Privacy Policy

POLICY STATEMENT

This Privacy Policy ("Policy") establishes the legally binding terms and conditions under which personal information is collected, used, disclosed, retained, and safeguarded by the operator of the browser-based entertainment platform accessible at https://canuckplayhouse.com (the "Platform"). This Policy is issued in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial privacy laws, Canada's Anti-Spam Legislation (CASL), and other relevant Canadian statutory and common law requirements governing data privacy, electronic marketing, and consumer protection.

This Policy applies exclusively to natural persons who are at least eighteen (18) years of age and are resident in Canada. By accessing or using the Platform, users confirm that they satisfy the applicable eligibility requirements and hereby consent to the processing of their personal information in accordance with this Policy and applicable law.

The Platform is operated by an organization established in Canada that assumes full accountability for the personal information it collects, directly or indirectly, in the course of providing access to its services. All privacy-related inquiries, including access or correction requests, complaints, or withdrawal of consent, must be submitted in writing to: support@canuckplayhouse.com

COLLECTION OF PERSONAL INFORMATION
USE AND PROCESSING OF PERSONAL INFORMATION
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
COOKIES AND TRACKING TECHNOLOGIES
DATA RETENTION AND SECURE DISPOSAL
INFORMATION SECURITY
AGE RESTRICTIONS AND ACCESS CONTROLS
ACCESS AND CORRECTION OF PERSONAL INFORMATION
DO NOT TRACK SIGNALS AND BROWSER PREFERENCES
AMENDMENTS TO THIS POLICY
COMPLAINTS AND CONTACT PROCEDURE

1. COLLECTION OF PERSONAL INFORMATION

The Platform collects personal information from users both directly and automatically through their interactions with the Platform. All collection is conducted in accordance with lawful purposes and is limited to information reasonably necessary to operate, maintain, and improve the services offered.

(a) Information Provided Voluntarily
Users may be required or permitted to submit personal information through direct interactions with the Platform, including but not limited to:

- Submitting inquiries or communications via customer support channels;

- Opting in to receive updates, notifications, or promotional content;

- Participating in tournaments, social features, or voluntary user feedback activities.

Personal information collected in this manner may include, without limitation:

- Full name;

- Contact email address;

- User-generated content or message details.

Users are solely responsible for ensuring that all submitted information is accurate, current, and complete. Submission of any false, misleading, or outdated information constitutes a violation of this Policy and may result in access restrictions or account termination.

(b) Prohibited Categories of Information
The Platform does not solicit, and users are expressly prohibited from submitting, any sensitive personal information, including but not limited to:

- Racial or ethnic origin;

- Political opinions or religious beliefs;

- Health, biometric, or genetic data;

- Sexual orientation or gender identity;

- Criminal records or allegations;

- Trade union membership.

Any submission of such data shall be deemed unsolicited and will be deleted without notice upon identification.

(c) Information Collected Automatically
Upon access or use of the Platform, the following categories of non-identifiable technical and usage data may be collected automatically using server logs, browser signals, and integrated third-party tools:

- IP address and geolocation (approximate region);

- Device identifiers, browser type, and system configuration;

- Language preferences and screen dimensions;

- Page views, clickstream, timestamps, and usage patterns;

- Referral sources, navigation events, and outbound links;

- Session identifiers and performance diagnostics.

This information is used solely for lawful purposes related to system operations, service monitoring, audience analytics, advertising attribution, fraud detection, and regulatory compliance. When combined with other personal data, such information is treated in accordance with the obligations set forth in this Policy.

2. USE AND PROCESSING OF PERSONAL INFORMATION

Personal information is collected and processed exclusively for the fulfilment of lawful, identified, and legitimate purposes related to the provision and governance of the Platform. These purposes include, but are not limited to:

- Facilitating user access to the Platform and maintaining operational functionality;

- Delivering technical support, responses to user enquiries, and customer service communications;

- Monitoring aggregate usage metrics and system performance diagnostics;

- Customizing content presentation and service experiences based on user interaction;

- Managing advertising attribution, affiliate validation, and promotional analytics;

- Enforcing Platform terms of service, resolving disputes, and investigating potential violations;

- Ensuring compliance with applicable Canadian laws and regulations, including privacy, consumer protection, and advertising standards.

