Privacy Policy

OUR COMMITMENT TO ACCOUNTABLE PRIVACY PRACTICES

This is the privacy policy for NorthStar Gaming (Ontario) Inc. (“NorthStar Gaming”) and our affiliated companies (“ NorthStar Gaming Companies”) that applies to NorthStar Gaming’s operation of lottery schemes that are conducted and managed by iGaming Ontario. It covers all related websites, applications and services that do not have a separate policy. A reference to “we”, “us” or “our” is a reference to the NorthStar Gaming Companies.

This policy is available to players at all times on the websites operated by NorthStar Gaming – www.northstarbets.ca – and by request to the Chief Privacy Officer at privacy@northstarbets.ca. The Player Agreement is also available to all times on the website operated by NorthStar Gaming. Questions with respect to this policy or the Player Agreement may also be forwarded to the Chief Privacy Officer prior to, during and after a player opens an account with us.

We protect your personal information in accordance with applicable law, including the Registrar’s Standards for iGaming,Canada’s Anti-Spam Legislation, Personal Information Protection and Electronic Documents Act and other applicable laws, including the Freedom of Information and Protection of Privacy Act with respect to the personal information collected, used and disclosed on behalf of and as agent to iGaming Ontario, and iGaming Ontario’sPrivacy Directive,Customer Care and Player Dispute Resolution Policy, and System, Data and Records Retention Policy. This privacy policy governs the collection, use, disclosure, retention and other processing of personal information by NorthStar Gaming Companies. It is incorporated into and forms part of the terms and conditions of the Player Agreement. Any conflict or inconsistency between this privacy policy and the terms and conditions shall be resolved in accordance with section 4 of the Player Agreement.

We may change this policy from time to time. If you decide to continue to use our products and services after we make changes, you may be required to consent to any material changes to the policy or any updated policy when you log in to your player account.

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

Certain digital properties and services may be subject to additional notices or policies. We may link to websites or applications outside of our control (including our payment processors, geolocation service, identification verification service, sports betting service) which may have their own policies. Our games, products and services are also subject to any applicable terms and conditions of the Player Agreement.

iGaming Ontario

NorthStar Gaming collects personal information on behalf of and as agent for iGaming Ontario. iGaming Ontario has appointed NorthStar Gaming as its agent for purposes of the operation of online lottery schemes that are conducted and managed by iGaming Ontario pursuant to section 6.1 of the Alcohol and Gaming Commission of Ontario Act, 2019 and Ontario Regulation 722/21. The information collected, used and disclosed on behalf of iGaming Ontario is collected, used and disclosed pursuant to the Freedom of Information and Protection of Privacy Act. NorthStar Gaming is running its website and providing its offerings as part of the open and regulated internet gaming (igaming) market in Ontario conducted and managed by iGO and is collecting, using and disclosing Personal Information on behalf of, and as agent to, iGO.

Complaints

NorthStar Gaming has a complaints process to address complaints, including complaints related to the collection, use and disclosure of personal information. If your complaint about the collection, use or disclosure of personal information has not been resolved through the customer care complaints process, you may ask the Chief Privacy Officer to resolve questions or concerns. To do so, you may email the Chief Privacy Officer at privacy@northstarbets.ca. If the Chief Privacy Officer is not able to resolve your questions or concerns, you may escalate your complaint to iGaming Ontario by calling or emailing at: igaming@igamingontario.ca

What is Personal Information?

Personal information means recorded information about an identifiable individual. It is collected and used by NorthStar Gaming Companies to provide the services to you that are contemplated under the Player Agreement and to comply with NorthStar Gaming Companies legal obligations. The following are examples of personal information that NorthStar Gaming Companies may collect and use:

• Identity information, such as full name and confirmatory documentation, such as driver’s licence, passport, or other government-issued official identification documents, which may include photographs,
• Demographic information, such as age and gender,
• Contact information, including email address, residential address, telephone number,
• Location information, including the location of the device you use to access our website or applications,
• Professional and employment information, such as your occupation or employer’s name and contact information,
• Banking or financial information, such as payment or withdrawal account information, including credit cards, debit cards or similar methods of payment
• Transaction information, including play or payment history, customer services history, or other information related to transactions between you and NorthStar Gaming Companies and its service providers, including gaming-related suppliers who provide games requested by you.

In general, NorthStar Gaming Companies collects and uses personal information for (1) program, service or product administration, (2) analysis and improvement of our products, services, programs, offerings, and processes, and (3) compliance with applicable laws and to maintain the integrity of the operations NorthStar Gaming Companies.

