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Effective Date: November 27, 2025
Version: 2025.3

Community Spirit Gaming Centre (“Community Spirit”, “we”, “us”, or “the Company”) is committed to protecting the privacy, confidentiality and security of personal information collected through our charitable gaming operations and our website. This Privacy Policy explains how we collect, use, disclose, store and protect personal information in connection with our charitable gaming centre and related online presence.

By accessing or using our website or participating in charitable gaming activities at our premises, you agree to the practices described in this Privacy Policy.

1. Definitions

For the purposes of this Privacy Policy:

“Community Spirit Gaming Centre”, “Community Spirit”, “we”, “us”, “our” means Community Spirit Gaming Centre, the operator of the charitable gaming centre and the owner of the website to which this Privacy Policy applies.

“You”, “your” means any individual who visits our website, participates in charitable gaming activities at our premises, or otherwise interacts with us.

“Charitable Gaming Centre” means the physical premises operated by Community Spirit Gaming Centre where charitable gaming activities (such as bingo and related games) are conducted and managed under the authority of OLG and the oversight of AGCO.

“Website” means the public website operated by Community Spirit Gaming Centre, and any associated pages or online content under our control that reference this Privacy Policy.

“Service” means, collectively, our charitable gaming operations, the Charitable Gaming Centre, the Website, and all related services, features and activities offered or administered by Community Spirit Gaming Centre.

“Personal Information” means information about an identifiable individual, including but not limited to name, contact details, date of birth, government-issued identification details, transaction or prize information, video images of identifiable individuals, incident reports and any other information that can reasonably be linked to an identifiable person.

“OLG” means the Ontario Lottery and Gaming Corporation, which conducts and manages charitable gaming and on whose behalf certain Personal Information is collected and processed.

“AGCO” means the Alcohol and Gaming Commission of Ontario, which regulates gaming activities in Ontario and may receive information in connection with its regulatory oversight.

“FIPPA” means the Freedom of Information and Protection of Privacy Act (Ontario), which applies to certain personal information collected by or on behalf of OLG.

“AML” means anti-money laundering, including measures, processes and obligations designed to detect and deter money laundering and related financial crime.

“PCMLTFA” means the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) and associated regulations, which set out certain AML obligations applicable to reporting entities.

“Law Enforcement” means police services or other public authorities authorized to enforce applicable laws, including criminal, regulatory or public safety laws.

“Service Provider” means a third-party organization or individual engaged by Community Spirit Gaming Centre to provide services in support of the Service, including but not limited to website hosting, email hosting, analytics, IT support, security, data storage or backup.

“Casino Time Inc.” means Casino Time Inc., an independent third-party gaming operator whose websites may be linked from our Website through outbound Referral Links.

“Casino Time Partners Inc.” means Casino Time Partners Inc., a corporate affiliate or related entity of Casino Time Inc. that operates or administers marketing or affiliate programs and whose websites may be linked from our Website through outbound Referral Links.

“Affiliate Link” or “Referral Link” means an outbound link on our Website that directs you to a third-party site (such as those of Casino Time Inc. or Casino Time Partners Inc.) and may contain tracking or referral parameters (for example, a “btag” or similar code) used by that third party to recognize that the visit originated from our Website.

“Aggregated Data” means summary information that does not identify individual persons, such as total number of referred players, aggregate deposit amounts or aggregate revenue figures.

“Cookies” means small data files stored on your device by your web browser at the request of a website, used to remember preferences, enable certain functionality or measure usage.

“Analytics and Marketing Tools” means technologies such as Google Analytics, Meta/Facebook/Instagram pixels and similar tools that help us understand how the Website is used and measure the effectiveness of advertising and referral activity.

“CCTV” means closed-circuit television or similar video surveillance systems used at the Charitable Gaming Centre for security, safety and compliance purposes.

2. Regulatory and Legal Framework

Community Spirit Gaming Centre operates a Charitable Gaming Centre under the authority and oversight of:

  • Ontario Lottery and Gaming Corporation (OLG), which conducts and manages charitable gaming; and
  • Alcohol and Gaming Commission of Ontario (AGCO), which regulates gaming in Ontario.

Personal Information collected on behalf of OLG is subject to the Ontario Lottery and Gaming Corporation Act, 1999 and FIPPA. Personal Information collected by or on behalf of OLG is collected pursuant to section 3 of the Ontario Lottery and Gaming Corporation Act, 1999.

