Policies

By accessing or using https://ab.stake.ca/, registering as a Member, or otherwise choosing to provide us with your Personal Information, you acknowledge that you have received and reviewed this Privacy Policy and you consent to Stake.ca collecting, using, processing, storing and disclosing your Personal Information for the purposes and on the legal bases set out herein. If you do not agree to the terms of this Privacy Policy, you may be unable to register for an account or use our services. All content, information, and data provided through Stake.ca is intended solely for your personal use in connection with our services and must not be copied, reproduced, disclosed, or used for any other purpose without the prior written consent of Stake.ca.

1. Purpose of this Policy and Website Use

This Privacy Policy explains how Stake Canada Ltd. ("Stake.ca" or "the Company") collects, uses, discloses, and protects your personal information when you use our services. Our goal is to ensure transparency, compliance with applicable Alberta and federal Canadian privacy laws, and alignment with best practices for responsible gaming and player protection. In this Policy, “Stake.ca ” refers to the Company, not a web address. Our Alberta gaming site is https://ab.stake.ca/. Our main Canadian domain, https://stake.ca , is a national landing page that simply directs players to the correct provincial site.

The Company is a company duly incorporated under the laws of Ontario under the register number 1001009105 with registered office at 199 Bay Street, Suite 2200, Commerce Court West, Toronto, Ontario, M5L 1G4, Canada, and operates the Alberta gaming site https://ab.stake.ca/.

This Privacy Policy also sets out how Stake.ca manages your personal information which we collect as a result of your membership with Stake.ca, your use of our website https://ab.stake.ca/ ("Website" or "Site") and any pages or websites under the "Stake" or "Easygo" brand, including any mobile phone or tablet applications that are owned and/or operated by the Company.

We are committed to ensuring that the personal information we collect about you is protected and is used, stored and disclosed in accordance with applicable Alberta and federal laws, including:

• The Personal Information Protection Act, SA 2003, c P-6.5 (PIPA) – Alberta's private sector privacy law;

• The Protection of Privacy Act (POPA) – Alberta's public sector privacy law applicable to AiGC and, through the Operating Agreement, to Operators;[PD4] [RS5] 

• The Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (PIPEDA) – where applicable to cross-border activities;

• The iGaming Alberta Act and regulations thereunder;

• The AiGC Operating Agreement and applicable iGaming Policies, including the AiGC Privacy Directive; and

• Any other applicable provincial or federal laws.

Stake.ca provides its services as part of the open and regulated iGaming market in Alberta and processes Personal Information on behalf of and as an agent of the Alberta iGaming Corporation ("AiGC"), a Crown corporation established pursuant to the iGaming Alberta Act.

PLEASE NOTE THAT, BY USING THE SERVICES, YOU REPRESENT THAT: (i) YOU ARE EIGHTEEN (18) YEARS OF AGE OR OLDER (THE "LEGAL AGE"); (II) YOU ARE LEGALLY ALLOWED TO GAMBLE ONLINE IN THE PROVINCE OF ALBERTA; AND (III) YOU ACCEPT THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, AS A CONDITION OF YOUR USE OF THE WEBSITE. STAKE.CA WILL NOT KNOWINGLY SOLICIT FROM OR COLLECT ANY PERSONAL INFORMATION FROM A PERSON UNDER THE AGE OF 18. IF ANY OF YOU BECOMES AWARE THAT A PERSON UNDER THE AGE OF 18 HAS PROVIDED THE COMPANY WITH PERSONAL INFORMATION, YOU MAY CONTACT THE COMPANY TO HAVE SUCH INFORMATION DELETED FROM OUR RECORDS.

