Privacy Policy

Last Updated: December 2024

At St. Lawrence Lotto, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our lottery services platform. Please read this policy carefully to understand our practices regarding your personal data.

1. Information We Collect

We collect several types of information from and about users of our services, including:

1.1 Personal Identification Information

When you register for an account with St. Lawrence Lotto, we collect personal information that may include:

• Full legal name as it appears on government-issued identification
• Date of birth for age verification purposes (must be 19 years or older)
• Email address for account communications and notifications
• Phone number for account security and prize notifications
• Residential address including street, city, province, and postal code
• Government-issued identification documents for identity verification
• Social Insurance Number for tax reporting on prizes exceeding regulatory thresholds

1.2 Financial Information

To process lottery ticket purchases and prize payments, we collect:

• Payment method details including credit card, debit card, or bank account information
• Transaction history and payment records
• Billing address information
• Financial verification documents as required by anti-money laundering regulations

1.3 Gaming Activity Information

We maintain records of your lottery gaming activities, including:

• Lottery games played and tickets purchased
• Number selections and play patterns
• Win and loss records
• Account balance and transaction history
• Deposit and withdrawal records
• Responsible gaming limit settings and self-exclusion requests

1.4 Technical and Usage Information

When you access our platform, we automatically collect certain technical information:

• IP address and geographic location data
• Device information including type, operating system, and browser
• Access times and dates
• Pages visited and features used
• Referring website addresses
• Clickstream data and navigation patterns

1.5 Communications

We keep records of communications between you and St. Lawrence Lotto, including:

• Customer support inquiries and responses
• Email correspondence
• Live chat transcripts
• Phone call recordings (with your consent and where legally permitted)
• Survey responses and feedback

2. How We Use Your Information

St. Lawrence Lotto uses the collected information for various legitimate business purposes:

2.1 Account Management and Service Provision

• Creating and maintaining your user account
• Processing lottery ticket purchases on your behalf
• Verifying your age and identity to comply with gaming regulations
• Managing your account balance and processing deposits and withdrawals
• Providing customer support and responding to your inquiries
• Notifying you of winning tickets and facilitating prize claims

2.2 Legal and Regulatory Compliance

• Complying with provincial and federal gaming regulations
• Conducting know-your-customer (KYC) verification
• Preventing fraud, money laundering, and other illegal activities
• Meeting tax reporting obligations for prize winnings
• Responding to legal processes and government requests
• Enforcing our Terms of Service and other policies

2.3 Responsible Gaming

• Implementing and monitoring responsible gaming tools and limits
• Identifying potential problem gambling behaviors
• Processing self-exclusion and cool-off period requests
• Providing access to responsible gaming resources and support

2.4 Service Improvement and Analytics

• Analyzing usage patterns to improve our platform and services
• Conducting research and statistical analysis
• Testing new features and functionality
• Optimizing user experience and interface design
• Monitoring system performance and security

2.5 Marketing and Communications

With your consent, we may use your information to:

• Send promotional emails about jackpots, special offers, and new games
• Provide personalized game recommendations
• Deliver targeted advertising on our platform and through third-party channels
• Conduct customer satisfaction surveys
• Share news and updates about our services

You can opt out of marketing communications at any time by using the unsubscribe link in our emails or updating your account preferences.

3. How We Share Your Information

St. Lawrence Lotto does not sell your personal information to third parties. However, we may share your information in the following circumstances:

3.1 Service Providers

We engage trusted third-party service providers to perform functions and provide services to us, including:

• Payment processors for handling financial transactions
• Identity verification services for KYC compliance
• Cloud hosting and data storage providers
• Customer support platforms and communication tools
• Marketing and analytics service providers
• Security and fraud prevention services

These service providers are contractually obligated to use your information only for the purposes of providing services to us and must maintain appropriate security measures to protect your data.

