Deal or No Deal Casino

This privacy policy (“Privacy Policy”) explains how iPro Games Canada, Inc., doing business as Deal or No Deal Casino (“iPro”), collects, uses, and discloses personal information about you. This Privacy Policy applies to all information iPro collects in connection with its operation and offering of, and your access to and use of, iPro’s online casino and internet gaming products and services offered in the Province of Ontario, whether accessed online via a computer or mobile device, or via a mobile application (collectively, the “Site”).

iPro offers the Site as part of the regulated internet gaming market in Ontario that is conducted and managed by iGaming Ontario. In the course of providing access to and use of the Site, iPro collects, uses and discloses personal information on behalf of and as agent for iGaming Ontario. iPro collects, uses, discloses, retains and/or disposes of personal information in accordance with the Freedom of Information and Protection of Privacy Act (“FIPPA”) and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act and the Operating Agreement between iPro and iGaming Ontario.

This Privacy Policy is incorporated into and constitutes part of the iPro terms of service, available at here (the “Agreement”). Any disputes related to this Privacy Policy, including any breaches in security or privacy, will be subject to the limitations on liability and dispute resolution provisions contained in the Agreement. All capitalized terms used in this Privacy Policy and not defined herein shall have the respective meanings assigned to them in the Agreement.

By using the Site, you acknowledge that you have read and agree to be bound by the terms of this Privacy Policy. If you do not agree to the terms set out herein, you may not use or access the Site.

For the purposes of this Privacy Policy, “Personal Information” means any information about an identifiable individual and includes any information that constitutes personal information within the meaning of FIPPA or any other applicable privacy law.

iPro will collect the information you directly provide to it in the course of using the Site, such as when you apply for an Account, complete a “Contact Us” form, participate in tournaments, promotions or surveys, or otherwise communicate with iPro.

When you register for an Account, iPro will require you to provide certain Personal Information including, at a minimum, your name, date of birth, mailing address, email address, and any other information which may be required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) and the regulations under it. iPro may also collect information contained on government issued identification (e.g., drivers’ license) and information needed to verify your place of residence if required to verify identity. When you fund your Account in order to participate in betting and wagering games offered through the Site, you will be required to provide your financial account and deposit information, along with withdrawal method details.

At any time during the Account registration process or thereafter, iPro may require you to provide additional information and documentation if iPro determines, in its sole discretion, that such additional information or documentation is: (a) required to comply with applicable laws or regulatory requirements, including the Alcohol and Gaming Commission of Ontario (“AGCO”) Standards and/or anti-money laundering (“AML”) rules and regulations; (b) considered necessary or advisable by iPro to prevent suspected or actual fraud or other illegal activity; (c) required to address a suspected or actual breach of the Agreement; and/or (d) required to confirm your identity, age or entitlement to receive or withdraw Unutilized Funds. iPro may, in its sole discretion, ask that you provide notarized copies of these documents as an additional layer of verification. You hereby expressly consent to iPro’s verification (including through disclosure of your information to third party verification services) of all information you provide during the Account registration process or thereafter during your use of the Site.

Without limiting the generality of the foregoing, you will be required to provide iPro with such information and documentation as iPro may request or require in order to comply with its Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) reporting obligations.

When you access or use the Site, iPro may automatically collect certain information about you, including:

1. Log Information: iPro logs information about your use of the Site, including the type of Internet browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the Site.


2. Device Information: iPro collects information about the computer or mobile device you use to access the Site, including the hardware model, operating system and version, unique device identifiers and mobile network information. iPro may collect data from certain other services running in the mobile or desktop application, including your data about your Wi-Fi connection and browser, the use of VPN services, and the presence of any applications that circumvent location detection.


3. Location Information: To participate in games, betting, wagering and promotions offered through the Site, you must be physically located in Ontario, Canada. iPro, its third-party service providers, and applicable federal or provincial regulators, including the AGCO and iGaming Ontario, may utilize tracking technologies to verify and record your physical location when you are participating or attempting to participate in games, betting, wagering and promotions offered through the Site (“Geolocation Technologies”). These Geolocation Technologies will report the physical location of the device you are using to access the Site. To enable the use of Geolocation Technologies on your desktop, you will be asked to install iProLocID software solution for location verification, which will collect information related to: (i) your device operating system, network adapter and network interface information; (ii) your IP address; and (iii) Wi-Fi.
   If accessing the Site from a mobile device, and if you grant iPro permission, the Geolocation Technologies will use your mobile devices’ built-in GPS to accurately show where the device, and the user of the device, are located.