2. Personal Information

Personal Information has the definition provided under PIPA and POPA and in general means information about a living identifiable individual. Stake.ca will collect Personal Information in order to provide our services to you, including:

• Name

• Telephone number

• IP Address

• Home address

• Information required to complete verification checks

• Answers to security questions

• Your betting and gaming activity

• Information on source of funds

• Information relating to self-exclusion and the Centralized Self-Exclusion (CSE) program administered by AGLC

• Your marketing preferences

• Email address

• Title

• Occupation

• Date of Birth (DOB)

• Sex

• Education, medical, psychiatric, psychological, criminal or employment history

• Account Number

• Information on deposits and withdrawals

• Account activity logs and history

• Information required to meet responsible gambling and/or AML-related obligations

• Payment methods

• Biometrics

3. Principles of Processing

We process personal information in accordance with the following principles:

• Limitation of collection and use: We only collect data necessary for providing and improving services and for all purposes identified under this Policy.

• Storage limitation: Data is retained for as long as required for the purposes identified in this Policy and upon termination of the relationship for the legally mandated period (currently seven years), subject to any longer retention that may be required by law.

• Openness & transparency: We provide clear information about how data is used. Disclosures to third parties shall be in accordance with this Privacy Policy, the AiGC Operating Agreement and applicable law.

• Accuracy & integrity: We are accountable for keeping your data accurate and up to date, pursuant to applicable provisions of POPA and PIPA.

• Processing outside Alberta: Stake.ca and its sub-contractors may process your Personal Information outside of Alberta as per the Cross-Border Data Transfers section below.

• Prohibition on sale: Stake.ca will not sell Personal Information for any purpose, in accordance with the AiGC Operating Agreement and POPA.

• Non-personal data restrictions: Use of de-identified or aggregated non-personal data is limited to research/analysis or managing/evaluating services offered to AiGC. Re-identification is strictly prohibited.

• Stake.ca will only use or disclose Personal Information to the extent necessary to carry out the identified purpose in a reasonable manner, in accordance with POPA and the PIPA reasonableness standard.

4. Collection of Information

We may collect the following types of information:

• Account Information: name, address, date of birth, phone number, email, government-issued ID, occupation, account number.

• Verification Data: Information that you provide to us by filling in forms on the Website or any other information you submit via the Website or email, including ID checks, proof of address, social insurance number or tax filing number, source of funds, and enhanced due diligence reports.

• Transaction Data: Details of the transactions you carry out with us such as deposits, withdrawals, account activity, betting and gaming history, whether via the Website or other means.

• Device & Connection Data: Details of your visits to the Website including traffic data, location data, weblogs and other communication data such as IP address, geolocation, cookies, device identifiers, browser fingerprinting, etc.

• Responsible Gambling Data: self-exclusion details, player limits, responsible gaming interactions, Centralized Self-Exclusion (CSE) status.

• Communications: correspondences including customer support or VIP chats, emails, call recordings, surveys whether via the Website or other means.

• Government issued photo identity: Copies of identification documents, usually photo ID, issued by a federal, provincial or territorial government or by a foreign government that is equivalent to a Canadian document.

Where it is reasonable to do so, we may conduct anti-fraud and anti-money laundering checks (including but not limited to Enhanced Due Diligence reports utilizing publicly available sources and ID verification).

We may combine information you provide us with other information about you that we obtain from your past use of the Site and Services, from our business partners, and from other companies. We may access other information about you collected from third parties, such as social media, credit and verification agencies.

If you choose to make usage of our live chat functionality we may store, record or otherwise process such data too.

We limit access to personal information to employees, contractors, and service providers who require such access to perform their job duties or provide services on our behalf. Depending on the nature of the information and the purpose for which it is being used, your Personal Information may be accessed by authorized personnel within the following categories:

• Customer Support team;

• Responsible Gambling and Player Protection teams;

• Compliance, Anti-Money Laundering (AML), Fraud Prevention, and Risk Management teams;

• Legal and Regulatory Affairs personnel;

• Payments, Finance, and Accounting teams;

• Information Security, Technology, and Systems Administration personnel;

• Identity Verification, Know Your Customer (KYC), and Account Verification teams;

• Vendors (payment provider, games provider, etc.) and

• Management personnel with oversight responsibilities requiring access for operational, legal, regulatory, or security purposes.

Access is granted on a need-to-know basis and is restricted to the minimum level necessary for employees and authorized personnel to perform their duties. All personnel with access to Personal Information are subject to confidentiality obligations and applicable privacy and security requirements.

