Privacy and Cookie Policy
Your privacy is important to us at Stablecorp. We respect your privacy regarding any information we may collect from you across our website.
Your privacy is important to us at Stablecorp. We respect your privacy regarding any information we may collect from you across our website.
Protecting the privacy, security and confidentiality of personal information is fundamental to the way Stablecorp does business. This Privacy Policy explains the ways we help protect personal information, and respect and support the trusted relationship between our business clients (Clients) and their customers (Consumers). For Stablecorp, “Information” means any personal, transaction and other details that we require to support Stablecorp Services.
By using the Stablecorp Services, including through a computer or mobile device, each Client and Consumer accepts the terms of this Privacy Policy and consents to our collection, use, disclosure and retention of their information as described in this Privacy Policy (including to contact them), and for all other purposes permitted under applicable personal information privacy statutes, anti-spam legislation, and consumer protection laws. Our website and Services are not targeted or directed at children under the age of 18 and do not knowingly collect or store any personal information from children under the age of 18.
We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last updated” date above. The revised version will be effective at the time we post it. Continued use of our Services constitutes acceptance of any amendment of this Privacy Policy.
The Privacy Policy consists of four key principles:
Collecting and using information: Before we ask for any personal information about the Client or the Consumer, we will explain why it is needed and how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain consent if we wish to use this information for any other purpose.
Releasing information: We may need to provide personal information to our suppliers who assist us in serving Clients. We may also need to release the information if we are required to do so by law and self-regulatory organizations to prevent, detect or suppress financial abuse, fraud and criminal activity.
Protecting information: We will protect information with appropriate safeguards and security measures. We will retain information only for the time it is required and for the purposes we explained.
Respecting privacy concerns: We will investigate and respond to Client and Consumer concerns about any aspect of our handling of their information.In this Privacy Policy, we explain how we fulfil each of these important principles.We collect the information we need and only use it for the purposes explained to the Client and Consumer.
Personal information is required to support transaction processing and communications, and to satisfy valid information requests from Interac™, banks, regulators, and other organizations who are legally entitled to make such requests.
When completing a Stablecorp transaction through the Internet or through a mobile device, we may collect device level information about that Consumer. This information will help to identify higher risk transactions and monitor potential fraud or suspicious transactions.
When a Consumer is using our website, we may monitor and/or record browsing habits to better understand usage of our on-line assets.If the Client provides us information about a specific Consumer to resolve a complaint, we may learn additional Consumer information. We will only use this information to address comments and/or reply to questions, and we may store the communication and our reply in case we correspond further.
If a Consumer receives an email claiming to be from Stablecorp that he/she believes to be fraudulent, he/she should not open, respond or click any links or open attachments contained within the email. Consumers may be instructed to notify us immediately by forwarding a copy of the email to us at admin@Stablecorp.com and then delete the email.
In order to provide certain services on mobile devices, we may require location information. If the Client or Consumer does not consent to collection of this information, then they cannot use the corresponding Services. Clients and Consumers can stop our collection of location information at any time by changing the preferences on their mobile devices. If the preferences are changed, our Services may no longer function. Clients and Consumers also may stop our collection of location information through the Services by following the standard uninstall process to remove all Stablecorp mobile applications from their devices.
We may send cookies to Client or Consumer computers or mobile devices. Cookies are small data files that are stored on a hard drive or in device memory when a Client or Consumer visits a website or views a message. Cookies support the integrity of our registration process, retain Client and Consumer preferences, and help evaluate and compile aggregated statistics about user activity.
We only release information where it is required to deliver the Stablecorp Services.
We will obtain the Client’s consent to release any information to third parties required to deliver Stablecorp Services. To deliver email and text messages, Client and Consumer information may be disclosed in response to valid demands or requests from governments, regulators, courts and law enforcement authorities.
We do not sell or rent customer lists or personal information to others.
We protect information with appropriate safeguards and security measures.
We have security standards to protect our systems and Client and Consumer information against unauthorized access and use.
Our systems have been designed to ensure that email address, mobile number, first name and Client account number are always private and confidential. Nevertheless, Stablecorp cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use Client or Consumer personal information for improper purposes. If any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.
All our suppliers and agents, as part of their contracts with Stablecorp, are bound to maintain confidentiality and may not use information for any unauthorized purpose. Protecting the confidentiality of information is also specified in our employment agreements. Our employees are familiar with this Privacy Policy and procedures to safeguard Client and Consumer information.
