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Privacy Policy

This Privacy Policy outlines how pacific-spins-casino, operated exclusively at pacific-spins-ca.com, collects, uses, discloses, and protects personal information of players and website visitors in accordance with Canadian laws and all applicable online gambling industry standards. This policy applies to all individuals accessing or using pacific-spins-ca.com. Effective as of 6 November 2025.

Who We Are

OBSERVE: pacific-spins-casino is operated by a Limited Liability Company registered in the Union of Comoros, providing online casino services for Canadian users via pacific-spins-ca.com.
EXPAND: Legal identification and contact points are required for regulatory transparency and user recourse.
REFLECT: Full operator details and contact information are presented for user and regulator reference.

  • Legal Entity: pacific-spins-casino LLC, registered in Hamchako, Mutsamudu, Anjouan, Union of Comoros.
  • Company Registration Number: 15757
  • Legal Address: Hamchako, Mutsamudu, Anjouan, Union of Comoros
  • Gaming License: Issued by the State of Anjouan, Union of Comoros under Computer Gaming Licensing Act 007 of 2005 (active validity)
  • Website: https://pacific-spins-ca.com
  • Data Protection Contact: Emma Tremblay (Data Protection Officer, DPO) - Contact email: [email protected]

What Personal Data We Collect

OBSERVE: Various categories of personal and technical data are collected to enable lawful, secure, and effective service provision.
EXPAND: Data collection encompasses registration, gameplay, payments, technical operations, and analytics.
REFLECT: Comprehensive data categorization ensures transparency and regulatory compliance.

  • Personal Identification Data: Full name, date of birth, residential address, email address, and phone number (where provided).
  • Account Data: Username, password (hashed), account preferences, and verification documents (for KYC/AML compliance).
  • Payment Data: Bank account numbers (masked), credit/debit card details (tokenized), e-wallet identifiers, and transaction histories.
  • Technical Data: IP address, device type, operating system, browser type, log files, and access timestamps.
  • Behavioral Data: Betting and gaming history, transaction records, site navigation paths, clickstream data, and activity logs.
  • Cookies & Tracking Technologies: Session cookies, persistent cookies, third-party cookies, web beacons, and similar technologies (see "Cookies & Tracking Technologies" section).

Legal Basis for Processing

OBSERVE: Processing of personal data must have a clearly stated legal basis under Canadian and international law.
EXPAND: Compliance with consent, contract, legitimate interest, and regulatory obligation is required.
REFLECT: All processing activities are mapped to their lawful grounds to ensure user rights and regulatory alignment.

  1. User Consent: Obtained for marketing communications, cookies, and where required for specific data uses. Consent can be withdrawn at any time.
  2. Contract Fulfillment: Data processing necessary for account creation, identity verification, provision of gaming services, and processing payments/winnings.
  3. Legitimate Interests: Prevention of fraud, ensuring network and information security, optimizing user experience, and conducting business analytics. These interests are balanced with user privacy rights.
  4. Legal Obligations: Compliance with anti-money laundering (AML), know-your-customer (KYC), tax reporting, and other regulatory requirements applicable in CA and the Union of Comoros.

Regional Compliance Note: Processing aligns with Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant CA provincial privacy laws.

Purpose of Processing

OBSERVE: Personal data is processed for multiple distinct but related purposes.
EXPAND: Each purpose corresponds to operational, regulatory, or business needs.
REFLECT: Users are informed of all purposes for which their data may be used.

  • Service Provision: Enabling account registration, verification, deposits, withdrawals, and access to casino games on pacific-spins-ca.com.
  • Customer Support: Managing user inquiries, complaints, and technical assistance requests.
  • Compliance & Security: Conducting AML/KYC checks, fraud detection, and risk management.
  • Analytics: Monitoring site usage, user behavior, and performance metrics to improve services and optimize offerings.
  • Marketing (with consent): Sending promotional offers, newsletters, and relevant communications, subject to user opt-in/out preferences.

