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Latest Revision: 2025-06-06

Overview

Cadtree Limited and its associated online casino platforms (collectively referred to as “the Group”) offer online entertainment via websites, mobile apps, and other digital tools (collectively referred to as “our Services”). This Privacy Notice is designed to explain how we collect, process, disclose, and safeguard your personal data.

Your privacy matters to us. This policy outlines our data handling practices—how information is obtained, where it’s stored, how it’s used, and under what circumstances it’s shared. We strictly adhere to applicable privacy legislation, including Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

In this Privacy Notice, we cover:

  • About Cadtree Limited
  • What Information We Gather
  • Policy Regarding Underage Users
  • Purposes for Data Usage
  • Marketing & Communication
  • Data Sharing Practices
  • Cross-Border Data Movement
  • Use of Cookies & Analytics
  • External Service Providers
  • How Long We Keep Your Data
  • Your Privacy Rights
  • Data Protection Methods
  • Policy Revisions
  • How to Reach Us

Please take time to carefully read this Privacy Notice. By accessing our Services or creating a user account, you indicate your acceptance of the practices outlined here.

How to Contact Us

If you have inquiries or concerns regarding this policy or the handling of your personal data, please direct them to our Privacy Officer through our contact form or by post. Please note that responses are subject to any applicable legal restrictions.

About Cadtree Limited

Cadtree Limited operates several gaming platforms, including: spincasino.ca, rubyfortune.ca, jackpotscitys.com, and royalvegas.ca.

The company is legally incorporated in Guernsey under registration number 2031, with its registered address at La Corvee House, La Corvee, Alderney GY9 3TQ. Cadtree Limited operates under a license issued by the Alcohol and Gaming Commission of Ontario (License #OPIG1236392), effective as of June 23, 2022.

Types of Information We Collect

As an officially regulated operator under iGaming Ontario (iGO), Cadtree Limited collects and uses personal data in full compliance with FIPPA, PIPEDA, and Ontario Regulation 722/21. “Personal Information” refers to any recorded detail that can be used to identify a specific individual. The information we collect generally falls into two main groups:

1. Personally Identifiable Information

Depending on how you interact with our platform, we may collect a range of personal data, including but not limited to:

  • Profile Information: Your name, email address, gender, date of birth, residential address, government-issued ID, phone number, and job role.
  • Identity Confirmation: We may ask you to provide a scanned copy or photo of official documentation for verification purposes.
  • Payment Credentials: To process transactions, we gather information such as your credit/debit card details and banking information.
  • User-Submitted Content: Any messages, chat input, or voluntary responses you send through our system or games.
  • Technical Identifiers: Data like your IP address, device ID (IMEI/MAC), browser signature, and geolocation data.
  • Call Recordings: We may record phone conversations for support training, service quality, or legal reasons.
  • Social Account Data: If you log in via social media, we may collect certain publicly accessible profile details and friend network information.
  • Referral Information: When you use features like “Refer a Friend,” we may track data related to the invited users.
  • External Reports: We may receive additional data such as fraud screening or creditworthiness checks from third parties.
  • Location-Based Information: Used to meet jurisdictional compliance requirements, including geo-restrictions.

2. Non-Identifiable Information

We also collect data that doesn’t directly identify you. These details are generally aggregated or anonymized and are used to enhance the functionality of our services. Examples include:

  • Device and Environment Data: Browser type, OS, screen size, device language, and other system info.
  • Usage Patterns: Information about your in-game behavior, time spent on platform, transactions, and bonuses used.
  • Security Scanning: Our system may check for prohibited tools like bots, VPNs, or cheating software.
  • Interaction Logs: Pages visited, buttons clicked, time spent on site, and other behavioral insights.
  • De-Linked Aggregated Data: Statistics compiled from user activity but stripped of personal identifiers, which may be used for research, advertising, or internal analytics.

Should any non-personal data later be linked to a specific individual, it will be treated with the same care as personal data under this policy.

Minors

Our platform is strictly intended for users who are 19 years or older, or the age of majority in their province, state, or country—whichever is higher (referred to as “Legal Age”). If you are under this age, you are not permitted to use our services or submit any personal information.

We reserve the right to verify the age and identity of any user. Should we identify that someone under the Legal Age has provided personal data, we will immediately remove such information. If you believe a minor has submitted data to us, please notify our support team without delay.

