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Privacy Policy

This Privacy Policy explains how Casino Classic, operating at casinoclassic-win.ca within the Casino Classic project (the "Website"), collects, uses, discloses, and protects personal information of players and other Website visitors. It applies to all individuals who access or use the Website, create an account, participate in games, promotions, or communications, or otherwise interact with us online.

By using the Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, please do not use the Website or our services.

Effective date: 1 January 2026

Who We Are

For the purposes of privacy and data protection laws, the entity responsible for your personal information (the "controller") depends on your location when using casinoclassic-win.ca and the Casino Classic project:

  • Canadian players outside Ontario: Your personal information is primarily handled on behalf of Fresh Horizons Ltd, licensed by the Kahnawake Gaming Commission (Interactive Gaming Permit No. 00812) for online casino services to Canadian players outside Ontario.
  • Players located in Ontario, Canada: Your personal information is primarily handled on behalf of Apollo Entertainment Ltd, registered as an internet gaming operator with iGaming Ontario (IGO) and regulated by the Alcohol and Gaming Commission of Ontario (AGCO).
  • Players outside Canada (where applicable): Certain services and processing activities may be carried out on behalf of another group company (including an entity referred to as "Holdings Ltd") licensed by the Malta Gaming Authority (MGA) for rest-of-world markets. This does not affect the rights described in this Policy.

The exact legal addresses and corporate registration numbers of these entities are recorded in the relevant corporate and licensing registers and may vary by jurisdiction. You can obtain the current registered office details by contacting us through the channels described below or by consulting the public registers of the Kahnawake Gaming Commission, iGaming Ontario/AGCO, or the Malta Gaming Authority.

Data Protection Contact: We have designated a privacy and data protection contact team (including a Data Protection Officer, where required by law) responsible for overseeing questions related to this Privacy Policy and our data handling practices. You can contact the privacy team by:

  • Using the support and contact features available on casinoclassic-win.ca (for example, live chat or in-account messaging) and indicating that your request concerns "Privacy" or "Data Protection"; or
  • Using any contact or feedback forms available on the Website and addressing your message to the "Privacy/Data Protection" team.

Requests submitted through these channels will be routed to the appropriate privacy contact for Fresh Horizons Ltd, Apollo Entertainment Ltd, or the relevant group company, depending on your location.

What Personal Data We Collect

We collect only the personal information that is reasonably necessary to operate and improve Casino Classic on casinoclassic-win.ca and the Casino Classic project, comply with legal and regulatory obligations, and provide you with a safe and fair gaming experience.

Identification and Contact Data

  • Basic identification: Full name, date of birth, gender (where provided), country and province/territory of residence.
  • Contact details: Email address, telephone number, postal/ billing address, preferred language.
  • Account information: Username, player ID, security questions/answers (where used), communication preferences.

Technical and Usage Data

  • Technical identifiers: IP address, device identifiers, browser type and version, operating system, time zone, language settings, referrer URLs.
  • Log and usage data: Login and logout times, session duration, pages viewed, clicks and navigation paths, error logs, and performance diagnostics.
  • Device and network data: Information about the device, internet service provider, and network connectivity used to access the Website.

Payment and Transaction Data

  • Payment details: Limited information about payment methods (such as card type, masked card number, expiry date) as provided by you or by payment providers; we do not store full card details where this is avoided by using secure payment processors.
  • Financial transactions: Deposits, wagers, wins, losses, withdrawals, bonuses credited and redeemed, loyalty points and related account balances.
  • Verification data: KYC (Know Your Customer) and AML (Anti-Money Laundering) information required to verify identity and source of funds, such as copies of identification documents (e.g., passport, ID card, driver's licence), proof of address, proof of payment method ownership, and any information collected during enhanced due diligence.

Behavioral and Gaming Data

  • Betting and gaming history: Records of games played, stakes, outcomes, time spent, gaming session history, and use of specific game features.
  • Interaction data: Clicks on promotions and banners, participation in tournaments or loyalty programs, use of responsible gambling tools (deposit limits, loss limits, time-outs, self-exclusion), and responses to in-product messaging.
  • Profile and preferences: Favourites, preferred game categories, marketing preferences and communication channels.

Cookies and Similar Technologies

  • Cookies: Small text files placed on your device to enable core Website functionality, remember preferences, perform analytics, and support advertising where permitted.
  • Similar technologies: Web beacons, pixels, tags, SDKs and local storage tools to measure usage, track the performance of content and promotions, and support security and fraud monitoring.

Communication and Support Data

  • Customer support records: Transcripts or recordings of live chats, emails, messages sent via contact forms, and internal notes related to your requests.
  • Compliance communications: Information you provide when responding to risk or compliance queries, investigations, or complaints.

