Privacy Policy

This Privacy Policy explains how Players Palace Casino, operated via the website playerspalace-ca.com, collects, uses, discloses, and protects personal information of players and website visitors in Canada. It applies to all users who access or use our website, register an account, participate in games, promotions, or communications, or otherwise interact with our services. By using our services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective as of 1 January 2026 and replaces any prior versions for Canadian users.

Who We Are

OBSERVE: The service is provided to Canadian players under a multi-operator structure, with different entities responsible depending on player location within Canada.

EXPAND: To ensure legal clarity and regulatory compliance, we identify the relevant controller/operator for each Canadian segment and provide contact details for privacy inquiries and data protection oversight.

REFLECT: The following entities are responsible for operating Players Palace Casino and for the processing of your personal information:

Operators and Legal Responsibility

• Rest of Canada (outside Ontario):
  Operator: Fresh Horizons Ltd.
  Role: Operator of Players Palace Casino for players located in Canada outside Ontario, under Kahnawake Gaming Commission Client Provider Authorization no. 0119, jurisdiction Kahnawake, Canada, valid until 30 November 2029.
  Registered / Legal Address: Not specified in this policy. Up-to-date registered office details may be obtained upon request using the contact information below.
• Ontario:
  Operator: Apollo Entertainment Limited
  Role: Internet gaming operator licensed by the Alcohol and Gaming Commission of Ontario (AGCO) with an operating agreement under iGaming Ontario (iGO), license number OPIG1237904, for Ontario players accessing Players Palace Casino.
  Additional Licences: Apollo Entertainment Limited also holds licences from the Malta Gaming Authority (MGA/B2C/164/2008) and the UK Gambling Commission (license no. 38620) for non-Canadian markets.

For the purposes of Canadian privacy laws (including applicable provincial privacy statutes and, where applicable, the Personal Information Protection and Electronic Documents Act "PIPEDA"), Fresh Horizons Ltd. and Apollo Entertainment Limited act as data controllers (or "organizations" responsible for personal information) for the personal information of players in their respective Canadian segments.

Data Protection Contact

• Data Protection / Privacy Contact: Data Protection Officer (DPO), Players Palace Casino (Canada)
• Email (primary for privacy): [email protected]
• Email (support-related privacy questions): [email protected]
• Website: https://playerspalace-ca.com
• Postal Address: A current postal address for privacy correspondence will be provided upon request via email and may differ depending on whether you are an Ontario or Rest-of-Canada player.

You may contact our DPO or privacy contact for any questions regarding this Privacy Policy or our data practices.

What Personal Data We Collect

OBSERVE: To provide regulated online gambling services, Players Palace Casino must collect a range of personal and technical data.

EXPAND: These data categories are necessary for account creation, age and identity verification, payment processing, fraud prevention, responsible gambling controls, and compliance with KYC/AML and gaming regulations.

REFLECT: We categorize the personal information we collect as follows:

Identification and Contact Data

• Account and profile data: Full name, date of birth, gender (if provided), username, password, security questions/answers.
• Contact details: Email address, telephone number, residential address, province/territory, country of residence.
• Verification data: Copies or details of government-issued ID (e.g., driver's licence, passport), proof of address (e.g., utility bill, bank statement), and any additional documentation requested by us or regulators for KYC/AML or eligibility checks.

Technical and Usage Data

• Technical identifiers: IP address, device identifiers, browser type and version, operating system, language settings, screen resolution.
• Usage logs: Login dates and times, session duration, pages visited, referral URLs, clicks, navigation paths, error logs, and system activity within the platform.
• Location data: Approximate geolocation derived from IP address or permitted device data, used primarily to determine jurisdiction (e.g., whether you are located in Ontario or the rest of Canada) and to comply with location-based regulatory requirements.