The Platform does not engage in automated decision-making processes that produce legal or similarly significant effects on users. Personal data is not used for purposes beyond those expressly disclosed unless prior consent is obtained or an applicable lawful exception exists.

3. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

The Platform processes personal information exclusively in accordance with lawful bases as recognized under the Personal Information Protection and Electronic Documents Act (PIPEDA), provincial privacy statutes, and relevant common law principles.

The applicable legal bases include:

LEGAL BASIS	DESCRIPTION
Informed Consent	Where users have affirmatively agreed to specific uses of personal information, such as through cookie consent tools or form submissions. Consent may be withdrawn at any time.
Legitimate Interests	Where processing is reasonably necessary for the operation, performance, or security of the Platform, provided such interests do not override the user's fundamental rights.
Legal Obligation	Where processing is required to comply with applicable federal, provincial, or territorial laws, including court orders, regulatory inquiries, or lawful access requests.
Contractual Necessity	Where processing is required to deliver services, fulfil user-initiated actions, or provide access to Platform features explicitly requested by the individual.

Where consent is relied upon as the legal basis, the Platform will ensure that it is specific, informed, and capable of being withdrawn by the user through the contact information set out in this Policy.

4. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

The Platform does not sell, rent, or exchange personal information for monetary consideration. Personal information may be disclosed only in accordance with lawful grounds and only to the extent strictly necessary for the following purposes:

(a) Advertising and Attribution Partners
Pseudonymized usage data may be shared with digital advertising platforms and affiliate marketing networks for the limited purposes of:

- Tracking conversion events and traffic sources;

- Validating referrals or partner activity;

- Generating performance analytics for paid campaigns.

Such disclosures are restricted to participating platforms, including but not limited to: Google Ads, Microsoft Advertising, Meta Ads, and designated affiliate partners contractually bound to confidentiality and data protection obligations.

(b) Analytics and Diagnostics Tools
The Platform uses third-party analytics providers for non-identifiable behavioural monitoring, performance auditing, and usability diagnostics. Such providers may include, without limitation:

- Google Analytics;

- Microsoft Clarity;

- Meta Pixel;

- Mouseflow or equivalent software.

All such service providers operate under binding data processing agreements which require implementation of reasonable safeguards, limitation of purpose, and prohibition on secondary use.

(c) Hosting and Infrastructure Vendors
Personal information may be stored or processed by third-party vendors responsible for hosting, platform scaling, caching, or backup infrastructure. Such services may operate within or outside of Canada, provided that appropriate contractual and technical protections are in place to ensure cross-border data protection equivalence.

(d) Legal and Regulatory Disclosures
Personal information may be disclosed to law enforcement agencies, regulatory authorities, courts, or other governmental bodies upon receipt of a lawful request, subpoena, or other enforceable legal instrument, or where such disclosure is necessary to assert legal rights, respond to claims, prevent fraud, or protect the safety of users.

(e) Business Transactions
In the event of a merger, acquisition, corporate reorganization, or asset transfer involving the Platform, personal information may be transferred to the successor entity, subject to compliance with applicable Canadian privacy law and the implementation of confidentiality safeguards.

5. COOKIES AND TRACKING TECHNOLOGIES

The Platform utilizes cookies and related tracking technologies for the lawful and disclosed purposes of analytics, user session management, advertising attribution, service optimization, and user preference retention.

(a) Consent Management
Except where strictly necessary for core platform functionality, cookies and tracking tools are only activated after the user provides explicit, informed consent via the Platform's integrated CookieYes consent banner. This banner enables the user to:

- View detailed descriptions of all cookies and trackers used;

- Choose to accept or reject categories of cookies (e.g., performance, marketing);

- Revoke or modify consent preferences at any time;

- Access links to third-party privacy policies for additional transparency.

Consent may also be managed through browser settings or third-party opt-out tools.

