Privacy Policy

This Privacy Policy explains how Techcore Holding B.V., operating the Fair Spin brand for the Canadian review project Fair Spin at fairspin-play.ca (the "Website"), collects, uses, discloses, and protects your personal information. It applies to players, account holders, and visitors who access or use the Website and related services.

This Policy is intended primarily for users located in Canada (excluding Ontario), but it also reflects requirements and best practices derived from international standards such as the EU General Data Protection Regulation ("GDPR") and Mexican data protection law, where applicable.

By using fairspin-play.ca, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, you should not use the Website or our services.

Effective date: 1 January 2026

Who We Are

The Website fairspin-play.ca, including the associated review project referred to as Fair Spin, is operated for Canadian users by:

Data controller / operator: Techcore Holding B.V.
Registered jurisdiction: Curaçao
Company registration number: 151612 (Curaçao)
Gaming licence: Curaçao eGaming, operating under Master Licence No. 1668/JAZ, held by Techcore Holding B.V. (licence status: active; verifiable via https://verification.curacao-egaming.com)

Techcore Holding B.V. is the primary entity responsible for determining the purposes and means of processing personal data collected through fairspin-play.ca.

Payment processing and certain back-office services for Fair Spin may be carried out by:

Payment processor: Fenechia Holdings Ltd
Jurisdiction: Cyprus

Because of the limited address information provided, the operator is identified as Techcore Holding B.V., Curaçao. Further corporate address details can be obtained on justified request.

Data Protection Contact (DPO/Data Protection Department)

Email: [email protected]
Website: https://fairspin-play.ca
Postal contact: Data Protection Officer, Techcore Holding B.V., Curaçao (please write to us by email first to obtain the most up-to-date postal details).

Our primary communication channel for privacy matters is email. If you require telephone contact for privacy issues, you may request this via email, and we will provide appropriate contact details where feasible.

What Personal Data We Collect

Account and Identification Data

Registration data: full name, date of birth, country of residence, address (where requested), email address, username, password, and contact phone number if provided.
Verification (KYC/AML) data: copies or details of identity documents (e.g., passport, ID card, driving licence), proof of address (e.g., utility bill, bank statement), source-of-funds information, and any other documents you submit to satisfy regulatory checks.

Technical and Device Data

Technical identifiers: IP address, device identifiers, browser type and version, operating system, language settings, time zone, and approximate location derived from IP.
Usage logs: login and logout timestamps, session activity, security events, pages visited, referral URLs, and interaction logs with our support team (including chat transcripts and emails).

Payment and Transaction Data

Financial and transactional data: selected payment method, partial payment card details (masked card number where applicable), e-wallet identifiers, bank account or IBAN details when used, deposit and withdrawal records, currency, amounts, bonus usage, and chargeback information.
Blockchain-related data: where you use crypto-assets or the TFS token, we may process wallet addresses, transaction hashes, and other on-chain identifiers. These may be visible via third-party explorers such as Etherscan.

Behavioral and Gaming Data

Gameplay and betting behaviour: game preferences, betting history, wager amounts, wins and losses, session duration, bonuses claimed and used, and self-exclusion or cooling-off settings.
Interaction data: clicks, navigation paths, response to promotions, and interaction with specific content on fairspin-play.ca (including Fair Spin content).

Cookies and Similar Technologies

Cookies: small text files stored on your device to enable core functionality, remember your settings, perform analytics, and support marketing.
Similar technologies: pixels, tags, scripts, SDKs, and local storage used for session management, fraud prevention, and measurement of Website performance.

For more detail, see the "Cookies & Tracking Technologies" section below.

Legal Basis for Processing

Because Fair Spin serves users in multiple jurisdictions, our legal basis for processing personal data depends on your place of residence and the nature of the processing. We design our processes to align with requirements under Canadian law (including PIPEDA and substantially similar provincial laws), the GDPR (where applicable), and Mexican data protection law.

Consent

We rely on your consent when:
- you choose to receive marketing communications (email, SMS, push notifications);
- we place non-essential cookies or use similar technologies for analytics and advertising;
- you agree to optional features, such as participation in surveys or certain loyalty programs that are not strictly necessary for providing the core service.

Performance of a Contract

We process personal data where it is necessary to enter into or perform our contract with you, including:
- creating and managing your Fair Spin account on fairspin-play.ca;
- processing deposits, wagers, bonuses, and withdrawals;
- providing customer support and resolving operational issues; and
- maintaining the technical availability and security of our services.

