Cadtree Limited, including all affiliated casinos and digital services (“The Group”), is committed to protecting your personal data while delivering online gaming services via our websites, mobile applications, and digital platforms (collectively, the “Services”).

This Privacy Policy outlines how we collect, use, disclose, and protect your information, and informs you of your rights. Our commitment to your privacy is rooted in full compliance with applicable laws, including Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

We encourage all users (“you”, “your”) to read this policy carefully and use it to make informed choices. By accessing our Services or creating an account, you agree to the terms of this Privacy Policy and consent to our data practices.

This policy explains:

For privacy-related inquiries, please contact our Privacy Executive by using the form provided or by mail. Requests may be subject to verification and limitations as defined by applicable laws.

Cadtree Limited is the licensed operator behind several trusted Canadian online casino platforms. In collaboration with our digital marketing and technology partner, Launchify Digital (launchifydigital.com), we deliver secure and compliant iGaming services to Ontario-based players.

The following casino brands are operated under Cadtree Limited’s license:

• www.spincasino.ca
• www.rubyfortune.ca
• www.royalvegas.ca

Cadtree Limited (2031) is a Guernsey-registered company headquartered at La Corvee House, La Corvee, Alderney, GY9 3TQ, Guernsey. It is fully licensed by the Alcohol and Gaming Commission of Ontario (AGCO), operating under License Number OPIG1236392, issued on 23 June 2022.

Launchify Digital is responsible for supporting Cadtree’s digital infrastructure, user experience optimization, and marketing compliance within the Ontario regulated market.

As a licensed operator authorized by iGaming Ontario (iGO), Cadtree Limited — supported digitally by Launchify Digital — collects and processes user data in accordance with the Freedom of Information and Protection of Privacy Act (FIPPA), Ontario Regulation 722/21, and the Personal Information Protection and Electronic Documents Act (PIPEDA).

“Personal Information” refers to recorded details about an identifiable individual. The scope and type of information collected may vary depending on the purpose of collection or applicable legal requirements. We generally collect the following categories:

Personal Information

• Registration details: Including name, email, gender, birth date, address, phone number, occupation, and ID number.
• Government-issued ID: For identity verification as required by regulation.
• Payment information: Such as bank account details or credit card numbers to support transactions.
• Voluntary communications: Information you provide through emails, live chat, or other communication channels.
• Device identifiers: Including IP address, MAC address, browser fingerprints, or geo-location for fraud detection and legal compliance.
• Recorded calls: Customer service interactions may be monitored or recorded for training, safety, and support purposes.
• Social account data: If connecting via social media (e.g. Facebook), basic public profile information may be accessed.
• Referral information: If you use features such as “Invite a Friend”, we may collect their name, contact details, and date of birth with consent.
• Third-party validation: Such as credit reports or KYC (Know Your Customer) verification services.
• Location tracking: Required by Ontario regulations to confirm legal jurisdiction for gameplay.

Non-Personal Information

We also collect technical or statistical data that does not identify individuals directly. This “Non-Personal Information” is used for optimization, analytics, and service improvement purposes.

• Technical specifications: Browser type, OS version, language, and screen resolution.
• Gameplay analytics: Activity logs such as bets, deposits, bonuses, and gameplay sessions.
• Device signals: Used to detect fraud, software conflicts, VPN/proxy usage, or suspicious behavior.
• Usage insights: Includes click behavior, page visits, interaction timestamps, and user flow data.
• Anonymous data: Aggregated or anonymized data may be used for insights and marketing, without linking back to individual identities.

If at any point non-personal information becomes associated with identifiable data, we treat it as Personal Information in line with applicable laws.

The Services provided by Cadtree Limited, promoted and managed digitally through Launchify Digital, are strictly intended for individuals who are at least 19 years old or have reached the legal age of consent in their respective jurisdiction — whichever is greater (“Legally of Age”).

If you are not Legally of Age, you are not permitted to register, access, or use any part of our Services, nor should you provide us with any personal information.

We reserve the right to verify the age and identity of users. If we become aware that we have collected information from an individual who is not Legally of Age, we will take steps to remove that information promptly and restrict further access.

If you believe a minor has shared personal data with us in error, please contact our privacy team immediately so that appropriate measures can be taken.

