Privacy Policy

OUR COMMITMENT TO ACCOUNTABLE PRIVACY PRACTICES

This is the main privacy policy for NorthStar Gaming (Ontario) Inc. (“NorthStar Gaming”) and our affiliated companies (“NorthStar Gaming Companies and covers all related websites, applications and services that do not have a separate policy. A reference to “we”, “us” or “our” is a reference to the NorthStar Gaming Companies.

This policy provides a snapshot of our personal information practices so that you may easily understand what information we collect and why, as well as how to access and update or correct your personal information. If you are interested, drop down menus contain more information.

We may change this policy from time to time. If you continue to use our products and services after we make changes, you are consenting to the updated policy. If the changes are significant, we will provide you with notice and archive prior versions.

In this policy, customized experience means content, recommendations, advertising, and offers (including from selected third party sponsors or advertisers) that may be personalized or tailored to your interests. Our games, products and services include any games you play, or anything you purchase, register for, use or attend such as contests, newsletters, auctions, advertising, events, commenting functions, and services provided through our websites and applications. We may refer to our websites and applications as our digital properties.

Certain digital properties and services may be subject to additional notices or policies. We may link to websites or applications outside of our control, including our payment processors, which may have their own policies. Our games, products and services are also subject to any applicable terms of use.

What is not covered by this policy?

Personal Information for Editorial or Journalistic Purposes â€“ Information collected for editorial or journalistic purposes, whether it is considered “personal”, is exempt from the requirements of privacy legislation and is not covered by this policy.

Information that is not personally identifiable, such as anonymous or de-identified information and aggregate data that cannot be associated with a specific person, such as demographic statistics about our customers, or number of visitors and average time spent on a website, may be collected and used by us and third parties including advertisers.

Any other information or circumstance that falls outside the scope of or is exempted by applicable privacy legislation, including permitted uses of business contact information (including the name, title, business and email address and telephone number of an employee of an organization) and publicly available information such as an individual’s name and address when listed in or made available through a directory.

We collect personal information you provide directly to us when you play our games, purchase our products, register for, use or attend our services, or fill out our surveys. We collect information we get from third parties or from you when you visit us, call us or you use our services. Unless the information collected or compiled is sensitive in nature, we assume your consent for all purposes set out in this policy.

Commonly Collected Personal Information

  • Purpose

Contact information such as name, address, postal code, email address, telephone number

  • provide requested games, products and services and related non-promotional communications
  • provide requested information, rewards points and receiptsverify delivery
  • provide a customized experience
  • develop better games, products and services
  • promote our games, products and services

Transaction information relating to games, products and services purchased or used and customized experience history

  • provide requested games, products and services and related non-promotional communications
  • provide requested information, rewards points and receipts
  • verify deliveryprovide a customized experience
  • develop better games, products and services
  • promote our games, products and services

Demographic and survey information such as postal code, gender, marital status, birth date/year, interests, household expenditures, reasons for cancellation and other customer service information, location preferences, interests and other preferences

  • provide a customized experience
  • develop better products and services
  • promote our games, products and services

Social media identifiers (such as single sign on through Facebook, Google or other social media accounts) and other information you share with us or make public via your social networking platform. You may control what information you share through the social networking sites™ privacy settings.

  • verify your identity when you use social login so that you may access your account and use our services
  • provide a customized experience
  • develop better games, products and services

Subscriber id and passwords

  • verify your identity so that you may access your account and use services

Credit card, PayPal or banking information and transaction ID

  • to complete a game registration, wagers within games, sale or donation
  • to process refunds and apply credit
  • to track your purchase history in PayPal or other payment processor

Audio or video recordings if you call us or come to our offices or events

  • to create a record of our interaction
  • for security, training and quality assurance purposes

Usage data, including content and advertisements viewed on our digital properties, search history, content you share, products and services you download, purchase or subscribe for, language preference, transaction history, time spent and other digital information through cookies, pixel tags, web beacons, and other technologies. We also collect information about the site you came from before visiting our digital properties and the site you go to next.

  • provide a customized experience
  • develop better games, products and services
  • promote our games, products and services
  • advertising delivery verification

Your device and location. We collect information about your device such as IP address, browser type, device type, unique device identifiers and operating system. We also collect information about your location, if enabled on your device or derived from your IP address.

  • provide a customized experience
  • develop better games, products and services
  • promote our games, products and services

User-generated content and public activities such as comments on online forums, public user profiles you generate and classified listings you create. This information is considered public and is subject to the applicable terms of use.