5. Collection Purposes

Stake.ca collects Personal Information solely through lawful and fair means, ensuring the process is not intrusive, and only as necessary to operate as a licensed online iGaming operator in Alberta. We use this information for purposes including:

• Know-Your-Customer (KYC) and identity verification: Stake.ca employs third-party electronic verification providers as part of its internal risk management procedures. Your information may be shared with these providers to meet compliance requirements.

• Member identification and authentication: To confirm your identity, maintain account security, and meet legal obligations.

• Geolocation: Alberta law requires that we verify your physical location when engaging in gameplay. You can only play while physically located within Alberta's provincial boundaries. We collect your geolocation data using industry-standard technology, third-party services and contractors, and may store records confirming your location for as long as required under applicable provincial and federal laws.

• Statistical analysis: To generate aggregated, anonymized data that helps us identify behavioural patterns and improve our services, subject to restrictions on non-personal data use under the AiGC Operating Agreement.

• Marketing communications: If you consent, we may contact you by email, SMS, or telephone with offers and promotions that may interest you. All marketing is subject to the AiGC Marketing & Advertising Conditions Policy and must comply with the SRIG.

• Customer support and engagement: To respond to questions, comments, or requests and to deliver a higher level of service.

• Membership management: To process your application, maintain your account, and provide access to Stake.ca.

• Product and service enhancement: To improve your experience, tailor services to your needs, and conduct market research and promotions.

• Cookies: Stake.ca uses cookies and similar technologies to support essential website functions, enhance user experience, and track performance. You can learn more and manage your preferences through our dedicated Cookie Policy.

• Legal and regulatory compliance: To fulfill contractual, legal, and statutory obligations under applicable laws and the AiGC Operating Agreement.

• Risk management and enforcement: To prevent, detect, investigate, and report suspected unlawful activities or misconduct; to safeguard against risks; and to establish, exercise, or defend legal claims.

• Automated decisions: Where Personal Information is used in an automated system to make decisions, recommendations or predictions about you, we will provide a notice prior to such use, as required by the AiGC Operating Agreement.[PD9] [RS10]

6. Direct Marketing and Opting Out

When we have collected your consent, we may use your Personal Information to inform you about our products or services or about promotional activities which Stake.ca believes may be of interest or benefit to you. We may do this via email, SMS, telephone or mail.

If you no longer wish to receive marketing or promotional material from Stake.ca at all or in any particular form, you may contact us at any time by email to support-ab@stake.ca with your request, which we will comply with as soon as is practical.

Any communications with regard to your registration information, KYC and/or the transactions on your account are mandatory and you cannot opt-out of these.

All marketing and advertising directed at Alberta players must comply with the Social Responsibility in Gaming (SRIG) standards, the AiGC Marketing & Advertising Conditions Policy, and the Canadian Gaming Association Code. The AiGC iGaming Logo must be displayed on all marketing materials. Advertising must not target minors, self-excluded individuals, or high-risk players.

7. Management of your Personal Information

Stake.ca will take all reasonable steps to ensure that the Personal Information which it collects, uses or discloses is correct and is stored in a secure environment accessible only by authorised persons.

Stake.ca regularly trains its staff on data protection issues in a manner appropriate to each employee's role, hierarchy, and job description to ensure awareness and privacy culture throughout the organization. Privacy training is a component of Stake.ca's Privacy Management Program (PMP) maintained pursuant to the AiGC Privacy Directive.

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Stake.ca will retain your Personal Information for the duration of the mandated data retention period. Per the AiGC's requirements, that period is currently seven (7) years minimum from the termination of our relationship. At the conclusion of this retention period, Stake.ca will dispose of your personal information in accordance with applicable Alberta law and AiGC requirements.

In some cases, Personal Information may be retained beyond that time period due to potential legal obligations or legitimate interest purposes such as prevention of money laundering and fraud, matters of taxation, responsible gambling, civil, criminal and penal law, resolution of claims or any other legal issues.

