
8.2 Exercising your rights
As the Services do not provide user accounts, requests must be
submitted using the contact details specified in Section 12.
To protect personal information
and prevent unauthorised access, we may require sufficient information to verify your identity before
processing a request. Where a request is submitted by an authorised representative, proof of
authorisation and identity verification may be required.
Requests must be sufficiently detailed
to allow us to understand, evaluate and respond appropriately. Where a request is unclear or
incomplete, we may request additional information before proceeding.
We will take reasonable
steps to respond to requests in a manner consistent with applicable legal requirements and operational
feasibility.
8.3 Response and limitations
We will respond to valid requests within the timeframes required by
applicable law or, where no specific timeframe applies, within a reasonable period, taking into
account the nature and complexity of the request.
We may refuse or limit a request where
permitted by applicable law, including where:
- the request is unfounded, excessive or
repetitive;
- fulfilling the request would disclose personal information about another
individual;
- the information is subject to legal privilege or other legal restriction;
-
retention is required for legal, regulatory, audit, security or dispute resolution purposes; or
-
the request conflicts with other legal obligations.
Where a request is refused or limited, we
will provide reasons to the extent permitted by law and inform you of any available
recourse.
We may also retain certain information as required to comply with legal obligations,
maintain appropriate business records, enforce our rights or protect the integrity and security of the
Services.
By using the Services, you acknowledge that your rights will be exercised in
accordance with applicable law and that certain limitations, procedural requirements and verification
steps may apply in order to protect personal information and ensure lawful processing.
9.  DO-NOT-TRACK SETTINGS AND CONTROLS
Some web browsers and devices offer “Do Not Track” (“DNT”) settings that
are intended to signal a user’s preference not to be tracked across websites.
At present, there
is no universally recognised or consistently applied standard that requires websites to respond to DNT
signals. Accordingly, the Services do not currently respond to DNT signals in a standardised
manner.
You may control the use of cookies and similar tracking technologies through the
mechanisms described in this Privacy Policy and the Cookies Policy, including:
- consent or
preference management tools made available through the Website;
- browser settings that allow you to
block, restrict or delete cookies and related technologies;
- device-level privacy and tracking
controls, where available; and
- third-party opt-out tools or industry frameworks where
applicable.
These mechanisms provide more granular and effective control over tracking
technologies than current DNT signals.
If a recognised standard or legal requirement emerges
requiring the recognition or implementation of DNT signals, we may update our practices and this Privacy
Policy to reflect such developments.
The handling of tracking technologies remains subject to
applicable legal requirements, including consent where required, and to the choices you make through the
available control mechanisms.
10.  CHANGES TO THIS PRIVACY POLICY
We may amend, update or revise this Privacy Policy from time to time to
reflect changes in our practices, technologies, legal obligations, regulatory guidance, industry
standards or the Services.
The most current version of this Privacy Policy will always be
indicated by the “Last updated” date set out at the beginning of this document.
Where changes are
material or may significantly affect your rights or the manner in which we process personal information,
we may take reasonable steps to bring such changes to your attention, including by:
- displaying a
prominent notice on the Website;
- providing contextual notices at the point of data collection;
or
- using other appropriate communication channels where available.
Your continued access to
or use of the Services following the publication of an updated Privacy Policy constitutes your
acknowledgement of the updated terms, to the extent permitted by applicable law.
Where required
by law, we will obtain your consent to material changes affecting the collection, use or disclosure of
personal information.
You are responsible for reviewing this Privacy Policy periodically.
11. ACCESS, UPDATE OR DELETE DATA
You may request access to, correction of, deletion of, or restriction of
the processing of personal information held about you, subject to applicable Canadian law.
These
rights are further described in Section 8. Requests must be submitted using the contact details set out
in Section 12.
We may require sufficient information to verify your identity before processing a
request.
We will respond within the timeframes required by applicable law or, where no specific
timeframe applies, within a reasonable period, taking into account the nature and complexity of the
request.
In certain circumstances, we may be required or permitted to retain or continue
processing personal information, including where necessary to:
- comply with legal or regulatory
obligations;
- establish, exercise or defend legal claims;
- protect our rights, property or
safety, or that of others;
- detect, prevent or investigate fraud, abuse or security incidents;
or
- maintain appropriate operational and compliance records.
Where a request cannot be
fulfilled, we will provide an explanation to the extent permitted by law and inform you of any available
recourse.
12. CONTACT DETAILS AND DATA ENQUIRIES
We have designated a person responsible for privacy compliance and the
protection of personal information (“Privacy Officer”). This individual is responsible for overseeing
our privacy practices, ensuring compliance with applicable Canadian privacy laws, and handling
privacy-related enquiries, complaints and requests.
If you have any questions about this Privacy
Policy or how your personal information is handled, or if you would like to make a request or submit a
complaint, please contact our Privacy Officer at support@onlinecasinocanadarank.com. Including “Privacy”
in the subject line will help us route your message more efficiently.
Requests may include:
-
requests for access to personal information;
- requests for correction or updates;
- requests to
withdraw consent;
- complaints regarding the handling of personal information; and
- enquiries
regarding data processing, cookies or advertising preferences.
All communications should
include:
- your full legal name and valid contact details;
- a clear description of your request
or concern; and
- any information necessary to allow us to identify and locate the relevant
data.
We may require additional information or identity verification where reasonably necessary
to ensure that personal information is disclosed only to authorised individuals and to prevent
unauthorised access.
We will respond to requests and enquiries within the timeframes required by
applicable law or, where no specific timeframe applies, within a reasonable period.
If you are
not satisfied with our response, you may have the right to lodge a complaint with a competent privacy
regulator, including the Office of the Privacy Commissioner of Canada or an applicable provincial
authority.