CADTREE LIMITED PRIVACY POLICY

Last Updated: 2022/07/01

INTRODUCTION

Cadtree Limited encompasses all the casinos mentioned below, including its related entities (collectively referred to as \" The Group \"). We provide online gambling options through various platforms, including websites and mobile applications (collectively known as the “ Services ”). This Privacy Policy aims to inform you about how your personal data is used, safeguarded, and processed.

Cadtree places great importance on protecting the privacy of its users (referred to as “ User(s) ”, “ you ”, or “ your ”). As such, we’ve developed this Privacy Policy to detail our data protection practices, explaining how we gather, use, share, and secure your Personal Information, along with your rights regarding that information. Cadtree complies with all relevant laws, including Ontario’s Freedom of Information and Protection of Privacy Act (“FIPPA”) and the Personal Information and Protection Electronic Documents Act (PIPEDA) (collectively known as the “Acts”).

Within this Privacy Policy, you will find information regarding:

CADTREE LIMITED
WHAT INFORMATION WE COLLECT?
MINORS
HOW WE UTILIZE THE INFORMATION WE COLLECT?
MARKETING
WITH WHOM WE SHARE INFORMATION?
INTERNATIONAL DATA TRANSFER
THIRD PARTY TRACKING TECHNOLOGIES
THIRD PARTY SERVICES
RETENTION OF PERSONAL INFORMATION
YOUR RIGHTS
HOW WE ENSURE THE SECURITY OF YOUR DATA
CHANGES TO THE PRIVACY POLICY
HOW TO CONTACT US

We strongly advise you to thoroughly read the Privacy Policy and use it to make well-informed choices. By accessing the websites, mobile applications, or other digital properties of Cadtree Limited, or by registering an account through our Services, you automatically consent to this Privacy Policy at the time you create your account.

If you have any inquiries or feedback regarding your personal information or this Privacy Policy, please feel free to reach out to our Privacy Executive at:
FORM

Information requests can be submitted either by filling out a designated form or by sending a letter to Cadtree. However, these requests might be subject to certain limitations and exceptions as stipulated by applicable laws.

CADTREE LIMITED

Cadtree Limited operates the following casino websites. www.laspartinette.com , www.rubyfortune.ca , www.jackpotcity.ca and www.royalvegas.ca

Cadtree Limited (2031), registered in Guernsey, has its official address at La Corvee House, La Corvee Alderney GY9 3TQ, Guernsey. Cadtree Limited is officially licensed and regulated by the Alcohol and Gaming Commission of Ontario (AGCO), holding License Number OPIG1237906, which was issued on June 23, 2022.

This organization serves as the owner and operator of the casino websites.

WHAT INFORMATION WE COLLECT?

Cadtree, functioning under authority from iGO, is involved in the collection, processing, and dissemination of personal information following FIPPA, Ontario Regulation 722/21 established under the Alcohol and Gaming Commission of Ontario Act, along with the Operator Agreement with iGO. The handling of personal data adheres to FIPPA, PIPEDA, and Ontario Regulation 722/21.

As defined by FIPPA, \"personal information\" refers to any recorded information that can identify an individual. Generally, Cadtree may gather the following types of personal data, although the specific data collected may vary based on the context or legal requirements:
We gather two categories of information from our Users:

Personal Information
The first category includes any information that can identify, or may reasonably be able to identify, an individual with due effort (referred to as “ Personal Information ”). The Personal Information we collect may include the following:

Account registration information: When you create an account to access our Services, you’ll be asked to provide certain personal details, such as your first and last name, email address, gender, date of birth, home address, identification number, phone number, occupation, etc.
Government-issued identification: In certain cases, you may need to provide a copy of a government-issued ID for verification purposes. Please be aware that this documentation is essential for accessing specific features of our Services.
Payment details: To utilize all functionalities of our Services (like placing bets, making purchases, or entering tournaments), we will collect your payment information, including credit card numbers and bank account details.
Voluntary submissions: We also accept information you choose to provide voluntarily. For instance, when you reply to our communications, interact with us via email, or share additional details about yourself while using the Services, such as through the chat function or within games.
Device specifics: We gather particulars about your device, its software, and hardware, which may allow us to identify you, including unique device identifiers (e.g., UDID, IMEI, MAC address), browser details, IP address, and geolocation data.
Telephone conversations: We may record or monitor calls made to our customer support team for training, quality assurance, and security purposes.
Social media accounts: If you register using your social media account (like Facebook), or link your gaming account to it, we can access basic information from your social profile, including your name, birthdate, profile picture, and friends list, as well as any publicly available information.
Additionally, while using our Services, you may invite others via social networks to join us. If they accept your invitation, we might receive Personal Information about them, such as their name, email address, phone number, and birthdate. This data will be used strictly for the intended purposes stated here and will only be shared with third parties as outlined in this Privacy Policy.
Third-party information: We may obtain Personal Information from external service providers, including credit history data from credit agencies and other financial information necessary for delivering our Services, as well as data needed for identity verification to thwart fraudulent or illegal actions.
Geolocation tracking: We may track your location to ensure compliance with legal requirements.

Non-personal information
The second type of information we collect is non-identifiable and anonymous data regarding our Users, which may be collected or generated through the User’s interaction with the Services (referred to as “Non-Personal Information”).
The Non-Personal Information we collect encompasses technical details and aggregated usage data, which may include, but is not limited to, the User’s operating system, browser type, screen resolution, browser and keyboard settings, click-stream activities, duration of Service visits, and related timestamps.

To clarify, any Non-Personal Information that is linked to any Personal Information will also be treated as Personal Information as long as the link remains intact.
Categories of Non-Personal Information we gather include:

Technical data: We collect technical information sent by your device to improve the Services and enhance your user experience, including software and hardware details like browser type, operating system, language preference, access time, and the domain name of the website that directed you to our Services, among others.
Gameplay data: We document gameplay-related information, including deposits, bets, bonus claims, game session lengths, and high scores. This information might also be shared or published on our Platforms.
Device and connectivity details: If you download our software onto your device, we may gather data regarding your specific device for security and fraud prevention. For instance, we might collect information on concurrent software running with our product to check for possible fraudulent activity (like bots or malware) or to ascertain if your connection is via a VPN or proxy.
Analytical data: We accumulate information on your interaction with the Services, such as app usage, logs, user actions (like pages visited, time spent on each page, online behavior, clicks, etc.), timestamps, and alerts. This data is collected for troubleshooting issues, fixing bugs, and conducting research and analytics regarding your use of our Services.
Anonymized data: We can anonymize or de-identify information collected through the Services, ensuring it cannot be linked back to you personally. The usage and sharing of such anonymized or de-identified data is not restricted under this Privacy Policy, allowing us to disclose it freely for purposes like marketing or advertising.

MINORS

Our Services are not intended for individuals under the age of 19 or those who do not meet the legal age requirement regarding the use of the Services in any jurisdiction, whichever is greater (“Legally of Age”). If you do not meet the Legally of Age criteria, you should refrain from downloading or utilizing the Services or submitting any Personal Information.

We reserve the right to review and confirm any Personal Information that we collect from you. If we discover that a user who is not Legally of Age has shared any information, we may eliminate that information. If you suspect that a minor has communicated any information to us, please notify us immediately.

HOW DO WE USE THE COLLECTED DATA?

Your Personal Information is utilized for the following purposes:

To establish, manage, and update your user account;
To deliver and manage the Services (including activities such as processing bets and payments);
Our goal is to keep you in the loop about our latest service updates and exclusive offers by communicating directly with you.
We aim to promote our Services and display advertisements that are tailored to your interests, including personalized behavioral ads.
We perform analysis and research to better tailor and enhance our Services based on your preferences and habits, including creating aggregated usage reports for specific features.
We utilize Customer Relationship Management tools to assist with support, resolve issues with the Services, and address any inquiries you may have.
Our focus is on continually improving our Services by tailoring them to the common preferences and usage patterns of Users.
We are dedicated to creating a responsible and safe gaming environment for all Users.
We will communicate with you and process any requests you have to exercise your User Rights effectively.
Our system is designed to verify and authenticate your access to certain features within our Services.
We actively work to identify and prevent any fraudulent, illegal, or harmful activities that could disrupt the integrity of our Services, thus assessing potential risks associated with your participation.
We investigate any breaches of our policies and User Agreement and take action to uphold these terms.
We look into and aim to resolve any disputes arising from your usage of our Services.
We comply with legal requirements or regulatory standards, including Know Your Customer (\"KYC\") and Anti-Money Laundering mandates, and respond to subpoenas or similar inquiries from governmental authorities.