3.2 Lottery Organizations

We share necessary information with official provincial lottery organizations and authorized retailers to:

• Purchase official lottery tickets on your behalf
• Verify winning tickets and facilitate prize claims
• Comply with lottery gaming regulations and reporting requirements

3.3 Legal and Regulatory Authorities

We may disclose your information to government authorities, regulatory bodies, or law enforcement when:

• Required by law, regulation, or legal process
• Necessary to comply with gaming license requirements
• Requested through valid subpoenas or court orders
• Needed to investigate or prevent fraud, security threats, or illegal activities
• Required for tax reporting purposes

3.4 Business Transfers

If St. Lawrence Lotto is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

3.5 With Your Consent

We may share your information with other third parties when you have given us explicit consent to do so.

4. Data Security

We implement robust technical and organizational security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction:

4.1 Technical Security Measures

• 256-bit SSL encryption for all data transmission
• Encrypted data storage using industry-standard protocols
• Secure, PCI DSS-compliant payment processing
• Regular security audits and vulnerability assessments
• Intrusion detection and prevention systems
• Firewalls and network security monitoring
• Regular security updates and patch management

4.2 Organizational Security Measures

• Strict access controls limiting employee access to personal data
• Mandatory security training for all staff members
• Confidentiality agreements with all employees and contractors
• Incident response procedures for security breaches
• Regular review and update of security policies

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we continuously work to maintain and improve our security measures.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Account Information: Retained for the duration of your active account plus seven years after account closure to comply with gaming regulations and financial record-keeping requirements
• Transaction Records: Retained for seven years as required by tax and anti-money laundering regulations
• Communications: Retained for three years for customer service quality and dispute resolution purposes
• Marketing Data: Retained until you withdraw consent or request deletion
• Technical Logs: Retained for 90 days unless needed for security investigations or legal compliance

After the retention period expires, we securely delete or anonymize your personal information in accordance with our data retention schedule and applicable laws.

6. Your Privacy Rights

Under Canadian privacy laws, including PIPEDA (Personal Information Protection and Electronic Documents Act) and applicable provincial privacy legislation, you have the following rights regarding your personal information:

6.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used format within 30 days of receiving your request.

6.2 Right to Correction

If you believe any personal information we hold about you is inaccurate or incomplete, you have the right to request corrections. We will update your information promptly upon verification.

6.3 Right to Deletion

You may request deletion of your personal information, subject to certain exceptions where we must retain data for legal, regulatory, or security purposes. When deletion is not possible, we will inform you of the reasons.

6.4 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

6.5 Right to Withdraw Consent

Where we process your personal information based on consent, you have the right to withdraw that consent at any time. This includes opting out of marketing communications.

6.6 Right to Object

You may object to certain types of data processing, particularly for marketing purposes or where we rely on legitimate interests as the legal basis for processing.

6.7 Exercising Your Rights

To exercise any of these rights, please contact our Privacy Officer at [email protected] or use the contact information provided at the end of this policy. We will respond to your request within 30 days and may require verification of your identity before processing your request.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our platform. For detailed information about our use of cookies, please refer to our Cookie Policy.

8. Third-Party Links

Our platform may contain links to third-party websites, including payment processors, responsible gaming resources, and lottery organization websites. This Privacy Policy does not apply to those external sites. We encourage you to review the privacy policies of any third-party sites you visit, as we are not responsible for their privacy practices or content.

9. Children's Privacy

Our services are strictly intended for individuals who are 19 years of age or older (or the legal age for gambling in their province, whichever is higher). We do not knowingly collect personal information from anyone under the legal gambling age. If we become aware that we have inadvertently collected information from a minor, we will take immediate steps to delete that information from our systems. If you believe a minor has provided us with personal information, please contact us immediately.

10. International Data Transfers

Your personal information is primarily stored and processed in Canada. If we transfer your information outside of Canada for processing by service providers, we ensure that appropriate safeguards are in place through standard contractual clauses, adequacy decisions, or other lawful transfer mechanisms to protect your data in accordance with Canadian privacy standards.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification to registered users
• Displaying a prominent notice on our platform

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our services after any changes indicates your acceptance of the updated policy.

12. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

13. Privacy Complaints

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

You may also contact your provincial privacy commissioner if applicable to your jurisdiction.

Acknowledgment: By using St. Lawrence Lotto's services, you acknowledge that you have read, understood, and agree to this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.