Privacy Statement

Great Canadian Gaming Corporation and its subsidiaries (collectively “GCGC”) are committed to ensuring you have the very best experience at our properties. You have a right to know how your personal information is collected and what we do with it, so you can make informed choices. We have created this Privacy Statement to explain in plain terms what we do and what we will not do with your personal information.

GCGC’s gaming-related activities are subject to the following legislation:

• Ontario Lottery and Gaming Corporation Act, 1999 (“OLGC Act”)[i]
• Freedom of Information and Protection of Privacy Act[ii]in British Columbia
• Freedom of Information and Protection of Privacy Act[iii]in Ontario
• Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act[iv]
• Right to Information and Protection of Privacy Act[v]in New Brunswick
• Protection of Personal Information and Electronic Documents Act (“PIPEDA”)[vi]in Nova Scotia

In this Privacy Statement, the term “Applicable Privacy Laws” will refer to the aforementioned legislation, as well as any other privacy and freedom of information laws as they apply to GCGC.

GCGC’s commercial activities in British Columbia are governed by the British Columbia Personal Information Protection Act and in other provinces are governed by PIPEDA and Provincial laws, as applicable. These laws set out how GCGC may access, collect, use and disclose your personal information.

“Personal Information” is defined as any information about an identifiable individual, including your name, contact details, transactions records, and identification numbers. For the purposes of this Privacy Statement, “Personal Information” does not include business contact information (to the extent that it is excluded from the application of Applicable Privacy Laws), or aggregate and de-identified data that does not relate to an identifiable individual and cannot be reverse engineered alone or in combination with other available information.

Collection and Use of Personal Information

GCGC may collect certain Personal Information about you under the statutory authority of the OLGC Act.

The Personal Information may be collected from the following sources:

• when you use our website (https://greatcanadian.com/);
• when you communicate with us by email, text, phone or through any other means;
• when you interact with our advertising and applications on third-party websites.

GCGC collects the categories of Personal Information listed below from you for the following purposes:

• Security: Name, address, phone number, date of birth, gender, driver’s licence number, government identification, passport number, vehicle plate number, vehicle description, video images and photographs – This information is collected in connection with security incidents, investigations, monitoring of potentially illegal or suspicious activity on or around our property and compliance with laws applicable to casinos. Such information is used for security purposes, including to enforce bans from our property and to report incidents to law enforcement. In addition, hand scan technology is used to restrict access.
• Contests, Promotions and Registrations: Name, address or email address, telephone number – This information is collected when you register for contests, promotions, newsletters, or services that require registration or subscription, and will be used only for the purpose that it is collected and consistent purposes (e.g., to communicate the results of the contest or provide the requested service). We will not send you electronic advertising or marketing messages without your consent[vii] If you no longer want to receive e-mail or other mail from us, you can let us know by emailing us at privacy@greatcanadian.com or by using the unsubscribe mechanism that will be included in each electronic message.
• Marketing and Advertising: Name, address, email, date of birth, gender, transaction and playing history – We may use this information to deliver marketing and/or advertising of relevant products, services and offers to you, and to measure the effectiveness of the advertising we serve you. You may opt out from GCGC using your Personal Information to deliver targeted advertising by emailing us at privacy@greatcanadian.com or by contacting customer service at any of our sites. Note that we will only deliver advertising and marketing materials that communicate gambling inducements, bonuses and credits if you have actively opted-in to receiving such advertising and marketing materials, and you may withdraw your consent at any time by emailing us at privacy@greatcanadian.com or by contacting customer service at any of our sites.
• Rewards Program: Name, address, email address, telephone number, gender, and date of birth – This information is collected when you sign up for a rewards program or subscription service at any GCGC properties. This information is collected to offer you rewards in connection with your land-based games or other play and to communicate with you in relation to our rewards program, including by sending you push notifications about your offers (unless you opt out of such notifications). We may also use your Personal information to customize our rewards to your demographic. You can cancel your rewards membership at any time by speaking with a guest services representative. Government identification is verified when you sign up for a rewards program, however it is not collected or retained by GCGC.
• Player Gaming Accounts:Name, address, email address, telephone number, date of birth, country of citizenship, valid government identification, occupation, name of employer, transaction and playing history, payment information, username, password, security questions and answers. This information is collected when you register for a Player Gaming Account with GCGC. This information is collected to register a player for an account with GCGC, and is intended for, inter alia, the following principle purposes: for the administration of the Player Gaming Account program, to validate transactions, to audit, and maintain a record for reporting (and other) purposes as generally required by the OLG, the casino service provider, Alcohol and Gaming Commission (AGCO), and Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), to communicate with you in relation to your account, and to adhere with OLG and AGCO requirements.
• Know your Client: Name, address, supporting documentation to verify identification – This information is collected in order for GCGC to conduct a ‘know your client’ analysis to verify your identity and prevent fraudulent activity, as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and the regulations under it.
• Feedback, Dispute Resolution and Customer Research: Information submitted by you and telephone recordings – We collect information that you submit to us in connection with your inquiries, complaints and other feedback (e.g., via phone, email, mail, or our website). Such information is used for the purposes of responding to you, resolving a dispute, evaluating, and enhancing our products and services, and for customer research and responsible gaming research purposes. We may also monitor and record phone calls for customer service and training as well as record keeping purposes.
• Employment: Information relevant to employment relationships – This information is collected when you apply for a position (through our website or otherwise) and/or work for GCGC and will be used for reasonable purposes related to establishing, managing or terminating the employment relationship.
• Health and Safety: Name, address, and contact information – This information is collected to, amongst others, help prevent the spread of COVID-19 and any other pandemic related viruses in the community and protect the health of our guests. If you are a member of a rewards program, we may also use Personal Information relating to your use of the rewards program in order to determine where you have been inside our properties and inform you of an increased risk of infection (subject to your right to opt out of being contacted by us, which you may exercise by completing the opt-out notice located at the Security Desk).
• Compliance with Laws: We may also collect and use your Personal Information as authorized or required under the Applicable Privacy Laws (including, without limitation, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act).