Stake.ca will, in compliance with applicable law and with the approval of AiGC, anonymize or destroy the Personal Information we hold when it is no longer required for any purpose under our legal or operational obligations.

Your aggregated data can be shared with AiGC, AGLC and other regulatory bodies including but not limited to law enforcement authorities and courts of law upon request.

8. Security of Personal Information

You acknowledge that no data transmission over the Internet is totally secure. Accordingly, Stake.ca does not guarantee or warrant the security of any information which you transmit to it. Any information which you transmit to Stake.ca is transmitted at your own risk. However, once Stake.ca receives your transmission, Stake.ca will take reasonable steps to protect your Personal Information from misuse, loss and unauthorized access, modification and disclosure including by using password-protected systems and databases and Secure Socket Layer (SSL) technology.

We also use the following measures to secure your data:

• Identity and access management measures (only authorized individuals have access to your Personal Information);

• Encryption and data masking;

• Data loss prevention mechanisms and controls;

• Anti-malware protection mechanisms;

• Physical access security measures.

We suggest practical steps our customers can take to keep their data safe from unlawful processing: using strong passwords; installing anti-virus and malware protection; ensuring Wi-Fi is secure; not allowing others to access your account; encrypting your data.

9. Your Responsibility

You are responsible for providing Stake.ca with all required Personal Information in order to access and use the Website fully and without interruption, and for ensuring that such information remains accurate and up to date.

• At registration: You must declare that all information submitted for the establishment of our business relationship is true, correct, and accurate.

• Ongoing updates: If your Personal Information changes, you are required to update it through the My Account page or, if that is not possible, by contacting our support team via the Contact Us section.

• Periodic reminders: From time to time, you may be prompted by an on-screen reminder to confirm or update your Personal Information.

• Non-amendable data: Certain Personal Information, such as your date of birth, cannot be changed once provided.

10. Your Individual Rights

While Stake.ca is maintaining or processing your Personal Information, you have the following rights, which may be exercised by submitting a request through your personal account or by contacting us directly:

• Right of access – You may request access to the Personal Information we hold about you.

• Right of rectification – You may request that any inaccurate or incomplete Personal Information be corrected, updated, or, where appropriate, deleted.

• 'Right to request deletion: PIPA and POPA do not provide a general right of erasure. You may request account deletion, which will be processed subject to our legal retention obligations. Right to restriction of processing – You may request that we limit or stop further use or processing of your Personal Information.

• Right to object – You may object to certain activities relating to the use, processing, or disclosure of your Personal Information.

• Right to withdraw consent – Where our processing is based on your consent, you may withdraw that consent at any time.

How to Exercise Your Rights

Please note that these rights are not absolute. Requests are subject to applicable laws and regulations, including gambling legislation and our obligations for recordkeeping, responsible gambling, and reporting. We will assess and respond to your request as soon as possible, and in any event within one (1) month of submission.

11. Disclosure of Personal Information

11.1 General Rule

Stake.ca will not sell, rent, or otherwise commercially exploit your Personal Information. In particular, and pursuant to the AiGC Operating Agreement, Stake.ca expressly prohibits the sale of personal information for any purpose. We will only disclose your Personal Information as outlined in this Privacy Policy and strictly for lawful purposes.

11.2 Corporate Transactions

We may disclose your Personal Information to potential purchasers, successors, or investors in Stake Canada Ltd. (or any entity within the Stake Group) in connection with a corporate transaction such as a merger, reorganization, asset sale, financing, bankruptcy, or acquisition. In such cases, the acquiring entity will assume the rights and obligations described in this Privacy Policy.

11.3 Legal, Regulatory, and Compliance Obligations

We may disclose Personal Information in order to comply with applicable legal or regulatory obligations, enforce our Terms and Conditions, protect the rights, property, or safety of Stake.ca, our customers, or others, or cooperate with lawful requests from law enforcement, regulators, or courts. Examples include disclosures to:

• Gaming regulatory authorities (e.g., AiGC, AGLC, Office of the Information and Privacy Commissioner of Alberta (OIPC));

• Sports governing bodies to uphold integrity in sports betting;

• Anti-Money Laundering / Counter-Terrorism Financing (AML/CTF) agencies, including FINTRAC;

• Law enforcement bodies in Canada or abroad;

• Competent courts or dispute resolution bodies.

