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Last Revised: 2025/06/01

Overview

Cadtree Limited, along with its affiliated online casinos listed below (collectively referred to as "the Group"), provides digital gaming experiences via websites, mobile applications, and other online platforms (referred to as "the Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data.

We take privacy seriously and have developed this Privacy Policy to outline the ways in which your information is collected, stored, and shared, as well as your rights regarding your data. Cadtree complies with all relevant privacy laws, including Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA).

This Privacy Policy addresses the following topics:

  • Cadtree Limited
  • Types of Data Collected
  • Minors
  • How Collected Data is Used
  • Marketing Practices
  • Sharing of Information
  • International Transfers of Data
  • Tracking Technologies
  • Third-Party Services
  • Data Retention
  • Your Rights Regarding Data
  • Data Protection
  • Policy Updates
  • How to Contact Us

Please take the time to read this Privacy Policy carefully. By using our Services or creating an account, you agree to the practices outlined in this policy.

How to Contact Us

If you have any questions or concerns regarding this Privacy Policy or the handling of your personal information, please reach out to our Privacy Officer using the provided contact form or by mail. Please note that responses may be subject to legal limitations.

Cadtree Limited

Cadtree Limited operates several casino websites, including: spincasino.ca, rubyfortune.ca, jackpotscitys.com, and royalvegas.ca.

The company is registered in Guernsey (company number 2031), with its registered office located at La Corvee House, La Corvee, Alderney GY9 3TQ. Cadtree Limited is licensed by the Alcohol and Gaming Commission of Ontario (License Number OPIG1236392), effective from May 23, 2025.

What Information Do We Collect?

As an operator licensed by iGaming Ontario (iGO), Cadtree Limited collects and processes personal data in line with FIPPA, PIPEDA, and Ontario Regulation 722/21. "Personal Information" refers to any data that can be used to identify an individual. We categorize the data we collect into two main types:

1. Personal Data

Depending on your interaction with our Services, we collect the following types of personal information:

  • Account Information: Includes your full name, email address, gender, date of birth, residential address, government-issued identification number, phone number, and job title.
  • ID Verification: We may ask you to provide a scan or photo of a valid ID to verify your identity.
  • Payment Information: To provide full functionality of our services, we collect payment data such as credit card details and bank account information.
  • Voluntary Data: Any information you provide voluntarily, such as responses to our communications or data shared through chats and games.
  • Device Information: Technical details such as IP address, device ID (IMEI, MAC), geolocation, and browser identifiers.
  • Call Recording: Phone conversations may be recorded for purposes such as training, customer support, or security.
  • Social Media Data: If you log in via social media platforms (e.g., Facebook), we may gather publicly available details from your profile and friends list.
  • Referral Data: If you use features like "Invite a Friend," we may collect information about the referred users.
  • Third-Party Data: Information such as credit history or fraud checks may be collected from third-party services.
  • Geolocation: We may collect location data to comply with legal requirements.

2. Non-Personal Data

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

  • Device Specifications: Information about your browser, screen resolution, operating system, etc.
  • Gaming Activity: Includes records of your deposits, bets, bonus usage, play duration, and game scores.
  • Security Monitoring: We scan your device for cheating software or proxies/VPNs.
  • Usage Logs: Logs of your browsing activity, including the items you click and how long you spend on each page.
  • De-Identified Data: Aggregated data that does not identify you personally may be used for marketing or statistical purposes.

If non-personal data becomes linked with personally identifiable information, it will be treated as personal information.

Minors

Our Services are exclusively designed for individuals who are at least 19 years old or have reached the age of majority in their country or region—whichever age is higher (referred to as the "Legal Age"). If you do not meet this criterion, you are not permitted to access, use, or download our Services, nor should you provide us with any personal information.

We reserve the right to verify and assess the personal information you submit. If we discover that any data has been provided by someone below the Legal Age, it will be removed from our systems. If you believe that a minor has submitted any data to us, please contact us immediately.