Legitimate Interests

We process personal data based on our legitimate interests, balanced against your rights and freedoms, to:
- prevent fraud, money laundering, abuse of bonuses, and other unlawful or inappropriate activity;
- secure our systems and investigate suspicious behaviour;
- analyse Website performance and improve user experience;
- conduct limited direct marketing to existing customers in accordance with applicable law; and
- protect our legal rights, including in connection with potential claims or disputes.

Compliance with Legal Obligations

We process personal data where necessary to comply with legal obligations, including:
- Know Your Customer (KYC) and Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) requirements under Curaçao and other applicable laws;
- record-keeping obligations for financial and gaming transactions;
- responses to lawful requests from regulators, courts, tax authorities, or law enforcement; and
- obligations arising under data protection laws where they apply to us (including GDPR and Mexican law for affected users).

Purpose of Processing

Provision and Operation of Services

Account management: to register and maintain your Fair Spin account on fairspin-play.ca, verify your eligibility (age and jurisdiction), and provide you with access to casino games and related content (including Fair Spin materials).
Payments: to process deposits, bets, withdrawals, and refunds, as well as to manage bonuses, loyalty programs, and rewards.

Service Improvement and Analytics

Website optimisation: to monitor Website performance, understand how users navigate and interact with our pages, and fix technical issues.
Product development: to analyse aggregated and pseudonymised data to improve game offerings, user interface, and features (including responsible gambling tools).

Marketing and Personalisation

Direct marketing (with consent where required): to send promotional emails, SMS messages, or in-account notifications about games, bonuses, and special offers relevant to you.
Personalised content: to tailor offers and content based on your previous activity and preferences, including targeted promotions displayed on the Website.

Security, Compliance, and Fraud Prevention

Risk management: to detect and prevent fraud, account takeovers, multiple-account abuse, and payment misuse.
Legal compliance: to meet KYC/AML obligations, sanction screening requirements, and gaming regulatory requirements arising from our Curaçao licence No. 1668/JAZ.
Dispute handling: to investigate and resolve complaints, disputes, and chargebacks.

Disclosure & Sharing

We do not sell your personal data. We share it only as necessary and subject to contractual safeguards, as described below.

Service Providers and Business Partners

Payment processors and financial institutions: including Fenechia Holdings Ltd (Cyprus) and other payment providers that facilitate card payments, bank transfers, e-wallets, and crypto-based transactions.
IT and infrastructure providers: hosting providers, cloud services, content delivery networks, and security service providers who support the operation and protection of fairspin-play.ca.
Customer support and communication tools: providers that help us manage support tickets, live chat, and email communications.
Analytics and anti-fraud tools: carefully selected partners that assist with analytics, fraud detection, identity verification, and risk scoring.

Affiliates and Marketing Partners

Affiliates and advertising networks: where you have given consent where required, we may share limited data (such as referral identifiers, campaign performance data, and pseudonymised identifiers) with affiliates and advertising partners to measure the effectiveness of campaigns.

Regulators, Authorities, and Legal Recipients

Gaming regulators: Curaçao eGaming and other competent regulators may receive personal data where required for licensing, audits, or investigations.
Law enforcement and public authorities: we may disclose personal data in response to lawful requests, court orders, or legal processes, or to protect our rights, property, and safety or those of others.
Professional advisers: lawyers, accountants, auditors, and consultants who require access to data in order to provide professional services to us, subject to confidentiality obligations.

Corporate Transactions

In connection with any merger, acquisition, restructuring, or sale of all or part of our business, personal data may be transferred to the relevant third parties, subject to appropriate confidentiality and data protection safeguards and, where required, notification to you.

International Transfers

Because Techcore Holding B.V. and some of our service providers are located outside Canada, your personal data may be transferred to and processed in countries that may have different data protection laws than your home jurisdiction.

Main Locations of Processing

Curaçao: primary registration and licensing jurisdiction of Techcore Holding B.V. and the Curacao eGaming licence (1668/JAZ).
Cyprus: location of Fenechia Holdings Ltd, handling certain payment and processing functions.
European Union/European Economic Area (EU/EEA) and other regions: some of our technical, security, or analytics providers may be located in or store data in the EU/EEA or other jurisdictions.