MARKETING

Our Group will utilize your Personal Information, including details like your name, address, email, and phone number, either directly or through third-party vendors, to provide promotional materials related to our Services, as well as to products and services that may pique your interest from (i) other companies in the Group; (ii) White Label Brands; or (iii) affiliates of the Group, collectively referred to as Marketing Affiliates .

We might share and disclose your Personal Information with our Marketing Affiliates to present marketing offers that we or they consider applicable to you. These Marketing Affiliates may use this information for various forms of marketing, such as through emails, postal mail, SMS, or phone calls.

You have the option to modify your marketing preferences at any time by contacting Customer Services when available. If you download software through our Services, it may install notification software on your device, which enables us to send you alerts about our Services, including new features, updates, and promotional offers.

By installing this software, you agree to receive notifications. If you choose not to receive these alerts, you will need to manually remove the notification software from your device, which can typically be done following the instructions on received notifications or by accessing the respective settings on your device.

You can opt out of receiving any future marketing communications from us or our partners at any time by using the Live Chat option. Keep in mind that if you unsubscribe from our marketing communications, we may still send you important updates and notifications related to our services.

WITH WHOM WE SHARE INFORMATION?

We respect your privacy and do not rent, sell, or share your Personal Information with third parties known as Recipients except as specified in this Privacy Policy. Any disclosure of your Personal Information to Recipients will only occur when necessary for a particular purpose outlined in this policy.

We may share your Personal Information with various recipients, which include:

White Label Brands and any alternative service providers engaged by these brands, when applicable.
Affiliated companies within the Group and third-party service providers, including subcontractors, which may involve providers such as cloud computing services, marketing affiliates, and companies focused on fraud detection and identity verification.
Credit reporting agencies;
Payment processors, banks, and other relevant financial service providers.
External parties who assist with the operation or promotion of any In House Brand or White Label Brands, if applicable.
Third-parties involved in organizing offline events or tournaments in collaboration with the Group.
Travel services, such as hotels and airlines, particularly in relation to offline events and promotions.
Auditors, contractors, or advisors linked to the business processes of the Group.
Authorities concerned with investigating and preventing fraud or illegal activities, such as government bodies, police, and financial institutions.
Licensing authorities and regulatory bodies must be informed in compliance with applicable legislation.
Potential buyers or investors interested in any companies within the Group or White Label Brands, especially in the case of significant business dealings such as sales, mergers, or reorganizations, where the new entity will inherit the rights and responsibilities detailed in this Privacy Policy.
Gaming Regulatory Bodies like the Alcohol and Gaming Commission of Ontario and iGaming Ontario.
Beyond the aspects mentioned in this Privacy Policy, we also share Personal Information with those recipients for several reasons, including:
Storing data on our behalf, often utilizing cloud service providers for enhanced security.
Processing information to facilitate our business needs, such as handling payments and deposits, verifying your access, auditing, and preventing any fraudulent or illegal actions.
Conducting research, technical diagnostics, and analytics to improve our Services.
Delivering targeted advertising and promotional content based on our marketing strategies.
In situations where we believe it’s essential to protect our legal rights or interests, enforce our policies, ensure safety for you and others, and to investigate or prevent any security threats.

TRANSFER OF INFORMATION

As our operations have a global reach, your Personal Information may need to be transferred to countries outside of Ontario. The laws regarding data protection in those countries may not be as robust as those under the Freedom of Information and Protection of Privacy Act.

We make every effort to safeguard your Personal Information according to our privacy policy, employing contractual protections where possible and other measures to ensure data security.