Special Categories and Sensitive Data

We generally do not seek to collect sensitive categories of personal information unless required or permitted by law (for example, to verify identity or assess risk). Where we do, we will apply additional safeguards and, where required, obtain your explicit consent.

We do not knowingly collect personal information from individuals under the legal gambling age in their jurisdiction (for most Canadian provinces, 18 or 19 years of age). If we discover that an underage person has provided personal information, we will take steps to delete or anonymise it and close the account.

Legal Basis for Processing

Because Casino Classic on casinoclassic-win.ca and the Casino Classic project serves players in multiple jurisdictions, our legal basis for processing your personal information may differ depending on where you live. We aim to comply with Canadian privacy laws (including the Personal Information Protection and Electronic Documents Act - PIPEDA - and applicable provincial laws), and, where relevant, align with the European Union's General Data Protection Regulation (GDPR) and Mexican data protection law.

Consent

  • Account creation and service use: When you register or use our services, you consent to our collection, use, and disclosure of your personal information for purposes described in this Policy and in our terms and conditions.
  • Marketing communications: We will obtain your consent (express or implied, depending on jurisdiction and context) before sending promotional emails, SMS, or push notifications, in line with Canadian anti-spam requirements and other applicable laws. You may withdraw consent at any time (see "Your Rights").
  • Optional data: Where we ask for optional information or additional permissions (e.g., certain analytics or advertising cookies), we rely on your consent.

Contractual Necessity

  • Providing services: We process your personal information to open and manage your account, allow you to place bets and play games, credit and pay out winnings, manage loyalty rewards, and provide customer support.
  • Enforcing terms: Processing is required to administer and enforce our terms and conditions, including verifying eligibility, calculating bonuses, and managing promotions.

Compliance with Legal and Regulatory Obligations

  • KYC/AML requirements: Gambling, financial, and anti-money laundering regulations in Canada (including Kahnawake and Ontario), Malta, and other applicable jurisdictions require us to verify your identity, monitor transactions, and report certain activities to regulators or law enforcement.
  • Responsible gambling and consumer protection: Laws and licence conditions require us to monitor player behaviour to identify possible problem gambling and to apply self-exclusion or other interventions where needed.
  • Record-keeping and reporting: We must retain certain records for specified periods and may be required to disclose them to regulators, tax authorities, or law enforcement.

Legitimate Interests (where recognised by applicable law)

  • Security and fraud prevention: We process data to secure our systems, detect and prevent fraud, abuse, and cheating, and protect the integrity of games.
  • Service improvement and analytics: We analyse aggregate and pseudonymised data to improve Website performance, game offerings, and user experience.
  • Business operations: We process data for internal management, audit, risk management, and compliance tracking.

Where we rely on legitimate interests, we balance our interests against your rights and freedoms, and implement appropriate safeguards.

Purpose of Processing

We use your personal information only for clear, lawful purposes and do not use it in ways that are incompatible with those purposes.

Providing and Managing Casino Services

  • Creating, administering, and securing your player account.
  • Enabling deposits, wagers, gaming activity, and withdrawals.
  • Operating loyalty programs, bonuses, promotions, and tournaments.
  • Providing customer support and responding to your questions or requests.

Compliance, Risk Management, and Responsible Gambling

  • Verifying identity and age, and confirming eligibility to use our services.
  • Performing KYC/AML checks, transaction monitoring, and sanctions screening.
  • Monitoring gaming behaviour to detect potential problem gambling and offering tools such as deposit limits, time-outs, and self-exclusion.
  • Meeting record-keeping and reporting obligations under gaming and financial laws.

Improving Our Services and Website

  • Analysing how users interact with the Website, games, and features to improve usability and performance.
  • Measuring the effectiveness of campaigns, promotions, and user interface changes.
  • Developing new games, features, or tools tailored to user preferences.

Marketing and Personalisation

  • Sending promotional communications (where permitted) about Casino Classic on casinoclassic-win.ca, including offers, bonuses, and loyalty rewards.
  • Personalising content, offers, and recommendations based on your profile and gaming behaviour.
  • Conducting surveys and feedback requests to understand customer satisfaction.

Security, Fraud Prevention, and Enforcement

  • Monitoring for fraudulent activity, account takeovers, bonus abuse, collusion, money laundering, or other prohibited conduct.
  • Protecting systems and data through intrusion detection, access controls, and other security measures.
  • Investigating and enforcing compliance with our terms and conditions, house rules, and applicable laws.