  • promote our games, products and services
  • provide a customized experience
  • develop better games, products and services

Additional detail about what information we collect and why:

  • Customized experience and promotions: We tailor content, recommendations, communications and advertising to your interests, providing you with more relevant information. We may use your contact and transaction information, usage and device data and other personal information to provide you with content recommendations and tailored communications, and to send promotional communications about our games, products and services, to track your use of our games, products and services across the devices that you use to access our digital properties, and to provide you with a customized experience.
  • Non-promotional communications: We use your contact and transaction information to provide you with communications about games, products and services you play, purchase or use. You may not opt out of these communications, however, you may close your account.
  • Internal analytics: We use IP addresses, cookies, pixel tags, web beacons and other technologies to gather demographic and statistical information about our users, including information about user behaviour and interaction with our digital properties and with emails and other communications we send to you, and your location and device type, to administer our digital properties, to understand how you interact with us and our digital properties, to improve our games, products and services, to develop games, new products and services, for systems administration and to diagnose problems with our servers, to detect fraud and to improve security.
  • Enforce our terms of use: We may use your personal information to contact you regarding or otherwise enforce issues with your use of services such as posting on online forums, subject to our applicable terms of use.
  • Other administrative reasons: If you make a complaint or send a request to customer service, we will keep the relevant information to investigate your complaint or request and respond to you. If you provide freelance or other services to us, we may collect your social insurance number for tax reporting purposes and other information required to enter a contract with and pay you. If you are a shareholder, we collect your contact information and share account information to administer shareholdings and communicate with you. If you are a former employee we may collect your banking, family contact information and your employment history to administer your pension or other benefits. We use your personal information for the purposes of managing, administering, collecting or enforcing your accounts, maintaining business records for a reasonable time and generally managing and administering our business and meeting relevant Canadian and international regulatory, legal, insurance, audit, security and processing requirements.
  • Corporate reasons: NorthStar Gaming Companies may disclose your personal information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We require such parties to treat your personal information in accordance with this privacy policy and to use and disclose it only for the purposes for which it was collected.
  • As permitted or required by law: NorthStar Gaming Companies may disclose your personal information as permitted or required by law including to third parties if we believe you have violated our terms of service or conditions of purchase, if we need to comply with applicable law including lawful access requests, or for certain business transactions.
  • Your information may be transferred or stored outside of Canada: Your personal information may be processed and stored outside of the province in which you reside and/or outside of Canada by us or a third party service provider for the purposes set out in this policy. Under the laws of these jurisdictions, in certain circumstances foreign courts, law enforcement or regulatory agencies may be entitled to access your personal information.

User-generated content and public activities: We offer you opportunities to engage in public activities, which are any actions you take that are designed to be visible to others, including comments, recommendations, reader reviews, ratings, classified listings, public user profiles or any other items that you submit. Any information you disclose in your public activities, along with your screen name or ID, or any image or photo, becomes public and may be used by the NorthStar Gaming Companies for online and offline promotional or commercial uses in any and all media.

If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users. We are not responsible for the personal information you choose to make public and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions. You agree that all sharing is deemed to have been done by you. Public activities may be included in our RSS fees, APIs and other distribution formats and thus your public activities may appear on other websites, blogs or feeds. For more information, please see the applicable terms of use. When you share or recommend links to content on a third-party platform such as Facebook or Twitter, that action and any information you share will be subject to their privacy policy.

Our use of cookies: If you use any of our digital properties we and our third party service providers may use cookies and other technologies such as JavaScript, Adobe Flash, web beacons and pixels to better understand your behaviour and interaction with our digital properties and with communications sent to you (such as open and click activity) and to improve your user experience and recognize you and/or your device, to make sure our ads and dynamic content are served correctly and to improve the performance of our digital properties. For example, a cookie may recall a set of preferences you have set and record items for which you have registered. Storing cookies on your browser allows us to give you customized experiences. We may use third party service providers in order to gather such data on user behaviour and to provide us with other data collection, reporting, ad response measurement and site analytics. These third party service providers may include Google Analytics and Google Firebase Analytics, which use data as described here: How Google uses data when you use our partners’ sites or apps. You may opt-out of data analytics services provided by Google at the Google Analytics opt-out page.

If you wish, you may disable cookies in your browser or delete them. While we do not require the use of cookies, some functionality may be disabled and your web surfing experience will be degraded.

Consent and your personal information: The form of consent required for the collection and use of your personal information depends on what is reasonable in the circumstances. We may assume consent from your actions. For example, if you provide us with your personal information for a subscription, we assume that we may also send you notices related to your subscription and bill you. This is an example of implied consent. No consent is required for certain uses, such as to comply with a court order or investigate a breach of an agreement or applicable law, or for use of de-identified information.

In general, we assume your consent for all purposes set out in this policy. If it is reasonable to do so, we will provide further notice at the point of collection. If personal information collected or compiled is sensitive in nature, or it is otherwise reasonable in the circumstances, we will provide you with an opportunity to expressly agree, such as a check box. Where consent is required to use your personal information, you may opt-out of our use of your information. More information about accessing, updating and opting-out may be found below.