How We Use Your Data

We use your information to deliver services efficiently and securely. The data we gather is used for various purposes, including but not limited to:

  • Creating and managing your account;
  • Processing payments and facilitating gameplay features;
  • Sending service-related messages, promotional materials, and system notifications;
  • Executing personalized marketing campaigns (details in “Marketing” section);
  • Studying user behavior for service improvements and personalization;
  • Providing technical assistance and handling inquiries;
  • Developing new platform features and refining existing ones;
  • Encouraging responsible gambling practices;
  • Enabling you to exercise your rights related to your personal data;
  • Securing restricted areas of the website or app via authentication;
  • Detecting and preventing suspicious, fraudulent, or illegal activities;
  • Investigating potential policy violations or misuse;
  • Managing disputes or complaints relating to your account;
  • Fulfilling legal obligations, such as KYC and AML procedures, and responding to legitimate requests from public authorities.

Marketing

We, along with our approved marketing partners, may use your personal contact information (e.g., email, phone number, postal address) to deliver promotional offers and service updates. These may originate from:

  • Other entities within our business group;
  • White-label brands we manage or support;
  • Authorized affiliates and third-party marketing agencies.

We may share your details with these third parties for direct outreach via emails, text messages, telephone calls, or physical mail—depending on your stated preferences.

You can manage or change your communication settings at any time through customer support. If you’ve downloaded any of our apps or software, you may receive push notifications. These may alert you to new features, games, or special offers.

By installing such software, you consent to receive these notifications. You may disable them at any time through device settings or unsubscribe options included in the notification.

You also have the right to opt out of marketing communications altogether by contacting our live support. Please note that essential system messages (e.g., transaction confirmations, policy updates) may still be sent regardless of your opt-out status.

Who We Share Your Information With

We do not sell, lease, or trade your personal information. However, we may share it with trusted parties when necessary for service delivery or compliance reasons, as outlined below.

We may disclose your information to the following recipient categories:

  • White-Label Operators: Partners managing platforms under our infrastructure or branding;
  • Group Affiliates: Internal teams, subsidiaries, and service providers handling IT, customer support, compliance, or marketing;
  • Credit Reference Bureaus: For background and financial checks;
  • Financial Institutions: Banks and services responsible for handling payments and withdrawals;
  • Marketing Service Providers: External parties assisting in brand promotion or campaign execution;
  • Event Organizers: Partners involved in prize draws, tournaments, or sponsored travel events;
  • Logistics & Travel Vendors: Companies handling prizes such as trips, hotel stays, or merchandise;
  • Auditors & Legal Advisors: Professionals evaluating our operations or ensuring compliance with regulations;
  • Fraud Prevention Units: Entities such as law enforcement, fraud-monitoring organizations, and regulatory authorities (e.g., FINTRAC);
  • Regulatory Bodies: Including but not limited to iGaming Ontario and the Alcohol and Gaming Commission of Ontario;
  • Business Acquirers: In the event of a sale, merger, or reorganization, personal data may be transferred to new ownership under existing policy terms.

These disclosures may serve the following purposes:

  • Secure storage of your data (e.g., via cloud infrastructure);
  • Carrying out essential operational functions such as fraud prevention, identity checks, and system audits;
  • Enhancing our platform through diagnostic tools and performance analytics;
  • Delivering tailored marketing content as outlined in the Marketing section;
  • Enforcing our Terms of Use, complying with legal requirements, and protecting against threats or misuse.

International Data Transfers

As we operate on a global scale, your personal data may be transmitted to countries or territories outside of Ontario. These external jurisdictions may not uphold the same privacy standards as those mandated by Ontario’s Freedom of Information and Protection of Privacy Act.

Nevertheless, we apply strict safeguards to protect your information during such transfers. These safeguards may include contractual commitments or limiting transfers only to countries with adequate data protection laws in place.

If you suspect that your personal information has been compromised or mishandled in any way, we encourage you to reach out to our support team via Live Chat for prompt assistance.

Use of Tracking Tools by Third Parties

When engaging with our platform—including websites and mobile interfaces—we and authorized third parties may employ various tracking technologies such as cookies, geolocation tags, web beacons, pixels, tracking scripts, and similar methods ("Tracking Tools").

