Privacy Policy

This Privacy Policy explains how spinpalace-win.ca (the "Site") collects, uses, discloses, and protects personal information of visitors to the Spin Palace Casino page and other content we provide. It applies to individuals who browse our website, subscribe to our communications, or otherwise interact with spinpalace-win.ca. It does not govern the processing of personal data by online casino operators we review or link to. This Privacy Policy is effective from 1 January 2026 and supersedes any earlier versions published on the Site.

Who We Are

spinpalace-win.ca is an independent informational and review website focusing on the Spin Palace Casino brand and related online gambling services for the Canadian market, including the Spin Palace Casino page. When this Privacy Policy refers to "we", "us" or "our", it refers to the operator of spinpalace-win.ca acting as the data controller for personal information collected via this Site.

The specific corporate details of the Site operator (legal name, registration number, and registered address) are not specified in the data you provided. These details, where legally required, will be published on the Site's legal notice, terms of use, or an equivalent "About/Imprint" section and will form part of this Privacy Policy by reference.

spinpalace-win.ca is a review and branding domain only. It is distinct from, and not operated by, the licensed casino operators whose services we describe. In particular:

• Bayton Ltd, 9 Empire Stadium Street, Gzira, GZR 1300, Malta, operates official casino services for most Canadian players (outside Ontario) via spincasino.com under Malta Gaming Authority licence number MGA/B2C/145/2007.
• Cadtree Limited operates the official Ontario-facing casino via spincasino.ca under licence number OPIG1237901 issued by the Alcohol and Gaming Commission of Ontario (AGCO) / iGaming Ontario.

These entities are part of the CityViews Group and act as independent data controllers for any personal data they collect on their own domains. Their respective privacy policies, not this Privacy Policy, govern your use of those sites.

Data protection contact: For questions about this Privacy Policy or our privacy practices relating to spinpalace-win.ca, please contact our data protection contact / DPO-equivalent using the contact options made available on the Site. Where a dedicated privacy contact email or telephone number is published on spinpalace-win.ca, that information will prevail over more general contact options.

What Personal Data We Collect

Because spinpalace-win.ca is an informational and review website, we do not operate player accounts, payment wallets, or betting systems. However, we may collect and process the following categories of personal and technical data when you use the Site, including the Spin Palace Casino page:

Identification and contact data

• Basic contact details: Name, email address, and any other contact information you voluntarily provide when you:
  • Subscribe to newsletters or alerts;
  • Request information or support via any contact form or email address provided on the Site;
  • Participate in surveys, feedback forms, or promotions we may host.

Technical and usage data

• Device and connection data: IP address, approximate location derived from IP (city/region level), device identifiers, browser type and version, operating system, language settings, referral URLs, and timestamps of visits.
• Log data: Server logs, security logs, error logs, and similar information generated when you access or interact with the Site.
• Usage and behavioural data: Pages visited (including interactions with the Spin Palace Casino page), time spent on pages, clicks on links and outbound links (e.g., to spincasino.com, spincasino.ca, or spinpalace.com), scroll depth, and other interaction data, typically collected via analytics tools.

Marketing and preference data

• Communication preferences: Your preferences about receiving promotional or informational emails, where such options are available, and records of consent or opt-out.
• Interest profiles: Non-sensitive inferences we may draw from your interactions with our content (for example, interest in welcome bonus information, game reviews, or responsible gambling content).

Payment and financial data

• spinpalace-win.ca does not process deposits, withdrawals, or real-money wagers. We therefore do not collect your payment card details, bank account numbers, or similar financial information in the ordinary course of operating this Site.
• If, in exceptional circumstances, you voluntarily share financial or transaction-related information with us (for example, when describing a dispute with a casino operator), we will treat that information as sensitive and use it solely for the purpose of assisting or documenting your enquiry.

Cookies and similar technologies

• Cookies: Small text files stored on your device that enable core Site functions, remember your preferences, or help us analyse how the Site is used.
• Tracking technologies: Pixel tags, web beacons, script-based trackers, and similar technologies used for analytics, performance measurement, affiliate tracking, and, where permitted, advertising optimisation.

Where required by law, we will ask for your consent before setting non-essential cookies or similar technologies on your device.

