Videoslots Privacy Policy

1. OVERVIEW

http://videoslots.ca/ (hereinafter the “Website”), is operated by Videoslots Ltd (hereinafter “Videoslots”), a private limited liability company constituted under the laws of Malta and has its registered office at The Space, Level 2 & 3, Alfred Craig Street, Pieta PTA 1320, Malta; or in accordance with the relevant license(s) and jurisdictions where it is licensed to operate.

Any reference to “We”, “Our”, “Us” or the “Company” in this Privacy Policy shall be construed as reference to Videoslots’ operations of Videoslots and/or the Website (hereinafter the “Services”). Any reference to “You” or “Your” in this Privacy Policy shall be construed as reference to Our players and customers.

The Company values Your integrity and privacy immensely and is committed to handle all of Your personal information transparently, fairly and lawfully.

This Privacy Policy (together with Our terms and conditions and Our cookie policy) sets the standard for how the Company collects, uses, discloses and retains Your personal information when You visit Our Website, as well as what Your rights are, how the law protects these rights, and how You can exercise them (hereinafter the “Privacy Policy”).

1. Overview
2. About Us
3. Your Personal Information
4. Sharing of Personal Information
5. Shared Responsibility for Personal Information
6. Transfer of Personal Information
7. Profiling & Automated Decision Making
8. Personal Information Security Measures
9. Personal Information Retention
10. Your Rights
11. Changes to the Privacy Policy
12. Governing Law

2. ABOUT US

(a) The Purpose of the Privacy Policy

This Privacy Policy aims to provide you with a thorough understanding of how We use, disclose and retain your personal information collected through your use of this Website and also includes all personal information you may have provided in connection with your registration and through your use of Our online casino.

The Services are being offered by Videoslots as part of the open and regulated iGaming market conducted and managed by the Alcohol and Gaming Commission of Ontario (AGCO) and iGaming Ontario (https://www.igamingontario.ca/en). In the course of providing the Services;

• Videoslots collects, uses, and discloses Personal Information on behalf of, and as agent to, iGaming Ontario (iGO), as part of the open and regulated internet gaming (iGaming) market in Ontario, conducted and managed by iGO. By using the Services, You hereby agree to be bound by the terms of this Privacy Policy, and You provide Your consent for the collection and processing of Personal Information (as defined below) by Us.Videoslots collects personal information in accordance with the Freedom of Information and Protection of Privacy Act (FIPPA) and The Protection of Privacy and Electronic Documents Act (PIPEDA), and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario (AGCO) Act, and the operating agreement entered into between Videoslots and iGaming Ontario;
• Videoslots also collects, uses, discloses, and retains, Your personal information in line with the AGCO’s Registrar Standards for Internet Gaming.

This Website is intended solely for persons over 19 years of age and We do not knowingly collect personal information related to persons under this age. If it becomes clear to us that We have collected personal information related to persons under the age of 19, for reasons related to the misuse of Our Website, We will do our utmost to ensure that such personal information is handled in accordance with applicable law and our policies and procedures.

This Privacy Policy must be read in conjunction with any other confidentiality information We may have given you from time to time. This Privacy Policy is complementary to other such information and is not intended as a substitute for it.

We aim to protect your personal information, and always respect your privacy, in accordance with the highest standards in the industry and applicable laws and legislations.

You are responsible for providing personal information that is correct and informing Us in writing of any changes that may occur, so that We can use all reasonable means to maintain Our information regarding you correct and up to date. In addition, We can implement accuracy checks in accordance with the applicable laws and regulations and ask you to verify your personal information We hold on you from time to time.

(b) Information, Queries & Complaints

We take Your privacy seriously and have appointed a Privacy Officer (“PO”) to oversee the Company’s handling of personal information. The PO ensures that Videoslots collects, uses, discloses, and retains Your personal information in compliance with PIPEDA and other applicable laws.

You are responsible for providing personal information that is correct and informing Us in writing of any changes that may occur, so that We can maintain accurate and up-to-date records. We may implement accuracy checks and, when necessary, ask You to verify the personal information We hold about You.

The PO is Your main contact for any questions, concerns, or complaints regarding this Privacy Policy or Your personal information. You can reach the PO using the following contact details:

3. YOUR PERSONAL INFORMATION

(a) Defining ‘Personal Information’ for you as an ‘Individual’

Applicable privacy laws define personal information as follows:

Our Services collect “personal information,” which means recorded information about an identifiable individual other than contact information i.e. information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including any information that constitutes “personal information” under applicable privacy laws.