These tools enable us to automatically gather data regarding your device (e.g., computer, phone, or tablet) and your activity while using our Services. Collected data is used for several purposes, including:

  • Confirming your location within Ontario, as required by law;
  • Improving the speed and usability of your browsing experience;
  • Enhancing performance and service delivery across platforms;
  • Tailoring site content and features to better align with your interests;
  • Analyzing traffic and usage patterns for product optimization;
  • Supporting advertising, partnerships, and affiliate program insights.

Some of these tools may be operated by external parties authorized to collect and analyze usage data. To learn more about how we use cookies and other technologies, please review our Cookie Policy.

External Services & Linked Content

While navigating our Services, you may encounter links to external websites, applications, or platforms that are not owned or managed by our Group. Please be aware that our Privacy Policy does not govern any third-party services, even if they are accessible through our platform.

These external sites operate independently and may have their own privacy rules and data processing practices. We strongly encourage you to review their respective privacy statements and terms of service before engaging with them.

You are solely responsible for your interactions with these third-party services. By accessing or using them, you agree that we are not accountable for any outcomes or damages resulting from such engagement.

Data Retention Policy

Once you create an account on our platform, we retain your personal information as long as the account remains active. Even after account closure, we may continue to store your data as required to comply with legal obligations—particularly under gambling legislation, Know Your Customer (KYC) protocols, Anti-Money Laundering (AML) measures, and our licensing agreement with iGaming Ontario (iGO).

If you wish to request the deletion of your personal data, please email [email protected]. We will review and process your request where legally permissible.

Your Privacy Rights

Under Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA), you have the right to access your personal data and verify its accuracy. Additionally, under the Personal Information Protection and Electronic Documents Act (PIPEDA), you may revoke your consent to the collection, use, or sharing of your data. However, withdrawing consent may limit our ability to provide certain Services.

You may contact us to request any of the following:

  • Access to or deletion of your personal data held on our systems;
  • Correction of incorrect, outdated, or incomplete data (unless legal obligations require otherwise);
  • Temporary or permanent limitation of how your data is processed;
  • Receipt of your submitted information in a portable and machine-readable format.

Please note that certain rights may be restricted by regulatory or legal requirements—particularly those related to gambling or financial laws. In some cases, we are obligated to retain specific data regardless of your request.

If you believe that your privacy rights have not been respected, you may file a formal complaint with the appropriate data protection authority. You are also entitled to escalate your concerns to iGaming Ontario (iGO). We fully cooperate with iGO in resolving such matters according to the Customer Care and Player Disputes Resolution (CCDR) framework.

Our Commitment to Data Security

We prioritize the protection of your personal data and the integrity of our platform. To ensure this, we employ a comprehensive range of physical, digital, and organizational safeguards aimed at preventing unauthorized access, ensuring data accuracy, and handling your information with care. The degree of protection applied is based on the nature and sensitivity of the data involved.

Our approach is grounded in widely accepted security frameworks and industry benchmarks. Key components of our security ecosystem include:

  • Robust network design with firewalls and active intrusion monitoring tools;
  • End-to-end encryption of sensitive data transmissions;
  • Access controls and identity verification protocols for system users;
  • Ongoing audits conducted both internally and by third-party security experts.

Although we take every reasonable step to protect your information, no online environment is entirely immune to threats. Therefore, while we strive to minimize risk, we cannot provide absolute guarantees against data breaches or unauthorized intrusions.

Security Practices, Breach Response, and Regulatory Cooperation

At Cadtree, maintaining the safety and privacy of your data is a top priority. We have implemented a multilayered defense strategy that blends technology, operational policies, and governance controls to shield personal data from unauthorized use, alteration, or loss. These protective measures are continuously updated to reflect emerging risks and advancements in cybersecurity.

While our security efforts are extensive, it's important to acknowledge that any data shared online is inherently exposed to some risk. Despite these limitations, we have a comprehensive plan in place to respond swiftly and effectively to any security breach.

In the event that your personal information is part of a breach that may result in serious consequences, we will inform you without undue delay. Additionally, we will alert the appropriate supervisory authorities—such as the Office of the Privacy Commissioner of Canada—and keep detailed incident records in line with legal obligations.

Our Breach Response Framework

To ensure a consistent and efficient approach to security events, Cadtree follows a formal Incident Management Protocol, which includes three critical stages:

1. Detection and Evaluation

Once a security threat is identified, we work immediately with relevant departments, technical teams, and compliance groups to evaluate the scope and potential impact. Monitoring is intensified, and investigations begin to determine the origin and extent of the issue while initiating protective countermeasures.