Disclosure & Sharing

OBSERVE: Data may be disclosed to third parties under strictly regulated circumstances.
EXPAND: The categories of recipients and conditions of disclosure must be transparent.
REFLECT: All disclosures are subject to legal safeguards and user consent where required.

  • Payment Partners: Banks, card processors, and e-wallet providers for the processing of financial transactions, subject to secure protocols and regulatory requirements.
  • Service Providers: IT support, game developers, data storage vendors, and analytics providers under strict confidentiality obligations.
  • Regulatory Authorities: Law enforcement, financial regulators, and authorities in CA and the Union of Comoros, as required by law.
  • Affiliates & Business Partners: Marketing affiliates and advertising networks, only with user consent for direct marketing purposes.

Legal Obligation: All third parties must process data in accordance with applicable privacy laws and are subject to regular due diligence reviews.

International Transfers

OBSERVE: Data may be stored or processed outside Canada, particularly in the Union of Comoros.
EXPAND: International transfers must include adequate data protection mechanisms.
REFLECT: Users are informed of transfer safeguards and legal rights.

  • Countries/Regions: Personal data may be transferred to and processed in the Union of Comoros, EU/EEA, and other jurisdictions where service providers are located.
  • Protection Guarantees: Standard contractual clauses (SCCs), contractual data protection commitments, and industry certifications (e.g., ISO 27001) are implemented to ensure adequate protection.
  • User Rights: Users may request further information on data transfer mechanisms at any time.

Regional Compliance Note: All international transfers comply with PIPEDA, CA provincial requirements, and industry best practices for cross-border data protection.

Data Retention

OBSERVE: Retention periods and deletion criteria must be specified by data type and legal requirement.
EXPAND: Balancing regulatory obligations (such as AML/KYC) with user privacy.
REFLECT: Clearly communicated procedures for data minimization and secure disposal.

  • Personal & Account Data: Retained for the duration of the account plus up to 5 years after account closure, or as long as legally required for regulatory and dispute purposes.
  • Payment & Transaction Data: Retained for at least 5 years following transaction date to comply with anti-money laundering and financial reporting obligations.
  • Behavioral & Analytical Data: Anonymized or deleted within 2 years after collection, unless longer retention is required for security or regulatory investigations.
  • Deletion Criteria: Personal data is deleted upon user request (where permitted), expiration of statutory retention periods, or when processing purposes are fulfilled.

Legal Protection: All data deletion is performed securely, with audit trails maintained for compliance verification.

Your Rights

OBSERVE: Users are entitled to a broad set of rights under GDPR, PIPEDA, and analogous CA privacy laws.
EXPAND: Procedures and timeframes for exercising these rights must be transparent and accessible.
REFLECT: Users are empowered to control their data with clear instructions and legal guarantees.

  1. Access: Request confirmation of whether pacific-spins-casino processes your personal data and receive a copy of such data free of charge.
  2. Correction: Request rectification of inaccurate or incomplete personal data.
  3. Deletion ("Right to be Forgotten"): Request erasure of your data where it is no longer necessary, where consent is withdrawn, or where processing is unlawful, subject to regulatory retention requirements.
  4. Restriction: Request restriction of processing where accuracy is contested, processing is unlawful, or you have objected to processing.
  5. Objection: Object to processing based on legitimate interests, including profiling for direct marketing purposes.
  6. Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and request its transfer to another controller where technically feasible.
  7. Withdrawal of Consent: Withdraw consent for marketing or other voluntary processing at any time without affecting the lawfulness of processing based on consent before withdrawal.
  8. Exercising Rights: Submit requests via email to [email protected] or through the user account dashboard.
  9. Response Timeframes: All rights requests will be addressed within 30 days of receipt, with possible extension for complex cases (with notification).
  10. No Charge: Users will not be charged for exercising their data protection rights unless requests are manifestly unfounded or excessive.