We use the personal information we collect to deliver, improve, and secure the Services provided by Cadtree Limited, in cooperation with Launchify Digital. The purposes for data use are strictly defined by applicable privacy laws and are as follows:

• To create, manage, and maintain your user account.
• To operate core functions of the platform, including gameplay, betting, deposits, and withdrawals.
• To communicate updates, account notifications, and optional promotional offers.
• To provide marketing and remarketing services in accordance with applicable policies (see section: Marketing).
• To analyze usage behavior and compile statistics that help us improve user experience and service features.
• To manage customer service interactions, support tickets, and account troubleshooting.
• To customize and optimize the Services based on user behavior and preferences.
• To promote responsible gaming practices and support tools for player protection.
• To process and verify requests submitted under your user rights (such as data access or deletion).
• To authenticate your identity and protect access to secure areas of the platform.
• To detect and prevent fraudulent or prohibited activity that may compromise platform integrity.
• To enforce our terms of use and investigate suspected violations of our User Agreement or internal policies.
• To resolve disputes or user-reported incidents relating to Service use.
• To meet legal obligations, including compliance with Know Your Customer (KYC), Anti-Money Laundering (AML), or any other regulatory requirements mandated by authorities.

Cadtree Limited, in collaboration with its marketing and technology partner Launchify Digital, may use your personal information—such as your name, email address, telephone number, and postal address—for direct marketing purposes. These communications may promote services offered by:

• Other companies under the Cadtree Limited group
• Our approved White Label casino brands
• Trusted business partners and marketing affiliates

Marketing messages may be delivered via email, SMS, telephone, or postal mail. We may also share your personal information with our affiliates who use it to provide relevant offers based on your preferences and interests.

You may update or change your marketing preferences at any time by contacting our Customer Service team. Additionally, if you have installed any software related to our Services, you may receive push notifications about updates, promotions, or new features directly to your device.

By choosing to download and use our Software, you consent to receiving such notifications. If you prefer not to receive them, you may disable or uninstall notification permissions via your device settings or through the specific notification management tools provided.

You can opt out of receiving promotional messages at any time by reaching out via our Live Chat. Please note that unsubscribing from marketing communications does not affect essential service-related updates, including changes to your account, legal notices, or security-related alerts.

Cadtree Limited, in partnership with Launchify Digital, does not rent, sell, or disclose your personal information to third parties (“Recipients”) except as outlined in this Privacy Policy. Any such sharing is limited to what is strictly necessary for operational, legal, or compliance-related purposes.

Your personal data may be shared with the following types of recipients:

• White Label Brands and any appointed operators managing those platforms.
• Affiliated companies within the Cadtree Group, including Launchify Digital, and their service partners or subcontractors.
• Cloud service providers, payment processors, identity verification platforms, and fraud prevention partners.
• Marketing affiliates and agencies who provide promotional and communications support.
• Credit reporting agencies and banking institutions that assist with payment facilitation and risk assessment.
• Event organizers, travel agencies, hotels, and airlines engaged in brand-sponsored events or contests.
• Auditors, legal consultants, or process advisors involved in operational or regulatory evaluation.
• Government bodies and legal authorities (e.g., FINTRAC, AGCO, iGaming Ontario) for compliance, investigations, or legal mandates.
• Prospective investors or acquirers during mergers, acquisitions, reorganizations, or similar transactions.

We may also disclose your personal information to these Recipients for reasons such as:

• Secure cloud-based data storage and hosting services.
• Operational support (e.g. user authentication, transaction processing, and customer service).
• Internal auditing, diagnostics, and statistical research.
• Compliant delivery of promotional materials based on your preferences (see section: Marketing).
• Enforcing our terms, protecting rights or safety, and assisting in the prevention or investigation of fraud or unlawful activity.

All third-party sharing is conducted in accordance with applicable laws, including FIPPA, PIPEDA, and the operational terms of our license under the Alcohol and Gaming Commission of Ontario and iGaming Ontario.

As Cadtree Limited operates in collaboration with Launchify Digital across multiple jurisdictions, your personal information may be transferred and stored in countries outside of Ontario or Canada. These jurisdictions may not offer the same level of data protection as required under Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA) or PIPEDA.

However, we take appropriate and legally required steps to ensure that your data remains protected during such transfers. This includes the use of approved contractual safeguards and ensuring data recipients adhere to adequate levels of data protection as defined by regulatory authorities.

Cadtree Limited uses secure infrastructure and carefully selected partners to manage these cross-border transfers in line with our obligations under applicable privacy legislation.

If you believe that your data has been handled improperly, or if you suspect misuse or abuse of our Services, we encourage you to report the matter promptly via our Live Chat support team. Your trust and data safety are of the utmost importance to us.

When you access or interact with the Services provided by Cadtree Limited and powered digitally through Launchify Digital, we and our authorized third parties may use a variety of technologies to collect information automatically. These technologies include, but are not limited to, cookies, pixels, web beacons, scripts, tags, and geolocation tools (collectively, “Tracking Technologies”).

These tools enable us to better understand how users engage with our Services, verify your location when required by law (e.g., ensuring access from Ontario), enhance navigation, customize your experience, and deliver content or offers tailored to your preferences.

Tracking Technologies also help us monitor the performance of our website, compile usage analytics, detect technical issues, and support advertising and affiliate tracking mechanisms used by our partners.

