Privacy Policy

This Privacy Policy explains how Winspirit Casino, operated through the website winspiritbet-ca.com, collects, uses, discloses, and protects personal information of players and visitors from Canada who access or use our services. It applies to all users of our website, casino platform, mobile access points, and related services, whether you register an account, place bets, or simply browse. By using winspiritbet-ca.com, you acknowledge that you have read and understood this Privacy Policy. The effective date of this Privacy Policy is 1 January 2025, and it remains in force until replaced or updated, with anticipated applicability through at least 31 December 2026.

Who We Are

Operator and legal entities

The online casino services offered under the brand "Winspirit Casino" for Canadian players via winspiritbet-ca.com (referred to in this document as "Winspirit Casino", "we", "us", or "our") are owned and operated by:

Complete Technologies N.V., a public limited company established under the laws of Curaçao, registration number 137314, acting as the primary operator and license holder under Antillephone N.V. master license number 8048/JAZ2014-044.
Complete Technologies Limited, a company incorporated in Cyprus, registration number HE 356402, acting as a payment processing subsidiary for certain European and North American transactions, including Canadian players.

Complete Technologies N.V. is regulated under the jurisdiction of Curaçao and its competent authorities, including Antillephone N.V. and the Curaçao Gaming Control Board (GCB), and is in the process of aligning with the new National Ordinance for Games of Chance (LOK) framework.

Although we target players in Canada, Winspirit Casino is not licensed by Canadian provincial regulators (including but not limited to iGaming Ontario, Loto-Québec, British Columbia Lottery Corporation, or Atlantic Lottery Corporation). Your relationship is with an offshore operator supervised under Curaçao law.

Because some corporate addresses are not publicly specified in the data you have received, you may verify the license status and related corporate information through the Antillephone N.V. validator at https://validator.antillephone.com and the Curaçao Gaming Control Board at https://gamingcontrolcuracao.org.

Contact details and data protection contact

Official website: https://winspiritbet-ca.com
General and support email: [email protected] / [email protected]
Regulator/ADR complaints channel (for gambling-related disputes): [email protected]

We have appointed an internal data protection contact point (Data Protection Officer-equivalent) who can be reached at:

Email (Data Protection contact): [email protected] (or, if unavailable, via [email protected] with "Privacy" in the subject line).

You should use this contact for any questions, requests, or complaints relating to personal information and this Privacy Policy.

What Personal Data We Collect

We collect only the personal information that is reasonably necessary to provide, operate, and improve Winspirit Casino and to satisfy legal and regulatory obligations that apply to us as a remote gambling operator and financial transaction recipient. The categories of data we may collect and process include:

Identification and contact data

Basic account data: full name, username, date of birth, country of residence, address (where required), email address, and phone number.
Verification (KYC) data: copies or data from identification documents (such as passport, national ID card, driver's license), proof of address (utility bill, bank statement), and any information required to verify age, identity, and eligibility to play.

Technical and device data

Technical identifiers: IP address, device identifiers, browser type and version, operating system information, language preferences, and time zone.
Usage and log data: access times, pages visited, clicks, scrolling activity, referring/exit pages, session duration, and other log information generated through your interaction with our website and applications.

Payment and financial data

Transaction data: deposit and withdrawal history, payment method details (e.g., masked card numbers or e-wallet identifiers), currency, amount, date and time of transactions.
AML/finance-related data: information obtained or generated in connection with anti-money laundering (AML), counter-terrorist financing (CTF), and source-of-funds checks, such as occupation, income range, and supporting documents where applicable.

Behavioral and gaming data

Gameplay data: betting history, games played, bet sizes, win/loss records, bonuses used, jackpots, tournament participation, and other in-game decisions.
Responsible gambling data: self-exclusion status, deposit or loss limits, session limits, time-outs, and any information you provide about gambling-related issues.
Interaction data: records of your contacts with our support team (emails, chat logs, complaint records), internal notes regarding the handling of your requests and disputes.

Marketing and preference data

Marketing preferences: opt-in/opt-out decisions for email, SMS, push notifications, and in-account messaging.
Campaign and response data: information about which promotional messages were sent to you, whether you opened them, clicked links, or redeemed associated bonuses.

Cookies and similar technologies

Cookies: small text files stored on your device to enable core site functions, remember settings, and help us understand usage patterns.
Similar technologies: pixels, tags, scripts, local storage, and device identifiers used for fraud detection, security, analytics, and marketing (subject to your consent where required by applicable law).