Legal Basis for Processing

spinpalace-win.ca is established for the Canadian market and primarily subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. For visitors from the European Union / European Economic Area (EU/EEA) and other jurisdictions, we also structure our practices to align with key principles of the EU General Data Protection Regulation (GDPR) and the Mexican Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP) where reasonably applicable. Our main legal bases and justifications are:

• Consent
  • We rely on your informed consent for:
    • Sending you newsletters or promotional communications where required;
    • Placing or reading non-essential cookies (such as advertising or advanced analytics cookies) on your device;
    • Processing any optional information you provide in forms that is not strictly necessary to respond to your request.
  • You may withdraw your consent at any time, as described below under "Your Rights".
• Contractual necessity / provision of requested services
  • We process limited personal data to:
    • Respond to your enquiries or support requests;
    • Deliver any email subscriptions or alerts you sign up for;
    • Provide tools or forms you actively choose to use (for example, forwarding a complaint to a third party, where available).
• Legitimate interests (as recognised under GDPR and analogous principles under PIPEDA and LFPDPPP)
  • We may process personal and technical data where necessary for our legitimate interests, provided these are not overridden by your fundamental rights and freedoms, including:
    • Ensuring the security and integrity of spinpalace-win.ca, including fraud detection and prevention;
    • Measuring and improving the performance and relevance of our content, including the Spin Palace Casino page;
    • Maintaining accurate records of communications and consents;
    • Operating affiliate links or referral tracking to official casino sites, in a privacy-conscious manner.
• Compliance with legal obligations
  • We may process and preserve personal information to:
    • Respond to lawful requests from Canadian or foreign regulators, law enforcement, or courts;
    • Comply with record-keeping obligations under applicable laws (for example, business, tax, or advertising rules);
    • Assist licensed gambling operators or alternative dispute resolution bodies in fulfilling their own regulatory obligations (such as KYC/AML) when you explicitly ask us to forward information to them.

Purpose of Processing

We use the personal and technical data described above for clearly defined and legitimate purposes. These include:

• Providing and operating the Site
  • Delivering the Spin Palace Casino page and related content;
  • Ensuring that pages load correctly and adapt to your device and browser;
  • Maintaining the overall availability, stability, and security of spinpalace-win.ca.
• Communicating with you
  • Responding to your questions, support requests, or feedback;
  • Sending service messages related to your interactions with the Site (for example, confirmations of subscription or changes to this Privacy Policy);
  • Sending newsletters or promotional communications where permitted by law and where you have not opted out.
• Analytics and service improvement
  • Conducting statistical analysis on how visitors use our content, including click paths from Spin Palace Casino to official casino domains;
  • Improving page layouts, review clarity, and user navigation;
  • Testing new features, tools, or layouts on limited subsets of users (A/B testing), where implemented.
• Marketing and affiliate operations
  • Tracking, in a privacy-conscious manner, which outbound links (e.g., to spincasino.com or spincasino.ca) are clicked so we can manage affiliate relationships;
  • Measuring the effectiveness of our marketing campaigns, where applicable;
  • Showing or tailoring promotional content on the Site or in permitted communications, subject to your consent where required.
• Fraud prevention, security, and legal protection
  • Protecting the Site against misuse, automated scraping, and attacks;
  • Investigating and addressing suspected violations of our terms of use or applicable law;
  • Establishing, exercising, or defending legal claims, including in cooperation with regulators or dispute resolution bodies.

Disclosure & Sharing

We do not sell your personal information. We may, however, disclose or share personal and technical data with carefully selected third parties where necessary for the purposes described above and subject to appropriate safeguards:

• Service providers (processors)
  • Technical hosting providers, security and anti-DDoS providers, email service providers, customer support tools, and analytics providers that process data on our behalf and under our instructions.
• Analytics and performance partners
  • Third-party analytics services that help us understand aggregate usage patterns (for example, visits to the Spin Palace Casino page, click-through rates to official casino websites), subject to any consent required for their cookies or trackers.
• Affiliate and advertising partners
  • Affiliate networks or partners that track referrals from spinpalace-win.ca to official casino domains such as spincasino.com, spincasino.ca, or spinpalace.com. In most cases, these partners receive only pseudonymous identifiers or aggregated information. Where marketing or advertising cookies are used, we will request your consent where legally required.
• Licensed casino operators and dispute resolution bodies
  • Where you explicitly request that we assist you with a complaint or enquiry relating to a licensed operator (such as Bayton Ltd or Cadtree Limited), we may forward relevant information you provide to that operator or their appointed alternative dispute resolution (ADR) entity.
  • We may refer you directly to third-party forms, such as the eCOGRA ADR dispute submission form available at https://ecogra.org/forms/adr-dispute-step-1. In such cases, your data is collected and processed under the privacy policy of eCOGRA or the relevant operator, not under this Privacy Policy.
• Regulators and public authorities
  • Where required or permitted by law, we may share information with:
    • Canadian privacy or gambling regulators;
    • Foreign regulators or supervisory authorities (for example, the Malta Gaming Authority or iGaming Ontario) if a matter falls within their jurisdiction;
    • Law enforcement, courts, or governmental agencies in response to lawful requests.
• Corporate transactions
  • In the context of a merger, acquisition, asset sale, or similar transaction involving the Site or its operator, personal information may be disclosed to potential or actual acquirers, their advisors, and other stakeholders, subject to confidentiality obligations and applicable law.

International Transfers

spinpalace-win.ca is targeted at users in Canada, but some of our service providers and partners may be located or may process data outside of your province, your country, or outside Canada. This may include:

• Transfers within Canada: Data may be transferred between provinces and territories in Canada for hosting, support, or analytics purposes, subject to PIPEDA and applicable provincial laws.
• Transfers to the European Union and Malta: Some casino operators we reference (such as Bayton Ltd in Malta) and certain service providers may be established in EU/EEA countries. These jurisdictions are subject to the GDPR and are generally regarded as providing a high level of data protection.
• Transfers to the United States or other third countries: Certain technical and analytics providers, advertising networks, or cloud service providers may be located in or process data from the United States or other countries that do not have the same legal level of data protection as Canada, the EU/EEA, or Mexico.

Where required by applicable law (for example, for EU/EEA or Mexican data subjects), we will implement appropriate safeguards for such transfers, which may include:

• Using service providers located in jurisdictions that have been recognised by the European Commission as providing an adequate level of data protection;
• Entering into Standard Contractual Clauses (SCCs) or equivalent contractual safeguards recognised under GDPR and LFPDPPP;
• Relying on providers that participate in recognised international data transfer frameworks, where applicable;
• Implementing additional technical and organisational measures, such as encryption and access controls, to protect your data during and after transfer.

You may contact us using the details available on spinpalace-win.ca for more information about the specific safeguards used for international transfers relevant to your situation, where such information is required by applicable law.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy or to comply with legal, regulatory, or contractual obligations. Retention periods vary depending on the type of data and the context of processing:

• Contact and enquiry data: Information you provide when contacting us (such as name, email address, and message content) is generally retained for up to 3 years after our last interaction, to allow us to handle follow-up requests and maintain accurate records of our communications.
• Newsletter and marketing data: Subscription details and consent logs are retained for the duration of your subscription and up to 2 years after you unsubscribe or withdraw consent, to demonstrate compliance with marketing and consent requirements.
• Technical and log data: Server logs and security logs are typically retained for 12 - 24 months, unless a longer period is required for security incident investigations, fraud prevention, or legal proceedings.
• Complaint and dispute-related data: If you contact us about issues related to casino operators or regulatory matters, we may retain relevant information for up to 5 years after the matter is closed, or longer if necessary to establish, exercise, or defend legal claims or to comply with statutory retention requirements.
• Aggregated and anonymised data: Data that has been irreversibly anonymised (so that it can no longer be linked to an identified or identifiable individual) may be retained indefinitely for statistical and analytical purposes.

When personal information is no longer required for the purposes for which it was collected and there is no legal requirement to retain it, we will delete, anonymise, or otherwise securely dispose of it. If you exercise your right to deletion (where applicable), we will also take reasonable steps to inform known third-party recipients, unless this is impossible or involves disproportionate effort.