We may also authorize select third parties to deploy these technologies on our Services to collect non-personal and aggregated information for measurement, marketing, or optimization purposes. These third parties are obligated to act in accordance with applicable privacy standards and contractual safeguards.

For further details on the types of cookies and other tracking methods we use, and to manage your preferences, please refer to our Cookie Policy.

While using the Services offered by Cadtree Limited and delivered digitally through Launchify Digital, you may encounter links or access points to third-party websites, applications, or platforms. These external resources are provided for your convenience but are not governed by this Privacy Policy.

Third-party services operate independently and may have their own privacy practices and terms of use. We strongly recommend reviewing their policies before submitting any personal information or engaging with their services.

Cadtree Limited and its affiliated partners assume no responsibility or liability for the privacy standards, data handling practices, content, or accuracy of any third-party platforms, even if they are linked or referenced within our Services.

Your use of any external site or service is entirely at your own discretion and risk. By accessing third-party content, you acknowledge and accept that we are not liable for any resulting consequences from those interactions.

If you have created an account through the Services operated by Cadtree Limited and powered by Launchify Digital, we will retain your personal information for as long as your account remains active.

Additionally, we may retain certain personal data beyond the duration of your account activity in order to comply with applicable laws and regulations. This includes obligations related to gambling legislation, Know-Your-Customer (KYC) and Anti-Money Laundering (AML) requirements, as well as operational requirements under our iGaming Ontario Operating Agreement.

If you wish to request deletion of your personal information, you may contact us directly at: [email protected]. We will review and respond to your request in accordance with applicable legal and contractual obligations.

As a user of services provided by Cadtree Limited and powered by Launchify Digital, you have certain rights regarding your personal information under the Freedom of Information and Protection of Privacy Act (FIPPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA).

Under FIPPA, you are entitled to access and ensure the accuracy of the personal information we hold about you. Under PIPEDA, you may also withdraw consent to the collection, use, or disclosure of your personal information — however, please note that such withdrawal may impact our ability to provide Services to you.

You may contact us at any time to:

• Request access to or deletion of personal information we hold about you
• Correct or update inaccurate or outdated personal data
• Restrict or object to further processing of your personal information
• Receive a copy of your personal data in a structured, machine-readable format

Please note that these rights are subject to applicable laws and operational obligations — particularly those related to gaming regulations, legal reporting requirements, and the retention of transaction records.

If you believe your rights have not been fully respected, you have the option to escalate your concern to the relevant regulator. In Ontario, this includes iGaming Ontario (iGO). We will fully cooperate with any iGO investigation in accordance with the Customer Care and Player Disputes Resolution (CCDR) policy.

At Cadtree Limited, supported by Launchify Digital, we are committed to protecting your personal information. We have implemented industry-standard administrative, physical, and technical safeguards designed to prevent unauthorized access, misuse, loss, or alteration of your data.

The level of protection applied is proportionate to the sensitivity of the information being stored or processed. Security controls include, but are not limited to:

• Secure network architecture, including firewalls and intrusion prevention systems
• End-to-end encrypted communications
• Strict user authentication and role-based access controls
• Internal monitoring, logging, and regular external and internal security audits

Despite our best efforts, no system can be guaranteed completely secure. While we take all reasonable steps to protect your personal information, we cannot be held responsible for unauthorized access or misuse beyond our control. We recommend that users also take proactive steps to safeguard their login credentials and personal devices.

At Cadtree Limited, powered by Launchify Digital, protecting your personal information is a top priority. We maintain a range of physical, technical, and administrative safeguards designed to prevent unauthorized access, preserve data integrity, and protect user privacy across our services.

Our security measures include industry best practices such as:

• Real-time monitoring and intrusion detection systems
• Data encryption at rest and in transit
• Access control protocols and internal audit procedures
• Incident response frameworks in coordination with critical service providers

Despite these safeguards, no internet-based system is entirely immune to risk. While we take every reasonable precaution to prevent unauthorized access or misuse, any data transmission is at your own risk. In the event of a confirmed privacy breach that may cause significant harm, we will:

• Promptly notify affected users with details and recovery guidance
• Inform iGaming Ontario and the Office of the Privacy Commissioner of Canada, as required
• Maintain detailed internal records of all breach events in compliance with applicable laws

Incident Response Process

Our Incident Management Process follows a three-phase protocol:

1. Initiation: In partnership with internal teams and suppliers, we evaluate the scope of the event, escalate internal monitoring, and notify stakeholders while assessing system impact.
2. Containment, Eradication & Recovery: We isolate the issue, verify data integrity, perform necessary restorations, and initiate a full audit to ensure all systems are secure before reactivation.
3. Notification: We transparently communicate recovery outcomes to affected users and authorities. Account updates and next steps are clearly conveyed via email or secure on-site messaging.