How We Utilize Your Personal Information

The personal information we gather is used for several purposes, all aimed at enhancing your experience and ensuring the proper functioning of our platform. These purposes include:

  • Setting up, managing, and maintaining your user account;
  • Providing our Services, including processing payments and placing bets;
  • Communicating updates, new features, and promotional offers;
  • Carrying out marketing campaigns (see "Marketing" for more details), including personalized advertising;
  • Conducting research, analysis, and statistical studies to improve and customize our Services according to user behavior and preferences;
  • Offering customer support, resolving technical issues, and addressing user inquiries;
  • Developing new functionalities and improving existing ones to better meet user needs;
  • Encouraging responsible and safe gaming behavior;
  • Processing requests related to your data rights;
  • Authenticating user access to secure areas of the platform;
  • Detecting and preventing fraud, misuse, or any activities that could harm the integrity of our systems;
  • Investigating violations of our Terms of Service or internal policies;
  • Resolving any disputes or issues arising from your use of our Services;
  • Complying with legal requirements, such as Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, and responding to government requests or legal processes.

Marketing

Along with select third-party partners, we may use your personal information—such as your name, email address, phone number, and mailing address—to send you promotional materials related to our Services. This includes offers from:

  • Other brands within our corporate family;
  • White-label services operated under our brand;
  • Partner businesses and marketing affiliates ("Marketing Partners").

We may also share your data with these Marketing Partners to allow them to send you personalized offers. These promotions could be delivered through various channels, such as email, text messages, phone calls, or physical mail.

You can change your communication preferences at any time by contacting our Customer Support team (where available). If you have downloaded our software, it may include a feature that allows us to send push notifications directly to your device. These notifications may inform you about new updates, features, or promotional content.

By downloading our software, you consent to receiving these notifications. If you wish to stop receiving them, you can easily disable this feature either by following the instructions in the notification or by adjusting the notification settings on your device.

At any time, you have the option to unsubscribe from future marketing communications—whether from us or our affiliates—by reaching out to our Live Chat support. Please note that unsubscribing from marketing emails will not prevent us from sending essential updates related to the services we provide.

Who We Share Your Information With

We do not sell, rent, or trade your Personal Information to third parties (“Recipients”), except in the circumstances specified in this Privacy Policy. Any information shared is done so strictly for the purpose of fulfilling legitimate business needs.

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

  • White Label Partners: Includes operators or service providers managing the White Label platforms.
  • Affiliated Entities: Other companies within our corporate group, related businesses, contractors, and approved third-party service providers such as hosting providers, marketing partners, identity verification services, and fraud prevention companies.
  • Credit Agencies: For credit checks and financial background verification.
  • Payment Processors: Banks and financial institutions responsible for processing deposits and withdrawals.
  • Third-Party Promoters: External vendors that assist in the promotion and operation of our brands, including White Label services, where applicable.
  • Event Organizers: External partners who manage events or tournaments associated with our brands.
  • Travel Providers: Airlines, hotels, or transport companies that are part of promotional events or travel-related prizes.
  • Consultants and Auditors: Professional advisors and reviewers who evaluate our business practices and ensure compliance.
  • Fraud Prevention Authorities: Including financial institutions, law enforcement, regulatory bodies (e.g., FINTRAC), and other authorities involved in investigations.
  • Regulatory Bodies: Licensing authorities and government regulators enforcing legal compliance.
  • Business Acquirers: Potential buyers or investors in the event of a merger, asset sale, bankruptcy, or restructuring of the Group or its brands. The new owner will be bound by this Privacy Policy.
  • Gaming Regulators: Regulatory bodies such as iGaming Ontario and the Alcohol and Gaming Commission of Ontario.

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

  • To securely store your data, for example, using cloud storage services;
  • To support business operations, such as handling deposits, verifying users, auditing systems, and preventing fraud;
  • To conduct diagnostics, analytics, and improvements to our services;
  • To send you promotional content or targeted advertising, in accordance with our marketing practices;
  • To protect our legal rights, enforce our policies (including this Privacy Policy and Terms of Use), and respond to security threats or fraud investigations.

Transfer of Data

As a global operator, we may need to transfer your Personal Information to locations outside of Ontario. These regions may not provide the same level of legal protection as is available under Ontario’s Freedom of Information and Protection of Privacy Act.