Your Rights

We are committed to respecting your privacy rights under applicable Canadian law and, where reasonably feasible, aligning our practices with key protections from the GDPR and Mexican LFPDPPP. Depending on your place of residence and the specific circumstances, you may have some or all of the following rights in relation to your personal data:

• Right of access
  • You may request confirmation as to whether we hold personal information about you and, where we do, receive a copy of such information along with an explanation of how it is used and with whom it is shared.
• Right to rectification (correction)
  • You may request that we correct or update inaccurate, incomplete, or outdated personal information held about you.
• Right to deletion / erasure ("right to be forgotten")
  • In certain circumstances (for example, where data is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis), you may request that we delete your personal information, subject to legal and regulatory retention requirements.
• Right to restriction of processing
  • You may request that we restrict the processing of your personal information in certain cases, such as while we verify the accuracy of data you contest or assess an objection you have raised.
• Right to object
  • You may object to the processing of your personal information for certain purposes, including:
    • Direct marketing, in which case we will stop using your data for such purposes; and
    • Processing based on our legitimate interests, where your particular situation justifies the objection and our interests do not override your rights and freedoms.
• Right to data portability
  • Where applicable (primarily for EU/EEA residents and under similar standards for other jurisdictions), you may request that we provide certain personal information you have provided to us in a structured, commonly used, machine-readable format, and that we transmit it to another controller where technically feasible.
• Right to withdraw consent
  • Where processing is based on your consent (for example, for non-essential cookies or marketing emails), you may withdraw that consent at any time. This will not affect the lawfulness of processing prior to withdrawal.
• Rights under Mexican LFPDPPP
  • If you are protected by Mexican law, the above rights correspond to your ARCO rights (Acceso, Rectificación, Cancelación y Oposición). We will handle such requests in a manner consistent with LFPDPPP principles where reasonably applicable to our activities.

How to exercise your rights

1. Submit your request: Contact us using the privacy contact methods made available on spinpalace-win.ca (for example, via any dedicated privacy email address or contact form). Please:
   • Identify yourself and provide sufficient information for us to verify your identity;
   • Describe clearly which right you wish to exercise and the data your request relates to.
2. Verification: To protect your privacy, we may request additional information to verify your identity, especially for access, deletion, or portability requests.
3. Response time: We aim to respond to your request within 30 days of receipt, in line with PIPEDA and comparable timelines under GDPR and Mexican law. If we need more time due to complexity or volume, we will inform you of the extension and reasons.
4. Cost: Exercising your rights is generally free of charge. We may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, particularly if they are repetitive, as permitted by applicable law.

If your request relates to personal data processed by an official casino operator (for example, Bayton Ltd or Cadtree Limited), please address your request directly to that operator using the contact details in their own privacy policies, as they act as the controller for data processed on their domains.

Cookies & Tracking Technologies

We use cookies and similar technologies to operate and improve spinpalace-win.ca, including the Spin Palace Casino page. Depending on your jurisdiction, certain cookies may require your consent before being placed on your device.

Types of cookies we may use

• Strictly necessary (functional) cookies
  • These cookies are essential for the proper functioning of the Site, such as enabling basic navigation, protecting forms against abuse, or storing limited technical preferences. They cannot be disabled via our internal tools, although you can block them through your browser settings (which may affect Site functionality).
• Preference cookies
  • These remember your choices, such as language or region preferences, and may make your browsing experience more convenient.
• Analytics and performance cookies
  • These help us understand how visitors use the Site, including which content (e.g., the Spin Palace Casino page) is most viewed and how users navigate to external casino sites. The information is usually aggregated and used to improve our content and layout.
• Advertising and affiliate cookies
  • These may be set by us or our partners to track referrals to third-party sites (such as spincasino.com or spincasino.ca) and to measure the performance of marketing or affiliate campaigns. In some cases, such cookies may be used to build non-sensitive profiles and show more relevant promotional content, subject to your consent where required.

Managing cookies

• Browser settings: Most browsers allow you to:
  • Block all cookies or only third-party cookies;
  • Delete existing cookies;
  • Receive alerts before a cookie is stored.
  Please refer to your browser's help documentation for instructions.
• Site-level tools: Where available, we may provide a cookie banner or preference centre that allows you to accept or reject different categories of cookies (except strictly necessary cookies). Your selections will be honoured for the lifespan of our preference cookie or until you clear your browser cookies.
• Third-party opt-outs: Some third parties offer their own opt-out mechanisms for analytics and advertising cookies. These are governed by their respective privacy policies.