Payment and Financial Data

• Transaction data: Deposits, wagers, wins, losses, withdrawals, bonus credits, loyalty points, chargebacks, and transaction timestamps.
• Payment method data: Limited payment instrument details such as payment card type and masked card number or e-wallet/online banking identifiers, as provided by payment processors; we do not store full card details where our payment partners process them on our behalf.
• Verification data: Information used to comply with anti-money laundering (AML) obligations, including source-of-funds or source-of-wealth documentation where required.

Behavioral and Profile Data

• Game activity: Betting history, game preferences, frequency and duration of play, stakes, patterns of wins and losses.
• Interaction data: Records of interactions with customer support (emails, chats, call notes), participation in promotions, offers accepted, and responses to surveys.
• Responsible gambling indicators: Voluntary limits, self-exclusion status, cooling-off periods, and behavioral markers used to identify potential gambling-related harm.

Cookies and Similar Technologies

• Cookies: Small text files stored on your device to remember your preferences, maintain sessions, and understand how you use our site.
• Tracking technologies: Web beacons, pixel tags, local storage, and similar technologies used for analytics, security, and (where permitted) marketing purposes.
• Third-party tags: Analytics and advertising tags (e.g., from network partners) that may collect anonymized or pseudonymized information about your interactions with our site.

Where permitted or required by law, some information may be collected automatically when you use our services, and certain data may be obtained from third parties such as identity verification providers, payment processors, or regulatory authorities.

Legal Basis for Processing

OBSERVE: Under Canadian privacy laws and, where applicable, international standards (such as the EU GDPR where relevant for our operators), we must have a valid legal basis for processing your personal information.

EXPAND: Our operations combine contractual necessity, legal obligations under gaming and financial regulations, legitimate interests for security and service improvement, and your consent for certain activities such as specific marketing or optional cookies.

REFLECT: We rely on the following legal grounds to process personal information:

Performance of a Contract

• To create and manage your player account on playerspalace-ca.com.
• To provide gaming services, process bets, calculate results, and pay out winnings.
• To manage promotions, loyalty programs, and bonuses associated with your account.
• To provide customer support and manage your relationship with us.

Compliance with Legal and Regulatory Obligations

• To comply with applicable gaming legislation and regulations in Canada, including requirements imposed by:
  • Kahnawake Gaming Commission;
  • Alcohol and Gaming Commission of Ontario (AGCO) and iGaming Ontario (iGO);
  • Other relevant governmental and regulatory bodies.
• To fulfill know-your-customer (KYC) and anti-money laundering (AML) obligations, including identity verification and monitoring of suspicious activities.
• To comply with record-keeping requirements, tax rules, accounting standards, and audit obligations.
• To respond to lawful requests from law enforcement, courts, and regulatory authorities.

Legitimate Interests

• Security and integrity: Protecting our systems and players against fraud, abuse, unauthorized access, and other security risks.
• Service improvement: Analyzing how users interact with our services to enhance user experience, improve game offerings, and optimize our platform.
• Business operations: Managing our business (e.g., performance analysis, reporting, internal audits, and governance) in a manner that does not override your privacy rights.
• Responsible gambling: Identifying and responding to patterns that may indicate problematic gambling behavior, and implementing appropriate interventions.

Consent

• For certain types of marketing communications (e.g., email, SMS, push notifications) where required by law.
• For the use of non-essential cookies and similar technologies for advertising or detailed behavioral analytics, where applicable.
• For specific optional features or processing activities that are not strictly necessary for the provision of our services.

Where we rely on consent, you can withdraw it at any time using the mechanisms described in this Policy, without affecting the lawfulness of processing carried out before withdrawal.

Purpose of Processing

OBSERVE: Personal information is processed to operate an online casino in a regulated environment.

EXPAND: These purposes range from providing core gaming services to ensuring compliance, security, responsible gambling, and tailored user experiences.

REFLECT: We process your personal information for the following purposes:

Provision and Management of Services

• Registering and verifying your player account, including age and identity verification.
• Providing access to casino games, processing wagers, determining outcomes, and paying out winnings.
• Managing deposits, withdrawals, bonuses, loyalty rewards, and account balances.
• Providing customer support and responding to your inquiries, requests, or complaints.