We do not intentionally collect sensitive categories of personal information (such as health data) except where you voluntarily disclose such information in the context of responsible gambling, account restrictions, or disputes. In such cases, we handle that information with heightened confidentiality and only for the specific purposes for which it was provided.

Legal Basis for Processing

Although Winspirit Casino primarily operates under Curaçao law and is directed at Canadian residents, we broadly align our privacy practices with international standards (including principles comparable to GDPR) to ensure a high level of protection. We rely on the following legal bases (or their functional equivalents for non-EU jurisdictions) to process your personal information:

Performance of a contract

To create and manage your player account, including verifying your age and eligibility to participate in online gambling under applicable laws.
To process your deposits, bets, gameplay, bonuses, and withdrawals, and to provide customer support related to your account and transactions.
To communicate with you regarding technical issues, service changes, and other matters strictly necessary to operate your account and our services.

Compliance with legal and regulatory obligations

To perform identity verification (KYC), anti-money laundering (AML) and counter-terrorist financing (CTF) checks, as required under Curaçao regulatory standards and applicable financial regulations.
To prevent minors and self-excluded persons from gambling, and to comply with responsible gambling obligations imposed by our license and best industry practices.
To maintain accurate records for auditing, tax, regulatory reporting, and to cooperate with competent authorities and Alternative Dispute Resolution (ADR) bodies.

Legitimate interests

To secure our platform, detect and prevent fraud, abuse, cheating, chargebacks, bonus misuse, and other violations of our Terms and Conditions.
To analyze site performance, user behavior, and gameplay metrics in order to improve our products, services, and user experience.
To establish, exercise, or defend legal claims, and to manage business operations (such as risk management, internal reporting, and restructuring).

Consent

For sending direct electronic marketing messages (such as promotional emails and SMS) where consent is required under applicable law.
For the use of non-essential cookies and similar technologies for analytics and advertising purposes where consent is legally required.

Where we rely on consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Purpose of Processing

We use your personal information only for specific, explicit, and legitimate purposes and do not process it in ways incompatible with those purposes. In particular, Winspirit Casino may process your data for the following purposes:

Provision of casino services: to open and manage your account, enable deposits and withdrawals, process bets and game outcomes, credit winnings and bonuses, and provide technical and customer support.
Compliance and risk management: to fulfill KYC, AML/CTF, and responsible gambling obligations; to verify identity and age; to monitor for suspicious or irregular behavior; and to comply with applicable laws, regulations, and licensing conditions.
Service improvement and analytics: to analyze website traffic, gameplay patterns, and user interactions; to troubleshoot technical issues; and to optimize performance, design, and functionality of winspiritbet-ca.com.
Marketing, promotions, and personalization: to send you promotional communications and personalized offers (subject to your preferences and applicable consent requirements), to measure the effectiveness of campaigns, and to recommend games or features that may be of interest to you.
Security and fraud prevention: to protect our systems and your account from unauthorized access; to detect and prevent fraud, collusion, money laundering, and abuse of promotions; and to enforce our Terms and Conditions.
Dispute resolution and legal enforcement: to handle player complaints, disputes with us or third parties, regulatory inquiries, and legal claims or proceedings, including cooperation with ADR bodies and regulators.

Disclosure & Sharing

We treat your personal information as confidential and disclose it only when necessary for the purposes described in this Privacy Policy, when required by law, or when you have provided your consent. The types of recipients include:

Service providers and partners

Payment processors and banks: financial institutions, card schemes, e-wallets, and payment gateways involved in processing your deposits and withdrawals. For Canadian players, this may include processors engaged by Complete Technologies Limited in Cyprus or other approved partners.
Gaming and platform providers: software suppliers that provide gaming content, platform infrastructure, and related services necessary for Winspirit Casino to operate.
IT and security providers: companies providing hosting, data storage, maintenance, security monitoring, DDoS protection, fraud and risk management tools, and technical support services.
Marketing and analytics partners: limited sharing with marketing platforms, analytics tools, or customer relationship management (CRM) providers, mainly in pseudonymized or aggregated form where possible and subject to consent requirements for marketing.

