Privacy Policy

Brand: Realz  |  Website: thehughesjonescentre.ca  |  Version: 1.0  |  Last Updated: June 21, 2025

At Realz, we are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, why we collect it, how we use and share it, and the rights and choices you have with respect to your data. This Policy applies to all users of the Platform at thehughesjonescentre.ca. Please also review our Terms & Conditions and Responsible Gaming pages, which form part of your agreement with us.

1. Introduction

1.1. Who We Are

Realz operates the online gaming platform accessible at thehughesjonescentre.ca. We act as the data controller in respect of personal data collected through the Platform. If you have any questions about how we handle your personal information, please contact our Privacy Officer at [email protected].

1.2. Scope of This Policy

This Privacy Policy applies to all personal data collected by Realz through the Platform, including during account registration, gameplay, customer support interactions, marketing communications, and use of our website. It does not apply to third-party websites or services that may be linked to from our Platform.

1.3. Your Consent

By registering an account on the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. Where we rely on consent as a legal basis for processing, you may withdraw consent at any time by contacting us at [email protected].

2. Data We Collect

2.1. Information You Provide Directly

We collect personal information that you provide when you:

• Register an Account (name, date of birth, email address, home address, phone number, username);
• Complete identity verification (government-issued ID, proof of address, payment documentation);
• Make deposits or withdrawals (payment method details, transaction history);
• Contact customer support (correspondence records, complaint details);
• Participate in surveys, promotions, or competitions (responses, preferences).

2.2. Information Collected Automatically

When you access the Platform, we automatically collect certain technical data, including:

• Device information: device type, operating system, browser type and version;
• Log data: IP address, access timestamps, pages visited, session duration;
• Geolocation data: country and region derived from IP address;
• Gameplay data: games played, bets placed, wins and losses, session history;
• Cookies and tracking data: as described in Section 6 of this Policy.

2.3. Information from Third Parties

We may receive information about you from third parties, including:

• Identity verification and KYC service providers;
• Payment processors and financial institutions;
• Fraud detection and anti-money laundering service providers;
• Marketing and analytics partners;
• Publicly available databases and credit reference agencies.

3. How We Use Your Data

Realz uses your personal information for the following purposes:

• Account creation and management: to register you as a player, maintain your Account, and provide you with access to Platform services;
• Identity verification (KYC): to confirm your identity, age, and eligibility in accordance with our compliance obligations;
• Transaction processing: to process deposits and withdrawals and maintain accurate financial records;
• Customer support: to respond to your inquiries, resolve disputes, and manage complaints;
• Responsible gaming: to monitor gameplay patterns and identify signs of problem gambling, and to administer responsible gaming tools;
• Fraud prevention and security: to detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct;
• Marketing and promotions: to send you relevant promotional offers, news, and updates where you have consented or where we have a legitimate interest to do so;
• Platform improvement: to analyse usage patterns, conduct research, and improve the quality and performance of the Platform;
• Legal compliance: to comply with our legal and regulatory obligations and respond to lawful requests from authorities.

4. Legal Bases for Processing

We process your personal data on the following legal bases:

• Contractual necessity: processing is necessary to perform the contract between you and Realz (e.g., account registration, payment processing);
• Legal obligation: processing is required to comply with applicable laws and regulations (e.g., KYC, AML obligations);
• Legitimate interests: processing is necessary for our legitimate business interests, including fraud prevention, security, and platform improvement, provided these interests are not overridden by your fundamental rights;
• Consent: where we rely on your consent to send marketing communications or process certain sensitive data, you may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Third Parties

5.1. Service Providers

We share your personal data with trusted third-party service providers who assist us in operating the Platform. These include:

• KYC and identity verification providers;
• Payment processors and banking partners;
• Cloud hosting and data storage providers;
• Customer support software providers;
• Email and communication service providers;
• Analytics and marketing technology providers;
• Game software developers and providers.

All third-party service providers are contractually required to process your data only on our instructions and to maintain appropriate security measures.

