Privacy Policy

This Privacy Policy explains how the Captain Cooks review pages on https://captain-play.ca (the "Website") collect, use, disclose, and protect personal information of players and website visitors. It applies to anyone who visits, browses, or interacts with the Website, including users who follow links from our content to the official Captain Cooks casino sites. This Privacy Policy is effective from 1 January 2026 and is intended to remain in force throughout 2026 unless replaced or updated in accordance with the "Updates" section below.

Who We Are

For the purposes of this Privacy Policy, "we", "us", and "our" refer to the operators responsible for the Captain Cooks brand as profiled by the Captain Cooks project on captain-play.ca, together with their Canadian-regulated online casino operations.

Operating entities

Fresh Horizons Ltd. - the company responsible for operating the Captain Cooks casino brand for Canada (excluding Ontario) under authorization from the Kahnawake Gaming Commission (KGC). Fresh Horizons Ltd. holds an interactive gaming permit issued by the KGC for online casino activities. Its registered office and company registration details are maintained with the Kahnawake Gaming Commission and other competent registries.
Apollo Entertainment Ltd. - the company responsible for operating the Ontario-regulated Captain Cooks casino site for players physically located in Ontario. Apollo Entertainment Ltd. is authorized by iGaming Ontario (iGO) and the Alcohol and Gaming Commission of Ontario (AGCO) for online casino operations. Its registered office and registration details are maintained with iGO/AGCO and other competent registries.

When you access Captain Cooks via links provided on Captain Cooks at captain-play.ca:

Ontario players are directed to an Ontario-regulated domain (such as https://captaincooks.games) operated by Apollo Entertainment Ltd.
Players from the rest of Canada (non-Ontario) are directed primarily to https://captaincooks.casino, operated under the Kahnawake Gaming Commission by Fresh Horizons Ltd.

Each operating entity acts as a controller of your personal information for its respective regulated environment. The Captain Cooks content on captain-play.ca is designed to reflect these operations and is aligned with this Privacy Policy.

Contact for privacy matters

Data Protection Officer / Privacy Team: You can contact our data protection function by using the contact options provided on https://captain-play.ca and, where applicable, on the Captain Cooks casino sites to which you are redirected. Please clearly mark your message "Privacy / Personal Information Request".
Postal contact: The official registered and mailing addresses of Fresh Horizons Ltd. and Apollo Entertainment Ltd. are published on their respective official websites and/or regulator registers (Kahnawake Gaming Commission, iGaming Ontario, AGCO). You may also request these details through our support channels if you require them for exercising your privacy rights.

What Personal Data We Collect

The Captain Cooks review pages on captain-play.ca, and the Captain Cooks casino sites you may access via our links, collect and process different categories of personal information depending on how you interact with our services.

Identification and contact data

Account and profile information: full name, date of birth, username, password, security questions, and any identity information you provide during registration or verification.
Contact details: email address, telephone number, postal address, preferred language, and communication preferences.
KYC/AML information: copies or details of identity documents (such as passport, driver's licence), proof of address, and information obtained from verification databases as required for age verification, anti-money-laundering (AML), and "know your customer" (KYC) obligations.

Technical and usage data

Technical identifiers: IP address, device identifiers, operating system, browser type and version, screen resolution, and approximate geolocation derived from your IP (for example, to determine whether you are in Ontario).
Log and interaction data: pages viewed, links clicked (including clicks from Captain Cooks on captain-play.ca to official casino domains), time and duration of visits, referral URLs, and error logs.

Payment and transactional data

Payment information: masked payment card details, payment method type (card, e-wallet, bank transfer), transaction identifiers, and payment status. Full card data is typically collected and processed by our authorised payment providers, not stored in plain form by us.
Gaming and transactional history: deposits, withdrawals, wagering and betting history, wins and losses, bonus usage, loyalty points, and reward redemption within the Captain Cooks ecosystem (including Casino Rewards group programs).

Behavioural and profiling data

Usage patterns: game preferences, frequency and duration of play, response to promotions, devices used, and time-of-day activity.
Responsible gaming indicators: self-exclusions, deposit or loss limits, unusual spending or play patterns that may indicate problem gambling or fraud, and related internal notes.
Marketing and analytics data: campaign performance, email open and click-through rates, and your interactions with marketing content and affiliate links on captain-play.ca.