We also comply, where applicable, with obligations under PCMLTFA. We collect patron information and transaction data to meet record keeping, patron monitoring, risk mitigation and reporting requirements under applicable law, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

3. Information We Collect

3.1 Website Interactions (including Cookies, analytics and forms)

When you visit our Website, we may automatically collect technical and usage information, which can include:

  • IP address
  • Browser type, device type and operating system
  • Date, time and pages accessed
  • Error logs
  • Information collected through Cookies and similar technologies
  • Information collected through Analytics and Marketing Tools (such as Google Analytics and Meta/Facebook/Instagram pixels)

We use this information to operate, secure and improve our Website and to measure the effectiveness of our advertising.

If you submit information through forms on our Website (for example, contact or inquiry forms), we will collect the information you choose to provide (such as your name, contact details and the content of your message) and use it to respond to you and manage our relationship with you. Information submitted through forms may be processed and stored in our Website and email systems, which may be hosted inside or outside Canada, including in the United States of America and Germany.

You can manage Cookie settings through your browser. Restricting Cookies may impact some Website functionality.

3.2 Outbound Referral Links and Affiliate Partners (Casino Time Inc. and Casino Time Partners Inc.)

Our Website may include outbound links to third-party gaming sites operated by Casino Time Inc. and Casino Time Partners Inc. These links may contain referral parameters (such as a “btag” or similar identifier) so that those third parties can recognize that a visitor was referred from our Website.

We may:

  • log click-through activity on these links for our own analytics; and
  • receive Aggregated Data in the form of referral performance reports (for example, total number of referred players or aggregated revenue measures).

We do not:

  • receive information that identifies individual players from Casino Time Inc. or Casino Time Partners Inc. through these referral arrangements; or
  • send any Personal Information from our Website to Casino Time Inc. or Casino Time Partners Inc. via these links.

Casino Time Inc. and Casino Time Partners Inc. do not have access to our internal patron records or operational systems.

3.3 In-Hall Operations

In connection with operating our Charitable Gaming Centre, we may collect Personal Information such as:

Identity and verification information

  • Name, date of birth and contact information
  • Government-issued identification details
  • ID scans for age verification, prize verification and AML compliance

Gaming activity and transactions

  • Purchase activity and prize claim information
  • Information required under PCMLTFA, where applicable

Security, safety and compliance information

  • CCTV footage
  • Incident reports involving patrons or staff
  • Information used to support trespass, exclusion or self-exclusion checks
  • Other information necessary to investigate safety or misconduct issues

Customer support information

  • Information you provide when you contact us with questions, feedback or service requests

Personal Information used in connection with in-hall operations is not stored on the public Website.

3.4 Promotional Activities, Surveys and Contests

From time to time, we may invite you to participate in surveys, promotions or contests. Participation is voluntary, and if you choose to take part, we may collect Personal Information such as your name, contact details and information related to your participation.

If you win a contest or promotion, then, subject to applicable law and the specific rules of the promotion, by accepting a prize you may be deemed to consent to the use of your name, city of residence and likeness (for example, photographs) for advertising and promotional purposes without additional compensation, except where prohibited by law.

We may also use Personal Information you provide in connection with promotions, surveys and contests to:

  • administer the promotion, survey or contest;
  • contact you about your participation; and
  • provide you with information about our products, services and promotions, and, where permitted by law, about other gaming-related products and services offered by us or our partners.

You can opt out of receiving promotional communications as described in section 8.

4. Purposes of Collection and Use

We collect and use Personal Information only for legitimate purposes, which can include:

  • Conducting and managing charitable gaming on behalf of OLG
  • Verifying identity, age and prize eligibility
  • Meeting regulatory and compliance obligations imposed by OLG and AGCO
  • Meeting applicable AML obligations, including record keeping, patron monitoring, risk mitigation and reporting requirements under PCMLTFA, where applicable
  • Investigating and responding to incidents, fraud, theft, safety issues or violations of gaming rules
  • Operating and improving our Charitable Gaming Centre and Website
  • Providing customer service and responding to inquiries
  • Measuring and improving the performance of marketing and outbound Referral Links
  • Communicating with you about our products, services, promotions, surveys and contests, where permitted by law, and honoring your choices regarding marketing communications

5. Disclosure of Personal Information

We may disclose Personal Information only as permitted or required by law.

5.1 Disclosures to OLG and AGCO

We may share information with OLG and AGCO as required to:

  • support regulatory oversight and audits;
  • comply with reporting and record-keeping obligations;
  • investigate incidents or suspected breaches of gaming requirements; and
  • verify prize claims or support other regulatory processes.

5.2 Disclosures to Law Enforcement and Other Authorities

We may disclose Personal Information to Law Enforcement or other authorized authorities when:

  • required by law, court order, subpoena or warrant;
  • necessary to investigate or report suspected fraud, theft, threats to safety or other unlawful activity; or
  • necessary to support enforcement of trespass or exclusion orders.