11.4 Fraud Prevention and Risk Reduction

We may share your Personal Information with banks, credit institutions, fraud prevention services, and similar organizations (within or outside Alberta) to investigate suspicious activity, prevent unlawful practices, and reduce credit risk.

11.5 Third-Party Service Providers

We may disclose Personal Information to unaffiliated third-party service providers, agents, and contractors who perform services on our behalf. Any disclosure of Personal Information to third parties requires the prior consent of AiGC. These providers are contractually required to use the information only for specified purposes, protect your Personal Information with equivalent security safeguards, and comply with applicable privacy frameworks.

11.6 Cross-Border Data Transfers

We may transfer your Personal Information outside Alberta to trusted service providers or affiliates located in Australia, Serbia, or other jurisdictions where necessary to provide our services to you.

Any transfer of your Personal Information outside Alberta is carried out only where permitted under applicable Canadian privacy law, including PIPEDA, PIPA, and POPA as it applies to Stake.ca through the AiGC Operating Agreement. Stake.ca remains responsible for ensuring that any organisation receiving your Personal Information outside Alberta protects it to an equivalent standard.

By creating an account with Stake.ca, you acknowledge and consent to the transfer, storage, and processing of your Personal Information outside Alberta for the purposes described in this Privacy Policy.

11.7 User Consent

By creating an account with Stake.ca, you acknowledge and consent to the transfer, storage, and processing of your Personal Information outside Alberta, including in jurisdictions such as Australia and Serbia, for the purposes outlined in this Privacy Policy.

12. No Persons Under 18

Stake.ca will not knowingly solicit and its services are not intended for persons under 18 years of age. Stake.ca will not knowingly collect Personal Information from minors.

If you are a parent or guardian of a child and become aware their Personal Information has been provided to us, please contact dpo-ab@stake.ca. We may request additional information to verify your relationship with the minor. Stake.ca will take the necessary measures to ensure the minor's Personal Information is deleted, subject to the requirements of applicable law.

13. Contact Details

If you have any queries, requests for access or correction, or complaints relating to the handling of your personal information, please contact us by email at support-ab@stake.ca or by the site customer support chat function.

For dedicated privacy concerns, the Stake Canada Data Protection Officer can be contacted at dpo-ab@stake.ca.

14. Complaint Process

To file a complaint with Stake.ca, please email complaints-ab@stake.ca and include all relevant facts and circumstances.

You are required to use all reasonable means to resolve complaints pertaining to the provision of online gaming services directly with us. If you have exhausted all such reasonable means, you may log a formal complaint with AiGC.

Stake.ca complies with the AiGC's Customer Care and Dispute Resolution (CCDR) requirements. Information about the CCDR program is readily accessible on the Stake.ca website. This program is provided to you free of charge and Stake.ca will not withhold any Winnings in respect of CCDR-related services.

We will aim to resolve all related CCDR disputes within 30 days of notice.

If you have any concerns or questions about our privacy practices, or would like to make a complaint, please email our Stake Canada Data Protection Officer at dpo-ab@stake.ca. We aim to respond within 30 business days.. If you are not satisfied with our response,you also have the right to file a complaint with the OIPC at www.oipc.ab.ca.

15. Incident Management and Notification

15.1 Commitment to Security

Protecting your Personal Information is of the utmost importance to Stake.ca. We continually work to implement and maintain appropriate safeguards to prevent unauthorized access, ensure data security, and use information responsibly. These safeguards include physical, technical, and organizational measures consistent with industry best practices.

15.2 Limitations and Transparency

While Stake.ca takes reasonable steps to secure your Personal Information, no transmission of data over the Internet is entirely risk-free. We cannot guarantee absolute security, and any transmission of information is at your own risk. If a breach occurs that creates a real risk of significant harm, we will promptly notify the Minister of Technology and Innovation, including AiGC, and the OIPC, in accordance with applicable law. Upon instruction from OIPC, we will inform you.