(b) Categories of Cookies and Tools
The following categories of technologies may be deployed upon receiving valid consent:

TOOL / TECHNOLOGY	PURPOSE AND FUNCTION	PRIVACY POLICY LINK
Google Analytics	Behavioural analytics, visitor traffic, session flow, demographic segmentation	https://policies.google.com/privacy
Meta Pixel	Conversion tracking, retargeting, custom audience creation	https://www.facebook.com/policies/cookies
Microsoft UET Tag	Ad attribution, audience creation, event tracking	https://privacy.microsoft.com/privacystatement
Microsoft Clarity	Session recording, heatmaps, user navigation diagnostics	https://clarity.microsoft.com/terms
Mouseflow (or equivalent)	Usability analytics, clickstream behaviour, scroll-depth measurement	https://mouseflow.com/privacy/
Affiliate Tracking Cookies	Attribution of referrals and commissions under affiliate network agreements	Varies by affiliate; accessible via CookieYes or set on redirect from referrer URL

(c) User Rights and Controls
Users retain full control over cookie preferences and may:

- Use the CookieYes interface to modify or revoke consent at any time;

- Configure their browser to reject all non-essential cookies or notify upon deployment attempts;

- Delete stored cookies through browser settings or security tools;

- Opt out of personalised advertising using tools such as the Digital Advertising Alliance of Canada's platform at https://youradchoices.ca.

Non-essential tracking will not occur absent affirmative user consent. Withholding consent may limit access to certain features but shall not preclude general Platform usage.

6. DATA RETENTION AND DISPOSAL

Personal information is retained only for the duration necessary to fulfil the purposes for which it was collected, as set out in this Policy, or to comply with applicable statutory or regulatory obligations.

(a) Retention Duration
Retention periods vary depending on the type of data and its purpose, but will be governed by the following general principles:

- Account-related communications or support records may be retained for a minimum of 24 months;

- Analytics and advertising data is subject to platform-specific retention windows, often 12–26 months, unless earlier deletion is requested;

- Backup and archival systems may preserve data for disaster recovery purposes for a limited, secure interval.

(b) Statutory and Legal Obligations
Retention may be extended beyond typical timeframes where necessary to:

- Comply with legal, audit, tax, or financial recordkeeping obligations;

- Fulfil regulatory retention mandates imposed by federal or provincial authorities;

- Respond to pending legal claims or enforce contractual rights.

(c) Disposal Practices
Once the applicable retention period expires, personal information is securely disposed of using one or more of the following methods:

- Permanent deletion from live databases;

- De-identification or anonymization to render the data non-attributable;

- Automatic deletion through expiry-based policies in storage systems.

Any residual data contained in system backups shall be subject to scheduled purging in accordance with infrastructure lifecycle policies. Users may request deletion of their information by contacting support@canuckplayhouse.com, subject to legal verification and exceptions required by law.

7. INFORMATION SECURITY MEASURES

The Platform maintains a comprehensive information security program incorporating administrative, physical, and technical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction.

Such safeguards include, but are not limited to:

- Encryption of all data in transit using TLS/HTTPS protocols;

- Role-based access controls and multi-factor authentication for administrative interfaces;

- Routine vulnerability scanning, threat detection, and intrusion monitoring;

- Security logging, patch management, and infrastructure hardening procedures;

- Hosting within secure Canadian or third-party data centres certified to ISO/IEC 27001 or equivalent standards.

While the Platform employs commercially reasonable measures to secure data, no security system is infallible. Users remain responsible for securing their devices, maintaining strong passwords, and taking reasonable precautions when accessing the Platform over public or unsecured networks.

In the event of a data breach posing a real risk of significant harm to affected individuals, the Platform will:

- Notify the impacted users without unreasonable delay;

- Provide information about the breach's nature, scope, and remediation steps;

- Report the breach to the appropriate regulatory body in accordance with PIPEDA's Breach of Security Safeguards Regulations or other applicable laws.

The Platform maintains internal policies and incident response protocols to ensure timely detection, containment, investigation, and reporting of any suspected breach event.

8. AGE-BASED ACCESS RESTRICTIONS

Access to and use of the Platform is strictly limited to individuals who are at least eighteen (18) years of age and who reside within the territorial jurisdiction of Canada. By accessing the Platform, users represent and warrant that they meet these eligibility requirements.