As a customer of the Company, You are an "individual" in relation to this Privacy Policy. In short, all personal information relating to You as a person or individual is protected under any applicable privacy laws and legislation. However, it does not include information from which identifiers have been removed in such a way that the personal information is rendered anonymous, meaning when You are not or no longer identifiable (i.e. anonymous personal information) or information which relates to an individual’s business or place of work.

In carrying out Our Services, We might make use of certain “Know Your Client” (KYC) technology which allows the Company to be able to verify the identity of the players in its customer base, falling in line with its regulatory obligations as a licensed operator in Ontario.

(b) The important things - what, how and why?

We may collect, use, store and transfer various kinds of personal information.

The table below provides a clear breakdown of:

• What kind of personal information We collect.
• How do We collect personal information.
• For which purpose do We collect personal information.
• What is our legal basis for collecting, using, disclosing and retaining personal information.

Player Responsibility: You are responsible for protecting Your account credentials, devices, and personal information. This includes:

• Keeping passwords confidential and secure
• Not sharing login information
• Protecting devices against malware and unauthorized access
• Reporting suspected unauthorized activity immediately

Legal obligations – It might be necessary to collect, use, disclose and retain certain personal information in order to comply with the applicable laws, regulations and legislation.

Appropriate purposes under PIPEDA – We collect, use, disclose, and retain your personal information only for purposes that a reasonable person would consider appropriate under the circumstances, with the ultimate goal of providing you with the best possible service and experience. Before using your personal information, We carefully assess the potential impact on your privacy and your rights. We do not use your personal information in ways that would override your interests or reasonable expectations, and We obtain your consent except where permitted or required by law.

Execution of the contract – Collecting, using, disclosing and retaining of personal information is necessary to fulfil the contractual obligations We enter into with you and of which you are a part (i.e. terms and conditions).

Consent – The legal basis for collecting, using, disclosing and retaining your personal information is your consent. We will handle your personal information only as long as We have your consent to do so. If you decide to withdraw your consent, We will stop these activities .Please note that any collection, use, disclosure and retention of personal information that We have already carried out with your consent before you withdrew it will not be affected.

Certain personal information We handle about You is classified as aggregate information, meaning information which cannot lead to Your identification as a natural person, yet may be used by us as a Company to better our services and product offering to You as an end-user and consumer. These types of aggregate information, how they’re collected and the reasons for which We use them are detailed in the table below.

Aggregate Information – Some of the information We collect, and process is classified as aggregated information. This means it has been combined or processed in a way that it cannot be used to identify you as an individual. We may use aggregated information to improve our services and product offerings for you as an end-user and consumer. Details about the types of aggregated information We collect, how We collect it, and why we use it are provided in the table below.

Here is a more detailed breakdown of which personal information We collect, how , when and why We do so, and the legal basis We rely on:

• Our own marketing activities -In accordance with the applicable laws and on the basis of purposes that a reasonable person would consider appropriate under the circumstances t or Your explicit consent, We may also use your personal information to send you marketing material and notifications by email or text messages.
  We aim to offer you the highest level of control over the marketing material that you receive from us or from authorised third-party acting on our behalf. These third parties may collect, use, or disclose your personal information strictly in accordance with our instructions and only for purposes permitted by applicable law.
  
  You may access and modify your marketing preferences in the Privacy section of your account. If you wish to have more control over the marketing material that We send you, We kindly request that you contact our Privacy Officer using the provided contact information. In the event that you choose to withdraw your consent, please be aware that it may take up to 48 hours for us to ensure that the changes have been implemented in our system and in the systems of our marketing partners. During this time, you may still receive emails or information from us.
• Consent Withdrawal - You can withdraw your consent at any time via the Privacy section located on "Your Account" on the Website. In addition, you can withdraw your consent from marketing through the ‘opt-out’ unsubscribe button provided in the email you receive from us.
• Marketing activities of our business partners – We never share your personal information with our business partners for their own marketing activities without your consent.
• AML and Social Responsibility – The Company is committed to providing you with the safest gaming environment We can create in any way. For that reason, We may collect, use, disclose and retain certain personal information that relates to you beyond the minimum legal requirements, as necessary to protect your account and ensure safe gaming to a level that exceeds the legal requirements slightly but is done for your safety and peace of mind. We do so in compliance with PIPEDA and for purposes that a reasonable person consider appropriate. as We feel responsible for your online security. Our checks are designed to be minimally invasive and respect your rights and freedoms as a patron.