15.3 Incident Management Process

Stake.ca has established a standardized Incident Management Process to ensure a consistent and effective response to any security-related event. This process includes:

• Initiation: Working with critical suppliers, internal departments, and assurance functions to assess the severity and impact of a reported incident.

• Containment, Eradication, and Recovery: Verification of the integrity of critical systems and customer data, sanitization and restoration of impacted data, and reporting to regulators as required.

• Notification: Players will be informed of any restored balances, exposed Personal Information (if applicable), and provided with guidance such as resetting passwords.

• Review: Internal review of the event and take action to prevent future security-related event

15.4 Regulatory Notification

Stake.ca will notify AiGC of any material Personal Information breach within the prescribed timeline of becoming aware, and provide ongoing support for investigations and resolution. Where required, Stake.ca will also notify affected individuals, the OIPC, and other relevant authorities within the timelines mandated by applicable law.

16. Registration with AiGC

16.1 Acceptance at Registration

In accordance with the AiGC Operating Agreement, Stake.ca requires you to accept the Website Terms and Conditions and this Privacy Policy before accessing any of our services. This acceptance is obtained during the registration process by actively selecting the relevant confirmation box.

A specific Privacy Notice will also be provided at registration, prior to the use of Personal Information in any automated decision-making system, and at other relevant touchpoints as required by the AiGC Privacy Directive.

16.2 Regulatory Approval and Amendments

This Privacy Policy has been developed in accordance with the AiGC Privacy Directive and applicable Alberta law. Any future version that includes material amendments will be submitted to AiGC for review prior to publication. You will be required to acknowledge and accept any material changes before continuing to use Stake.ca's services.

16.3 Privacy Management Program

Stake.ca maintains a Privacy Management Program (PMP) in accordance with the AiGC Privacy Directive. The PMP includes appointment of Stake Canada Data Protection Officer, policies for responding to access requests, privacy incident response and complaints, data classification, privacy and security training, privacy impact assessment processes, and policies related to the use of AI systems and non-personal data.

16.4 Privacy Impact Assessment

Stake.ca has completed a Privacy Impact Assessment (PIA) using the OIPC template, submitted through AiGC to the OIPC for comment and review prior to launch. Any material changes to data processing activities will be assessed to determine whether an updated PIA is required.

17. Consequences of Refusing to Provide Personal Information

The collection, use, and disclosure of Personal Information by Stake.ca are conducted in compliance with applicable privacy legislation, including PIPA, POPA, and PIPEDA where applicable.

17.1 Registration and Account Creation

Failure to provide required identifiers and supporting documentation may prevent Stake.ca from completing your registration or establishing an account.

17.2 Identity Verification, Transactions, Crime Prevention, and Responsible Gambling Measures

Where Personal Information is required to satisfy legal and regulatory obligations, refusal or failure to provide such information may result in suspension or closure of your account, inability to log in or access your account, and/or freezing, cancellation, or denial of withdrawal requests.

17.3 Personalization, Marketing, and Promotional Activities

Where Personal Information is processed on the basis of consent for personalization or marketing communications, withdrawal of consent or failure to provide such data may result in loss of access to personalized offers, bonuses or promotions, and a less tailored gambling experience.

18. Updates to this Privacy Policy

We may update this policy from time to time. Stake.ca is committed to keeping you informed about updates to this Privacy Policy. Any revisions will be communicated through the Website and clearly dated so you can review the most recent version. The Privacy Policy is accessible at all times through the footer on both the desktop and mobile versions of the Website. Material changes will be submitted to AiGC prior to publication and you will be required to acknowledge and accept material changes before continuing to use our services.

19. Governing Law

This Privacy Policy, together with all related matters, is governed by the laws of Alberta and the applicable federal laws of Canada, including PIPA, POPA, and PIPEDA where applicable. Any disputes arising in connection with this Privacy Policy shall be subject to the jurisdiction of the courts of Alberta.