The Platform does not knowingly collect or process personal information from individuals under the age of 18. If it is determined that such information has been collected inadvertently or through misrepresentation, the Platform shall:

- Immediately delete the affected data from all accessible systems;

- Revoke access and terminate any associated accounts or sessions;

- Notify the parent or guardian, if identified, and provide remedial assistance.

Parents, guardians, or other lawful representatives who believe that a minor has submitted personal information may submit a removal request to privacy@canuckplayhouse.com.

The Platform reserves the right to implement or enhance age verification measures at its discretion to comply with applicable regulatory, contractual, or advertising platform obligations, including the use of soft-gating, self-certification, or third-party age verification solutions.

9. ACCESS AND CORRECTION RIGHTS

Under PIPEDA and applicable provincial privacy legislation, individuals have the right to:

- Access personal information held by the Platform about them; and

- Request correction of any such information that is inaccurate, incomplete, or outdated.

(a) Submission Process
To exercise these rights, a written request must be submitted to privacy@canuckplayhouse.com and must include sufficient detail to enable verification of the requestor's identity and identification of the information in question.

(b) Platform Obligations
Upon receipt of a valid request, the Platform will:

- Acknowledge receipt and initiate a verification process;

- Respond within a reasonable period, generally not exceeding thirty (30) calendar days;

- Provide access to the personal information or a written reason for any refusal, along with instructions for submitting a complaint to the Office of the Privacy Commissioner of Canada or other applicable authority.

Where correction is warranted, the Platform shall amend the relevant records and, where appropriate, inform any third parties to whom the information was disclosed, unless prohibited or unduly burdensome.

(c) Fees
The Platform does not charge a fee for responding to standard access or correction requests. However, where the request is unduly complex or repetitive, a reasonable administrative fee may be charged, provided that the user is notified of the fee in advance and given the opportunity to withdraw or modify the request.

10. DO NOT TRACK AND BROWSER PREFERENCES

Certain web browsers offer a "Do Not Track" ("DNT") signal that expresses a user's preference not to be tracked across websites. At this time, the Platform does not respond to DNT signals due to the absence of a universally accepted standard for interpreting such signals under Canadian law.

Users may nevertheless exercise control over their data through the following means:

(a) Managing cookie permissions via the CookieYes consent management interface;

(b) Adjusting browser settings to block or delete cookies;

- The Digital Advertising Alliance of Canada: https://youradchoices.ca

- Google Ads Settings: https://adssettings.google.com

- Meta Advertising Preferences: https://facebook.com/adpreferences

The Platform remains committed to reviewing and updating its practices should a binding standard for DNT compliance be adopted by Canadian privacy regulators or recognised industry bodies.

11. CHANGES TO THIS POLICY

This Privacy Policy may be amended, revised, or updated at any time to reflect changes in legal requirements, regulatory guidance, technological advancements, or operational practices.

Material changes shall be:

- Reflected in the "Last Updated" date at the beginning of this Policy; and

- Communicated to users through prominent disclosures, including but not limited to banner notifications, pop-up disclosures, or Platform-wide alerts.

Continued access to or use of the Platform following the publication of an amended Privacy Policy constitutes binding acceptance of the revised terms. Users are encouraged to review this Policy periodically and consult the contact mechanisms herein for any clarification or objections.

12. CONTACT AND COMPLAINTS PROCEDURE

All questions, concerns, or complaints regarding this Privacy Policy, or the Platform's privacy practices, must be submitted in writing to:

Contact: Contact Form
Email: support@canuckplayhouse.com
Phone: (+1) 782 508 0751

The Platform commits to:

- Acknowledging receipt of all inquiries in a timely manner;

- Investigating the substance of the concern in accordance with applicable policies and regulations;

- Responding with findings, explanations, or remedial actions, as applicable, within a reasonable timeframe.

If a user is dissatisfied with the resolution provided, they may escalate the matter to the Office of the Privacy Commissioner of Canada (OPC) at https://www.priv.gc.ca.

Where a complaint involves a provincially regulated matter (e.g., under Quebec's Law 25 or Alberta's PIPA), users may be directed to the applicable provincial authority.