Your personal information will only be used, disclosed, and retained for the purposes for which it was originally collected. In the event that We need to collect,use, disclose, or retain it for any other purpose, We will assess whether the new purpose is reasonable and appropriate under PIPEDA and consistent with the original purpose for which the personal information was collected.We will then inform you of the new purpose and provide you with all necessary information. Should the new purpose not be compatible with the original purpose, We will ask for your consent.

Operator Advisory to Player: Videoslots implements strong safeguards, but You must also act to protect Your personal information. Always verify communications from Videoslots, use strong passwords, and enable two-factor authentication where available.

4. SHARING OF PERSONAL INFORMATION

As part of our operations, We may collaborate with various business partners, suppliers, and service providers who play a key role in the functioning of our Website, Games, and other services. These third parties may collect, use, disclose and retain your personal information on our behalf for the purposes outlined in this privacy policy.

All such activities are conducted under our direction, ensuring that your personal information is handled in accordance with applicable laws and our commitment to safeguarding your privacy. We are committed to ensuring the security of your personal information. Therefore, We requires all third parties with whom We share your personal information to uphold the same standards of security and to comply with applicable laws.

Our third-party service providers are prohibited from using your personal information for their own purposes unless legally permitted or required. They may only collect, use, disclose, and retain your personal information for specific purposes that align with our instructions. To ensure compliance and security, We conduct thorough vetting of our partners and enter into, contractual arrangements as necessary. This ensures that your information handled appropriately and safeguarded throughout its lifecycle.

• Game Providers - At times, Our game providers will need access to selected data, included personal information (such as username and IP address) in order to provide us with the games you play on Our Website.
• Sportsbook Providers & Sports Governing Bodies - We may share your personal information with our sportsbook provider to facilitate the delivery of sportsbook services and for risk management purposes.
• Payment Providers and Related Service Providers - Similarly, We may share some of your personal information with the payment provider you use to make deposits and withdrawals on Our Website.
• Marketing Partners - When you consent to us sending you marketing and promotions, We may share your contact information (such as email address or postal address) with our marketing partners who are responsible for sending Our marketing material to you. By agreeing (‘Opt in’) to receive marketing and promotional material from us, you acknowledge that your contact information, such as your email, phone number or postal address, will be shared with our marketing partners who will be responsible for sending the material to you.
• Client communication software - Third-party software is used to facilitate communication with you. This software enables us to send emails and engage with you via live chat should you have any queries. We use 3rd party software to help us communicate with you. This software allows us to send emails to you and talk to you on Our live chat whenever you have any questions.
• AML and anti-fraud tools - We use third party software to perform certain AML and fraud verification checks, which in this case are necessary to comply with Our legal obligation.
• Professional advisers e.g. lawyers, auditors and other third parties as necessary.
• Government or Regulatory Authorities - We may, if necessary or authorized by law, provide your personal information to law enforcement agencies, government or regulatory organizations, courts or other public authorities. We strive to keep our customers informed about legal requirements regarding their personal information, unless prevented by legislation, courts, or emergency situations. While We reserve the right to contest requests that We believe are disproportionate, unclear, or lack proper authority, We cannot guarantee that We will challenge every request.
• Cloud Service Providers - We may engage cloud service providers to offer cloud-based solutions, including but not limited to storage and hosting of certain software and data, included personal information.

Intra-Group Sharing

To effectively manage and enhance our services, companies within our corporate group may share and access customer personal information as needed to support the Controller in specific functions. This intra-group sharing enables us to provide consistent and high-quality service across all brands and operations, allowing us to offer certain services, support essential functions, and ensure alignment in key areas of our business.

Centralized Self-Exclusion (BetGuard)

iGaming Ontario offers a voluntary centralized self-exclusion tool (“BetGuard”) whereby individuals may register to centrally self-exclude from all regulated igaming sites in Ontario . BetGuard is offered subject to the BetGuard privacy policy.

In connection with BetGuard, iGaming Ontario, Videoslots, and their respective authorized suppliers on behalf of iGaming Ontario, may collect, use, share, disclose, retain, or otherwise process your Personal Information to develop, operate, maintain, sustain, update and modify BetGuard. This information may be used to verify your identity and centralized self-exclusion status, enable your centralized self‑exclusion from regulated igaming sites, or for any other lawful purpose under the BetGuard privacy policy and the BetGuard terms and conditions. Personal Information will be retained only for the period allowed by the BetGuard privacy policy and Applicable Law.

For further information please review the applicable BetGuard privacy policy.