Compliance and Risk Management

• Conducting KYC and AML checks and maintaining required records.
• Monitoring transactions and game activity for fraud, money laundering, match-fixing, and other prohibited activities.
• Complying with regulatory reporting obligations to gaming authorities, financial intelligence units, and other competent authorities.

Service Improvement and Analytics

• Analyzing aggregated and pseudonymized data to understand performance, user behavior, and game popularity.
• Improving platform stability, user interface, game selection, and technical performance.
• Conducting surveys, tests, and statistical analyses to enhance our services.

Marketing and Personalization

• Sending promotional communications, offers, and newsletters, where permitted by law and consistent with your marketing preferences.
• Customizing content, bonuses, and recommendations based on your profile and game activity, in accordance with applicable regulations.
• Measuring the effectiveness of marketing campaigns and promotions.

Fraud Prevention, Security, and Responsible Gambling

• Preventing unauthorized access, abuse of bonuses, and fraudulent activities.
• Maintaining logs and implementing measures for cybersecurity and system integrity.
• Monitoring gameplay and other indicators to detect problematic gambling behavior and implementing proactive measures such as alerts, limits, or account restrictions.

Disclosure & Sharing

OBSERVE: To operate a multi-jurisdictional online casino, personal information must be shared with carefully selected third parties.

EXPAND: These include payment processors, technical providers, regulatory bodies, group companies, and marketing partners. Sharing must be limited to what is necessary and governed by appropriate safeguards.

REFLECT: We may disclose your personal information under the following circumstances:

Group Companies and Operators

• With Fresh Horizons Ltd. and Apollo Entertainment Limited, and other entities within the Casino Rewards network, to manage your account, offer network-wide services, perform internal reporting, and ensure consistent service quality, in compliance with applicable laws and licences.

Payment Service Providers and Financial Institutions

• To banks, payment processors, e-wallet providers, prepaid card issuers, and similar entities to process deposits, withdrawals, and refunds.
• To support fraud detection, chargeback management, and AML compliance in collaboration with these partners.

Service Providers and Technical Partners

• To IT hosting providers, platform and software vendors, game providers, CRM and customer support tools, analytics providers, and email/SMS gateways that process data strictly on our behalf and under written agreements.
• To security and anti-fraud solution providers who help us monitor and secure our systems.

Regulators, Authorities, and Dispute Resolution Bodies

• To gaming regulators and authorities, including:
  • Kahnawake Gaming Commission;
  • AGCO and iGaming Ontario;
  • Other competent regulatory or governmental bodies where required.
• To alternative dispute resolution services or certification bodies, such as eCOGRA (https://ecogra.org), where needed to handle complaints, audits, or fairness certifications.
• To law enforcement, courts, or other public authorities where required by law, court order, or to protect our rights, property, or safety, or that of our players or third parties.

Affiliates and Marketing Partners

• To marketing affiliates, advertising networks, and campaign management partners, primarily in aggregated or pseudonymized form, for the purpose of measuring campaign performance and attribution.
• To selected partners for direct marketing only where you have provided the necessary consent or where otherwise permitted by law, and always subject to your rights to opt-out.

Business Transfers

• In the context of a merger, acquisition, reorganization, sale of assets, or similar corporate transaction, personal information may be shared with prospective or actual purchasers or successors, subject to appropriate confidentiality and data protection safeguards.

We do not sell personal information in the sense of transferring it for monetary consideration as a standalone asset. Any sharing is limited to what is necessary for the purposes set out in this Privacy Policy and is subject to contractual, technical, and organizational safeguards.

International Transfers

OBSERVE: Our operations, licensors, and service providers are located in multiple jurisdictions.

EXPAND: This may involve transferring personal information from Canada to other countries, including Malta, the United Kingdom, and other locations where our group companies or providers are established.