5.3 Service Providers

We may use Service Providers to support functions such as:

  • Website hosting and operation;
  • email hosting and communication;
  • analytics and marketing measurement;
  • IT, security and infrastructure support; and
  • storage and backup.

These Service Providers may be located inside or outside Canada, including in the United States of America and Germany. They are provided only with the information necessary to perform their services and are required to protect Personal Information in accordance with applicable laws and contractual obligations.

5.4 Business Transactions

If we are involved in a prospective or completed business transaction such as a merger, acquisition, financing, reorganization, insolvency, receivership or sale of all or part of our business or assets, Personal Information and other information we have collected may be shared with or transferred to one or more third parties as part of that transaction, subject to appropriate confidentiality protections and continued safeguards for the Personal Information.

5.5 No Sale of Personal Information

We do not sell or trade Personal Information.

6. Cross-Border Data Storage

  • Website hosting, email hosting, analytics data and technical logs associated with our online presence may be stored on servers located outside Canada, including in the United States of America and Germany. Personal Information stored or processed in those jurisdictions may be subject to the laws of those jurisdictions as well as Canadian law.
  • Personal Information associated with in-hall charitable gaming operations is stored on systems located in Canada, in accordance with applicable OLG and AGCO requirements.

7. Retention of Personal Information

We retain Personal Information only for as long as necessary to:

  • meet legal, regulatory and audit requirements;
  • satisfy obligations imposed by OLG and AGCO;
  • comply with applicable AML and record-keeping obligations; and
  • manage incidents, investigations and operational needs.

Retention periods vary depending on the type of information and applicable legal or regulatory requirements. When information is no longer required, it is securely destroyed or anonymized where appropriate.

8. Your Choices and Updating Information

You may contact us at service@communityspiritgaming.com to:

  • update or correct certain Personal Information we hold about you;
  • request that we delete Personal Information, subject to our legal, regulatory and contractual obligations to retain certain records; and
  • opt out of receiving promotional communications from us.

We may ask you to provide sufficient information to verify your identity before we act on your request. If you opt out of promotional communications, we may still send you non-promotional communications relating to your participation in charitable gaming activities, regulatory notices or other service-related messages.

9. Security Measures

We use reasonable administrative, technical and physical safeguards to protect Personal Information against loss, theft, unauthorized access, disclosure, copying, use or modification. These safeguards may include:

  • secure server environments and access controls;
  • password-protected systems and restricted access to sensitive information;
  • firewalls, monitoring and other security tools;
  • controls and safeguards for CCTV systems; and
  • staff procedures and training related to privacy and security.

No system can be guaranteed to be completely secure, but we take appropriate steps to reduce risks to a reasonable level.

10. Protection of Minors

Our Charitable Gaming Centre and related services are intended for individuals 18 years of age or older. Any person who provides Personal Information to us through any part of the Service represents that they are at least 18 years old. If we become aware that a minor has provided Personal Information to us, we will take steps to delete such information where appropriate and permitted by law.

11. Third-Party Websites

Our Website may contain links to websites or online services operated by third parties. These third-party websites and services are not under our control, and we are not responsible for their content, security, or privacy practices. If you follow a link to a third-party site, any information you provide will be governed by that site’s own privacy policy and terms, not this Privacy Policy. We encourage you to review the privacy policies of any websites or services you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on our Website, and the “Effective Date” at the top of the policy will be updated accordingly. Your continued use of our Website or participation in charitable gaming activities after changes are posted will signify your acceptance of the revised policy.

13. Legal Disclaimer

The Service and the Website are provided on an “AS-IS” and “AS-AVAILABLE” basis, without any warranty of any kind, to the fullest extent permitted by law. Due to the nature of internet technologies and systems, we do not guarantee and do not represent that there will be error-free performance with respect to the privacy or security of Personal Information.

To the fullest extent permitted by applicable law, we will not be liable for any indirect, incidental, consequential, special or punitive damages arising out of or relating to the use or release of Personal Information, even if we have been advised of the possibility of such damages. We are not responsible for events beyond our reasonable control.

Nothing in this section limits any rights you may have under applicable privacy laws that cannot be limited or waived by contract.

14. Contact Information

If you have questions about this Privacy Policy or our handling of Personal Information, you may contact:

General Manager
Community Spirit Gaming Centre
900 Montreal Street
Kingston, Ontario, Canada
K7K 3J9
Email: service@communityspiritgaming.com
Phone: 613-546-6839