5. SHARED RESPONSIBILITY FOR PERSONAL INFORMATION

The Company may share responsibility for personal information with one or more organizations when they jointly collect, use, store or disclose personal information for a common purpose. In such cases, each organization is responsible for ensuring compliance with applicable privacy legislation, and the roles and responsibilities of each party will be clearly defined. You will be informed of these arrangements where relevant.

6. TRANSFER OF PERSONAL INFORMATION

Service providers mentioned in section 3 above may be located in countries outside of Ontario, and this may involve sharing your personal information outside Canada. When transferring personal information to countries outside Canada, We ensure that it is protected in accordance with the same high standards as it is in Ontario.

To ensure your personal information's protection during these transfers, We may implement one or more of the following safeguards

(I) Adequate Level of Protection - We will only transfer your personal information to countries that are deemed to provide an adequate level of protection or where legal frameworks exist that are considered to offer similar protections to those in Canada.

(II) Standard Contractual Clauses - In cases where the organization is not located in Canada, We may use Standard Contractual Clauses (SCCs) or similar contractual safeguards to ensure that your personal information is protected to the same standards as it would be in Canada.

7. PROFILING & AUTOMATED DECISION-MAKING

In certain circumstances, We use automated systems to make decisions based on personal information. This allows us to streamline our decision-making processes, ensuring that decisions are timely, impartial, efficient, and consistent. As a result, automated decision-making may influence the products, services, or features We offer to you, both now and in the future, as well as your ability to use our services.

We may employ automated decision-making in the following situations:

• Opening an Account: When you open an account with us, We use automated processes to determine whether the product or service is suitable for you, based on the information provided. We also verify that you meet the necessary conditions to open an account, including age, residency, nationality, and financial standing, in accordance with our Customer Acceptance Policy.
• Fraud Detection: We use your personal information to assess whether there are any indications of fraud or money laundering related to your account. If We detect potentially fraudulent activity, We may block or suspend your account to protect your interests and comply with regulatory requirements.
• Betting Risk Assessment: Our automated system evaluates the risk level of your betting activities according to our Betting Rules. This system, used widely across the industry, helps us make fair and informed decisions regarding betting, taking into account the information you provide during registration and throughout the use of our services.
• Anti-Money Laundering (AML) & Responsible Gambling (RG) Risk Assessment: We utilize an automated profiling system to assess various risk factors associated with your account. These factors are scored and averaged to create a risk profile, which helps us evaluate your compliance with AML and RG policies and guidelines.

Based on this information, We make an impartial and informed decision about whether your account falls within our risk appetite and whether We will continue our business relationship with you, in accordance with our internal policies and legal obligations.

You have the right not to be subject to decisions based solely on automated means, including profiling, when such decisions have a legal effect or a similarly significant impact on you.

However, this right does not apply in cases where:

• The automated decision-making is necessary for the performance of a contract with you.
• It is authorized by law; or
• It is based on your explicit consent.

If you have any questions or concerns about how We use automated decision-making or profiling, please contact our Privacy Officer in writing.

8. PERSONAL INFORMATION SECURITY MEASURES

We are committed to ensuring the security and protection of your personal information, both within our organization and with any third parties to whom We may disclose it.

Internally, We have implemented a range of technical, contractual, and organizational measures to safeguard your personal information from accidental loss, unauthorized use, access, alteration, or disclosure. These measures form part of our defence-in-depth strategy, which includes continuous investment in technology, processes, and resources that align with industry-leading practices.

To ensure effective protection, We apply strict access controls on a "need-to-know" basis. This means that only authorized personnel with a direct, legitimate need to access your personal information are granted access. Additionally, all individuals with access to your personal information are bound by strict confidentiality agreements.

We have established robust procedures to identify and address any suspected or actual security breaches involving personal information. If such an event occurs, We will notify you, the Patron, as well as the relevant regulatory authorities in a timely manner, in compliance with the legal requirements. Specifically, We will inform iGaming Ontario and other relevant authorities if applicable and will assist in reporting and resolving the breach, all in accordance with PIPEDA requirements.

While We take every reasonable step to protect your personal information, it is also crucial for you to remain vigilant and follow basic information security best practices:

• Do not share your account credentials, personal information, or any confidential personal information with anyone.
• Never allow unauthorized persons to control your computer or device.
• Verify the legitimacy of mobile calls, emails, or SMS messages before taking any action. Always verify through trusted sources before responding to requests for personal or account information.