Cookies and similar technologies

Cookies: small text files stored on your device for authentication, remembering preferences, security, analytics, and advertising purposes.
Pixels and tags: tracking pixels, web beacons, and script tags used for measuring traffic, analysing trends, and attributing marketing performance.
Device and browser storage: local storage or similar technologies used to maintain session and preference information.

Legal Basis for Processing

Our handling of your personal information is grounded in Canadian privacy legislation (including the Personal Information Protection and Electronic Documents Act - PIPEDA - and substantially similar provincial laws where applicable), gaming regulatory requirements, and, where relevant, alignment with international standards such as the EU General Data Protection Regulation (GDPR) and Mexican data protection law.

Consent

When required by law, we obtain your informed consent before collecting or using your personal information for specific purposes (for example, optional marketing communications, non-essential cookies, or certain types of behavioural analytics).
You may withdraw consent at any time for non-essential processing, subject to legal or contractual restrictions, by adjusting your preferences or contacting us as described in this Privacy Policy.

Contractual necessity

We process personal information that is necessary to enter into and perform a contract with you, such as:
- creating and managing your Captain Cooks casino account;
- enabling gameplay, deposits, withdrawals, and loyalty rewards;
- providing customer support and resolving operational queries.

Legitimate interests / reasonable purposes

Consistent with Canadian "reasonable purposes" principles and, where relevant, with GDPR "legitimate interests", we process personal information to:
- prevent fraud, abuse, money laundering, and other unlawful activities;
- secure our systems and ensure the integrity of games and bonus programs;
- understand how users interact with Captain Cooks content on captain-play.ca and our casino platforms to improve services and user experience;
- conduct internal reporting, analytics, and business planning.
Where applicable, we balance these interests against your rights and freedoms and implement safeguards such as pseudonymisation and access controls.

Compliance with legal and regulatory obligations

We process personal information because we are legally required to do so under:
- Kahnawake Gaming Commission (KGC) rules and regulations;
- iGaming Ontario (iGO) and AGCO requirements for Ontario operations;
- anti-money-laundering and counter-terrorist financing laws and reporting obligations (such as FINTRAC requirements in Canada);
- record-keeping, tax, accounting, and audit obligations under applicable laws.

Purpose of Processing

We use the personal information described above only for specific, explicit, and legitimate purposes, and we limit further use to purposes compatible with the original ones.

Provision and management of casino services

Creating, verifying, and managing your Captain Cooks casino account when you arrive via Captain Cooks on captain-play.ca.
Facilitating game play, deposits, withdrawals, and reward redemption within the Casino Rewards group ecosystem.
Providing technical support, answering your questions, and resolving operational issues.

Personalization and service improvement

Understanding game preferences and navigation patterns to optimise the Website and the casino interfaces.
Testing, developing, and improving features, promotions, and responsible gaming tools.
Measuring the effectiveness of information presented on Captain Cooks and adjusting content for clarity and compliance.

Marketing and communications

Sending you service messages (for example, security alerts, policy updates, transaction confirmations) that are necessary for operating your account.
With your consent, sending targeted promotions, bonuses, newsletters, and information about Captain Cooks or other Casino Rewards brands that are relevant to your interests and permitted in your jurisdiction.
Conducting analytics to understand the performance of marketing campaigns, including those originating from captain-play.ca.

Analytics, research, and reporting

Compiling aggregated statistics on usage, performance, and reliability of games and systems.
Producing regulatory reports required by KGC, iGO/AGCO, and other competent authorities.
Improving risk models and responsible gaming frameworks through aggregated analysis.

Fraud prevention, security, and compliance

Monitoring for suspicious behaviour, such as bonus abuse, collusion, account sharing, or prohibited VPN access (for example, attempts to play from restricted jurisdictions).
Verifying identity, age, location, and source of funds where required by law or regulation.
Detecting, investigating, and responding to potential security incidents, legal claims, and regulatory investigations.

Disclosure & Sharing

We do not sell your personal information to third parties. We may, however, disclose or share personal information with carefully selected recipients where necessary for the purposes described above, subject to appropriate safeguards and contractual protections.

Group companies and brand partners

Casino Rewards group entities: We may share information within the Casino Rewards group (which includes the Captain Cooks brand) to manage loyalty programs, cross-brand promotions, and consolidated risk and fraud controls.
Fresh Horizons Ltd. and Apollo Entertainment Ltd.: Information may be shared between these operating entities when needed to comply with regulatory obligations, manage cross-jurisdictional operations, or when you interact with more than one regulated environment.