However, we take all necessary steps to protect your data, which may include entering into legally approved agreements or ensuring that data is only transferred to countries or regions with sufficient privacy protections in place.

If you believe that your information has been mishandled or if you notice any behavior that violates this Privacy Policy, we encourage you to contact us through Live Chat support.

Third-Party Tracking Tools

When you access or use our Services—including our websites—both we and authorized third parties may utilize various digital technologies such as cookies, location identifiers, beacons, pixels, tags, scripts, and other similar tools (collectively referred to as "Tracking Tools").

These tools allow us to automatically collect data about your online behavior and details about the device you’re using (e.g., smartphone or computer). This information is used for several important purposes, such as:

  • Verifying your presence in Ontario to ensure compliance with local regulations;
  • Enhancing your browsing experience and improving navigation speed;
  • Optimizing Service performance and responsiveness;
  • Personalizing features and content to suit your preferences;
  • Conducting analytics and generating user behavior insights;
  • Assisting advertisers, publishers, and business partners with relevant data.

Additionally, we may allow select third parties to collect data through these Tracking Tools. For further details on how we use cookies and other similar technologies, please consult our Cookie Policy.

Third-Party Services

While using our Services, you may encounter links that direct you to third-party websites, external platforms, or independent applications. Please be aware that our Privacy Policy does not apply to these third-party services, even if you access, download, or use them through our platform.

These third-party sites and services operate independently from our Group. We are not responsible for the content, privacy practices, or legal procedures of these external entities. We strongly recommend reviewing their privacy policies and terms of service before engaging with them, as your interactions will be governed by their own terms, not ours.

You are solely responsible for any decisions regarding these third-party services and assume all associated risks. By engaging with them, you acknowledge that we are not liable for any aspect of your interaction with these services.

Retention of Personal Information

When you create an account with us, we will retain your personal information as long as your account remains active. We may also retain your data beyond the lifespan of your account to comply with our legal and regulatory obligations—such as gambling laws, Know Your Customer (KYC) protocols, Anti-Money Laundering (AML) standards, and our agreements with iGaming Ontario (iGO).

If you would like to have your personal data removed, you may request it by emailing [email protected]. We will make reasonable efforts to accommodate your request, subject to any applicable legal requirements.

Your Data Rights

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

You can contact us via email to request the following:

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

Please be aware that these rights are not absolute. We may be legally required to retain certain data, particularly in relation to gambling and financial regulations. Furthermore, we reserve the right to correct or remove incomplete or inaccurate data according to our internal data management policies.

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

How We Protect Your Information

We are dedicated to protecting your personal information and ensuring the security of our Services. To achieve this, we employ a variety of physical, technical, and procedural security measures designed to prevent unauthorized access, ensure data integrity, and handle your information responsibly. The level of protection we apply depends on the type and sensitivity of the data being processed.

We adhere to widely recognized industry standards to safeguard your data. Our security infrastructure includes:

  • A secure network with firewalls and intrusion detection systems;
  • Encryption of all sensitive communications;
  • Authentication methods and controlled access to systems and data;
  • Regular internal and external security audits.

While we take every reasonable precaution to secure your data, no system can guarantee 100% security. We cannot be held responsible for unauthorized access caused by malicious activities, and we do not guarantee that such breaches can be entirely prevented.

Security, Breach Management & Cooperation

Cadtree places the highest priority on protecting your personal data. Our security framework incorporates multiple layers of defense—technical, organizational, and procedural—to prevent misuse, unauthorized access, modification, or loss of data. These measures are regularly updated to reflect industry best practices and are scaled according to the sensitivity and risk level of the information.

Despite our efforts to safeguard your data, it is important to acknowledge that no online transmission is fully secure. Sharing personal information online carries inherent risks. While we cannot guarantee absolute immunity from security breaches, we are prepared to act swiftly in the event of an incident.