Regulators, authorities, and dispute resolution bodies

Regulatory authorities: Curaçao license authorities (including Antillephone N.V. and Curaçao Gaming Control Board) and other competent authorities, courts, law enforcement, or governmental bodies that may lawfully request or require information.
Alternative Dispute Resolution (ADR): complaints referred to [email protected] or other ADR/ombudsman bodies may involve disclosure of relevant account and transaction data to handle the dispute.

Corporate transactions and affiliates

Group entities: sharing within the Complete Technologies group (including Complete Technologies N.V. and Complete Technologies Limited) for internal administration, risk management, and consolidated reporting.
Corporate deals: in the context of a merger, acquisition, sale of assets, reorganization, or insolvency event, your data may be transferred to potential or actual acquirers, subject to appropriate confidentiality measures and continued protection.

Advertising networks (with consent)

Where permitted by law and based on your consent where required, we may use advertising partners and networks that deploy cookies or similar technologies to deliver targeted or interest-based advertising, including remarketing campaigns. These partners process identifiers and behavioral data in accordance with their own privacy policies, which you should review separately.

We do not sell your personal information in the commonly understood sense, nor do we share personal information with third parties for their own independent marketing purposes without your explicit consent.

International Transfers

As an offshore operator headquartered in Curaçao with a payment-processing subsidiary in Cyprus, Winspirit Casino routinely transfers personal information across country borders. This includes transfers:

From Canada (and other user locations) to servers and corporate entities in Curaçao (CW), where Complete Technologies N.V. is registered and licensed.
To Cyprus (CY), where Complete Technologies Limited provides payment processing and certain back-office services.
To other countries in the European Economic Area (EEA) or the United Kingdom, where some of our service providers (such as hosting, analytics, and payments) may be located.
To other jurisdictions where selected third-party providers or technology partners operate, always subject to appropriate safeguards.

Where personal information is transferred from jurisdictions with specific data transfer requirements (such as the EEA or U.K.) to countries that may not provide the same level of data protection, we aim to put in place suitable safeguards, which may include:

Standard Contractual Clauses (SCCs) or equivalent contractual protections approved by relevant regulators.
Contractual obligations on recipients to maintain adequate data security and confidentiality measures.
Technical measures such as encryption in transit and at rest, strict access controls, and minimization of data transferred.

By using winspiritbet-ca.com, you understand that your personal information may be processed in Curaçao, Cyprus, and other jurisdictions where our partners or service providers are based, subject to the safeguards and protections described in this Privacy Policy.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements. Retention periods may vary depending on the type of data and the circumstances. As a general guideline:

Account and identification data: typically retained for the duration of your account and for up to 5 - 7 years after account closure, in line with licensing, AML/CTF, and financial record-keeping requirements applicable to gambling operators under Curaçao law and relevant financial regulations.
KYC and AML documents: copies of identification documents, proof of address, and AML-related records are normally stored for at least 5 years after the end of the business relationship or the date of the last transaction, or longer if local regulations require it.
Transaction and gaming data: deposit/withdrawal history, bet records, game logs, and bonus usage records may be kept for at least 5 - 7 years from the relevant transaction date, to meet auditing, regulatory, and tax obligations, and to handle potential disputes.
Customer support and complaint data: records of communications with you and complaints are generally retained for 3 - 5 years after their resolution, or longer where necessary for legal defense.
Marketing data: information related to marketing preferences and campaign performance is retained while you maintain an active account and for up to 2 years after withdrawal of consent or account closure, unless longer retention is needed for proof of consent or legal defense.
Cookies and analytics data: stored according to cookie type and purpose, typically from the end of each browsing session (for session cookies) up to 24 months (for certain analytics cookies), subject to earlier deletion where you clear your browser or withdraw consent.

When personal information is no longer required for the purposes outlined above, we will either irreversibly anonymize it (so it can no longer be associated with you) or securely delete or destroy it, unless we are legally required to retain it for a longer period.

Your Rights

While Winspirit Casino primarily operates under Curaçao law and serves Canadian residents, we endeavor to align our privacy practices with internationally recognized standards, including principles comparable to the EU General Data Protection Regulation (GDPR). Depending on your location and the laws that apply, you may have some or all of the following rights in relation to your personal information:

Access and information

The right to obtain confirmation as to whether we process personal information about you and, if so, to request a copy of that information together with an explanation of how it is used, shared, and protected.

Rectification (correction)

The right to request correction of inaccurate personal information and completion of incomplete data (for example, updating your contact details or correcting spelling errors in your name), subject to verification requirements and fraud prevention considerations.