We will only use Personal Information for reasonable business purposes for which it is collected, or consistent purposes in accordance with Applicable Privacy Laws. Your Personal Information will not be used for a new purpose unless we have your consent. If we use your Personal Information to make a decision that directly affects you, we will make commercially reasonable efforts to ensure that such information is accurate, complete and up-to-date.

We will only collect Personal Information directly from you unless you have consented to collection from other sources or Applicable Privacy Laws allow collection from third parties or other sources. For example, some information may be obtained from law enforcement while investigating a security incident or other potentially unlawful activity.

In most cases, we will provide you with clear notice when we collect your Personal Information. When we provide notice, we will state the reason for which we will use your information and we will obtain your express or implied consent to allow us to use your Personal Information for the purposes stated. For example, our properties contain signage notifying individuals of surveillance, and consent will be implied for individuals who choose to enter such properties. However, there are some circumstances where Applicable Privacy Laws do not require the giving of notice or the obtaining of consent. For example, depending upon Applicable Privacy Laws in the relevant jurisdiction, you may not be provided with notice and/or your consent may not be sought when your Personal Information is collected for certain purposes related to law enforcement, public health requests, litigation matters, investigations or protection of property.

Other Information Collected through our Website

GCGC also collects certain information through our website. For example, when you visit our web pages, we gather the date and time of your visit as well as your browser type, ISP, referring site, pages requested, and IP address. Typically, this information will not allow us to identify you personally. We use this information for our internal security audit log, trend analysis and system administration, and to gather broad demographic information about our user base for aggregate use. This information may be shared with third parties to provide services to us or to analyze, store or aggregate the information. If you object to the collection of this information, you should not use or access our web pages.

Our web pages may employ the use of “cookies”. A “cookie” is a small line of data that is sent to your internet browser from a web server and stored on your computer’s hard drive. Cookies can track how and when you use a site, and which site you visited immediately before. A cookie does not damage your system; it identifies your browser, not you personally. We use cookies to identify which areas of our network you have visited, so the next time you visit those pages may be readily accessible. If you do not wish to receive a cookie, please set the options in your web browser accordingly. Please note, however, that this may impact the functioning of some aspects of our website, and/or make it impossible to offer you customized services.

We may also use the technologies mentioned above and third-party advertising technologies to collect information about your online activities over time and across third-party websites or other online services, in order to serve targeted advertising. You can opt-out of being targeted by certain ad-service companies by using the National Advertising Initiative’s Opt-Out Tool  or the Digital Advertising Alliance of Canada’s (DAAC) About Ads Opt-Out Tool. Note that opting out of tailored advertising does not mean you will no longer receive online advertising.

To the extent that our websites contain links to other websites, the owners of those websites are responsible for the privacy practices or content of those other websites. We do not endorse and will not be responsible for the privacy practices on third party websites.

Minors

GCGC does not knowingly collect the Personal Information of individuals under the age of 18. Individuals under the age of 18 are not permitted to create accounts, join a loyalty rewards program, or enter contests or promotions.