4. Information Collected by Cookies and Other Tracking Technologies: iPro may use various technologies to collect information via the Site. This may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help iPro to improve the Site and your experience, see which areas and features of the Site are popular, and count visits. iPro may also collect information using web beacons (also known as “gifs”, “pixel tags” and “tracking pixels”) and flash cookies. Web beacons are electronic images that may be used on the Site or in emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Flash cookies are text files sent by web servers when your browser requests Adobe Flash-supported content and are used for similar purposes as traditional cookies. For more information about cookies, web beacons, and flash cookies, and how to disable them, please see Section 11 (Your Choices) below.

When you use the Site to play for real money online, iPro may use the services of Aristotle International Inc. ("Aristotle"), a third-party service provider, for purposes of verifying your identity to meet Ontario regulatory requirements. For such purposes, iPro and Aristotle may collect personal information from you and verify your identity with a credit bureau, including by accessing your credit file (for identity verification only). This is not a credit check and will not affect your credit rating or credit score. Collection, use and disclosure of your personal information for this purpose is required for regulatory compliance and therefore is a mandatory condition of using our products and services. By using the Site, you expressly authorize iPro to provide your personal information to Aristotle and to receive information from Aristotle as described in this Privacy Policy.

All of your Personal Information that is provided to or collected by iPro shall only be used by iPro in connection with the Site and may be shared with the AGCO and/or iGaming Ontario, in addition to the other entities listed herein.

iPro uses the information collected through the Site for the purposes described in this Privacy Policy or as otherwise disclosed to you in connection with the Site. For example, iPro may use your information:

1. to communicate with you about iPro’s or other companies’ products, services, offers, promotions, rewards, and events and provide other news and information about iPro and other companies with which it partners, as permitted by applicable laws;
2. to provide, maintain and improve the Site;
3. to process and administer payments and Account deposit and withdrawal requests;
4. to provide and deliver the products and services you request, process transactions, and send you related information, including transaction confirmations;
5. to send you technical notices, updates, security alerts and support and administrative messages;
6. to respond to your comments, questions and requests and provide support services;
7. to confirm your continued eligibility to maintain an Account;
8. to confirm that your Account information remains true and accurate;
9. to monitor and analyze trends, usage and activities in connection with the Site;
10. to personalize and improve your experience on the Site and provide ads, content, or features that match user profiles or interests;
11. to process and deliver promotion and contest entries, rewards and surveys; and
12. as otherwise as permitted or required by applicable law.

iPro may share Personal Information about you, in accordance with the following or as otherwise described in this Privacy Policy:

1. with iGaming Ontario for any and all purposes for which iPro may use your information and as further permitted or required by applicable law;
2. with AGCO for any regulatory compliance purpose as permitted or required by applicable law;
3. with iPro’s third party service providers, including:
   1. iPro Inc. – to investigate AML transactions or administer player self-exclusions, and to resolve certain technical issues regarding game play;
   2. Conduet – for customer relationship management and player support;
   3. Incline Marketing – for marketing, including email marketing where you have provided opt-in consent; and
   4. Aristotle – for the purposes described in this Privacy Policy.
4. for analytics services (e.g., web site usage);
5. with your express consent, with other companies with which iPro partners for direct marketing purposes;
6. with vendors, consultants and other service providers who need access to such information to carry out work on behalf of iPro, including technical support and payment processing services;
7. in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of iPro’s business;
8. in response to a request for information if iPro believes disclosure is required by, or is in accordance with, any applicable law, regulation or legal process. For example, as agent for iGaming Ontario, and given that information collected through the Site is under the control of iGaming Ontario, iPro may disclose Personal Information in compliance with FIPPA to facilitate responses to freedom of information requests and requests from individuals for information relating to them;
9. to investigate any suspected breaches of the Agreement, including any suspected fraudulent or dishonest activity, or if iPro believes your actions are inconsistent with the spirit or language of the Agreement, this Privacy Policy, or any other iPro policies, or to protect the rights, property or safety of iPro or others;
10. with your consent or at your direction including if iPro notifies you through the Site that the information you provide will be shared in a particular manner and you provide such information; and
11. to exercise any of iPro’s other rights as described in the Agreement.

iPro may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

The Site may offer social sharing features and other integrated tools (such as the Twitter “Tweet” button), which will let you share actions you take on the Site with other media. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with such social sharing features, please visit the privacy policies of the entities that provide these features.