REFLECT: We take steps to ensure that international transfers are carried out in compliance with applicable Canadian and international data protection requirements.

Locations of Processing

• Canada: Primary hosting and operational activities related to Canadian players, including Kahnawake and Ontario-specific processing.
• Malta (MT): Processing by Apollo Entertainment Limited and certain service providers under MGA regulation.
• United Kingdom (GB): Processing related to systems and controls overseen by the UK Gambling Commission and certain technical partners.
• Other countries: Cloud hosting, support, and technical services may operate from other jurisdictions, always under contractual data protection obligations.

Safeguards for International Transfers

• We use contractual measures, including standard contractual clauses or equivalent agreements, where appropriate, to ensure an adequate level of protection for personal information transferred outside Canada.
• We limit access to personal information to those who have a legitimate business need and only for the purposes described in this Policy.
• We evaluate the privacy and security practices of our third-party service providers to ensure that your personal information is protected consistently with this Policy.

By using our services, you understand that your personal information may be transferred to, stored, and processed in countries other than Canada. When we do so, we will ensure that appropriate safeguards and compliance mechanisms are in place.

Data Retention

OBSERVE: Gaming and financial regulations require us to retain certain personal information for minimum periods, while privacy laws require that data not be kept longer than necessary.

EXPAND: Retention periods vary depending on the category of data and the purpose for which it is processed (e.g., legal compliance vs. marketing).

REFLECT: We apply the following retention principles:

General Retention Rules

• Account and identification data: Typically retained for the duration of your account plus a period of up to 7 years after account closure, unless a longer period is required by applicable law, for example, for AML or regulatory investigations.
• Transaction and gaming records: Typically retained for at least 5 to 7 years after the transaction or account closure, to comply with gaming, tax, audit, and AML obligations.
• Responsible gambling records: Data regarding self-exclusions, limits, and interventions may be retained for the period necessary to comply with legal requirements and to protect you and us from harm, usually aligned with or exceeding the duration of self-exclusion plus a reasonable period.

Marketing and Analytics Data

• Marketing preferences and communication logs: Retained for as long as you remain opted in to marketing, and for a limited period thereafter (normally up to 2 years) to evidence consent and compliance with applicable marketing rules.
• Cookie and analytics data: Retention depends on the type of cookie or identifier but is generally limited to what is necessary for the stated purpose (for example, session cookies expire once you close your browser; persistent analytics cookies may remain for several months to a maximum of 2 years unless you delete them earlier).

Deletion and Anonymization

• When personal information is no longer required for the purposes for which it was collected, or for legal or regulatory requirements, we will securely delete it or irreversibly anonymize it.
• In some cases, we may retain aggregated or anonymized data that no longer identifies you, for statistical, research, or business analytics purposes indefinitely.
• If you request deletion, we will comply to the extent permitted by law, while retaining information that we are legally required or entitled to keep.

Your Rights

OBSERVE: Canadian privacy laws grant individuals rights regarding their personal information, similar in many respects to those articulated in international frameworks such as the EU GDPR.

EXPAND: Although this Policy does not apply to Mexico, we align our approach to individual rights with leading privacy principles, including transparency, access, correction, deletion, and control over marketing preferences.

REFLECT: Subject to applicable law, and to any regulatory constraints under gaming and AML rules, you may exercise the following rights:

Access to Your Data

• You may request confirmation as to whether we hold personal information about you and, if so, obtain a copy of your personal information and information about how we process it.

Correction (Rectification)

• You may request that we correct or update inaccurate or incomplete personal information, such as an incorrect address or outdated contact details.

Deletion (Erasure)

• You may request deletion of your personal information where:
  • the information is no longer necessary for the purposes for which it was collected; or
  • you have withdrawn consent (where processing was based on consent) and there is no other legal ground for processing.
• We may need to retain certain information to comply with legal obligations, resolve disputes, or enforce our terms (for example, AML or gaming law requirements may prevent immediate deletion of some records).