If you believe your privacy has not been properly upheld according to our policies, or if someone has misused the Services, please reach out to us directly through Live Chat.

THIRD PARTY TRACKING TECHNOLOGIES

Whenever you access our Services, such as when browsing our websites, we utilize (and allow third parties to utilize) various technologies like location tracking, web beacons, cookies, pixels, scripts, tags, and other similar tools, collectively termed as Tracking Technologies .

These Tracking Technologies allow us to automatically gather data regarding your online activity and device specifics, such as your computer or mobile phone, for diverse purposes including verifying your location in Ontario, enhancing your navigation experience on our Services, boosting performance, and customizing your overall user experience. We also analyze this information for statistical insights into Service usage and to provide tailored content to our users and partners.

We permit third parties to collect data about you using these Tracking Technologies as well. For further details, please visit our. Cookie Policy .

THIRD PARTY SERVICES

While interacting with our Services, you may come across links to external websites, services, or applications. It’s important to remember that this Privacy Policy does not extend to these third-party entities, even if accessible through our Services.

Please be aware that these third-party sites, services, and applications operate independently from our Group. We do not assume any responsibility for privacy issues or other legal matters pertaining to these third-party platforms. We advise you to carefully review the privacy policies and terms of service for any third-party sites, as their stipulations will govern your engagements with them.

Always exercise caution and thoroughly consider their privacy practices before sharing your Personal Information with third parties.

By using any third-party websites, services, or applications, you willingly accept all associated risks. You also agree that we bear no liability concerning the usage of these third-party sites.

RETENTION OF PERSONAL INFORMATION

When you create an account using our Services, we will keep your Personal Information for as long as your account remains active. Furthermore, we are required to hold onto your Personal Data for specific durations to comply with various legal responsibilities, including gambling laws, Know-Your-Customer (KYC) guidelines, Anti-Money Laundering (AML) regulations, and terms set forth in the iGO Operating Agreement.

Should you decide to remove your Personal Information for any reason, we encourage you to reach out to us via email at.

YOUR RIGHTS

According to FIPPA, you have the right to Access your information and ensure its Accuracy. Under PIPEDA, you may choose to retract any consent you’ve given regarding the collection, sharing, or utilization of your personal data; however, it's important to note that doing so might hinder our ability to continue providing services to you.

You are welcome to get in touch with us at any time via email and request the following:
1. Access to or deletion of any Personal Information associated with you.
2. Modifications or updates to any of your Personal Information (for instance, if you notice inaccuracies, you can request corrections or even deletions). Keep in mind that while we can amend inaccuracies in your Personal Information, we must preserve certain data in its original format as mandated by applicable regulations.
3. Initiation of actions to limit or cease further utilization of your Personal Information.
4. Delivery of the Personal Information you provided to us in a format that can be easily read by machines.
It's important to understand that these rights have certain limitations and any requests made are subject to existing legal standards, including those related to gambling and other reporting or documentation retention rules. Additionally, we reserve the right to correct, complete, or remove any incomplete or inaccurate information at our discretion, in line with our internal guidelines.
If you have any questions or concerns concerning your rights regarding personal information, remember that you can always lodge a complaint with a regulatory body. To escalate such concerns, you may reach out to iGO. Cadtree will assist iGO during the investigation and resolution process, following the established Customer Care and Player Disputes Resolution policy (CCDR).

HOW WE ENSURE THE SECURITY OF YOUR INFORMATION

We prioritize the security of our Services and the information you provide. We have implemented various physical and technological measures designed to prevent unauthorized access, ensure data security, and correctly utilize the information we gather online. The type of safeguards we use varies according to the sensitivity of the data we collect and maintain.

To protect the information of our users, we adhere to standard industry protocols and controls which include:

A secure network structure that features intrusion prevention and Firewall systems;
Encrypted communication;
Authentication and Access Control;
Conducting both internal and external audits; and more.

Even though we take significant measures to protect your information, we cannot guarantee complete immunity against unauthorized individuals who may exploit the system, and clearly state that we do not offer any warranties, either express or implied, regarding our ability to prevent such intrusions.

