Effective Date: May 26, 2026
Licence Holder: Bluewater Gymnastics Club Sarnia
Official Advertiser: Academia Española de Marketing S.L
1. Introduction & Joint Control
This Privacy Policy governs the processing of personal data on the website ontario-lotto.app. The platform is operated jointly by Bluewater Gymnastics Club Sarnia (the Raffle License Holder) and Academia Española de Marketing S.L (the Technical Advertiser). We respect your privacy and are committed to safeguarding your personal data in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada, the Ontario Freedom of Information and Protection of Privacy Act, and the General Data Protection Regulation (GDPR) of the European Union (applicable due to our Advertiser headquarters in Madrid, Spain).
2. Personal Data We Collect
When you interact with our platform, purchase ticket bundles, or submit contact forms, we collect specific categories of personal information:
- Identity Details: Full name, age range (to verify you are 18 or older).
- Contact Details: Email address, physical address, and telephone number.
- Transaction Records: History of ticket bundles purchased, transaction timestamps, and values. Note: We do not collect or store full credit card numbers or CVV codes; these flow directly through our PCI-compliant payment gateways.
- Geolocation Information: Coordinate data checked during checkout to verify your location inside Ontario, Canada.
- Technical Identifiers: IP address, device type, browser settings, and cookie consents.
3. How We Process Your Geolocation
To comply with provincial lottery licensing laws under the Alcohol and Gaming Commission of Ontario (AGCO), we must verify that all ticket purchases occur within Ontario. When you authorize the location prompt in your browser, the system performs a localized lookup based on your coordinates. Once compliance is confirmed, the lookup result is recorded as a simple yes/no flag in our transaction log, and the exact coordinates are discarded. We do not track your location continuously or collect historical movements.
4. Legal Grounds & Purposes of Processing
We process your information under the following legal bases:
- To Perform a Contract: Generating your electronic tickets, processing bank transactions, and communicating draw results.
- To Meet Legal Obligations: Verifying age and location constraints to satisfy provincial licensing requirements under the AGCO.
- Under Your Consent: Sending you optional email notifications for upcoming draws, early access notices, and promotions. You can withdraw your consent at any time via the unsubscribe links in our emails.
5. Data Retentions and Storage Locations
All transaction and compliance records are stored securely on servers located in Canada and the European Union. In compliance with provincial audit requirements, lottery records and winner logs must be retained for a minimum of seven years following the drawing. General contact form inquiries and email subscription lists are kept only for the duration of the active raffle season plus six months, unless longer retention is required by law.
6. Third-Party Data Disclosures
We do not sell, rent, or trade your personal information with third-party marketing brokers. Your data is only shared with trusted service providers who enable us to run the raffle:
- Payment gateway processors (under strict PCI-DSS compliance).
- RNG audit providers and provincial gaming compliance officers.
- Email delivery engines and security hosts.
7. Player Rights and Data Management
Under PIPEDA and GDPR, you hold rights over your personal data. You may request access to, correction of, or deletion of the personal information we hold about you. To file a data request, contact our Data Protection Officer at support@ontario-lotto.app.
8. Updates to This Policy
We may modify this policy occasionally to align with changes in local legislation or digital auditing standards. Any revisions will be posted to this page with an updated effective date. We recommend checking this document regularly to stay informed.