Elements Casino Privacy Policy

1. Introduction

This Privacy Policy describes how Elements Casino collects, uses, retains, discloses, and protects the personal information of guests and registered program participants at its Canadian properties. Elements Casino operates land-based casino venues in British Columbia and Ontario, including properties in Victoria, Nanaimo, Surrey, and Elora. Privacy practices at these properties are governed by applicable Canadian federal and provincial legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial statutes.

By visiting an Elements Casino property, enrolling in a guest program, or otherwise providing personal information to Elements Casino, guests acknowledge the practices described in this document.

2. Operator and Privacy Responsibility

Privacy obligations for Elements Casino Victoria and Casino Nanaimo are administered by LAHAL, the entity responsible for collecting and managing personal information at those properties. Elements Casino Grand River Raceway in Elora, Ontario operates under the regulatory oversight of the Alcohol and Gaming Commission of Ontario (AGCO) and within the framework established by the Ontario Lottery and Gaming Corporation (OLG). Elements Casino Surrey operates under the regulatory authority of the British Columbia Lottery Corporation (BCLC).

Each property designates a Privacy Officer responsible for overseeing compliance with this policy and applicable privacy legislation. Guests with questions or concerns regarding the handling of their personal information may contact the Privacy Officer through the channels described in Section 8.

3. Personal Information Collected

Elements Casino collects personal information only to the extent necessary for the purposes described in this policy. The categories of personal information that may be collected include:

• Full legal name and date of birth
• Contact details, including mailing address, telephone number, and email address
• Government-issued identification details, where required for regulatory compliance
• Player card and rewards program enrollment data
• Gaming activity records, where required by law or for program administration
• Financial transaction records, as required under anti-money laundering and tax obligations
• Security and surveillance data collected on-premises in accordance with regulatory requirements

Elements Casino does not collect personal information beyond what is required for the stated purposes of collection.

4. Purposes of Collection and Use

Personal information collected by Elements Casino is used for the following purposes:

• Administration of guest rewards programs and player accounts
• Verification of guest identity and eligibility to participate in casino programs
• Communication with guests regarding program updates, where consent has been provided
• Compliance with regulatory requirements, including anti-money laundering obligations, gaming integrity standards, and reporting requirements imposed by BCLC, AGCO, OLG, and other applicable authorities
• Security operations, including fraud prevention and on-premises surveillance
• Resolution of disputes and handling of guest inquiries

Personal information is not sold to third parties for marketing purposes. Disclosure to third parties occurs only where necessary to operate services, fulfill legal obligations, or respond to lawful requests from regulatory or law enforcement authorities.

5. Consent

Elements Casino obtains consent from guests prior to collecting personal information, except where collection is authorized or required by law without consent. Guests may withdraw consent to receive marketing communications or to participate in guest programs at any time by contacting Guest Services at the relevant Elements Casino property.

Withdrawal of consent to certain uses of personal information may affect a guest’s ability to participate in specific programs or receive related services. Elements Casino will advise guests of any such consequences at the time consent is withdrawn.

6. Retention of Personal Information

Elements Casino retains personal information for the period necessary to fulfill the purposes for which it was collected and to satisfy applicable legal and regulatory obligations. Financial transaction records are retained for a minimum of seven years in compliance with anti-money laundering and tax requirements. Gaming activity records and account information are retained for the duration of an active enrollment and for the period required by applicable law following account closure or program cancellation.

When personal information is no longer required for its stated purpose and no legal obligation requires its continued retention, Elements Casino takes reasonable steps to securely destroy or anonymize that information.

7. Guest Rights

Guests whose personal information is held by Elements Casino have the following rights under applicable Canadian privacy legislation.

7.1 Right of Access

Guests may request access to the personal information that Elements Casino holds about them, including account details, transaction history, and records of gaming activity where applicable. Requests must be submitted in writing to the Privacy Officer at the relevant property.

7.2 Right of Correction

Guests may request correction of inaccurate or incomplete personal information. Elements Casino reserves the right to correct personal information in its possession and will process correction requests within a reasonable timeframe. Where a correction is not made, Elements Casino will note the guest’s request in the relevant record.

7.3 Right to Withdraw Consent

Guests may withdraw consent to the collection, use, or disclosure of their personal information for non-mandatory purposes by contacting Guest Services at Elements Casino Victoria, Casino Nanaimo, or the relevant Elements Casino property.

7.4 Right to Cancel Enrollment

Guests may cancel their enrollment in casino programs or rewards accounts by contacting Guest Services at the applicable property. Cancellation of enrollment does not affect the retention of records required by law.

7.5 Response Timeframe

Elements Casino will respond to written privacy requests within thirty (30) days of receipt, in accordance with PIPEDA and applicable provincial requirements.

8. Contact Information

Guests with questions, concerns, or requests regarding this Privacy Policy or the handling of their personal information may contact the Privacy Officer at the relevant Elements Casino property.

For Elements Casino Victoria and Casino Nanaimo, inquiries may be directed to LAHAL’s Privacy Officer via the email address published on the Elements Casino Victoria website. A paper copy of the privacy statement for these properties is available upon request from a Guest Services Representative at either location.

For Elements Casino Grand River Raceway, general inquiries may be directed by telephone:

• General Information: (519) 846-2022
• Alternative Line: (519) 846-5455

The property address for Elements Casino Grand River Raceway is:

7445 Wellington County Road 21
Elora, Ontario
N0B 1S0
Canada

9. Regulatory Oversight and Escalation

If a guest’s privacy concern is not resolved to their satisfaction through direct contact with Elements Casino, the guest may escalate the matter to the applicable privacy regulator.

For British Columbia properties, guests may contact the Office of the Information and Privacy Commissioner for British Columbia. For Ontario properties, guests may contact the Office of the Privacy Commissioner of Canada, located in Gatineau, Quebec, or the OLG Freedom of Information and Privacy Office in Sault Ste. Marie, Ontario.

10. Amendments to This Policy

Elements Casino reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or operational practices. Updated versions of this policy will be made available at Guest Services at each property and, where applicable, on the relevant property website. Continued participation in Elements Casino programs following the publication of an amended policy constitutes acceptance of the revised terms.