5.2. Legal and Regulatory Disclosures

We may disclose your personal data to law enforcement agencies, regulatory bodies, courts, or other competent authorities where required to do so by applicable law or legal process, or where we believe disclosure is necessary to protect the rights, property, or safety of Realz, our players, or others.

5.3. Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity as part of the transaction. We will notify you via email or prominent Platform notice before your data becomes subject to a materially different privacy policy.

5.4. No Sale of Personal Data

Realz does not sell, rent, or trade your personal information to third parties for their own marketing purposes without your explicit consent.

6. Cookies & Tracking Technologies

6.1. What Are Cookies

Cookies are small text files stored on your device when you visit a website. They allow websites to remember your preferences, improve navigation, and gather analytical data. We also use similar technologies such as web beacons, pixels, and local storage.

6.2. Types of Cookies We Use

6.3. Managing Cookies

You can manage your cookie preferences through our cookie consent banner upon first visiting the Platform. You may also adjust your browser settings to refuse or delete cookies; however, disabling strictly necessary cookies may impair the functionality of the Platform. For more information about managing cookies in your browser, please refer to your browser's help documentation.

7. Data Security

7.1. Security Measures

Realz implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your browser and our servers;
• Firewalls and intrusion detection systems;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and vulnerability assessments;
• Data pseudonymization and anonymization where appropriate.

7.2. Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, Realz will notify affected individuals and, where required, relevant regulatory authorities within the timeframes prescribed by applicable law. We will also take prompt remedial action to contain and address the breach.

8. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, and reporting obligations. Specific retention periods include:

• Account data: retained for the duration of your account and for a minimum of 5 years following account closure;
• Financial and transaction records: retained for a minimum of 7 years in accordance with Canadian financial record-keeping requirements;
• KYC documentation: retained for a minimum of 5 years after the end of the business relationship;
• Marketing data: retained until you withdraw consent or opt out of communications;
• Customer support records: retained for 3 years following resolution of the inquiry.

When your data is no longer required, we will securely delete or anonymize it in accordance with our data retention procedures.

9. Your Rights

As a Canadian resident, you have the following rights with respect to your personal data:

• Right of Access: you have the right to request a copy of the personal data we hold about you;
• Right to Correction: you have the right to request that we correct inaccurate or incomplete personal data;
• Right to Withdrawal of Consent: where processing is based on your consent, you may withdraw it at any time;
• Right to Complain: you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe your privacy rights have been violated;
• Right to Request Deletion: you may request that we delete your personal data, subject to our legal retention obligations.

To exercise any of these rights, please contact our Privacy Officer at [email protected]. We will respond to all verifiable requests within 30 calendar days. We may require proof of identity before processing your request.

10. International Data Transfers

As an online platform, some of your personal data may be processed by our service providers in countries outside of Canada. Where data is transferred internationally, we ensure that appropriate safeguards are in place to protect your information, including:

• Contractual agreements incorporating equivalent data protection standards;
• Use of service providers located in jurisdictions recognized as providing adequate data protection;
• Data processing agreements that comply with applicable privacy law requirements.

By using the Platform, you acknowledge and consent to the transfer of your personal data as described in this section.

11. Minors

The Platform is strictly intended for individuals aged 19 years and over. We do not knowingly collect personal data from individuals under the age of 19. If we become aware that we have inadvertently collected data from a minor, we will promptly delete such data and close the associated account. If you believe a minor has registered on our Platform, please contact us immediately at [email protected].

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Platform's functionality. When we make material changes, we will notify you by email or by posting a prominent notice on the Platform. The version number and "Last Updated" date at the top of this document will always reflect the most current version. We encourage you to review this Policy periodically.

13. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or our data handling practices, please contact us:

• General Support: [email protected]
• Privacy & Data Protection Officer: [email protected]

You also have the right to contact the Office of the Privacy Commissioner of Canada (OPC) if you have concerns about how we handle your personal data:
Website: www.priv.gc.ca