Protection Measures

Where required by applicable law (for example, in relation to data originating from the EU/EEA or Mexico), we implement:
- Standard Contractual Clauses (SCCs) or equivalent contractual mechanisms approved by relevant regulators;
- robust technical and organisational measures (encryption, access controls, logging) to protect data during transfer and storage; and
- internal policies to limit access to personal data to those who need it for legitimate business purposes.
By using fairspin-play.ca, you understand that your data may be processed in Curaçao, Cyprus, and other countries, and may be accessible to foreign courts, law enforcement, and regulatory authorities in those jurisdictions.

Data Retention

We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, including for legal, accounting, regulatory, and reporting requirements. Retention periods may vary depending on the category of data and applicable law (including AML/CTF and gambling regulations).

Category of data	Typical retention period	Retention rationale
Account profile data (name, contact details, account settings)	For the duration of your account and up to 5 years after account closure	To manage your account, comply with limitation periods for claims, and handle any post-closure disputes.
KYC/AML verification records	5 - 10 years after the end of the business relationship or single transaction, depending on applicable AML laws	To comply with mandatory anti-money laundering, counter-terrorist financing, and gaming requirements.
Transaction and gaming history	At least 5 years, and up to 7 years after the transaction or account closure where required by law	To maintain financial and regulatory records and to defend against potential legal claims.
Marketing preferences and communication logs	Until you withdraw consent or object to marketing, plus a short period to maintain suppression lists	To respect your marketing choices and demonstrate compliance.
Technical logs and security data	6 months to 3 years, depending on the type of log and security needs	To investigate incidents, ensure security, and maintain service integrity.

When the applicable retention period expires, or when data is no longer needed for the purposes described in this Policy, we will securely delete, anonymise, or aggregate the data, unless further retention is required by law.

Your Rights

Your privacy rights may differ depending on your country of residence. We aim to provide a high and broadly harmonised level of protection, taking guidance from the GDPR and Mexican privacy law (including the Federal Law on Protection of Personal Data Held by Private Parties), while also respecting Canadian privacy law (including PIPEDA and substantially similar provincial laws).

Key Rights

Right of access: You can request confirmation of whether we process your personal data and receive a copy of such data, together with information about how we use it.
Right to rectification: You can request that inaccurate or incomplete personal data be corrected or completed.
Right to erasure ("right to be forgotten"): You can request deletion of your personal data in certain circumstances, for example when it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis for processing. We may retain data where required by law (e.g., AML/CTF obligations).
Right to restriction of processing: You can request that we temporarily restrict the processing of your data, for example while we assess a correction request or an objection.
Right to object: You can object to processing based on our legitimate interests, and we will assess your request and stop processing unless we have compelling legitimate grounds. You can always object to direct marketing, and we will honour this.
Right to data portability: Where applicable, you may receive personal data you have provided to us in a structured, commonly used, and machine-readable format, and request that we transmit it to another controller where technically feasible.
Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal. This includes opting out of marketing communications and non-essential cookies.

How to Exercise Your Rights

Submit a request: Contact us at [email protected] with:
- your full name and account username;
- the right(s) you wish to exercise;
- any specific details that will help us identify the data in question.
Verification: We may request additional information to verify your identity before fulfilling your request, particularly for sensitive data or high-risk actions (such as access or portability).
Response time: We aim to respond to all valid requests within 30 days of receipt. In complex cases or where we receive multiple requests, we may extend this period, in which case we will inform you. Where Mexican law applies, we will also respect the statutory periods established there (including initial responses within 20 days, and implementation within 15 additional days, where applicable).
Fees: Requests are processed free of charge. We may charge a reasonable fee or refuse to act on a request only where it is manifestly unfounded, repetitive, or excessive, consistent with applicable law.

Cookies & Tracking Technologies

We use cookies and similar technologies to ensure the proper functioning of fairspin-play.ca, to enhance user experience, and to support analytics and marketing activities.

Types of Cookies

Session cookies: Temporary cookies that are deleted when you close your browser. They are used to maintain your session, keep you logged in, and remember certain actions during a single visit.
Persistent cookies: Cookies that remain on your device for a defined period or until you delete them. They help us remember your preferences and recognise you when you return.
First-party cookies: Cookies set directly by fairspin-play.ca to support core functionality and preferences.
Third-party cookies: Cookies set by external providers (e.g., analytics, anti-fraud, and advertising partners) that assist with service improvement and campaign measurement.

Purposes of Cookies

Strictly necessary/functional cookies: Required for the Website to function correctly (e.g., login, security, account navigation, and language settings). These cannot generally be disabled without affecting service performance.
Analytics/performance cookies: Used to collect aggregated information about how visitors use the Website (e.g., most visited pages, error messages) so we can improve content and navigation.
Advertising and marketing cookies: Used, where permitted, to deliver or measure personalised advertising and promotions, including tracking the effectiveness of partner campaigns related to Fair Spin content.