Data Security

We implement technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration, or disclosure. While no online service can guarantee absolute security, we strive to maintain a level of security appropriate to the risks associated with our processing activities. Measures include:

• Encryption in transit: Communications between your browser and spinpalace-win.ca are protected using Transport Layer Security (TLS) version 1.2 or higher, helping to prevent interception or tampering while data is in transit.
• Data protection at rest: Where feasible, we use encryption, access controls, and secure storage practices to protect personal data stored on our systems and those of our service providers.
• Access controls: Access to personal information is restricted on a need-to-know basis to individuals and service providers who require it for legitimate business purposes and are bound by confidentiality obligations.
• Security monitoring and audits: We employ logging, monitoring, and periodic review of systems and access rights. Where appropriate, we may engage external experts or rely on service providers that adhere to recognised security frameworks (such as ISO/IEC 27001 or SOC 2) for relevant components of our infrastructure.
• Staff awareness: Individuals involved in the handling of personal information are expected to follow internal policies on data protection, information security, and confidentiality. Training and awareness measures are updated periodically.
• Incident response: We maintain procedures for detecting, investigating, and responding to suspected data breaches or security incidents. Where a breach is likely to result in a real risk of significant harm, or where required by GDPR, LFPDPPP, or other applicable laws, we will notify the appropriate authorities and affected individuals without undue delay.

If you believe that your interaction with spinpalace-win.ca is no longer secure (for example, if you suspect that an account or communication with us has been compromised), please notify us immediately using the contact options available on the Site.

Complaints & Contacts

We take privacy-related concerns seriously and aim to resolve them in a fair and timely manner.

How to contact us

• Primary contact for privacy matters: Data Protection Contact / DPO-equivalent for spinpalace-win.ca, reachable via the contact mechanisms published on the Site (for example, a contact form or dedicated privacy email address, where available).
• Telephone: If a telephone number is provided on spinpalace-win.ca for privacy or general enquiries, you may also use that channel. Where no number is published, please submit your request electronically.

Complaint procedure

1. Initial enquiry: Submit your question or complaint to us, clearly describing the issue and, where relevant, the pages or communications it relates to (for example, the Spin Palace Casino page).
2. Acknowledgement: We aim to acknowledge receipt of your complaint within 7 business days.
3. Investigation and response: We will investigate your complaint and endeavour to provide a substantive response within 30 days of receipt. If more time is required due to complexity or the need to liaise with third parties, we will inform you of the delay and provide an updated timeframe.
4. Escalation: If you are not satisfied with our response, or if you believe we are not handling your personal information in accordance with applicable law, you may escalate the matter to a competent supervisory authority as described below.

Supervisory authorities

• Canada: You may contact the Office of the Privacy Commissioner of Canada (OPC) via its website at https://www.priv.gc.ca or, where applicable, the privacy commissioner for your province or territory.
• European Union / EEA: If you are located in the EU/EEA, you may lodge a complaint with your local data protection authority. Contact details are available via the European Data Protection Board (EDPB) website.
• Mexico: If you are protected by Mexican data protection law, you may contact the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI), whose details are available at https://www.inai.org.mx.

If your complaint concerns gambling services provided by licensed casino operators (such as Bayton Ltd or Cadtree Limited), rather than our handling of your personal information on spinpalace-win.ca, you may also:

• Use the dispute or complaint procedures described in the relevant operator's own terms and privacy policy;
• Submit a dispute to eCOGRA via their ADR form at https://ecogra.org/forms/adr-dispute-step-1, where appropriate, noting that any data you provide there is governed by eCOGRA's own privacy policy.

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

• Notification of changes:
  • Minor changes (for example, editorial updates or clarifications) may be implemented by posting an updated version on spinpalace-win.ca with a revised "Last updated" date.
  • For material changes that significantly affect how we collect or use your personal information, we will provide additional notice where feasible, which may include:
    • Prominent notices on the Site (e.g., banners or pop-up messages);
    • Notifications within user interfaces associated with subscriptions or services, where applicable;
    • Email notifications to users who have provided us with their email address and for whom the change is relevant.
• Advance notice for significant changes:
  • Where practicable and required by law, we will provide at least 30 days' advance notice before material changes take effect, particularly where they involve new purposes of processing or new categories of data recipients.
• Your options:
  • If you do not agree with the updated Privacy Policy, you may choose to stop using spinpalace-win.ca and withdraw any consents previously given (for example, by unsubscribing from newsletters or adjusting your cookie settings).
  • Continued use of the Site after the effective date of an updated Privacy Policy will be deemed acceptance of the changes, to the extent permitted by applicable law.

Last updated: February 2026.