Erasure (deletion)

The right to request deletion of your personal information where:
- the data is no longer necessary for the purposes for which it was collected;
- you have withdrawn consent (where consent was the sole legal basis); or
- you believe the processing is unlawful or unnecessary.
We may need to retain certain information despite your request, where required by gambling, AML, tax, or other laws, or where necessary to establish, exercise, or defend legal claims.

Restriction of processing

The right to request that we temporarily restrict processing of your data (other than storage) where:
- you contest its accuracy (for the period needed to verify it);
- the processing is unlawful and you prefer restriction instead of deletion; or
- we no longer need the data, but you require it to establish, exercise, or defend legal claims.

Objection to processing

The right to object to processing based on our legitimate interests, on grounds relating to your particular situation. We will consider your objection and stop processing unless we have compelling legitimate grounds that override your interests, rights, and freedoms or where processing is required for legal claims.
You always have the right to object to direct marketing, including profiling related to such marketing. If you object, we will stop using your data for direct marketing purposes.

Data portability

The right, where technically feasible and legally applicable, to receive certain personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit it to another controller.

Withdrawal of consent

Where we rely on your consent (for example, for certain marketing or cookies), you can withdraw that consent at any time via your account settings, unsubscribe links in messages, or by contacting us directly. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

Practical procedures, timeframes, and costs

How to exercise your rights: you can submit requests by:
- Emailing our data protection contact at [email protected] or [email protected] with "Privacy Request" in the subject line.
- Using any dedicated privacy tools or settings provided in your account dashboard, where available.
Verification: for your security, we may ask you to verify your identity (for example, by logging into your account or providing additional information) before acting on your request.
Response time: we aim to respond to all valid requests within 30 days of receipt. If your request is complex or we receive many requests, we may extend this period by up to an additional 30 days, in which case we will notify you.
Fees: we process your requests free of charge unless they are manifestly unfounded, repetitive, or excessive. In such cases, we may charge a reasonable fee or refuse to act on the request.

Your rights may be limited under certain circumstances (for example, where fulfilling your request would adversely affect the rights and freedoms of others or where data must be retained to comply with legal obligations). If we decline your request (in whole or in part), we will provide a clear explanation, unless prohibited by law.

Cookies & Tracking Technologies

Winspirit Casino uses cookies and similar technologies on winspiritbet-ca.com to ensure the proper functioning of the site, improve performance, enhance security, and support marketing and analytics. Cookies are small text files that are placed on your device when you visit our site.

Types of cookies we use

Strictly necessary (functional) cookies: These cookies are essential to enable basic site operations, such as logging into your account, maintaining your session, processing transactions, and securing the platform. They cannot be switched off in our systems and are typically set only in response to your actions.
Preference cookies: These cookies remember your choices, such as language, region, and display settings, to provide a more personalized and convenient experience on subsequent visits.
Analytics and performance cookies: These cookies collect information about how visitors use our website (for example, which pages are visited most often, time spent on pages, and error messages). We use this aggregated data to improve the performance and usability of winspiritbet-ca.com.
Advertising and targeting cookies: These cookies may be set by us or our advertising partners to deliver targeted advertising, measure campaign effectiveness, and help us show content or offers that may be more relevant to your interests.
Third-party cookies: Some cookies are placed by third-party providers (such as analytics platforms, security providers, and ad networks) that assist us in operating our services. These third parties may use the data for their own purposes, in accordance with their own privacy policies.

Managing cookies

Browser settings: Most web browsers allow you to manage cookies through their settings, including blocking, disabling, or deleting cookies. Refer to your browser's help section for specific instructions.
In-site controls: Where available, you may use our internal cookie or privacy panel to manage non-essential cookies and update your choices at any time.
Impact of disabling cookies: If you block or delete certain cookies (especially strictly necessary ones), some parts of winspiritbet-ca.com may not function properly, and you may not be able to log in or use all features.

Data Security

We implement and maintain technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. While no system can guarantee absolute security, Winspirit Casino applies industry-standard safeguards and continuously improves its security posture.

Technical measures

Encryption in transit: Data exchanged between your browser and winspiritbet-ca.com is protected using Transport Layer Security (TLS) version 1.2 or higher, helping to prevent interception or tampering during transmission.
Encryption at rest: Sensitive data, including certain financial and authentication information, is stored in encrypted form where feasible, using strong encryption algorithms and proper key management practices.
Access controls: Access to personal information is restricted to authorized staff and service providers who require it for legitimate business purposes, using role-based access control, unique user IDs, and authentication mechanisms.
Multi-factor authentication (MFA): Internal administrative access is protected by multi-factor authentication, and we may offer or require enhanced authentication for user accounts where appropriate.