Disclosure of Personal Information

Generally, GCGC will only disclose your Personal Information with your informed consent. We do not sell your Personal Information to third parties. However, subject to Applicable Privacy Laws, we may disclose your Personal Information without your knowledge and/or consent in the following circumstances:

• To our subsidiaries and affiliates for purposes set out in this Privacy Statement. Some of our affiliates are located outside Canada, which means that some Personal Information may be stored outside Canada and may be subject to the laws and lawful disclosure requirements in the recipient jurisdictions.
• To provide our services and/or comply with our contractual obligations to third parties. We may share Personal Information with our crown agency partners and other government bodies, or institutions, provided they are authorized to collect such information under applicable laws. Crown agency partners that may be authorized to collect personal information include the Ontario Lottery and Gaming Corporation, British Columbia Lottery Corporation, New Brunswick Lotteries and Gaming Corporation, and Nova Scotia Provincial Lotteries and Casino Corporation. These crown agency partners protect your personal information in compliance with Applicable Privacy Laws.
• To our service providers – In some cases we share Personal Information with other companies who provide services to us or perform services on our behalf, and in these instances we provide them only with the information needed to perform those services. In such cases we will enter into contractual or other arrangements to protect the security and confidentiality of your Personal Information. Some of our service providers rely upon cloud computing, which means that some Personal Information may be stored in multiple countries outside Canada and may be subject to the laws and lawful disclosure requirements in the recipient jurisdictions.
• To comply with our legal obligations – Gaming is a highly regulated activity and is subject to oversight by provincial and federal regulatory bodies. Personal Information may be disclosed in response to a subpoena or search warrant, or otherwise for compliance with legal processes or regulatory obligations. Gaming regulatory bodies we may be authorized to disclose Personal Information to include the Alcohol and Gaming Commission of Ontario, British Columbia Gaming Policy and Enforcement Branch, Nova Scotia Alcohol, Gaming, Fuel and Tobacco Division, and New Brunswick Gaming Control Branch.
• To assist law enforcement to investigate illegal activity, and for other purposes related to law enforcement – Information related to security incidents and other potentially unlawful activities may be disclosed to police and other law enforcement authorities upon request to aid in investigations.
• To assist provincial public health bodies with mitigating the spread of contagious illnesses, such as COVID-19.
• Otherwise as required or permitted by Applicable Privacy Laws.

In addition to the above, from time to time we may be involved in transactions to sell or restructure parts of our business or assets or merge with other businesses. Where permitted by Applicable Privacy Laws, some Personal Information may be disclosed as required to facilitate such transactions. In such cases, the information that is shared is limited to what is necessary to accomplish the transaction, and we take appropriate steps to protect the information from improper use or disclosure.

Being Accountable

We will take reasonable physical, technical, and organizational steps to secure and safeguard your Personal Information. Access to Personal Information is restricted to only those with a legitimate business need. We provide appropriate orientation and training to our employees so that those handling your Personal Information understand how to protect it. We have appointed employees who are specifically responsible for the management of information privacy and privacy matters.

GCGC makes best efforts to protect Personal Information entrusted to us, however we cannot guarantee the security of your Personal Information transmitted from systems or services we do not control. Any transmission of Personal Information from you to a GCGC website, platform or email is at your own risk.

Retention of Personal Information

We retain Personal Information for as long as required for the purposes identified in this Privacy Statement, subject to retention for the period prescribed by our agreement with any crown agency partner and other government body, or institution, or legal requirements applicable to us. Information that is subject to an access request will be retained even if access is denied in accordance with Applicable Privacy Laws until the requestor has exhausted all recourses and/or appeal mechanisms under such laws.

Access

Subject to restrictions and exceptions under Applicable Privacy Laws, upon request we will provide you with access to your Personal Information as well as information about the collection, use and disclosure of your Personal Information and a listing of the individuals or organizations to which your information has been disclosed.

To review records containing your Personal Information, you will be required to submit a formal, written request to our Chief Privacy Officer at:

Great Canadian Gaming Corporation

Chief Privacy Officer
39 Wynford Drive
North York, ON M3C 3K5
Tel. 604.303.1000
Email: privacy@greatcanadian.com

Such requests should include sufficient information to allow us to locate the records that you are seeking. Reasonable fees may apply to access requests, where permitted under Applicable Privacy Laws.

We generally respond to access requests within 30 days, except where an extension is permitted under Applicable Privacy Laws. If access is denied, we will provide you with an explanation in accordance with Applicable Privacy Laws.

You may also be able to access some information held by GCGC under applicable provincial freedom of information legislation. Such requests should be submitted to the applicable institution or public body in accordance with its policies and procedures. If you would like to request access to your player information, you can complete a Freedom of Information request: (1) in British Columbia, with the British Columbia Lottery Corporation[viii]; (2) in Ontario, with the Ontario Gaming and Lottery Corporation[ix]; and (3) in New Brunswick and Nova Scotia, by emailing GCGC’s Chief Privacy Officer at privacy@greatcanadian.com.