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 processing all of Your personal data 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, stores and uses Your personal data 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”).

Valid from Date	Description	Version
16.12.2022	Creation of the document	1.0
30.05.2025	Revision and amendments	1.1

Overview
About Us
Your Data
Sharing of Data
Shared Responsibility for Personal Information
Transfer of Personal Information
Profiling & Automated Decision Making
Data Security Measures
Data Retention
Your Rights
Changes to the Privacy Policy

2. ABOUT US

(a) The Purpose of the Privacy Policy

This Privacy Policy aims to provide you with a thorough understanding of how We process your personal data collected through your use of this Website, and also includes all data 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;
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 processes, handles and stores 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 data related to persons under this age. If it becomes clear to us that We have collected personal data 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 data is processed in accordance with applicable law and our policies and procedures. This could not prevent you to assume the consequences due to said misuse or abuse of Our Website in accordance with Our Terms & Conditions.

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 data, 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 data 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 data accuracy checks in accordance with the applicable laws and regulations and ask you to verify your data we hold on you from time to time.

(b) Information, Queries & Complaints

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

As We take Your privacy seriously, We have appointed a Privacy officer (“PO”), whose responsibility is to oversee that the Company:

acts in accordance with its legal obligations and
is processing Your personal data in compliance with applicable rules and regulations.

The PO is Your contact person regarding any questions or complaints you may have relating to this Privacy Policy or Your data. Should You have any queries, complaints or require further information regarding this policy, please contact Our PO using the information below.

If you are using the services provided by Videoslots in accordance with the relevant license(s) as provided here, the following shall apply:

Full Name of Legal Entity	Videoslots Ltd (C49090)
Mailing address	The Space, Level 2 & 3, Alfred Craig Street, Pieta, PTA 1320 Malta
Email address	dpo@videoslots.com

3. YOUR DATA

(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 data relating to You as a person or individual is protected under the applicable data protection laws and legislation. However, it does not include data where the identifiers relating to a "data item" have been removed in such a way that the data is rendered anonymous, meaning when You are not or no longer identifiable (i.e. anonymous data) or data 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 data.

The table below provides a clear breakdown of:

What kind of data we collect
How do We collect data
For which purpose do we collect data
What is our legal basis for processing personal data

Legal obligations – It might be necessary to process this data in order to comply with the applicable laws, regulations and legislation.

Legitimate interest – In relation to the legal basis, we process your data to operate and control our company, with the ultimate goal of providing you with the best possible service and experience. Prior to exercising this right, we carefully evaluate the potential impact that such processing may have on you and your rights. As such, we do not employ a method where your rights and interests as a 'data subject' are overridden by our interests in processing data.

Execution of the contract – Processing of personal data 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 processing your data is your consent. We will process your data only as long as we have your consent to do so. If you decide to withdraw your consent, we will stop processing your data.   Please note that any processing of personal data that we have already carried out with your consent before you withdrew it will not be affected.

Certain data We collect and process 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.

Here is a more detailed breakdown of which personal information We process, when and why We process it and which legal basis We rely on to do so:

Data collected	How do we collect Your data?	Purpose of collection	Legal basis for data processing
Identification data – e.g.: name & surname, selected username, date of birth, gender.	Requested upon registration.	(1) Identify the customer and create a unique customer profile. (2) Verify the customer for Anti-Money Laundering (“AML”) reasons. (3) Identify the customer when the contract is performed.	(1) Execution of contract. (2) Legal obligation. (3) Execution of contract / Legitimate interest.
Contact details - e.g.: email address, home address, mobile number.	Requested upon registration.	(1) Identify the customer and create a unique customer profile. (2) To be able to contact the customer. (3) Dissemination of marketing materials.	(1) Execution of contract. (2) Execution of contract. (3) Consent.
Necessary data for verification purposes -  e.g.: your ID document, proof of address, and possibly proof of income, proof of wealth.	To be uploaded on the player profile upon request, can be requested either via a pop-up message on the website or via email.	(1) Verification of the player's identity. (2) Necessary for us to comply with AML legislation.	(1) Legal obligation. (2) Legal obligation.
Financial data - e.g.: the financial data related to your chosen deposit and withdrawal method, therefore your bank details, credit card details and all relevant details related to the chosen payment method.	Collected upon deposit or withdrawal from the player's account. Can also be requested via email / chat / phone calls.	(1) Required in order to offer a service (e.g. deposit into the player's account). (2)  Required for Know-Your-Customer (“KYC”) reasons. (3) Required, for cybercrime check. (4) Required, to ensure a "closed-loop" policy.	(1) Execution of contract. (2) Legal obligation. (3) Legitimate interest. (4) Legal obligation.
Transaction details - e.g.: payments made to and received from your account.	Automatically generated when placing deposits and requesting withdrawals.	(1) Required, in order to offer you the service. (2) Required, to comply with AML law and gaming license requirements. (3) Required, to track your activity for social responsibility reasons.	(1) Execution of contract. (2) Legal obligation. (3) Legal obligation / Legitimate interest.
Game data - e.g.: details related to the games you play on our Website (your game activity).	Automatically generated by game activity.	(1) Required, in order to offer you the service. (2) Required, to comply with Remote Gaming legislation.	(1) Execution of contract. (2) Legal obligation.
Data related to your communication with us (via email, live chat, phone calls).	When you contact Us via Email correspondence and live chat. Telephone calls may be recorded to meet registration requirements.	(1) Required, in order to provide you with service (for customer inquiries, answering questions).	(1) Execution of contract.
Profile data - data related to your gaming habits and preferences.	Automatically generated by game activity or by the use of cookies, to capture preferences.	(1) Will possibly be used in an aggregated and anonymized format, to improve the service. (2) Will possibly be used, to create a more personal user experience. (3) Segmentation purpose - to place you in different groups based on different factors such as your gaming activity, etc. This is mainly so that we improve our product and service, by understanding our customers better. (4) Segmentation purpose for AML and social responsibility. (5) Targeted marketing.	(1) Legitimate interest - data in anonymised format is not personal data. (2) Consent. (3) Legitimate interest. (4) Legitimate interest. (5) Consent.
Technical data - e.g.: your internet protocol (IP) address, your login information, browser type and version, time zone, location and location, system and platform. User data - include data related to how you use our Website.	Cookie data.	(1) Location data / IP used to ensure that customers are not from a blocked country, or a high-risk country. (2) Location data / IP address is also used to ensure customers do not use a proxy or VPN, to ensure that they do not misuse bonuses or fraud when registering. (3) All other data (including location and IP) is used to improve the functionality of the website, solve technical problems and create more products for different platforms.	(1) Execution of contract. (2) Legitimate interest. (3) Legitimate interest.
My RTP data - e.g.: number of bets, total number of spins, overall RTP of your account, your own RTP compared to the game's RTP, highest win in specific games, and the bet placed, to achieve that win.	Automatically generated by games.	(1) You can see your own RTP based on your game activity - this is a feature that should give you a better game service. Our goal is to enhance the transparency for players, while ensuring compliance with consumer protection laws.	(1) Legal obligation / Legitimate interest.
Marketing and communication data - includes your preferences regarding receiving marketing messages from us and other 3rd parties (as affiliates), and your communication preferences.		(1) Own marketing via various communication channels. (2) Marketing through affiliates.	(1) Consent (granular - per channel). (2) Consent.
Cookie data - please see our Cookie Policy for further information about how and for what purpose we collect your Cookies.