The following types of information may be collected through your account registration and in administering your account and providing you with the services you have requested, including the playing of games and wagering:

• Name
• Date of Birth
• Full Home Address
• Email Address and Telephone Number
• Transaction and Play History
• Supporting Documents to Verify Identify
• Device Information and Connection IP Address
• Payment Information
• Withdrawal Account Information and Supporting Documentation
• Language and Marketing Preferences
• Device Location
• Responsible Gambling Settings and Limits
• Username and Password
• Security Questions and Answers
• Occupation and Industry
• Customer Service Records
• Player ID

Personal information will usually be collected during one or more of the following periods:

• Account Registration and Activation, including any required ID verification
• Use of Services, including for geolocation confirmation, transaction, responsible gambling, compliance purposes, and customer services
• Purchasing and Withdrawals
• Inactivity and Deletion

The personal information may be disclosed to third party service providers to NorthStar Gaming Companies (“Suppliers”), including gaming-related and non-gaming-related suppliers for identification and address verification, geolocation confirmation, content providers, payment and banking services, and responsible gambling services..

Accuracy

We have an obligation to keep personal information accurate and up-to-date. Our ability to do so requires you to ensure that the information that you have provided to us is accurate and up to date. It is a condition of opening an account with NorthStar Gaming and maintaining an account that you provide us with accurate and up-to-date information that is required for us to perform services on behalf of and as agent to iGaming Ontario, and to ensure that the information remains accurate and up-to-date. As provided for in the Player Agreement, if you discover any inaccuracy or error in the information that is contained in your Player Account, or if you suspect that such an inaccuracy or error may exist, regardless of who is responsible for the inaccuracy or error, you shall immediately contact Customer Support at the number shown below[?]to provide the accurate and up-to-date information.

Consent

The Player Agreement and this Privacy Policy require the player to consent as part of the account registration process to the collection, use and disclosure of personal information in order to register an account and to maintain the player account. Should there be material amendments to this Privacy Policy, the player will be required to provide further consent to the collection, use and disclosure of personal information pursuant to the amended Privacy Policy.

We collect personal information you provide directly to us when you register an account to be a customer, play our games, purchase our products, use or attend our services, or fill out our surveys. We collect information we get from third parties or from you when you visit us, call us or you use our services. Unless the information collected or compiled is sensitive in nature, we assume your consent for all purposes set out in this policy where there has not already been active consent as noted below.

Commonly Collected Personal Information	Purpose
Contact information such as name, address, postal code, email address, telephone number	provide requested games, products and services and related non-promotional communications provide requested information, rewards points and receipts verify delivery provide a customized experience develop better games, products and services promote our games, products and services
Transaction information relating to games, products and services purchased or used and customized experience history	provide requested games, products and services and related non-promotional communications provide requested information, rewards points and receipts verify delivery provide a customized experience develop better games, products and services promote our games, products and services
Demographic and survey information such as postal code, gender, marital status, birth date/year, interests, household expenditures, reasons for cancellation and other customer service information, location preferences, interests and other preferences	provide a customized experience develop better products and services promote our games, products and services
Social media identifiers (such as single sign on through Facebook, Google or other social media accounts) and other information you share with us or make public via your social networking platform. You may control what information you share through the social networking sites’ privacy settings.	verify your identity when you use social login so that you may access your account and use our services provide a customized experience develop better games, products and services
Player Account id and passwords	verify your identity so that you may access your account and use services
Credit card, debit card, Interac, PayPal, banking information and similar payment methods used to fund the Player Account, and transaction ID	to complete account registration, wagers within games, sale or donation to process refunds and apply credit to track your purchase history in PayPal or other payment processor
Audio or video recordings if you call us or otherwise make contact with us	to create a record of our interaction for security, training and quality assurance purposes
Usage data, including content and advertisements viewed on our digital properties, search history, content you share, products and services you download, purchase or subscribe for, language preference, transaction history, time spent and other digital information through cookies, pixel tags, web beacons, and other technologies. We also collect information about the site you came from before visiting our digital properties and the site you go to next.	provide a customized experience provide access to the requested services, including for game play and wagering purposes develop better games, products and services promote our games, products and services advertising delivery verification
Your device and location. We collect information about your device such as IP address, browser type, device type, unique device identifiers and operating system. We also collect information about your location, if enabled on your device or derived from your IP address.	provide a customized experience develop better games, products and services promote our games, products and services ensure geolocation and compliance with legal requirement that game play and wagering only occurs in Ontario
User-generated content and public activities such as comments on online forums, public user profiles you generate and classified listings you create. This information is considered public and is subject to the applicable terms of use.	promote our games, products and services provide a customized experience develop better games, products and services

Additional detail about what information we collect and why:

• Customized experience and promotions: We tailor content, recommendations, communications and advertising to your interests, providing you with more relevant information. We may use your contact and transaction information, usage and device data and other personal information to provide you with content recommendations and tailored communications, and to send promotional communications about our games, products and services, to track your use of our games, products and services across the devices that you use to access our digital properties, and to provide you with a customized experience.
• Non-promotional communications: We use your contact and transaction information to provide you with communications about games, products and services you play, purchase or use. You may not opt out of these communications, however, you may close your account.
• Internal analytics: We use IP addresses, cookies, pixel tags, web beacons and other technologies to gather demographic and statistical information about our users, including information about user behaviour and interaction with our digital properties and with emails and other communications we send to you, and your location and device type, to administer our digital properties, to understand how you interact with us and our digital properties, to improve our games, products and services, to develop games, new products and services, for systems administration and to diagnose problems with our servers, to detect fraud and to improve security.
• Enforce our terms and conditions: We may use your personal information to contact you regarding or otherwise enforce issues with your use of services such as posting on online forums, subject to our applicable terms and conditions.
• Other administrative reasons: If you make a complaint or send a request to customer service, we will keep the relevant information to investigate your complaint or request and respond to you. If you provide freelance or other services to us, we may collect your social insurance number for tax reporting purposes and other information required to enter a contract with and pay you. We use your personal information for the purposes of managing, administering, collecting or enforcing your accounts, maintaining business records for a reasonable time and generally managing and administering our business and meeting relevant Canadian and international regulatory, legal, insurance, audit, security and processing requirements.
• Corporate reasons: NorthStar Gaming Companies may disclose your personal information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We require such parties to treat your personal information in accordance with this privacy policy and to use and disclose it only for the purposes for which it was collected.
• As permitted or required by law: NorthStar Gaming Companies may disclose your personal information as permitted or required by law including to third parties if we believe you have violated our terms and conditions, if we need to comply with applicable law including lawful access requests, or for certain business transactions. NorthStar Gaming Companies have lawful obligations to provide information, including personal information, to the Alcohol and Gaming Commission of Ontario, which regulates NorthStar Gaming Companies and the services it provides under the Gaming Control Act, 1992 and to iGaming Ontario, which is authorized to conduct and manage lottery schemes that are online pursuant to the Alcohol and Gaming Commission Act, 2019. Both the Alcohol and Gaming Commission of Ontario and iGaming Ontario are required to collect, use and store any such information in accordance with the Freedom of Information and Protection of Privacy Act.
• Compliance with regulatory and contractual obligations: Your personal information may be collected, used and stored by NorthStar Gaming Companies and its service providers to comply with the regulatory standards and requirements under the Registrar’s Standards for iGaming and the obligations that NorthStar Gaming Companies have to iGaming Ontario. These standards, requirements and obligations include the collection and verification of identification and financial information, payment processing, the use of a geolocation service to ensure players are in Ontario during game play and when wagering, and the detection and prevention of fraud, money laundering and other criminal activities. This information may be shared or transferred to NorthStar Gaming Companies service providers who provide the required services for NorthStar Gaming Companies to comply with these standards, requirements and obligations.
• Provide the requested services. Your personal information may be collected, used and stored by NorthStar Gaming Companies and its service providers to provide the services that you have requested, including but not limited to account registration, game play, watering activities, depositing and withdrawing of funds, and for similar purposed contemplated under the terms and conditions.
• Your information may be transferred or stored outside of Canada: Your personal information may be processed and stored outside of the province in which you reside and/or outside of Canada by us or a third-party service provider for the purposes set out in this policy. Under the laws of these jurisdictions, in certain circumstances foreign courts, law enforcement or regulatory agencies may be entitled to access your personal information. Our agreements with third-party service providers require that any personal information that may be transmitted outside of Canada may only be transmitted to jurisdictions that have similar privacy protection legislation, including the General Data Protection Regulation (GDPR) in the European Union, in which practices are at least equivalent to those in Ontario and Canada.

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

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

Our use of cookies: If you use any of our digital properties we and our third party service providers may use cookies and other technologies such as JavaScript, Adobe Flash, web beacons and pixels to provide the services necessary for you to participate in game play and wagering, to understand better your behaviour and interaction with our digital properties and with communications sent to you (such as open and click activity) and to improve your user experience and recognize you and/or your device, to make sure our ads and dynamic content are served correct, to improve the performance of our digital properties, and to comply with regulatory standards and requirements and other lawful obligations. NorthStar Gaming Companies and its service providers use both session cookies (used only during your visits and expire when you close your browser) and persistent cookies (stored on your device for longer than just your visit) on NorthStar Gaming Companies internet websites. Cookies collect certain information about your device, such as IP address, operating system, and browser specifications, but do not collect your name or email address. A cookie may recall a set of preferences you have set and record items for which you have registered. Storing cookies on your browser allows us to give you customized experiences. We may use third party service providers in order to gather such data on user behaviour and to provide us with other data collection, reporting, ad response measurement and site analytics. These third-party service providers may include Google Analytics and Google Firebase Analytics, which use data as described here: How Google uses data when you use our partners' sites or apps . You may opt-out of data analytics services provided by Google at the Google Analytics opt-out page.