When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required.
Client and Consumer data is stored on Amazon Web Services (AWS), encrypted in accordance with information security standards, and located in Canada.
We retain information only if it is required for the reasons it was collected. We are required to retain transaction data for a period of 7 years following completion of the transaction. We will destroy, delete, erase or convert it to an anonymous form after that point.
We take any complaints seriously – and are committed to helping resolve complaints.
Usually, the best way to address the complaint is to raise the issue as soon as it comes up with the person the Client or Consumer is dealing with. Even if the Client or Consumer doesn’t notice the issue right away, the Client or Consumer can always get in touch with us at any time to voice their complaint.
Before beginning, be ready to have any supporting documents available and consider what solution may be appropriate.
To tell us about any concerns or complaints or questions regarding this Privacy Policy, please contact us at admin@Stablecorp.com. We may request additional details regarding the concerns and may need to engage or consult with other parties in order to investigate and address the issue. We will keep records of the request and any resolution.
If the resolution provided is unsatisfactory, the complaint can be escalated in the following ways:
The Client or Consumer can ask the individual they are dealing with to escalate on their behalf.
Escalate the complaint directly with Stablecorp management, using the following contact information.
Alex McDougall
CEO
alex@stablecorp.ca
If the results of our investigation or any resulting corrective measures remain unsatisfactory, the Client or Consumer may be entitled to make a written submission to the Privacy Commissioner in their jurisdiction or to the Office of the Privacy Commissioner of Canada at the address below:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
https://www.priv.gc.ca/en
POLICY STATEMENT
Canada Stablecorp Inc is committed to protecting the personal information entrusted to us by our customers. We protect your personal information in accordance with all applicable law, including Ontario’s Freedom of Information and Protection of Privacy Act (“FIPPA”), Canada’s Anti-Spam Legislation (“CASL”) and other applicable laws (collectively the “Acts”). This Policy governs the collection, use, disclosure, retention and other processing of personal information by STABLECORP, including through STABLECORP products and services, on STABLECORP websites and via mobile applications. It explains what types of personal information is collected from our customers, how it may be used, and how you can ask us questions about our privacy practices.
STATUTORY AUTHORITY
Any personal information collected by or on behalf of STABLECORP is collected pursuant to the existing laws and regulations.
SCOPE
This Policy governs our practices with respect to personal information we collect from individuals through our products, services, and offerings, including through STABLECORP’s websites and online applications.
REGARDING CHILDREN AND MINORS
Our website, applications and the services offered on our website and applications are not directed to individuals under the age of 18. We will not knowingly collect personal information about individuals under the age of 18. We do not allow individuals under the age of 18 to create accounts, make purchases or enter contests or promotions.
WHAT IS PERSONAL INFORMATION?
Under FIPPA, “personal information” means recorded information about an identifiable individual. In general, STABLECORP collects the following types of personal information, although different types of information may be collected depending on the purpose of collection or if the collection is required by law:
• Identity information (such as your full name, Driver’s Licence number or other official ID number, etc.);
• Demographic information (such as your age or gender);
• Contact information (such as your email address or phone number);
• Location information (such as your address or the location of a device you use to access our website or applications);
• Professional information (such as your occupation or industry of employment);
• Banking or financial information (such as payment or withdrawal account information); and
• Transaction information (such as payment history, customer service history, or other information related to transactions between you and STABLECORP);
WHY DOES STABLECORP COLLECT PERSONAL INFORMATION?
STABLECORP uses the personal information it collects for a variety of purposes in the course of carrying out its objects. When we collect personal information from customers, we provide a ‘“Notice” which explains the specific purposes of collection for a given program, service, or offering. In general, the most common purposes for STABLECORP’s collection of personal information can be organized into three main categories:
A. For program, service, or product administration – in order to provide you with service you have requested or to administer your participation in a particular program, we may use personal information. That may include using personal information for the following purposes:
• Uniquely identifying and authenticating customers to provide them access to their account.