Our own marketing activities -

In accordance with the applicable laws and on the basis of Our legitimate interest or Your consent, We may also use your personal data 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 third-party data processors who process your data on our behalf and follow our instructions.

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 data 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 process certain personal data that relates to you to a level that exceeds the legal requirements slightly but is done for your safety and peace of mind. We have a legitimate interest in doing so, as We feel responsible for your online security. Our checks are designed to be minimally invasive and respect your rights and freedoms as a data subject.

Your personal data will only be processed for the purposes for which it was collected. In the event that we need to process it for any other purpose, we will conduct a compatibility assessment to ensure that the new purpose is compatible with the original purpose for which the data 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.

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 process your personal data on our behalf for the purposes outlined in this privacy policy.

This processing is conducted under our direction, ensuring that your data is handled in accordance with applicable data protection laws and our commitment to safeguarding your privacy. We are committed to ensuring the security of your personal data. Therefore, we require all third parties with whom we share your data to uphold the same standards of security and to comply with applicable data protection laws.

Our third-party service providers are prohibited from using your personal data for their own purposes unless legally permitted or required. They may only process your personal data for specific purposes that align with our instructions. To ensure compliance and security, we conduct thorough vetting of our partners and enter into stringent data processing agreements as necessary. This ensures that your data is handled appropriately and safeguarded throughout the processing lifecycle.

Game Providers - At times, Our game providers will need access to selected data (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 data 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 data 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.

Intra-Group Sharing

To effectively manage and enhance our services, companies within our corporate group may share and access customer data 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.

5. SHARED RESPONSIBILITY FOR PERSONAL INFORMATION

The Company may share responsibility for personal information with one or more organizations when they jointly collect, use, 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 data 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 data'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 data to countries that are deemed to provide an adequate level of protection for personal data, 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 data 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 potential 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 processing, 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 processing is necessary for the performance of a contract with you;
The processing is authorized by law; or
The processing 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. DATA 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 your personal data.

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 data are granted access. Additionally, all individuals with access to your personal data are bound by strict confidentiality agreements.

We have established robust procedures to identify and address any suspected or actual data security breaches. If such an event occurs, we will notify you, the data subject, 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.

While we take every reasonable step to protect your data, 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 data 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. DATA RETENTION

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

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

If you have questions about our data retention practices or the specific retention period for your personal data, 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, have certain rights regarding your personal information. You have the right to:

Request Access to Your Personal Data - You have the right to request a copy of the personal data 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 Data - If the personal data 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.

Request to have Your personal data deleted - You can request to have Your personal data deleted if We no longer have a legal reason to continue to process or store it. 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 data or if We have the reason that it is necessary to store Your personal data, in order to defend ourselves in a legal dispute.

Object to the processing of your personal data - where We rely on Our legitimate interest (or a third-party legitimate interest) to process your personal data and you feel that We process your data in such a way that it violates your fundamental rights and freedoms. However, in some cases, We may be able to demonstrate that We have a compelling legitimate ground to process your data which may override your rights and freedoms. You may submit your objections to the processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our PO.

Withdraw Your consent at any time when we rely on Your consent to process Your personal data - Termination or withdrawal of your consent will not affect the legality of the processing 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 data 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 Processing - You may request that we temporarily restrict the processing of your personal data in the following circumstances:

While we verify the accuracy of your data.
If the processing is unlawful but you do not want the data deleted.
If you require us to store the data for the purpose of establishing, exercising, or defending legal claims.
If you have objected to processing, but we need to verify whether our legitimate grounds override your objection.

Request Transfer of Your Personal Data (i.e. data portability) - This means that you may request us to transfer certain data about you that We have processed to a third party. This right only applies to data acquired through automated sources that you originally gave Us consent to use, or where We used your data, 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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.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.

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