Privacy Policy

1. Introduction

Winspinsplay Ltd ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our social casino service. We comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, as well as GDPR where applicable.

2. Data Controller

Winspinsplay Ltd is the data controller responsible for your personal information.

3. Information We Collect

3.1 Information You Provide Directly

• Account Information: Email address, username, age verification
• Contact Form Data: Name, email, message content
• Communication Records: Support requests, feedback

3.2 Information Collected Automatically

• Technical Data: IP address, browser type, device information
• Usage Data: Pages visited, time spent, click patterns
• Game Analytics: Game interactions, session duration (with consent)
• Cookies and Tracking: See our Cookie Policy

3.3 Location Data

• General geographic location (country/province level) for service eligibility
• We do not collect precise location data without explicit consent

4. Legal Basis for Processing

• Contractual Necessity: Account management, service delivery
• Legal Obligation: Age verification, compliance with Canadian regulations
• Legitimate Interest: Service improvement, security, fraud prevention
• Consent: Analytics, marketing communications, non-essential cookies

5. How We Use Your Information

5.1 Essential Service Functions

• Verify age and geographic eligibility (19+ Canada residents)
• Provide and maintain our social casino service
• Process account registration and authentication
• Handle customer support requests
• Ensure security and prevent fraud

5.2 With Your Consent

• Analyze usage patterns to improve our service
• Send promotional communications (opt-in only)
• Personalize gaming experience
• Marketing and advertising (with explicit consent)

5.3 Legal Compliance

• Comply with Canadian gaming and advertising regulations
• Respond to legal requests and court orders
• Maintain required business records

6. Information Sharing and Disclosure

6.1 Third-Party Service Providers

We may share information with trusted service providers who assist us in:

• Website hosting and maintenance
• Analytics and performance monitoring (with consent)
• Customer support tools
• Email communication services

Important: Non-essential third-party processors only load after you provide consent.

6.2 Legal Requirements

We may disclose information when required by:

• Canadian federal or provincial law
• Court orders or legal processes
• Regulatory authorities (gaming commissions)
• Law enforcement agencies

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, personal information may be transferred with appropriate safeguards.

6.4 We Do Not Sell Personal Information

We do not sell, rent, or trade your personal information to third parties for their commercial purposes.

7. Data Retention

• Account Data: Retained while account is active + 2 years after closure
• Support Records: 3 years from last interaction
• Analytics Data: 26 months (Google Analytics standard)
• Legal Compliance Records: As required by Canadian law (typically 7 years)
• Marketing Consent: Until withdrawn or account deletion

We review and delete personal information when it's no longer needed for the purposes it was collected.

8. Your Privacy Rights

Under PIPEDA and GDPR (where applicable), you have the right to:

8.1 Access and Portability

• Request access to your personal information
• Receive a copy of your data in a portable format
• Know what information we have about you

8.2 Correction and Updates

• Correct inaccurate personal information
• Update your contact preferences
• Modify account information

8.3 Deletion ("Right to be Forgotten")

• Request deletion of your personal information
• Close your account and remove associated data
• Note: Some information may be retained for legal compliance

8.4 Restriction and Objection

• Object to processing based on legitimate interest
• Restrict processing in certain circumstances
• Opt out of marketing communications

8.5 Withdraw Consent

• Withdraw consent for analytics and marketing
• Modify cookie preferences
• Note: Withdrawal doesn't affect previously lawful processing

8.6 How to Exercise Rights

To exercise your rights, contact us at privacy@winspinsplay.com. We will respond within 30 days as required by Canadian law.

9. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Encryption in transit (HTTPS/TLS)
• Secure hosting infrastructure
• Access controls and authentication
• Regular security assessments
• Staff training on data protection

While we strive to protect your information, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

10. International Data Transfers

Your information is primarily processed in Canada. If we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Adequacy decisions by the European Commission or Privacy Commissioner of Canada
• Standard contractual clauses
• Certification under approved frameworks

11. Children's Privacy

Our service is strictly intended for individuals 19+ years of age. We do not knowingly collect personal information from anyone under 19. If we become aware of such collection, we will delete the information immediately.

Parents or guardians who believe their child under 19 has provided information should contact us immediately at privacy@winspinsplay.com.

12. Changes to This Privacy Policy

• We may update this Privacy Policy periodically
• Material changes will be communicated via email or prominent website notice
• Continued use after changes constitutes acceptance
• Previous versions are available upon request

13. Complaints and Contact

13.1 Contact Our Data Protection Officer

For privacy-related questions or concerns: privacy@winspinsplay.com

13.2 Regulatory Complaints

If you are not satisfied with our response, you may file a complaint with:

• Privacy Commissioner of Canada: priv.gc.ca/report-a-concern
• Provincial Privacy Commissioners (depending on your location)
• For EU residents: Your local Data Protection Authority