• To deliver marketing and promotional material, including offerings (in accordance with the Acts) tailored to the recipient;
• To administer safe harbour, loyalty or responsible programs;
• To provide customer service, and otherwise respond to customer requests, inquiries, comments, and concerns;
• To customize the presentation of our products, services, webpages, and applications to individual users;
B. To analyze and improve upon our products, services, programs, offerings, and processes – in addition to day-to-day administration of the services you engage with, we may also use personal information to assist us in evaluating and improving our products, services, programs, offerings, and processes. That may include using personal information for purposes such as:
• To research the operational effectiveness and business viability of current and prospective products, programs, campaigns, and services;
• To better understand the interests of current and prospective customers;
• To tailor or personalize offers and information (in accordance with the Acts) to receiving patrons; and
• To engage in research.
C. To help STABLECORP comply with applicable law and to maintain the integrity of STABLECORP’s operations – in certain circumstances, STABLECORP may be permitted or required to collect, use or disclose personal information so that it can comply with applicable law, or to maintain the integrity of its business. That could include using personal information for purposes such as:
• Ensuring that customers are eligible to participate;
• Maintaining the physical security of STABLECORP premises, such as through use of video surveillance or by checking patron identification;
• Collecting, organizing, and assessing customer 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;
• As otherwise required or permitted under applicable law or regulations
• Collection.
DOES STABLECORP DISCLOSE PERSONAL INFORMATION?
From time to time, STABLECORP may disclose personal information to service providers or vendors acting on its behalf to enable them to perform specific types of processing and other specialized services. Additionally, STABLECORP may disclose personal information to law enforcement, regulators, and other third parties where permitted or required by law.
HOW IS PERSONAL INFORMATION RETAINED AND SECURED?
Personal information collected by STABLECORP is retained in accordance with applicable law and STABLECORP’s records retention policies. After the applicable retention period for records containing personal information has elapsed, the records are securely disposed of in accordance with STABLECORP information security policies. Throughout the retention period, STABLECORP will make reasonable efforts to ensure personal information in our custody or under our control is kept accurate, complete, and up to date. STABLECORP has implemented physical, procedural, and technological security measures to protect the personal information in its custody and under its control. Access to personal information at STABLECORP is restricted to individuals who require such access to perform their duties. Furthermore, STABLECORP imposes information security requirements on third party vendors and service providers to whom personal information is disclosed. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. STABLECORP therefore does not warrant, represent, or guarantee the absolute security personal information in our custody or under our control.
HOW IS THE PERSONAL INFORMATION OF STABLECORP’S INTERNET CUSTOMERS PROCESSED?
You can visit STABLECORP’s websites and download its mobile applications without registering for an account. However, certain products and services available through STABLECORP websites and mobile applications require that you register for an account. Should you choose to register for an account, STABLECORP will process your personal information in the course of administering your account. The following types of information may be collected throughout your registration for, and use of, an Internet account:
• Name
• Date of Birth
• Full Home Address
• Email Address and Phone Number
• Transaction and Play History
• Supporting Documents to Verify Identity
• Device Information and connection IP address
• Payment Information
• Withdrawal Account Information
• Language and Marketing Preferences
• Device Location
• Supporting Documents to Confirm Withdrawal Account Ownership
• Username and Password
• Security Questions and Answers
• Occupation and Industry
• Customer Service Records
• Customer ID (assigned by STABLECORP)
In general, and in addition to other processing as described throughout this Policy, the processing of personal information for administering accounts can be organized into four main phases:
A. Registration & Account Activation – when you choose to register for an account, STABLECORP will collect certain identity, demographic, employment, and contact information. This information will be used to administer your account throughout your use on the service, to confirm your eligibility, and for anti-fraud and legal compliance purposes. Additionally, STABLECORP will seek to confirm that the device you use to register is located in Canada, as STABLECORP’s service is only available to persons residing in Canada. Prior to account activation, STABLECORP will seek to verify the identity of a registering individual. To confirm your identity, STABLECORP shares some of the information you provide at registration with a third party identity verification service(s). If your identity cannot be verified with the information you provided at registration, we may require that you submit additional information or proof of identity prior to the completion of registration. Access to this additional information will only be provided to STABLECORP personnel who require such access to complete the identity verification process. The information will be retained in a manner consistent with this Policy and STABLECORP’s internal retention and information security procedures.
B. Use of the Service - after registration and account activation, you will be able to securely log into STABLECORP’s service. When you log in, STABLECORP will seek to confirm that the device you are using is located in Canada, as STABLECORP’s service is only available to persons residing in Canada and who use the service while physically located in Canada. Additionally, information about your use, such as transaction data, settings, and history will be retained and used to provide you access to your overall account history, including monitoring, analyzing and communicating with you about your use of the service, and for purposes as otherwise described throughout this Policy.