SECURITY & INCIDENT BREACH MANAGEMENT AND COLLABORATION

Safeguarding your Personal Information is a top priority for Cadtree, and we continuously strive to enforce and enhance its security. We have established appropriate safeguards to prevent unauthorized access, maintain data security, and handle the information we gather properly. These measures are tailored according to the sensitivity of the information and are in line with current best practices to ensure customer privacy. They encompass various technical, procedural, monitoring, and tracking steps aimed at protecting data from misuse, unauthorized access, loss, change, or destruction.
Although we apply reasonable precautions and utilize appropriate security strategies to protect information, the reality is that the Internet is not wholly secure. We cannot assure the absolute safety of your Personal Information, and any information transmitted over the Internet is at your own risk. We are not liable for actions taken by individuals who obtain unauthorized access to your data, and we do not guarantee that we can prevent such access or misuse. Nonetheless, should your Personal Information be affected by a breach of privacy that poses a significant risk to you, we will notify you promptly. We will also inform relevant authorities, as required by law (including, without limitation, the Office of the Privacy Commissioner of Canada), and maintain a record of any privacy breach as mandated by applicable regulations.
Cadtree’s Incident Response Management plan consists of a structured approach to managing security incidents, collectively referred to as the 'Incident Management Process.' This process outlines a standardized way of addressing security-related incidents. When a security event is reported, involved resources will follow this Incident Response Process to ensure appropriate actions are taken. The Incident Management Process includes three key stages:

Initiation: In conjunction with our critical suppliers, internal teams, and assurance functions, we will assess the seriousness and impact of any cyber event. We will increase monitoring and alert the necessary network and systems. A thorough investigation into the extent of the breach within our infrastructure will take place, while all internal stakeholders will be alerted about the initiation of recovery efforts.
Containment, Eradication, and Recovery: Alongside our key suppliers, internal stakeholders, and assurance teams, we will run audits to verify the integrity of important data related to customers. If any data is found to be compromised, it will require additional cleaning and restoration efforts. Once the data has been sanitized, we will analyze player account balances. All failed transactions, bets, and game data will be compiled into a report and communicated to the appropriate authorities. Following their approval, player account balances will be restored or refunded as per our recovery processes. We will also confirm that the restored assets function correctly and fulfill the security standards set by our security team before we make the site operational again.
Notification: Players will receive updates about their restored balances via email or on-site messaging. Additionally, they will be informed of any Personal Information that may have been compromised during the breach, with guidance to reset their passwords to help keep their accounts secure. Notifications will also be dispatched to iGO and the Office of the Privacy Commissioner of Canada, with Cadtree providing assistance to iGO and other relevant authorities in managing and addressing the aftermath of the breach.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any given time, and encourage you to frequently check this page for updates. Any significant changes to this Privacy Policy will be communicated through our Services and/or via email to the address you provided. Such substantial changes will take effect seven (7) days post-communication through the outlined methods. All other modifications to this Privacy Policy will be effective as of the indicated \"Last Revised\" date, and your continued use of the Services following that date implies your acceptance of those changes.

HOW TO CONTACT US

For any general inquiries regarding our Services or the information we collect about you and how we utilize it, please don't hesitate to contact us through the chat feature available on our contact page.

We aim to respond within a reasonable timeframe. Feel free to reach out to us whenever you need assistance. If our response does not meet your expectations, you have the option to contact the appropriate data protection supervisory authority.

CADTREE COOKIE POLICY

Last Updated: 2022/07/01

INTRODUCTION

When you engage with our Services—such as accessing our websites or applications, or interacting with our content—we use (and permit third parties to use) tracking mechanisms, including web beacons, cookies, pixel tags, scripts, tags, APIs, and other related technologies (collectively referred to as \" Tracking Technologies \").

These Tracking Technologies enable us to automatically gather details about you and your online activities, as well as your device (like your computer or mobile phone), to enhance your experience on our Services, optimize performance, and tailor your interactions. We also utilize this information to analyze usage patterns, generate statistics, provide content aligned with your interests, and manage services for our users, advertisers, publishers, clients, and partners.