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

Incident Response Procedure

Cadtree has established a structured “Incident Response Procedure” to ensure a consistent and effective approach to handling security incidents. This procedure is divided into three key stages:

1. Detection and Evaluation

When a cybersecurity event occurs, we immediately collaborate with critical partners, internal teams, and oversight functions to assess the severity and potential impact of the incident. We intensify monitoring of our systems, investigate the extent of any compromise, and work with our teams to initiate response and recovery actions.

2. Containment, Resolution, and Restoration

Our teams, along with key suppliers and stakeholders, conduct forensic investigations to verify the integrity of essential systems and user data. If any data has been exposed, it is isolated, cleaned, and restored. We carefully review player account balances and investigate any failed transactions. Relevant reports are submitted to regulatory authorities. After verification, user balances are adjusted or refunded, and systems are validated before being restored to full operation.

3. Notification and Communication

Affected players will be informed via email or direct messages on our platform about the incident. This will include details about which personal data may have been exposed and recommended actions, such as updating passwords. We will also notify iGaming Ontario (iGO), the Office of the Privacy Commissioner of Canada, and other relevant authorities. Cadtree fully cooperates with these organizations to manage the breach and reduce further risks.

Changes to This Privacy Policy

We may update this Privacy Policy periodically, so we encourage you to review this page regularly. If significant updates are made, we will notify you by posting an update on our Services or sending an email to the address you provided. Major updates will take effect seven (7) days after the notice is issued. For minor changes, the policy will become effective as of the "Last Updated" date displayed. Continued use of our Services after that date indicates your acceptance of the revised policy.

Contact Us

If you have any questions regarding this Privacy Policy, the information we collect, or how it is used, please contact us via the live chat feature on our Contact Us page.

We strive to respond promptly. If you are not satisfied with our response, you may reach out to the appropriate data protection authority for further assistance.

Cadtree Cookie Policy

Last Updated: 2025/06/01

Overview

When you access our Services—whether through our websites, apps, or by engaging with our content—both we and authorized third parties use cookies and other tracking tools such as web beacons, pixel tags, scripts, APIs, and similar technologies (collectively referred to as "Tracking Tools").

These tools help us collect data about your online activities and the device you’re using (such as a smartphone or computer). This data is used to enhance your experience, personalize features, and optimize the performance of our Services. We also use it for analytics, tailored content, advertising, and tracking user engagement.

Additionally, we allow third parties to collect data through these Tracking Tools as part of our platform’s ecosystem.

What Are Cookies?

Cookies are small text files made up of letters and numbers that are stored on your device when you visit a website. These files store preferences (like language settings) and improve user experience by making navigation easier and more personalized. For more information, visit www.allaboutcookies.org.

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

Types of Tracking Tools We Use

The Tracking Tools used on our Services fall into two main categories:

  • First-Party Tools: These are set directly by us when you interact with our Services.
  • Third-Party Tools: These are set by external partners, such as advertisers or analytics providers.

These tools may either be temporary (used only during your session) or persistent (used across multiple sessions).

Categories of Tracking Tools We Use

  • Essential Tools:

    These are necessary for securely accessing and navigating the platform. They help with login, session management, and enabling core platform functions. These do not require your consent.

  • Functional Tools:

    These remember your preferences (such as language or region) and enhance your experience. For example, they help keep you logged in or enable accessibility features.

  • Performance Tools:

    These collect behavioral data, such as time spent on pages or clicks, which is aggregated for analytics, service improvement, and performance optimization.

  • Marketing & Advertising Tools:

    These are used to deliver personalized ads and marketing content based on your interactions. They help minimize repeated ads and measure campaign effectiveness. These tools are generally managed by advertising partners. Features such as Facebook's "Like" and "Share" buttons also fall into this category and are subject to the policies of their respective third-party providers.

Examples of Tracking Tools Used

Technology Type Purpose
Analytics Cookies First-Party Tracks user interactions, behavior, referral sources, and helps with performance reporting and service enhancement.
Other Cookies First & Third-Party Supports basic platform functionality, such as storing login credentials and remembering user settings.

Managing Your Cookie Preferences

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

Browser Settings

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

Here are links for common browsers:

Managing Third-Party Cookies

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

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