Organizational and procedural measures

Security policies and training: We maintain internal policies governing information security, acceptable use, and incident response. Staff with access to personal information are required to undergo regular training on data protection and security best practices.
Vendor due diligence: We select service providers with appropriate security capabilities and require them, through contractual obligations, to protect personal information, follow data protection requirements, and notify us of relevant incidents.
Audits and monitoring: We perform periodic internal reviews, technical testing, and monitoring of our systems to detect vulnerabilities, suspicious activities, or potential breaches, and to maintain compliance with applicable standards. Where feasible, we align our controls with internationally recognized security frameworks (such as ISO 27001 and SOC 2-type controls), even if formal certification is not always maintained.
Incident response: We maintain procedures for identifying, assessing, and responding to security incidents. In the event of a data breach that is likely to result in a significant risk to your rights and freedoms, we will take appropriate steps to mitigate harm and, where required by applicable law, notify affected players and relevant authorities without undue delay.

Complaints & Contacts

If you have questions, concerns, or complaints about how Winspirit Casino handles your personal information, or if you wish to exercise your privacy rights, you can contact us using the channels below.

Primary contact channels

Data protection contact (preferred for privacy matters): [email protected]
Customer support (general issues, including privacy): [email protected]

If online feedback or contact forms are made available on winspiritbet-ca.com, you may also use those forms to submit privacy-related requests or complaints, clearly indicating that your request concerns personal information.

Complaint handling procedure

Submission: You submit your complaint or request via email or any dedicated online form, providing sufficient details to identify your account (e.g., username, registered email) and describe your concern.
Acknowledgment: We will acknowledge receipt of your complaint within a reasonable period, typically within 5 business days, and may request additional information if needed to understand or verify your concern.
Investigation: We will investigate your complaint, which may involve reviewing internal records, consulting relevant departments, and, where appropriate, liaising with service providers.
Response: We aim to provide a substantive response to privacy-related complaints or rights requests within 30 days of receipt (or of receiving necessary additional information). If we cannot meet this timeframe, we will inform you of the delay and explain the reasons.
Escalation: If you are not satisfied with our response, you may request that your complaint be escalated internally, or you may pursue external remedies as described below.

Escalation to regulatory or supervisory authorities

Winspirit Casino is licensed under Curaçao jurisdiction and not directly supervised by Canadian provincial gaming regulators. If your complaint is specifically about gambling operations, fairness of games, or license compliance and is not resolved by us, you may contact our license-related ADR/regulator channel:

Antillephone N.V. complaints/ADR channel: [email protected]

If data protection laws in your country of residence provide for oversight by a data protection authority (for example, in EU/EEA jurisdictions), you may have the right to lodge a complaint with that authority. We encourage you to contact us first, so we can attempt to resolve your concerns directly and efficiently.

Updates

We may update or modify this Privacy Policy from time to time to reflect changes in legal requirements, regulatory guidance, technological developments, or our business operations (including expansion into new markets or adoption of new services and partners). When we make changes, we will take appropriate steps to inform you.

Notification of changes

Website notice: We will post the updated version of this Privacy Policy on https://winspiritbet-ca.com, with a revised "Last updated" date at the top or bottom of the document.
Email and account alerts: For material changes that significantly affect your rights or the way we process your personal information, we will, where feasible, notify you via email and/or in-account notifications or banners.
Advance notice: Where legally required or reasonably practical, we will provide at least 30 days' advance notice before material changes come into effect, allowing you time to review the new terms.

Version control and your options

Version tracking: We will maintain an internal record of material changes to this Privacy Policy, including the effective date of each version. Key changes may be summarized in a short changelog or notice.
Your continued use: Your continued use of winspiritbet-ca.com after the effective date of an updated Privacy Policy will constitute your acceptance of the changes, to the extent permitted by applicable law.
Right to object or close account: If you do not agree with the updated Privacy Policy, you may choose to stop using our services and request account closure. Where changes materially affect processing based on consent, you may also withdraw your consent for the affected activities.

Last updated: January 2025 (intended to remain applicable and periodically reviewed through at least December 2026).