We also permit third parties to collect information about you through the use of Tracking Technologies.

WHAT ARE COOKIES?

Cookies are tiny text files composed entirely of letters and numbers, which a web server places on your device when you visit a webpage. These cookies can make our Services more user-friendly by retaining your language preferences and settings. For further information regarding cookies, you can refer to. www.allaboutcookies.org .

Cookies are extensively used to enhance the operational efficiency of websites. Their implementation facilitates smooth navigation between pages, preserves your preferences, and promotes a seamless interaction between you and the Services. Additionally, cookies play a crucial role in ensuring that the advertisements you encounter online are pertinent to your interests.

STORING TRACKING TECHNOLOGIES

When you access our Services, such as by visiting our websites, we implement Tracking Technologies known as \"First Party Tracking Technologies\". Furthermore, other external entities, including our analytics partners, business collaborators, and advertisers, may also utilize Tracking Technologies while displaying content on our Services, referred to as \"Third Party Tracking Technologies\".

Both First Party and Third Party Tracking Technologies may be retained during your visit or for any subsequent visits you may make.

WHAT CATEGORIES OF TRACKING TECHNOLOGIES DO WE EMPLOY?

Tracking Technologies can be categorized into four primary types:

Essential Tracking Technologies
These Tracking Technologies are fundamental for enabling functionalities such as logging in, navigating our Services, and utilizing its various features, including responding to specific requests you make (like entering your username). Consent is not required for the implementation of these technologies, which may also be employed for security purposes, such as detecting policy violations and enhancing overall security and support features.
Personalized Tracking Technologies
These types of Tracking Technologies help our Services retain your preferences (such as language selection) and deliver customized, user-friendly features. For instance, they are useful for confirming your logged-in status and supporting other Service functionalities.
Analytics Tracking Technologies
These Tracking Technologies gather data on your online behaviors (such as how long you spend on our Services), which includes analyzing user activity and metrics associated with content engagement. They play a crucial role in research, analytics, and generating statistical insights from aggregated data.
Advertising Tracking Technologies
These Tracking Technologies aim to present you with personalized offers and advertisements based on identified interests, as well as facilitate email marketing initiatives. They can help regulate how often you're exposed to specific advertisements and assess the success of advertising strategies. Typically set by our advertisers or advertising networks, these technologies give insights into user interactions with ads and websites. Additionally, our site features social media buttons (like Facebook's \"Like\" or \"Share\"), which may be hosted by third parties or directly on our Services, and your use of these functions is subject to the privacy policies of the respective companies.

Tracking Technologies	Type	Purpose
Analytics Cookies	First party Tracking Technology	Analytics Tracking Technologies These Tracking Technologies gather insights about your interaction with the content on our Services for purposes like attribution (for instance, the URL that referred you) and other analytics. The information collected helps us generate reports, calculate revenues owed, enhance our Services, and tailor products and content to your preferences.
Other cookies	First and Third-party Tracking Technologies	Essential Tracking Technologies Various cookies that are not explicitly listed may be active within internal areas of our Services, aiding in personalizing and streamlining your experience by remembering your preferences and login information.

HOW TO MANAGE YOUR COOKIE SETTINGS

Please be aware that we do not acknowledge or react to automated browser signals regarding Tracking Technologies, including \"Do Not Track\" requests. However, you have multiple options to manage and modify your cookie preferences. It's important to note that deleting or rejecting cookies may affect how well some features of the Services function.

If you wish to modify your preferences at any point,click here .

Disabling cookies through your web browser
Most web browsers provide general information about cookies, enabling you to view stored cookies on your device, delete some or all of them, and block or permit cookies for all sites or specific ones. You can typically disable third-party cookies independently as well. Keep in mind that browser or device settings usually apply solely to the specific browser or device in use.
Details on cookies can typically be found in the \"Help\" section of your web browser.
Here are some links to popular web browsers:
Turning off third party cookies
To disable certain third-party advertising cookies, please use the following link: Network Advertising Initiative.