Restriction and Objection

• You may request that we restrict processing of your personal information in certain circumstances, such as while we verify its accuracy or assess an objection.
• You may object to processing based on our legitimate interests, including profiling, where you believe your privacy interests outweigh our legitimate purposes, except where processing is necessary for legal or regulatory obligations.

Data Portability

• Where technically feasible and required by applicable law, you may request that we provide certain personal information you have provided to us in a structured, commonly used, and machine-readable format, or transmit it directly to another organization you designate, where this is technologically practical and does not adversely affect others.

Marketing and Consent Management

• You may opt out of receiving marketing communications at any time by using the unsubscribe link in our emails, adjusting your account preferences, or contacting us.
• Where processing is based on consent (for example, non-essential cookies or certain marketing activities), you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

How to Exercise Your Rights

1. Submit a request: Contact our DPO or privacy contact at [email protected] or [email protected]. Clearly state your identity, your jurisdiction (e.g., Ontario or another Canadian province/territory), and the right you wish to exercise.
2. Verification: We may request additional information or documentation to verify your identity and ensure the security of your account before processing your request.
3. Response timeframe: We aim to respond within 30 days of receiving a complete request. If additional time is reasonably required due to complexity or volume, we will inform you of the extension and reasons.
4. Fees: We do not charge a fee for handling your request, unless it is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request in accordance with applicable law.

Cookies & Tracking Technologies

OBSERVE: Cookies and similar technologies are essential for providing secure, user-friendly online gambling services.

EXPAND: Some are strictly necessary for the site to function, while others are used for analytics and marketing subject to your preferences.

REFLECT: We use the following categories of cookies and tracking technologies:

Types of Cookies

• Session cookies: Temporary cookies that exist only while your browser is open. They allow us to recognize you as you move from page to page and are essential for secure login and game sessions.
• Persistent cookies: Cookies that remain on your device for a set period or until you delete them. They are used to remember your preferences (e.g., language, login status) and for analytics.
• First-party cookies: Cookies placed directly by playerspalace-ca.com to support core functionality and analytics.
• Third-party cookies: Cookies set by service providers such as analytics platforms or advertising networks, used to measure site performance and, where permitted, deliver or measure advertising.

Purposes of Cookies

• Strictly necessary / functional: Required for the website to operate securely and correctly, including authentication, load balancing, and fraud prevention. These cannot be switched off via our systems.
• Performance / analytics: Help us understand how users interact with our site, which pages are most visited, and how our games perform, so we can improve our services.
• Advertising / targeting: Used, where permitted, to deliver relevant promotions and measure the effectiveness of campaigns. These may involve third-party networks.

Managing Cookies

• Browser settings: Most browsers allow you to manage or disable cookies via their settings (for example, to block all cookies or delete existing ones). Please note that blocking essential cookies may affect site functionality.
• Site controls: Where required by law, we may provide a cookie banner or preference center on playerspalace-ca.com that allows you to manage your cookie preferences, including opting out of certain categories.
• Third-party tools: Some third-party analytics or advertising providers may offer their own opt-out mechanisms.

Data Security

OBSERVE: Online gambling involves sensitive financial and personal information, requiring robust security measures.

EXPAND: We implement a combination of technical, organizational, and physical controls aligned with recognized best practices to protect your data.

REFLECT: While no system can guarantee absolute security, we continuously work to maintain a high level of protection.

Technical Measures

• Encryption in transit: Data transmitted between your device and our servers is protected using TLS 1.2 or higher, helping prevent interception or tampering.
• Encryption at rest: Sensitive data is stored using industry-standard encryption and hashing techniques where appropriate (for example, salted hashes for passwords).
• Access controls: Access to personal information is restricted to authorized staff and service providers needing it for legitimate purposes, controlled through authentication, authorization, and role-based permissions.
• Network and system security: Firewalls, intrusion detection/prevention systems, anti-malware tools, and other safeguards are used to protect our infrastructure.