Cadtree will fully cooperate with iGO, regulatory authorities, and law enforcement agencies to mitigate impact, support investigations, and uphold responsible data stewardship.

Cadtree Limited, in collaboration with Launchify Digital, reserves the right to modify this Privacy Policy at any time in order to reflect updates to legal, operational, or service-related requirements.

Any material changes to this Privacy Policy will be communicated through the Services or via email to the address you provided during account registration. In such cases, notice will be provided at least seven (7) days in advance of the changes taking effect.

Minor or non-material updates will take effect immediately upon publication. The “Last Updated” date at the top of this page indicates when this policy was most recently revised. By continuing to use our Services after the effective date, you agree to the updated terms.

We recommend reviewing this page periodically to stay informed about how we protect your personal information.

If you have any questions regarding this Privacy Policy, the Services provided by Launchify Digital, or the personal information we collect and how we use it, you are encouraged to contact us at any time.

The quickest way to reach us is through our live chat support, accessible via the Contact Us page. Our team is available to provide guidance, handle privacy-related inquiries, and assist with your data requests.

We aim to respond to all inquiries within a reasonable timeframe. If you are not satisfied with our response or believe your rights have been infringed, you may contact the relevant data protection supervisory authority in your jurisdiction.

This Cookie Policy explains how Cadtree Limited and our digital experience and marketing partner Launchify Digital (launchifydigital.com) use cookies and similar tracking technologies across our online platforms (“Services”), including websites, mobile apps, and partner integrations.

When you access or interact with our Services, we and our authorized third-party partners may use a variety of tracking technologies such as cookies, web beacons, pixel tags, scripts, APIs, and device identifiers (“Tracking Technologies”).

These technologies help us understand how users engage with our Services, personalize your experience, analyze site performance, improve navigation, and serve ads that are relevant to your interests. This includes enabling remarketing features and audience measurement tools provided by third parties like Google Ads, Google Analytics, and other compliant advertising platforms.

By continuing to use our Services, you consent to the use of these Tracking Technologies unless you have disabled them via browser settings or consent management tools. You can learn more about managing your preferences in the sections below.

Cookies are small data files, typically consisting of letters and numbers, that are placed on your device by a website’s server when you access certain webpages. These files serve to enhance your browsing experience by remembering your preferences (such as language, location, and login settings) and improving the functionality of the Services.

Cookies are a widely used web technology that support seamless navigation between pages, improve load performance, and enable personalized content delivery. Additionally, cookies are commonly used to serve advertising that is more aligned with your interests—helping ensure relevance and limiting repetition.

You can learn more about cookies and how they function by visiting www.allaboutcookies.org.

When you access the Services operated by Cadtree Limited and digitally managed by Launchify Digital, Tracking Technologies may be stored directly by us or by authorized third parties. These fall into two categories:

• First-Party Tracking Technologies: These are stored directly by our systems to support functionality, preferences, security, and analytics across launchifydigital.com and our affiliated platforms.
• Third-Party Tracking Technologies: These are placed by our analytics providers, advertising networks, affiliate platforms, and business partners. These tools help us measure performance, deliver advertising, and personalize user experiences based on activity.

Both types of Tracking Technologies may persist only during your current session or remain stored across multiple visits (persistent cookies), depending on the purpose and your chosen preferences.

On Services operated by Cadtree Limited and powered by Launchify Digital, we use the following categories of Tracking Technologies, each serving a specific purpose to enhance performance, personalization, security, and marketing.

Below is a summary of key Tracking Technologies used on Services operated by Cadtree Limited and supported by Launchify Digital. This list is not exhaustive but highlights common types you may encounter.

We regularly review the use of these technologies and update this list as necessary to reflect any new tools added to launchifydigital.com or our partner Services.

Please note that Cadtree Limited and Launchify Digital do not currently recognize or respond to automatic browser signals such as "Do Not Track" requests. However, you have several options to manage how cookies and other Tracking Technologies are stored or used on your device.

Be aware that disabling or blocking cookies may affect certain features of our Services, including login functionality, personalization, or secure access areas. You may update your cookie preferences at any time by clicking here.

Managing Cookies via Your Browser

Most web browsers allow you to view and manage cookies directly. You can delete individual cookies, block all cookies, or configure settings for specific websites. Some browsers also let you control third-party cookies independently.

For convenience, here are links to cookie management instructions for common browsers:

• Google Chrome
• Chrome (Mobile)
• Internet Explorer / Microsoft Edge
• Mozilla Firefox
• Safari (macOS & iOS)

Controlling Third-Party Cookies

To opt out of interest-based advertising from certain third parties, you may also visit the Network Advertising Initiative (NAI). This allows you to disable behavioral targeting across participating ad networks.