Managing Cookies

You can manage cookies via:
- your browser settings (e.g., blocking or deleting cookies); and
- where available, our internal cookie or privacy settings panel on fairspin-play.ca, which allows you to adjust preferences for non-essential cookies.
Disabling certain cookies may impact your ability to use some features of the Website, including maintaining a logged-in session or receiving tailored content.

Data Security

We implement technical and organisational measures designed to protect your personal data against unauthorised access, loss, misuse, alteration, or destruction. While no system is entirely risk-free, we strive to maintain a level of security proportionate to the risks associated with online gambling operations.

Technical Measures

Encryption: Data in transit is protected using industry-standard encryption (such as TLS 1.2 or higher). Where feasible and appropriate, sensitive data at rest is encrypted or pseudonymised.
Access controls: Personal data is accessible only to authorised staff and service providers who require it to perform their duties and are bound by confidentiality obligations.
Authentication: We use secure authentication mechanisms; multi-factor authentication is implemented for sensitive internal systems and administrative accounts.
Network and system protection: Firewalls, intrusion detection/prevention systems, and other tools are used to monitor and defend against unauthorised access and malicious activity.

Organisational Measures

Policies and training: Staff with access to personal data receive appropriate privacy and security training and are required to follow internal policies and procedures.
Vendor due diligence: We assess relevant service providers for their security practices and require them to implement adequate safeguards.
Security testing and audits: We perform internal reviews and, where appropriate, external assessments or audits of our systems and controls.
Incident response: We maintain procedures for identifying, investigating, and responding to security incidents. Where required by law, we will notify affected users and relevant authorities of data breaches without undue delay.

We take guidance from recognised security frameworks and international standards (such as ISO 27001 and SOC 2) and endeavour to align our practices with them where appropriate, even if we may not hold formal certifications in all cases.

Complaints & Contacts

If you have questions about this Privacy Policy or how your personal data is processed, or if you wish to make a complaint, you can contact us using the details below.

How to Contact Us

Email (primary contact): [email protected]
Website: https://fairspin-play.ca
Postal: Data Protection Officer, Techcore Holding B.V., Curaçao (please contact us by email to obtain the most current postal details).

Internal Complaint Procedure

Submit your complaint: Send a detailed description of your concern to [email protected], including your account information and any relevant supporting documentation.
Acknowledgement: We will acknowledge receipt of your complaint as soon as reasonably possible.
Investigation: We will investigate the issue, which may include reviewing system logs, consulting with relevant departments, and requesting additional information from you if needed.
Response time: We aim to provide a reasoned response or resolution within 30 days of receiving your complaint. If more time is required due to complexity, we will keep you informed of progress and expected timelines.

Escalation to Supervisory Authorities

If you are not satisfied with our response or believe we are not handling your personal data in accordance with applicable law, you may lodge a complaint with a competent data protection authority. Depending on your place of residence, this may include:

Canada: The Office of the Privacy Commissioner of Canada (OPC) or, where applicable, a provincial privacy commissioner (e.g., in Alberta, British Columbia, or Quebec). See https://www.priv.gc.ca/en/ for contact details.
Mexico: The National Institute for Transparency, Access to Information and Personal Data Protection (INAI). See https://www.inai.org.mx for guidance on submitting complaints.
European Union/EEA: Your local data protection authority, particularly in the country of your habitual residence, place of work, or where the alleged infringement occurred.

We encourage you to contact us first so that we have the opportunity to address your concerns directly.

Updates

We may modify or update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. When we make material changes, we will take appropriate steps to inform you.

Notification of Changes

Website notice: We will publish the updated Policy on fairspin-play.ca and adjust the "Last updated" date below.
Direct communication: For significant changes (for example, changes to the purposes of processing, or to your key rights), we will endeavour to notify registered account holders via email, in-account messages, or prominent banners on the Website.
Advance notice: Where feasible and where changes are material, we will provide at least 30 days' notice before the new terms take effect, so you have time to review them.

Your Options

If you continue to use fairspin-play.ca after changes to this Privacy Policy take effect, you will be deemed to have accepted the updated Policy.
If you do not agree with the updated terms, you may close your account and, where appropriate, exercise your rights as described in the "Your Rights" section (including requesting deletion of your personal data, subject to legal retention requirements).

Last updated: January 2026