If you use the message boards, leaderboards, chat rooms, comment tools, or other public forums of the Site, you will be publicly identified by your screen name and other Player Content you submit. Additionally, when you participate in certain promotions or tournaments offered through the Site (e.g., a leaderboard promotion), iPro may also identify you by your screen name. Your screen name and all information you provide on these public forums will be viewable by the general public. Your screen name will be either the content of the email address associated with your Account preceding the ‘@’ symbol, or such other screen name chosen by you in accordance with the terms of the Agreement. iPro cannot be responsible for any personal or sensitive information in your screen name or which you choose to post on public forums and iPro recommends careful consideration before you include any personal or sensitive information in your screen name or otherwise post such information. You agree that you will not disclose personal or sensitive information relating to any other person in a public forum of the Site without that person’s prior, express consent.

iPro may allow others to serve advertisements on its behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Site and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by iPro and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Site and other websites and better understand your online activity. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit: www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.

iPro’s advertising and analytics service providers include:

1. Firebase: Firebase is a suite of performance analysis and monitoring tools, which is provided by Google Inc. iPro uses Firebase to monitor the overall performance and stability of its mobile application, implement internal version control, identify bugs and prioritize fixes. For this purpose, Firebase collects your IP address, device identifier, as well as event and usage data specifically related to your use of iPro’s mobile application. It is not possible to opt-out of this as Firebase is an essential tool that iPro requires in order to provide a functioning mobile application to you.
2. Google Analytics: Google Analytics is a web analytics service that provides statistics and analytical tools for search engine optimization and marketing purposes. iPro uses Google Analytics to see information on concerning Site activities including, but not limited to, page views, source and time spent on a Site and to provide advertisements to you on other websites. iPro uses Google Analytics on Sites to analyze how users use the website. Google Analytics may collect information such as user location as inferred from IP address, the amount of time a visitor spends on a Site, which pages are more frequently accessed, how the Site is accessed (either directly, from a search engine, or from a link), what sort of software is used (e.g., operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/.
   For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.
3. Google Tag Manager: Google Tag Manager is a tag management system. Tags are small code elements that serve, for example, to measure traffic and visitor behaviour, to capture the impact of online advertising and to optimise remarketing. Google Tag Manager only manages tags, meaning that no cookies are used, and no Personal Information is stored. Google Tag Manager triggers these tags, which in turn collect data if necessary. If a deactivation has been made at the domain or cookie level, it remains valid for all tracking tags if they are implemented with the Google Tag Manager.
4. AppsFlyer: AppsFlyer is an attribution and marketing analytics service. iPro uses AppsFlyer to measure and analyze the effectiveness of its marketing campaigns by understanding which marketing campaigns contributed to the download/installation of iPro’s mobile application. iPro also uses AppsFlyer to measure and analyze certain events and actions within the Site, such as in-app purchases made by you. iPro may share information that can be used to personally identify your device, such as IP address, operating system, device attributes and settings; the downloads and installations of iPro’s mobile application, and your other interactions with iPro’s mobile application.
   For information about how to opt out of having your information used by AppsFlyer, visit:https://www.appsflyer.com/legal/opt-out/
5. Facebook Conversion API: Facebook Conversion API helps iPro better understand how you interact with the Site, including by allowing iPro to measure the impact of its ads on the Site’s conversions, and improves ad targeting through custom audiences. With the help of the Facebook pixel, iPro can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to the Site after clicking on a Facebook ad (“conversion”).
   Due to the marketing tools used (Facebook pixel and Conversions API), your browser automatically establishes a direct connection with the Facebook server. Through the integration of the Facebook pixel and the usage of the Conversions API, Facebook receives the information that you have called up the corresponding website of iPro’s Internet presence or clicked on an advertisement from iPro. If you are registered with a Facebook service, Facebook can assign the visit to your account.
   You can deactivate this tool via the Cookie Settings and for logged in users at https://www.facebook.com/settings/?tab=ads#.

iPro and its third-party service providers may use, store, retain, and disclose collected Personal Information outside of the Province of Ontario and Canada.

iPro and/or iGaming Ontario will retain your Account information, including Personal Information, for as long as needed to provide you the services on the Site. Upon closure, suspension or deactivation of your Account, iPro and iGaming Ontario will retain all records and information associated with your Account if, and for so long as is necessary, to comply with all requirements of the Gaming Control Act, 1992, the regulations thereunder, the AGCO Standards, and any other applicable law.

iPro may establish general retention practices and limits concerning use of the Site, including the maximum period of time that data or other content will be retained by and the maximum storage space that will be allotted on the Site on your behalf. iPro has no responsibility or liability for the deletion or failure to store any data or other content maintained or transmitted through the Site. iPro reserves the right to change these general retention practices and limits at any time, in its sole discretion, with or without notice.