Service providers and payment partners

Payment processors and banks: To process deposits, withdrawals, chargebacks, and fraud checks.
IT, hosting, and security providers: Cloud hosting, data centres, security monitoring, support tools, and email delivery platforms.
Verification and compliance providers: Identity verification, geolocation, AML screening, and responsible gambling tools.
These providers are contractually required to protect your information and to use it only for the services they provide to us.

Regulators, authorities, and dispute bodies

Gaming regulators: Kahnawake Gaming Commission, iGaming Ontario, AGCO, and any other competent gaming regulator, for licensing, audits, reporting, and investigations.
Alternative dispute resolution (ADR): eCOGRA (see https://ecogra.org/ata/policies_procedures.php) and similar bodies when you escalate a gaming dispute through those channels.
Law enforcement and governmental authorities: Where required or permitted by law, for example in connection with suspected fraud, money laundering, terrorist financing, or other unlawful activities.

Advertising and analytics partners

With your consent where required, we may share pseudonymised identifiers and usage data with advertising networks and analytics providers to:
- measure and improve the performance of campaigns (including those originating from captain-play.ca);
- deliver tailored advertising on third-party sites, where legally permitted; and
- avoid showing you irrelevant or duplicate ads.

Corporate transactions

In the event of a merger, acquisition, reorganisation, or sale of assets involving Casino Rewards group entities or the Captain Cooks brand, your personal information may be disclosed to potential or actual buyers or their advisers, subject to confidentiality obligations and applicable law.

International Transfers

Because online gaming and supporting services are provided through international infrastructure, your personal information may be transferred to, stored in, or accessed from countries outside your province or country of residence, including outside Canada.

Typical transfer destinations

Within Canada: Data may be processed in data centres and offices located in different provinces, subject to Canadian privacy laws.
European Economic Area (EEA) and United Kingdom: Certain IT, fraud prevention, and analytics providers may be based in or process data from these locations.
Other countries: Some service providers or group partners may process data in jurisdictions such as the United States or other countries that may not offer the same level of data protection as Canada.

Safeguards for cross-border transfers

When personal information is transferred outside Canada, we take steps to ensure it remains protected, including:
- using contractual protections, such as standard contractual clauses or equivalent data protection agreements, where appropriate;
- limiting transfers to providers that implement robust security and privacy controls;
- conducting due diligence and, where feasible, risk assessments of the legal environment in the destination country.
Where EU or Mexican data protection concepts are relevant (for example, if an EU or Mexican data subject interacts with our services), we aim to align with applicable cross-border transfer requirements, including the use of recognised transfer mechanisms approved by competent regulators.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, to meet legal, regulatory, accounting, or reporting obligations, and to resolve disputes. Retention periods may differ between Ontario and non-Ontario operations due to differing regulatory requirements, but the principles described here apply across our operations and are intended to remain in effect through at least the end of 2026.

Typical retention periods

Account and identification data: Usually retained for the duration of your account plus a period of approximately 5 - 7 years after account closure, to comply with gaming, AML, and financial record-keeping obligations.
Transactional and gaming history: Retained for at least 5 years after the relevant transaction or account closure, as required by gaming and financial regulations and for the defence of legal claims.
Marketing and communication data: Retained during the time you remain subscribed to marketing communications and for a limited period thereafter (typically up to 2 years) to document consent and manage opt-out lists.
Technical logs and security data: Retained for a shorter period (often from several months up to 2 years), unless longer retention is necessary for investigating security incidents, fraud, or legal claims.

Deletion and anonymisation

When personal information is no longer required for its original purpose or any compatible lawful purpose, we:
- securely delete it or anonymise it so that it no longer identifies you; or
- segregate and archive it in a secure form where continued retention is required by law.
Where technically feasible and legally permitted, we honour your requests for deletion or anonymisation as described in the "Your Rights" section.

Your Rights

Your rights are primarily governed by Canadian privacy laws (such as PIPEDA). In addition, we voluntarily align our practices, where feasible, with principles from the European Union's GDPR and Mexico's Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP). This means that, subject to legal and contractual limitations, you may be able to exercise the following rights in relation to your personal information.

Access and portability

Right of access: You can request confirmation of whether we hold personal information about you and obtain a copy of that information, together with an explanation of how it is used.
Data portability (where applicable): For information processed by automated means and based on your consent or a contract, you may request a copy in a structured, commonly used, and machine-readable format, and, where feasible, ask us to transmit it to another organisation.