9. PERSONAL INFORMATION RETENTION

The Company will retain your personal information only for as long as necessary to fulfil the purpose for which it was collected, and in accordance with our retention policies. This may include fulfilling legal, accounting, or reporting requirements. Once the purpose for which your personal information was collected and used is no longer applicable, and unless We have another legal obligation to retain it, We will ensure that your personal information is securely and permanently disposed of.

When determining the appropriate retention period for your personal information, We consider factors such as the nature and sensitivity of the information the potential risk of unauthorized use or disclosure, the purpose for which the information was collected ,and used as well as any applicable legal or regulatory requirements.

If you have questions about our personal information retention practices or the specific retention period for your personal information, please contact our Privacy Officer (PO) using the contact details provided in this Privacy Policy

10. YOUR RIGHTS

Applicable legislation gives You, as an Individual, certain rights regarding your personal information. You have the right to:

Request Access to Your Personal Information - You have the right to request a copy of the personal information We hold about You against a minimal fee. To request such access, please exercise Your right by filing a Freedom of Information Request with iGaming Ontario here: https://www.igamingontario.ca/en/freedom-information-requests.

Request for Correction of Your Personal Information -If the personal information We hold about you is incomplete or inaccurate, you have the right to request that We correct it. To facilitate this, We may ask for proof or documentation (e.g., ID, address verification) to process your request. If We do not agree with your requested correction, we will annotate your disagreement as required under PIPEDA, ensuring your objection is recorded and considered.”

Request to have Your personal Information deleted - You can request to have Your personal information deleted if We no longer have a legal reason to continue to collect, use, disclose or retain . Please note that this right is not guaranteed - in the sense that We do not have the ability to comply with Your request if We are subject to a legal obligation to store Your personal information or if We have the reason that it is necessary to store Your personal information, in order to defend ourselves in a legal dispute.

Object to the collection, use, disclose, or retain of your personal information -  You may object to the collection, use, disclosure, or retention of your personal information if you believe that it is not being handled in accordance with FIPPA or for purposes other than those for which it was collected. In some cases, We may be required to continue managing the information if it is necessary to fulfill our legal or operational obligations. You may submit your objections by contacting our Privacy Officer at the following email address: dpo@videoslots.com

Withdraw Your Consent and Right to Restrict Use, Disclosure, or Retention of Personal Information- Termination or withdrawal of your consent will not affect the legality of the collection, use, disclose, or retention of your personal information We have performed until the time you withdrew your consent. Withdrawal of your consent means that in the future you no longer want to have your personal information treated in the same way. This means that you can no longer give us permission to provide certain services (e.g. Marketing). Should you wish to withdraw your consent at any time, you may do so via the Privacy section located on "Your Account" on the Website. Furthermore, you can withdraw your consent from marketing by clicking the 'opt-out' unsubscribe button provided in the email you receive from us.

Right to Request Restriction of Use or Disclosure- You may request that We temporarily restrict the use, disclose, of your personal information in the following circumstances:

• While We verifies the accuracy of your personal information.
• If the use or disclosure, is unlawful but you do not want the information deleted.
• If you require us to store the personal information for the purpose of establishing, exercising, or defending legal claims.
• If you have objected to the use or disclosure of your personal information, but We need to verify whether our legitimate grounds override your objection.

Request Transfer of Your Personal Information (i.e. personal information portability) - This means that you may request us to transfer certain personal information about you to a third party. This right only applies to personal information that We have collected through automated sources that you originally gave Us consent to use, or where We used your information, to perform Our obligations under a contract with you.

Right to Lodge a Complaint with the Privacy Commissioner - You have the right to lodge a complaint with the Privacy Commissioner of Canada if you believe your privacy rights under applicable laws and legislations have been violated. We would really appreciate the opportunity to resolve your issues before contacting the respective authority, so please contact us in the first instance.

In the event you exhaust our complaints process without what you believe to be a satisfactory resolution, you may request a copy of your case file, which We shall provide, in order to escalate the complaint to iGO. We will aid iGO in the investigation and handling of your complaint.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You can exercise your rights through the following channels:

• Our Customer Support live chat
• By sending us the request via email on: on.support@videoslots.com
• By contacting our PO: dpo@videoslots.com

11. CHANGES TO THE PRIVACY POLICY

We reserve the right, at our complete discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. If you are an existing client with whom We have a contractual relationship, you will be informed of any changes made to this Privacy Policy.

12. GOVERNING LAW

This Privacy Policy is governed by the laws of Ontario, Canada, and any disputes will be resolved by the courts of Ontario and the applicable federal laws of Canada.