Privacy Policy
1. What We Collect
- Account: email address, full name, date of birth, province, preferred language.
- Payment: wallet balance, transaction history, Stripe payment intent IDs (no card numbers are stored on our servers).
- Technical: IP address, country, signup metadata, and basic device/browser information for fraud prevention.
- Compliance: age and residency confirmations, terms acceptance timestamps, audit logs of sensitive actions.
2. How We Use It
To create and operate your account, verify eligibility, process wallet top-ups, run draws, pay out prizes, prevent fraud and underage participation, comply with legal obligations, and send transactional emails (purchase confirmations, draw results, claim links).
3. Who We Share With
- Stripe Payments Canada, Ltd. — to process top-ups and chargebacks.
- Supabase (managed by Lovable Cloud) — to host our database and authentication, in Canadian/US regions.
- Email delivery providers — to send transactional notifications.
- Regulators & law enforcement — when legally required (RACJ, AGCO, court orders).
We do not sell personal information.
4. Legal Basis
We handle personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) federally, the Personal Information Protection Act (PIPA) in Alberta and British Columbia, and the Loi modernisant des dispositions législatives en matière de protection des renseignements personnels (Loi 25) in Quebec.
5. Retention
We retain account, transaction, and compliance records for as long as the account is active and for at least 7 years thereafter to meet financial and regulatory obligations.
6. Your Rights
You may request access, correction, or deletion of your personal information at any time, subject to legal retention obligations. To exercise your rights, contact privacy@wincircle.ca.
7. Contact & Privacy Officer
WinCircle's Privacy Officer can be reached at privacy@wincircle.ca.