2. Mitigation and System Restoration

Our teams, often alongside external cybersecurity specialists and vendors, perform in-depth diagnostics to contain the issue. Affected systems or accounts are isolated and thoroughly examined. Any compromised data is secured, systems are cleansed, and disrupted financial activity—such as user balances and pending transactions—is corrected or refunded. Affected infrastructure is not brought back online until fully vetted.

3. Transparency and Notification

If your personal data is affected, you will be contacted through your registered email or in-platform notifications. These messages will outline the nature of the breach, which data may have been involved, and steps you can take to protect yourself. We also inform regulatory bodies, including iGaming Ontario (iGO) and the Office of the Privacy Commissioner of Canada. Cadtree works in full cooperation with these agencies to resolve issues and limit future risk.

Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy as needed. We encourage you to revisit this page regularly for the latest version. If we introduce any material changes, we will notify you via email or through a clear announcement on our Services. Major revisions will come into effect seven (7) days after notification, while all other updates become valid as of the "Last Updated" date shown. Your continued use of our platform after these changes will constitute acceptance of the revised terms.

Getting in Touch

For any concerns or questions about this Privacy Policy, how we handle your personal information, or our privacy practices in general, please contact our support team via the Live Chat option on the Contact Us page.

We aim to respond in a timely and thorough manner. If you’re not satisfied with our response, you are entitled to escalate your concerns to your local data protection authority for further investigation.

Cadtree Cookie Policy

Effective Date: July 1, 2022

Introduction

When you interact with our Services—whether through websites, mobile applications, or other digital interfaces—we and select third parties utilize cookies and similar tracking mechanisms, including pixel tags, web beacons, JavaScript, APIs, and other technologies (collectively referred to as “Tracking Tools”).

These technologies collect data about how you use our Services and the devices you use to access them. This helps us deliver a more customized experience, optimize platform performance, and offer tailored features. Additionally, this information supports analytics, advertising, personalization, and user engagement analysis.

We also allow certain authorized third parties to access and use Tracking Tools as part of our broader digital ecosystem.

Understanding Cookies

Cookies are small text-based files composed of letters and numbers, stored on your device when you browse a website. These files hold settings like your language preference and help streamline your interaction with the site. For additional details, you can visit www.allaboutcookies.org.

Cookies serve multiple functions: they help web pages load faster, remember your settings, and display content relevant to your interests, including targeted advertisements.

Types of Tracking Tools

Our Services use two primary types of Tracking Tools:

  • First-Party Tools: Placed directly by our platform when you use our Services.
  • Third-Party Tools: Placed by external entities such as analytics services, advertisers, or affiliate networks.

Tracking Tools can either be session-based (active only while you use the site) or persistent (remain active across multiple visits).

Categories of Tracking Tools We Employ

  • Strictly Necessary Tools:

    These are vital for the platform to function securely and effectively. They manage logins, session validation, and basic navigation. These tools operate without user consent.

  • Preference-Based Tools:

    These remember your selections—such as language or region—and help maintain user preferences across sessions. They also support accessibility options and keep you signed in.

  • Analytics Tools:

    These gather anonymized behavioral data, including time on page, scroll depth, and clicks. The insights gained are used to improve functionality, identify issues, and enhance overall performance.

  • Advertising & Retargeting Tools:

    These tools serve ads tailored to your behavior and preferences. They reduce repetitive ad displays and track ad campaign effectiveness. Social media integrations like Facebook’s “Like” or “Share” buttons also use these tools and follow the policies of their respective providers.

Common Tracking Technologies in Use

Tool Origin Purpose
Site Analytics Cookies First-Party Monitor usage patterns, user behavior, and referral sources for reporting and product improvement.
Platform Cookies First & Third-Party Preserve login details and settings to enhance usability and personalize the user experience.

Managing Your Cookie Settings

Currently, our platform does not support automatic browser settings such as “Do Not Track.” However, you still have options to control how cookies operate on your device:

Adjusting Browser Preferences

Most internet browsers provide tools to view, delete, and manage cookie behavior. You can configure your browser to block or allow cookies on a site-by-site basis. These options are typically located in your browser’s Settings or Help menu.

Useful links for managing cookies in common browsers:

Controlling Third-Party Cookies

To opt out of interest-based advertising cookies from participating third parties, visit the Network Advertising Initiative.

Please keep in mind that disabling cookies may limit the functionality and overall experience of our Services.