Organizational Measures

• Policies and training: Staff and contractors handling personal information are subject to confidentiality obligations and receive training on data protection, security, and responsible gambling obligations.
• Security governance: We maintain internal procedures for access management, data handling, incident response, and vendor oversight consistent with international security standards such as ISO 27001 or SOC 2 principles, where applicable.
• Audits and testing: Regular security reviews, vulnerability assessments, and, where relevant, external audits are undertaken to assess and improve our security posture.

Incident Response

• We maintain procedures to identify, investigate, and respond to actual or suspected personal data breaches or security incidents.
• Where required by law, we will notify affected individuals and relevant authorities of a data breach without undue delay, taking into account the nature and impact of the incident.
• We document incidents and implement remedial measures to prevent recurrence.

Complaints & Contacts

OBSERVE: Players and visitors must have clear channels to raise privacy concerns and escalate complaints to independent authorities if they are not satisfied.

EXPAND: Our complaint handling includes internal review and, where applicable, reference to relevant supervisory or gaming authorities.

REFLECT: You can use the following channels to contact us or raise a privacy complaint:

Contacting Us

• Primary privacy contact / DPO: Data Protection Officer, Players Palace Casino (Canada)
• Email: [email protected]
• Support email: [email protected]
• Website: https://playerspalace-ca.com

Internal Complaint Procedure

1. Submit your complaint: Send us an email with a detailed description of your concern, including any relevant account identifiers and supporting documentation.
2. Acknowledgement: We will acknowledge receipt of your complaint as soon as reasonably possible, typically within 5 business days.
3. Investigation: Your complaint will be reviewed by our privacy and/or compliance team. We may contact you for additional information where necessary.
4. Response: We aim to provide a substantive response within 30 days of receiving all necessary information. If we require more time due to complexity, we will inform you of the extension and reasons.

Escalation to Supervisory or Regulatory Authorities

If you are not satisfied with our response or believe that we are not handling your personal information in accordance with applicable laws, you may have the right to lodge a complaint with a relevant privacy regulator or, where appropriate, a gaming authority, depending on your location.

• Canadian privacy authorities: You may contact the Office of the Privacy Commissioner of Canada (OPC) or your provincial/territorial privacy commissioner. Contact details are available at: https://www.priv.gc.ca.
• Kahnawake Gaming Commission (for Rest-of-Canada players): Complaints related to gaming operations can be submitted via: https://gamingcommission.ca/complaints.htm.
• AGCO / iGaming Ontario (for Ontario players): For regulatory and dispute matters related to Ontario iGaming, information is available at: https://agco.ca/iGaming-dispute-resolution and https://igamingontario.ca.
• eCOGRA: For certain dispute resolution services related to fair gaming and payouts, you may refer to eCOGRA at: https://ecogra.org.

Updates

OBSERVE: Our services, technologies, and legal obligations may evolve over time.

EXPAND: We therefore need to update this Privacy Policy periodically and inform users of material changes in a transparent way.

REFLECT: We apply the following procedures for updates:

Notification of Changes

• We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, regulatory requirements, or for other operational reasons.
• When we make material changes, we will:
  • post the updated Policy on playerspalace-ca.com with a new "Last updated" date; and
  • where appropriate, notify you via email, account notifications, or prominent website banners.

Advance Notice and User Options

• For significant changes that affect how we process your personal information or your rights, we will provide, where reasonably practicable, at least 30 days' advance notice before the changes take effect.
• If you do not agree with the updated Policy, you may choose to close your account and stop using our services. Continued use of our services after the effective date of the updated Policy will constitute your acceptance of the changes.

Version Control

• Last updated: January 2026.
• Previous significant changes may include updates to reflect:
  • separation of Ontario and Rest-of-Canada operational structures;
  • enhanced responsible gambling and security measures;
  • clarifications on data sharing with regulators and external dispute resolution bodies.

We encourage you to review this Privacy Policy regularly to stay informed about how Players Palace Casino, through playerspalace-ca.com, protects your personal information.