Privacy Policy

Boreal Spins Studios Inc. ("Boreal Spins", "we", "us", "our") respects your privacy and is committed to handling personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy legislation, including Quebec's Law 25, Alberta's PIPA, and British Columbia's PIPA.

This Privacy Policy explains what personal information we collect when you use the Boreal Spins website, mobile applications, and related services (the "Service"), how we use it, with whom we share it, how long we keep it, and the rights you have under Canadian privacy law.

Account data: email address, display name, date of birth, declared province of residence, and a hashed password.

Gameplay data: pull history per game, coin balance, daily-streak counters, badges earned, settings preferences, and timestamps of in-app actions.

Device and connection data: browser type, operating system, screen size, IP address (used to derive approximate region only), and the language of your browser.

Communications data: support tickets you send us, replies we send back, and your email preference settings (promotional, security-only, fully paused).

Sweepstakes entry data: if you choose the free mail-in entry method, the postal information printed on your 3×5 card.

We do not collect financial information, health information, social-insurance numbers, biometric data, precise GPS location, or any special-category personal information.

We use your information to: (a) create and operate your account; (b) verify that you meet the eligibility requirements set out in our Terms of Use; (c) deliver the Service, including syncing your coin balance and unlocking daily rewards; (d) detect and prevent fraud, multi-accounting, abuse of bonuses, and breaches of our Terms; (e) administer sweepstakes promotions and contact selected winners; (f) send transactional emails (account confirmation, security alerts, prize notifications); (g) send promotional emails where you have opted in, with a one-tap unsubscribe in every message; and (h) improve the Service through first-party, aggregate-only analytics.

We do not use your personal information to make any decision about you that has a legal or similarly significant effect through solely automated means.

Under PIPEDA and applicable provincial law, we process your personal information on the bases of your consent (which you provide when you create an account and which you can withdraw at any time), the performance of our contract with you (the Terms of Use), and our legitimate interests in operating, securing, and improving the Service in a manner that is balanced against your privacy rights.

We use a small set of first-party cookies. A session cookie keeps you logged in. A preference cookie remembers your theme and audio settings. An aggregate analytics cookie (provided by Plausible Analytics, configured in cookieless mode where possible) tells us which pages are visited and which pulls are popular, without tracking you across other sites.

We do not use third-party advertising trackers, cross-site tracking pixels, Facebook conversion pixels, Google remarketing tags, or session-replay tools.

We share personal information only with: (a) service providers acting on our written instructions, under contractual privacy obligations equivalent to our own (cloud hosting in Canada, transactional email delivery, fraud screening, the audit lab that certifies our RNG); (b) sweepstakes administrators where required to deliver prizes; and (c) authorities where compelled by a valid Canadian court order, search warrant, or production order.

We do not sell, rent, or trade personal information to any third party for any purpose.

Boreal Spins stores personal information on servers physically located in Canada. A small subset of operational metadata (anonymized error logs, aggregate analytics) may be processed by service providers in jurisdictions outside Canada; in those cases we use contractual safeguards consistent with PIPEDA guidance to maintain a comparable level of protection.

Under PIPEDA and applicable provincial law you have the right to: (a) access the personal information we hold about you; (b) request correction of inaccurate information; (c) withdraw consent and ask us to delete your account and associated personal information; (d) request that we stop sending marketing communications; and (e) lodge a complaint with the Office of the Privacy Commissioner of Canada or your provincial regulator.

We respond to verified rights requests within thirty days, and at no charge for the first request in any twelve-month period. To exercise a right, write to [email protected] from the email associated with your account.

We retain account data for as long as your account is active. After closure, we retain a minimal record (email hash, closure date, reason code) for up to twelve months for fraud-prevention purposes, then permanently delete it. Support correspondence is retained for twenty-four months. Aggregate analytics are retained indefinitely in fully anonymized form.

We protect your personal information with administrative, physical, and technical safeguards proportionate to its sensitivity. These include encryption at rest and in transit, least-privilege access controls, mandatory multi-factor authentication for staff, third-party penetration testing at least once a year, and a documented breach-response plan that meets PIPEDA's mandatory breach-notification requirements.

The Service is intended exclusively for adults aged 21 and over. We do not knowingly collect personal information from anyone under 21. If we learn that we have inadvertently collected information from an underage person, we close the account, delete the information, and document the incident.

Privacy Officer · [email protected] · Boreal Spins Studios Inc., 120 Adelaide St W, Suite 1500, Toronto, ON M5H 1T1 · Telephone (privacy line) 1-877-555-0144.