Disclosure & Sharing

We do not sell your personal information to third parties. We share your personal information only as necessary for the purposes described in this Policy, and subject to appropriate safeguards and contractual protections.

Group Companies and Operators

  • Related operators: Fresh Horizons Ltd, Apollo Entertainment Ltd, and other group companies may share data among themselves as necessary to operate the Casino Classic services on casinoclassic-win.ca, comply with licensing obligations, and provide cross-jurisdictional support.
  • Intra-group transfers: Information may be shared within the group for internal administration, risk management, compliance, and consolidated reporting.

Service Providers and Business Partners

  • Payment processors and banks: To process deposits, withdrawals, and refunds; to verify ownership of payment methods; and to handle chargebacks or disputes.
  • Technology and hosting providers: To host the Website, operate game servers, store data, provide security and monitoring tools, and support customer service platforms.
  • Analytics and anti-fraud providers: To perform analytics, verify identity, assess risk, prevent fraud, and detect abuse or collusion.
  • Marketing and communications providers: To send emails, SMS, push notifications, or on-site messages, but only in accordance with your marketing preferences and applicable law.

Regulators, Authorities, and Law Enforcement

  • Gaming regulators: Kahnawake Gaming Commission, iGaming Ontario/AGCO, Malta Gaming Authority and other competent authorities may receive your personal information as part of licence conditions, audits, investigations, or regulatory reporting.
  • Law enforcement and government bodies: We may disclose information where required by law, court order, or lawful request, or to establish, exercise, or defend legal claims.

Affiliates and Advertising Partners

  • Affiliates: We may share limited, aggregated, or pseudonymised information with affiliate partners and network partners for tracking referrals and calculating commissions.
  • Advertising networks: Where permitted by law and with your consent where required, we may work with advertising networks that use cookies or similar technologies to deliver or measure advertisements relating to Casino Classic. When possible, we use aggregated or pseudonymised data.

Corporate Transactions

  • In connection with a merger, acquisition, restructuring, or sale of assets involving Casino Classic, your personal information may be transferred to a successor entity, subject to confidentiality obligations and continued protection in line with this Policy.

International Transfers

Your personal information may be transferred to and processed in countries or regions outside your province, state, or country of residence, including outside Canada. These jurisdictions may have different data protection laws, but we take steps to ensure that your information remains adequately protected.

  • Hosting and support locations: Some of our group companies, service providers, and technical partners may be located or may store data in the European Economic Area (EEA), the United Kingdom, and other jurisdictions where they operate data centres or support teams.
  • Intra-group transfers: Transfers between Fresh Horizons Ltd, Apollo Entertainment Ltd, Holdings Ltd, and other group companies are governed by intra-group agreements that impose privacy and security obligations.
  • Contractual safeguards: Where required (for example, under GDPR for transfers from the EEA or comparable rules under other laws), we use appropriate safeguards such as Standard Contractual Clauses or equivalent contractual protections.
  • Regulatory requirements: Transfers of data relating to players in regulated markets are carried out in accordance with licensing and regulatory requirements of Kahnawake, Ontario, Malta, and other competent authorities.

By using the Website, you understand that your personal information may be processed in countries with different data protection regimes. In all cases, we implement technical and organisational measures to protect your information, as described in the "Data Security" section.

Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal, regulatory, and reporting obligations. Retention periods may vary depending on the type of data, the jurisdiction, and regulatory requirements (especially for gambling and financial services).

General Retention Principles

  • Active account: For as long as your Casino Classic account on casinoclassic-win.ca remains active, we retain the personal information needed to operate the account and provide services.
  • After account closure: After you close your account or it becomes inactive, we typically retain:
    • Core account and identification records for up to 5 years following closure or last activity, or longer if required by law.
    • Transaction, KYC/AML, and responsible gambling records for up to 7 years following the last relevant transaction or activity, or longer if regulators require.
  • Logs and technical data: Access logs, security logs, and usage logs are generally retained for 6 - 24 months, depending on security and audit needs.
  • Marketing data: Information used for marketing is retained for as long as you remain subscribed and for a reasonable period afterwards (typically up to 2 years) unless you withdraw consent earlier.

Deletion, Anonymisation, and Exceptions

  • When data is no longer required, we will securely delete it or irreversibly anonymise it so that it can no longer be associated with you.
  • We may keep limited information (such as a record of your account ID, country, and key dates) to comply with our obligations, prevent fraud, maintain self-exclusion lists, resolve disputes, and enforce our terms.
  • If you exercise your rights to deletion or cancellation (see "Your Rights"), we will apply those rights in line with legal and regulatory obligations that may require continued retention of some data.