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

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

Certain services, including those provided by GeoComply, will make use of your location data. If you such services, you consent to us and GeoComply transmitting, collecting, maintaining, processing and using your location data in order to provide and improve location-based services. You may withdraw this consent at any time by turning off the location settings or by notifying us in writing that you would like to withdraw such consent.

In general, in addition to your active consent at the time of opening an account and for any material changes to the policy, we assume your consent for purposes set out in this policy. If it is reasonable to do so, we will provide further notice at the point of collection. Where consent is required to use your personal information, you may opt-out of our use of your information. More information about accessing, updating and opting-out may be found below.

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

• You have consented.
• We are permitted or required to do so by law.
• We have engaged an authorized service provider to carry out services on our behalf. Personal information may be transferred outside of Ontario and/or outside of Canada for processing or storage.
• We are required to share the information with service providers and gaming-related suppliers with respect to the playing of games and wagering requested by you and to allow them to keep track of what they have provided. We have in place measures to keep personal information we collect secure , which may include:

• Limiting the number of people who view or process personal information
• Locking and restricting access to paper files
• Using appropriate methods to secure electronic files, including computer passwords, firewalls and encryption.

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

Safeguards: The NorthStar Gaming Companies use technical, contractual, administrative and physical security measures to protect your personal information in a manner that is reasonable for the nature of the personal information you provide to us. For example, our agreements with third-party service suppliers who may have access to your personal information require those suppliers to protect your personal information. If you are a register for our services, access to your information on the servers used to store your information is protected, and we help protect the security of your credit card information by using industry standard secure sockets layer (SSL) encryption technology.

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

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

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

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

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

• updating or deleting your account information for the relevant game, product or service;
• updating your preferences if a customer preference option is provided by the relevant game, product or service;
• Google Analytics: you may opt-out of data analytics services provided by Google by visiting the Google Analytics opt-out page and installing the add-on for your browser;
• Offers and advertising: you may opt-out of promotions and bonuses;
• You may opt-out of online behavioural advertising where applicable by clicking the icon on ads appearing on our websites or by visiting https://youradchoices.ca/choices/ and Understanding Digital Advertising - NAI: Network Advertising Inititative (thenai.org). More information about online behavioural advertising is here.
• Contact us for the relevant product or service by telephone or email. We will be happy to help you update your information or address any concerns you may have.

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

Chief Privacy Officer
NorthStar Gaming Inc.
342 Queen Street West, Suite 200

Toronto, Ontario M5V 2A2

privacy@northstarnets.ca
 

Incident Breach Management and Cooperation

If we learn of a breach or potential breach of the protection of personal information, we will take a number of important steps. The Chief Privacy Officer will work with others within NorthStar Gaming and its service providers to take steps necessary to contain the breach and to identify who has been affected by any breach. This initial investigation will also determine whether the breach would allow any unauthorized access to any other personal information and, if so, will result in other necessary steps such as changing of passwords or similar actions.

NorthStar Gaming will also notify iGaming Ontario and assist iGO and other authorities in breach management and the handling of any results from a breach. The other authorities to whom NorthStar Gaming will provide notification include the Alcohol and Gaming Commission of Ontario, the Information and Privacy Commission of Ontario and, where relevant, the Office of the Privacy Commissioner of Canada.

NorthStar Gaming will notify you of any breach of your personal information at the first reasonable opportunity, including what information is involved. We will also advise you at the first reasonable opportunity of the steps being taken to address the breach and if we have notified the Information and Privacy Commissioner of Ontario and/or the Office of the Privacy Commissioner of Canada. You are also entitled to make a complaint to the Information and Privacy Commissioner of Ontario and/or the Office of the Privacy Commissioner of Canada.

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

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

You may visit www.priv.gc.ca if you are interested in learning more about privacy or wish to contact the Office of the Privacy Commissioner of Canada or https://www.ipc.on.ca to contact the Information and Privacy Commissioner for Ontario with respect to the collection, use and storage of personal information by the Alcohol and Gaming Commission of Ontario and iGaming Ontario.

This Privacy Policy is effective as of April 4, 2022.