Regional Compliance Note: These rights are aligned with PIPEDA, CA provincial law, and relevant international standards. Users may escalate complaints to the Office of the Privacy Commissioner of Canada or applicable provincial authorities.

Cookies & Tracking Technologies

OBSERVE: The use of cookies and similar technologies must be disclosed and user control provided.
EXPAND: Each cookie type and its purpose should be clearly described.
REFLECT: Users are empowered to manage their preferences easily.

  • Session Cookies: Temporary cookies used for secure navigation and authentication during a browsing session. Automatically deleted when browser is closed.
  • Persistent Cookies: Remain on the device for a defined period to remember user preferences and enhance experience.
  • Third-Party Cookies: Set by analytics providers (e.g., Google Analytics), advertising networks, and affiliates for analytics and targeted advertising (with user consent).
  • Purpose of Cookies: Functional (enabling core site features), analytics (usage statistics), advertising (personalized offers), and security (fraud detection).
  • Management: Users can manage or disable cookies via browser settings or through the cookie consent panel on pacific-spins-ca.com. Note that disabling certain cookies may affect site functionality.

Data Security

OBSERVE: Robust security measures must be implemented and communicated to users.
EXPAND: International standards and incident response protocols are critical for user trust and regulatory compliance.
REFLECT: All reasonable steps are taken to protect data confidentiality, integrity, and availability.

  • Encryption: All personal and payment data is encrypted in transit using TLS 1.2+ and at rest using industry-standard encryption algorithms.
  • Access Controls: Multi-factor authentication for staff, strict role-based access controls, and regular access audits.
  • Security Audits: Regular internal and external security assessments, vulnerability scanning, and penetration testing.
  • Staff Training: Ongoing data protection and cybersecurity training for all employees and contractors.
  • Incident Response: Formal procedures for detection, containment, notification, and remediation of data breaches, including regulatory notification within required timeframes.
  • International Standards: Security practices are aligned with ISO 27001 and SOC 2 frameworks where applicable.

Legal Disclaimer: While all reasonable measures are implemented, no system can guarantee absolute security. Users are encouraged to use unique, strong passwords and to notify pacific-spins-casino of any suspected unauthorized activity immediately.

Complaints & Contacts

OBSERVE: Users must have accessible complaint channels and escalation options.
EXPAND: Clear procedures and authority contacts must be provided.
REFLECT: User grievances are handled promptly and transparently.

  • Primary Contact: Emma Tremblay, Data Protection Officer
    Email: [email protected]
    Online Form: Available via the "Contact Us" section at https://pacific-spins-ca.com/contact
  • Postal Address: Hamchako, Mutsamudu, Anjouan, Union of Comoros
  • Complaint Procedure:
    1. Submit complaint via email, online form, or in writing.
    2. Receive written acknowledgment within 7 days.
    3. Investigation of complaint and response within 30 days of receipt.
    4. If unsatisfied, escalate to relevant supervisory authorities (see below).
  • Supervisory Authority:
    • Office of the Privacy Commissioner of Canada
      Website: https://www.priv.gc.ca/en/
      Phone: 1-800-282-1376
    • Provincial privacy authorities (where applicable)

Updates

OBSERVE: Users must be informed of material policy changes in advance.
EXPAND: Notification methods, versioning, and user options are required.
REFLECT: Policy changes are transparent, and users' rights are preserved.

  • Notification Procedures: Users will be notified of material changes to this Privacy Policy via email, website banners, and alerts in their account dashboard.
  • Advance Notice: For significant changes, at least 30 days' advance notice will be provided prior to the effective date.
  • User Options: Users may object to changes or close their account before the new policy takes effect without penalty.
  • Version Control: This Privacy Policy is version-controlled. Last updated: 6 November 2025
  • Changelog: A summary of material changes will be available at the end of this document or upon request.