Your Rights

We respect your rights regarding your personal information and have processes to help you exercise them. These rights arise from Canadian privacy laws (such as PIPEDA and applicable provincial legislation) and, where relevant, are aligned with the rights under the GDPR and Mexican privacy law (including the Federal Law on Protection of Personal Data Held by Private Parties and its Regulations).

Access to Your Data

  • You have the right to request confirmation of whether we process your personal information and to obtain a copy of that information, subject to limited exceptions.
  • Upon verification of your identity, we will provide access in a commonly used format, unless doing so would disclose personal information about another individual or be restricted by law.

Rectification / Correction

  • You may request correction of inaccurate or incomplete personal information that we hold about you.
  • Where appropriate, we may ask for supporting documentation (for example, updated proof of address) to verify requested changes.

Deletion / Cancellation ("Right to be Forgotten" / ARCO "Cancellation")

  • You may request deletion or cancellation of your personal information when:
    • It is no longer necessary for the purposes for which it was collected.
    • You withdraw consent and there is no other legal basis for processing.
    • You believe it has been processed unlawfully.
  • We will honour valid requests unless we are required or permitted by law, regulation, or licensing conditions to retain certain data (for example, KYC/AML and gaming transaction records).

Restriction of Processing

  • You may request that we restrict the processing of your personal information in certain circumstances, for example while we verify its accuracy or assess an objection.
  • During restriction, we will limit processing to storage and necessary legal uses.

Objection to Processing

  • You may object to processing based on legitimate interests, including profiling, where applicable law provides such a right.
  • You may object at any time to the use of your personal information for direct marketing, in which case we will stop such processing.

Data Portability

  • Where applicable (for example under GDPR), you may request a copy of certain personal information in a structured, commonly used, and machine-readable format and ask us to transfer it to another controller where technically feasible.

Withdrawal of Consent

  • You may withdraw your consent at any time for processing activities that rely on consent (such as marketing communications or certain cookies).
  • Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal and may limit your ability to use certain services.

Mexican ARCO Rights and GDPR Alignment

  • If you are subject to Mexican data protection law, we recognise the ARCO rights: Access, Rectification, Cancellation, and Opposition to personal data processing, and we will address such requests in accordance with that law.
  • If GDPR applies to you (for example, if you are in the EEA), we will handle your requests in accordance with GDPR requirements, including additional rights related to automated decision-making and profiling, where applicable.

Procedures, Timeframes, and Cost

  • How to exercise your rights: Submit your request via the support or contact mechanisms on casinoclassic-win.ca, clearly stating that it is a "Privacy/Data Protection" request and specifying the right you wish to exercise.
  • Verification: We may need to verify your identity (for example by asking for login information or additional documentation) before fulfilling your request.
  • Response timeframe: We aim to respond to all valid requests within 30 days from receipt and verification, or within any shorter or longer period required by applicable law. If we need more time due to complexity or volume, we will inform you.
  • Fees: We generally do not charge a fee for processing rights requests. However, where permitted by law, a reasonable fee may be charged for excessive or manifestly unfounded requests; if so, we will inform you in advance.

Cookies & Tracking Technologies

We use cookies and similar technologies to operate the Website, enhance your user experience, perform analytics, and support marketing activities where permitted by law.

Types of Cookies

  • Strictly necessary (session) cookies: Essential for the functioning of the Website and enabling core features such as logging in, maintaining sessions, and processing transactions. These cookies are usually temporary and expire when you close your browser.
  • Functional (persistent) cookies: Used to remember your preferences (such as language, region, or display settings) and provide enhanced features. They remain on your device for a longer period or until deleted.
  • Analytics and performance cookies: Used to gather information about how visitors use the Website (e.g., pages viewed, time spent, click paths) to help us improve performance and usability.
  • Advertising and targeting cookies: Used, where permitted and with your consent where required, to deliver relevant advertisements relating to Casino Classic, measure the effectiveness of marketing campaigns, and limit the number of times you see an ad.
  • Third-party cookies: Set by service providers, analytics companies, or advertising partners to provide functionalities or metrics on our behalf.

Managing Cookies

  • Browser settings: Most web browsers allow you to manage cookies through their settings, including blocking, deleting, or disabling some or all cookies. Please note that disabling strictly necessary cookies may affect the functionality of the Website.
  • On-site tools: Where available, you may use our cookie management tools or banners to adjust your preferences for non-essential cookies.
  • Opt-outs: For certain third-party analytics or advertising cookies, you may be able to opt out through industry tools or the third party's own settings, subject to their availability and policies.