Rectification and correction

You have the right to request correction of inaccurate or incomplete personal information. In many cases you can update your details directly via your account profile on the Captain Cooks casino site.
For information that cannot be corrected directly, you may contact us and we will update it where appropriate, or annotate the record where legal or regulatory reasons prevent alteration.

Deletion, cancellation, and restriction

Deletion / cancellation: Subject to legal and regulatory retention obligations, you may request that we delete or "cancel" certain personal information (equivalent to the "right to be forgotten" under GDPR and the "cancelación" right under Mexican law).
Restriction of processing: You may request that we restrict the processing of your information in specific circumstances, for example while we verify its accuracy or assess an objection.

Objection and opposition

You may object (or "oppose") to certain processing activities, including:
- direct marketing, including profiling related to direct marketing; and
- processing based on our legitimate interests / reasonable purposes where you believe your privacy interests outweigh those interests.
Where the objection is justified, we will stop the processing in question, subject to overriding legitimate grounds or legal requirements.

Withdrawal of consent

Where processing is based on your consent, you may withdraw that consent at any time. This will not affect the lawfulness of processing carried out before withdrawal but may affect our ability to provide certain services (for example, receiving promotional offers).

How to exercise your rights

Submit a request: Contact us using the privacy contact options on https://captain-play.ca or, where applicable, through the account portal or support channels on the Captain Cooks casino site you use. Please clearly state:
- your full name and account identifier (if any);
- the right(s) you wish to exercise (access, correction, deletion, restriction, objection, portability, consent withdrawal); and
- any relevant details to help us locate your information.
Verification: For your protection, we may need to verify your identity and jurisdiction (for example, confirming whether you are in Ontario, another Canadian province, the EU, or Mexico) before acting on your request.
Response time: We aim to respond to your request within 30 days. If your request is complex or we receive multiple requests, we may extend this period in line with applicable law, informing you of the extension and reasons.
Fees: Requests are generally handled free of charge. We may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, repetitive, or excessive, as permitted by law.

Cookies & Tracking Technologies

Cookies and similar technologies are used both on Captain Cooks pages on captain-play.ca and on the official Captain Cooks casino sites to provide, protect, and improve our services.

Types of cookies

Session cookies: Temporary cookies that remain on your device only while your browser is open and are automatically deleted when you close it. They are used for session management, authentication, and load balancing.
Persistent cookies: Cookies that remain stored on your device for a defined period or until you delete them. They help remember your preferences, such as language and region, and assist with analytics and marketing attribution.
First-party cookies: Cookies set directly by our domains (such as captain-play.ca or official Captain Cooks casino domains) for essential functionality, security, and internal analytics.
Third-party cookies: Cookies set by third-party providers (for example, analytics or advertising networks) to measure campaign performance and deliver, where permitted, tailored advertising.

Purposes of cookies

Strictly necessary / functional: To enable core site functionality, secure login, account management, and navigation.
Performance and analytics: To understand how users interact with Captain Cooks content on captain-play.ca and with the Captain Cooks casino interfaces, so we can improve usability and performance.
Advertising and marketing: To measure and optimise promotional campaigns and, where allowed by law and your preferences, present relevant offers.

Managing cookies

You can manage or disable cookies through your browser settings. The "Help" section of most browsers explains how to block new cookies, receive notifications when cookies are set, or delete existing cookies.
Some of our sites may offer an internal cookie or privacy preferences panel where you can consent to or opt out of non-essential cookies. Essential cookies cannot be disabled as they are required for the site to function correctly.
Please note that blocking or deleting cookies may affect the availability and functionality of some features, including secure login and personalised content.

Data Security

We implement technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. While no online system can be guaranteed 100% secure, we continuously assess and improve our controls.

Technical safeguards

Encryption in transit: Data transmitted between your device and our systems is protected using industry-standard Transport Layer Security (TLS) protocols (TLS 1.2 or higher), where supported by your device and browser.
Encryption at rest: Sensitive data is stored using strong encryption mechanisms (for example, AES-based encryption) and protected in secured environments.
Access controls: Access to personal information is restricted on a need-to-know basis, using unique user accounts, role-based permissions, and, where appropriate, multi-factor authentication.
Network and system security: Firewalls, intrusion detection/prevention systems, anti-malware solutions, and regular patch management are employed to reduce vulnerabilities.