iPro takes reasonable measures to help protect your Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. iPro uses technology that is designed for use with secure web servers. Secure Sockets Layer technology encrypts your Personal Information as it is transmitted over the Internet during the Account registration process and during any subsequent verification requests iPro may make. Please be advised that no means of transmission over the Internet is 100% secure and accordingly, your use of the Site remains at your own risk.

iPro will take appropriate steps to contain, investigate, and remediate data security incidents. iPro will notify applicable regulatory authorities and affected parties about data security incidents as appropriate and/or required by law and will aid iGaming Ontario and any other applicable authorities in the management and handling of such data incidents.

The Site is intended only for users over the age nineteen (19). iPro does not knowingly collect Personal Information from persons under nineteen (19) years of age. If iPro determines that an individual is under nineteen (19) years of age, it will not use, maintain, or continue to collect Personal Information from such individual. If you are a parent or guardian and believe iPro has mistakenly collected Personal Information from your child who is under nineteen (19) years of age, you can notify iPro using the contact information set out in Section 13 (Contact Us) below.

You may opt out of receiving promotional emails or text messages from iPro by following the instructions in those emails or text messages, or through your “My Account” page on the Site. If you opt out, iPro may still send you transactional or relationship messages, such as emails or text messages about its ongoing business relations.

With your consent, iPro may send push notifications to your mobile device to provide game-related information, service updates, promotional communications and other related messages. You can deactivate these notifications by changing the notification settings applied to iPro’s mobile application on your device, or you can opt out of receiving these notifications through your “My Account” page on the Site.

You may opt-out of flash cookie placement at http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html.

To participate in games, betting, wagering and promotions offered through the Site, you must be physically located in Ontario, Canada at all times while participating in such activities. iPro, its third-party service providers, and applicable federal or provincial regulators may use Geolocation Technologies to confirm your physical location when using the Site. If you disable or attempt to disable iPro’s use of Geolocation Technologies at any time, you may not participate in wagering games or promotions available through the Site but may continue to access or otherwise use the Site. You may choose to disable certain Geolocation Technologies through the location settings applied to iPro’s mobile application on your device. You may also disable certain Geolocation Technologies by deleting iPro’s mobile application from your device or otherwise ceasing use of the Site.

Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Please note that iPro does not interpret or respond to “Do Not Track” signals. However, you can usually choose to set your browser to remove or reject cookies and web beacons. Please note that the Site may not function properly if you do so. To opt out of iPro’s use of cookies for targeted advertising, please refer to Section 6 (Advertising and Analytics) of this Privacy Policy.

Subject to legal limitations, you may contact iPro using the contact information set out in Section 13 (Contact Us) below to make requests for access to, correction or deletion of certain Personal Information that iPro stores. Any such communication must be in writing.

Your right to access the Personal Information that iPro holds about you is not absolute. There are instances where applicable law or regulatory requirements allow or require iPro/iGaming Ontario to refuse to provide some or all of the Personal Information that it holds about you. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with record retention obligations and practices. In the event that iPro cannot provide you with access to your Personal Information or if iPro does not agree with your request to change your Personal Information, iPro will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

iPro may change this Privacy Policy from time to time. If iPro makes any changes, it will notify you by revising the “Last Updated” date at the top of this Privacy Policy, and, in some cases, iPro may provide you with more prominent notice (such as by adding a statement to the homepage of the Site or sending you an email notification). You are encouraged to review this Privacy Policy whenever you access the Site to stay informed about iPro’s information practices and about ways you can help protect your privacy.

If you have any questions about this Privacy Policy or concerns about the handling of your Personal Information, please contact iPro:

1. by e-mail at: support@casinodond.com; or
2. by mail at: iPro Games Canada, Inc., 5800 Ambler Drive, Suite 210, Mississauga, Ontario L4W 4J4.

Alternatively, you may contact iGaming Ontario:

1. by e-mail at: igaming@igamingontario.ca;
2. by telephone at: 416 326-8283, 833 55-iGame / 1 833 554-4263; or
3. by mail at: 90 Sheppard Avenue East, Suite 310, Toronto, Ontario M2N OA4.

iPro will endeavor to respond to all privacy complaints as soon as possible. If you are not satisfied with the way that iPro handled your privacy complaint, you may contact the relevant privacy regulator, as follows:

Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400

Toronto, Ontario M4W 1A8

iPro reserves the right to provide a copy of your complaint and relevant documentation to the privacy regulator.