We may share your personal information within the NorthStar Gaming Companies. We combine information internally across different NorthStar Gaming Companies , games, products and services and may further combine information with demographic information, publicly available records and other third party information sources and may use this information to provide you with a customized experience and to develop and promote our products and services. We may be able to identify you by location and across different digital properties and devices using cookies, web beacons and other technologies and derive information based on our records. We may assign you a unique customer identification number. Personal information is not shared outside of the NorthStar Gaming Companies unless:

  • You have consented.
  • We are permitted or required to do so by law.
  • We have engaged an authorized service provider to carry out services on our behalf. Personal information may be transferred outside of your province and/or outside of Canada for processing or storage.
  • We are required to share the information with merchants from whom you have purchased something or registered for something to allow them to provide the products or services to the correct individuals and to allow them to keep track of what they have provided. We have in place measures to keep personal information we collect secure, which may include:
  • Limiting the number of people who view or process personal information
  • Locking and restricting access to paper files
  • Using appropriate methods to secure electronic files, including computer passwords, firewalls and encryption.

Once we no longer require your personal information for purposes you have consented to, we securely dispose of it.

Safeguards: The NorthStar Gaming Companies use technical, contractual, administrative and physical security measures to protect your personal information in a manner that is reasonable for the nature of the personal information you provide to us. If you are a subscriber or register for our services, access to your information on our servers is password-protected, and we help protect the security of your credit card information by using industry standard secure sockets layer (SSL) encryption technology.

If you choose a direct payment gateway to complete a purchase, our payment processors store your credit card data. It is encrypted through Payment Card Industry Data Security Standard (PCI-DSS). All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like VISA, MasterCard, American Express and Discover. PCI-DSS requirements help ensure secure handling of credit card information.

We also offer secure https access to our websites. We regularly monitor our systems for possible vulnerabilities and attacks. However, the internet is not 100% secure and we cannot guarantee that information may not be breached. Please guard your login information carefully and use a strong password. Email and other similar forms of communication may not be encrypted. Please do not send sensitive personal information or other confidential information through these means.

Children: Our digital properties are not targeted to children and NorthStar Gaming Companies do not knowingly collect personal information from children.

Data retention: We retain the personal information you provide while your account is in existence or as needed to provide you with requested products or services. You may always access and update personal information you have provided to us, opt-out of uses of your personal information in accordance with our access and out-out procedures (below), , and you may close your accounts with us. Upon these actions, we will correct or cease to use your personal information for such purposes. We may retain your information for a reasonable period for re-engagement purposes. Information included in analytics reports may be retained. We will retain your information if it is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce this policy or our terms of use.

You may access, update and delete your personal information and use of games, products and services provided by the NorthStar Gaming Companies by:

  • updating or deleting your account information for the relevant game, product or service;
  • updating your preferences if a customer preference option is provided by the relevant game, product or service;
  • Google Analytics: you may opt-out of data analytics services provided by Google by visiting the Google Analytics opt-out page and installing the add-on for your browser;
  • Offers and advertising: you may opt-out of direct offers and advertisements by following the instructions at the bottom of the email or speaking with any telemarketer;
  • You may opt-out of online behavioural advertising where applicable by clicking the  icon on ads appearing on our websites or by visiting http://youradchoices.ca/choices/ and https://networkadvertising.org/understanding-online-advertising/what-are-my-options. More information about online behavioural advertising is here.
  • Contact us  for the relevant product or service by telephone or email. We will be happy to help you update your information or address any concerns you may have.

If you have questions or concerns that have not been resolved to your satisfaction by customer service, you may contact NorthStar Gaming’s Chief Privacy Officer in writing at:

Chief Privacy Officer
NorthStar Gaming Inc.
342 Queen Street West, Suite 200
Toronto, Ontario M5V 2A2
info@northstargaming.ca

Online behavioural advertising: Online behavioural advertising involves tracking consumers’ online activities (including web pages you visit and content and advertisements you view), across sites and over time to deliver advertisements targeted to their inferred interests. Behavioural advertisers often use sophisticated algorithms to analyze the collected data, build detailed personal profiles of users, and assign them to various interest categories. Interest categories are used to present ads defined as relevant to users in those categories. If you opt-out of behavioural tracking, you will still receive advertising, it just won’t be tailored to your interests.

Third parties such as ad-serving companies may assign cookies and other tracking technology directly on our digital properties. The information collected is used to deliver future targeted advertisements to you when you visit our digital properties and other third party sites in their network. Some ads appearing on our digital properties are delivered to you by DoubleClick or AdTech, which are web advertising companies. If you do not want to have information about your visits to our digital properties tracked by these companies, you may opt-out at: DoubleClick Opt Out, AdTech Opt-Out. We may place advertising or other links on our digital properties that originate from outside advertisers and other third parties. If you view these ads, advertisers may assign a cookie or use other technology to track your behaviour. Various browsers offer a “do not track” option. We do not currently recognize this option as there is no industry standard for this technology.

You may visit www.priv.gc.ca if you are interested in learning more about privacy or wish to contact the Office of the Privacy Commissioner of Canada.

This Privacy Policy is effective as of November 5, 2021