Organisational and procedural measures

Policies and training: Staff with access to personal information are bound by confidentiality obligations and receive training on privacy, data protection, and responsible gambling requirements.
Vendor management: Third-party providers handling personal information are assessed for security and privacy practices, and we use contracts that require adequate protection of your information.
Audits and monitoring: We conduct internal reviews and, where appropriate, engage independent audits (for example as part of eCOGRA or regulator assessments) to evaluate the security and fairness of our systems.
Incident response: We maintain incident response procedures to detect, investigate, and mitigate security events. Where a breach creating a real risk of significant harm occurs, we will notify affected individuals and relevant authorities in accordance with applicable law.
We aim to align our practices with recognised security frameworks (such as ISO/IEC 27001 and SOC 2 principles) where appropriate. Unless explicitly stated, references to such frameworks do not imply formal certification.

Complaints & Contacts

If you have concerns about how your personal information is handled in connection with Captain Cooks on captain-play.ca or the associated Captain Cooks casino sites, you have several channels for raising questions or complaints.

Internal complaint procedure

Contact support: First, contact customer support using the channels available on the Captain Cooks casino site or via the contact options on https://captain-play.ca. Explain your concern and state that it relates to privacy or data protection.
Escalate to the Privacy Team / DPO: If the issue is not resolved, request that it be escalated to the Data Protection Officer or Privacy Team. Provide any reference numbers and supporting documentation.
Written complaint: You may submit a written complaint through electronic means (for example, by email via the website's contact form) or, where available, by post to the registered address of the relevant operating entity (Fresh Horizons Ltd. or Apollo Entertainment Ltd.).
Response timeframe: We aim to acknowledge your complaint within 10 business days and provide a substantive response within 30 days, or inform you if more time is needed due to complexity.

Complaints to privacy regulators

Canada - Office of the Privacy Commissioner of Canada (OPC):
- Website: https://www.priv.gc.ca
- Mailing address (as of this Policy's date): Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3, Canada.
European Union (where applicable): If you are in the EU and believe your GDPR-related rights have been infringed, you may lodge a complaint with your local supervisory authority. A list of authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Mexico - National Institute for Transparency, Access to Information and Personal Data Protection (INAI):
- Website: https://home.inai.org.mx
- INAI provides channels for individuals to exercise ARCO rights (Acceso, Rectificación, Cancelación y Oposición) and to lodge complaints in relation to Mexican data protection law.

Gaming-related dispute escalation (non-privacy)

For completeness, if your concern relates to game fairness or gambling disputes rather than privacy, you may also be able to escalate to:

eCOGRA: via https://ecogra.org/ata/policies_procedures.php;
Kahnawake Gaming Commission: via the complaints page at https://gamingcommission.ca/complaints.htm;
iGaming Ontario / AGCO: for Ontario-regulated play, as per the instructions provided on the Ontario-specific Captain Cooks site and the operator directory at https://igamingontario.ca/en/operator/operators.

These bodies primarily address gaming-related matters and are not general data protection authorities; however, they may consider privacy aspects in the context of regulatory compliance.

Updates

We may update this Privacy Policy from time to time to reflect changes in our services, legal or regulatory developments, or industry best practices. The updated version will apply to all processing of personal information from the date it is posted, unless otherwise indicated.

How we will notify you

Website posting: The most current version of this Privacy Policy will always be available on the Captain Cooks pages at https://captain-play.ca and, where relevant, on the Captain Cooks casino sites.
Email notifications: For material changes, we may notify registered players by email to the address linked to their Captain Cooks account, where such contact details are available.
On-site notices: We may display banners, pop-ups, or dashboard alerts on the Website or casino interfaces to draw attention to important updates.

Effective date, advance notice, and your options

Advance notice: Where changes materially affect your rights or how we process your personal information, we will, where practicable, provide at least 30 days' advance notice before the changes take effect.
Your choices: If you do not agree with the updated Privacy Policy, you may:
- adjust your privacy or marketing preferences; and/or
- request account closure and, where applicable, deletion or restriction of your personal information, subject to legal and regulatory retention requirements.
Continued use: By continuing to use Captain Cooks on captain-play.ca or the linked Captain Cooks casino services after the effective date of an updated Privacy Policy, you acknowledge that the updated Policy applies to your continued use.

Last updated: January 2026.