Data Security

We take data security seriously and implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

Technical Measures

  • Encryption in transit: Data transmitted between your device and the Website is protected using strong transport-layer security (such as TLS 1.2 or higher) where technically supported.
  • Encryption at rest: Sensitive data is stored using encryption or other industry-standard protection mechanisms, where appropriate.
  • Access controls: Access to systems and databases is restricted on a need-to-know basis and protected by authentication mechanisms, including passwords, access tokens, and, where used, multi-factor authentication.
  • Network and application security: Firewalls, intrusion detection/prevention systems, and security monitoring tools help to detect and mitigate threats.

Organisational Measures

  • Policies and training: Staff who handle personal information receive guidance and training on data protection, confidentiality, and security obligations.
  • Vendor management: Service providers who process personal information on our behalf are required to implement appropriate security controls and to process information only according to our instructions.
  • Audit and review: We periodically review security controls and may conduct internal or external audits or assessments as part of maintaining security and compliance.

Incident Response

  • We maintain procedures to identify, assess, and respond to suspected or actual personal data breaches.
  • Where required by law, we will notify relevant authorities and affected individuals without undue delay, providing information on the nature of the breach and recommended protective steps.

While we aim to implement security measures consistent with industry standards (and, where relevant, aligning with frameworks such as ISO 27001 or SOC 2), no system can be guaranteed to be entirely secure. You are also responsible for maintaining the confidentiality of your account credentials and for securing the devices you use to access the Website.

Complaints & Contacts

If you have questions, concerns, or complaints about how Casino Classic on casinoclassic-win.ca and within the Casino Classic project handles your personal information, you have several options.

Contacting Us

  • Step 1 - Contact customer support: Use the support channels provided on the Website (such as live chat, in-account messaging, or contact forms) and clearly state that your inquiry concerns "Privacy" or "Data Protection".
  • Step 2 - Escalation to privacy team: If your concern is not resolved at first instance, you may request that it be escalated to our privacy or data protection team (including the Data Protection Officer, where appointed).

Complaint Procedure and Timeframes

  • We will acknowledge receipt of your privacy-related complaint, typically within a reasonable time after we receive it through our support or contact channels.
  • We aim to investigate and respond to privacy complaints within 30 days, or within any timeframe required by applicable law.
  • If we cannot respond within this period, we will inform you of the delay and the expected timeframe for a full response.

Escalation to Supervisory Authorities

If you believe that your privacy concerns have not been adequately addressed, you may have the right to lodge a complaint with a supervisory authority in your jurisdiction.

  • Canada - Office of the Privacy Commissioner of Canada (OPC):
    • Website: https://www.priv.gc.ca
    • Telephone (toll-free in Canada): 1-800-282-1376
    • You may also contact the privacy commissioner's office in your province or territory, where applicable.
  • Mexico - National Institute for Transparency, Access to Information and Personal Data Protection (INAI):
    • Website: https://www.inai.org.mx
    • INAI provides mechanisms for individuals to enforce their ARCO rights and file complaints related to personal data protection.
  • European Union / EEA - Data Protection Authorities:
    • If GDPR applies to you, you may contact your local Data Protection Authority (DPA). A list of DPAs is available via the European Data Protection Board (EDPB) website at https://edpb.europa.eu.

You are encouraged to contact us first so that we can attempt to resolve your concerns directly, but you are not required to do so before contacting a supervisory authority where local law grants you a direct right to complain.

Updates

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, regulatory guidance, or technological developments.

Notification of Changes

  • Website notice: We will post the updated Policy on casinoclassic-win.ca with a "Last updated" date at the top or bottom of the document.
  • Direct communications: For material changes that significantly affect your rights or how we process your information, we will provide additional notice, which may include:
    • Email notifications (where we have your email address).
    • In-account messages or alerts.
    • Prominent banners or pop-ups on the Website.

Advance Notice and Your Options

  • Where required by law or where we consider it appropriate, we will provide at least 30 days' advance notice of material changes before they become effective.
  • During the notice period, you may review the updated Policy and, if you do not agree with the changes, you may choose to discontinue use of the Website and request account closure.
  • Continued use of the Website after the effective date of an updated Policy will be considered acceptance of the revised terms.

Version Control and Changelog

  • Last updated: January 2026
  • Recent material changes may include:
    • Clarifications regarding the roles of Fresh Horizons Ltd, Apollo Entertainment Ltd, and other group entities as controllers for different jurisdictions.
    • Enhanced descriptions of data subject rights, including alignment with GDPR and Mexican ARCO rights.
    • Additional detail regarding data retention, international transfers, and security measures.

We encourage you to review this Privacy Policy periodically to stay informed about how Casino Classic on casinoclassic-win.ca, within the Casino Classic project, protects your personal information.