C. Purchasing and Withdrawals – while logged in to your account, you will have the option to purchase certain STABLECORP products and services. Should you choose to do so, STABLECORP will collect payment information and payment through its third-party secure payment providers. Transaction information will be processed to provide you access to a history of your transactions, for anti-fraud purposes, for compliance with applicable law and regulation, and as otherwise described throughout this Policy. Should you choose to withdraw funds from your account, STABLECORP will collect bank account information from you to process your withdrawal requests. This information will be shared with STABLECORP’s partner financial institution to process your withdrawal request. Where permitted or required for compliance with applicable law, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, STABLECORP may collect additional information a third-party identity verification service. In addition, you will be required to upload supporting documentation to confirm your withdrawal information. Access to uploaded supporting documentation will only be provided to STABLECORP personnel who require such access to complete the withdrawal process. The documentation will be retained in a manner consistent with this Policy and STABLECORP’s internal retention and information security procedures.
D. Inactivity & Deletion –in certain circumstances as described in the Agreement, your account may be deemed inactive or dormant. In such circumstances, personal information will be retained in accordance with applicable law and STABLECORP’s records retention policies. After the applicable retention period for records containing personal information has elapsed, the records are securely disposed of in accordance with STABLECORP information security policies. In addition to the processing as described above, your personal information associated with your account may be processed in circumstances unique to you. Examples of such processing include:
• Customer Service – additional personal information may be collected and processed to assist you with your customer service inquiries.
• Prize Winner Publication – should you win a qualifying prize, your personal information may be published as described in the Player Agreement and where permitted or required by law. To provide Internet Gaming products and services, your personal information may be disclosed to third party service providers assisting STABLECORP in the administration. Examples of such third parties include:
• Identity Verification Services – to prevent fraudulent activity and for compliance with applicable law, STABLECORP shares your name, date of birth, and address with a third party identity verification service at registration or in the course of administering active accounts;
• Content Providers – to provide casino games and sports wagering, STABLECORP shares your language preferences and a unique alphanumeric identifier assigned by STABLECORP to your Internet Gaming account with third party content providers.;
• Address Verification – to confirm your address is entered correctly at registration, STABLECORP shares the address with an address verification service. The other information you provide STABLECORP is not shared for address verification;
• Payment Provider – to facilitate payment, your payment card information is collected and processed by STABLECORP’s secure payment provider. Your full payment card information is retained by the secure payment provider, and is not shared with or stored by STABLECORP;
• Banking Provider – to facilitate your requests for withdrawals of funds, the bank account information you provide is shared with STABLECORP’s partner financial institution. This information is used to ensure your withdrawals are deposited into your account;
• Geo-location Provider – the STABLECORP Internet Gaming service is only available to eligible individuals who are physically located in Canada. Accordingly, your connection information and the location of the device you use to access the Internet Gaming service may be shared with STABLECORP’s third party geo-location service; and Personal information collected in the course of administering the service is stored by STABLECORP in Canada and is retained in accordance with its records retention policies. Personal information disclosed to third party service providers may be stored in other jurisdictions.
YOUR RIGHTS
If you have an account, you may log in to access and update certain personal information stored with your account. For assistance, please contact the STABLECORP Support Centre at 1-800-387-0098.You have the right to request access to personal information retained by STABLECORP. Upon request, STABLECORP will make reasonable efforts to catalogue and summarize the personal information related to you that is in its custody or under its control. You have the right to request the correction of any personal information in STABLECORP’s custody or under its control. If, in STABLECORP’s sole and absolute discretion, the correction cannot be made, you may require that a statement of disagreement be attached to the information reflecting any correction that was requested but not made.
COOKIES & WEBSITE LOG DATA
In addition to any information that you choose to submit to us, we or selected third parties may use a variety of technologies that store or access information already stored on your personal computer, laptop, tablet or mobile phone (each a “device”) whenever you visit or interact with our website or applications. A cookie is a text file placed on a device when a user visits a website. Cookies can be temporary (i.e. session) or permanent (e.g., persistent). They can also be first party (i.e., placed by us) or third party (i.e.., placed by a third party advertiser or advertisements server). Cookies that may be used to store or access information already stored by STABLECORP on your device include but are not limited to:
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