Privacy Policy

This Privacy Policy explains how Altacore N.V. ("Altacore", "we", "us", "our") collects, uses, discloses, and protects personal data when you visit or use the Smokace online casino services made available to Canadian users through the project Smokace on smokace-game.com (the "Website"). It applies to players, registered account holders, and any other visitors to the Website.

By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, you should stop using the Website and our services.

This Privacy Policy is effective as of 1 February 2026 and replaces any earlier version applicable to the project Smokace on smokace-game.com.

Who We Are

The Website and the Smokace online casino services accessible through Smokace on smokace-game.com are operated by:

• Operator (data controller): Altacore N.V.
• Legal form: Public company (Naamloze Vennootschap - N.V.)
• Registration number: 151002
• Registered office / legal address: Dr. Henri Martinus, Willemstad, Curaçao
• Licensing: E-Gaming license No. 8048/JAZ2019-049 issued by Antillephone N.V. and authorized by the Government of Curaçao (status verified as active as of 2024, subject to further updates).

Altacore N.V. is the entity responsible for determining the purposes and means of processing your personal data when you use Smokace on smokace-game.com.

Contact for Privacy Matters

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, you may contact our data protection contact point (Data Protection Officer or data protection team) using the following details:

• Postal address (for privacy correspondence): Data Protection Officer, Altacore N.V., Dr. Henri Martinus, Willemstad, Curaçao
• Email:
• Online contact: via the support or contact forms provided on https://smokace-game.com

For Canadian residents, including those accessing Smokace, we handle your personal data in accordance with this Policy, applicable Curaçao law, and, where relevant, Canadian federal and provincial privacy laws.

Ontario notice: Smokace is not licensed by iGaming Ontario or any other authority in Ontario. Ontario residents should not use the Website. If you are located in Ontario and believe we process your personal data, please contact us so that we can address your request appropriately.

What Personal Data We Collect

We collect and process different categories of personal data depending on how you interact with Smokace on smokace-game.com, whether you register an account, and which services you use.

Identification and Contact Data

• Full name, username or nickname
• Date of birth and age verification information
• Residential address, country and province/territory of residence
• Email address and phone number(s)
• Copies of identification documents (e.g., passport, ID card, driving licence) and, where required, proof of address (utility bills, bank statements)

KYC / Compliance Data

• Know-Your-Customer (KYC) verification results
• Politically exposed person (PEP) and sanctions screening data, where required by law
• Information obtained from publicly available sources or third-party databases for identity verification, anti-money laundering (AML), and responsible gambling purposes

Technical and Usage Data

• IP address, approximate geolocation (e.g., country, province, city)
• Device identifiers, browser type and version, operating system, language settings
• Log data, including access times, pages visited, clicks, referral URLs, session identifiers
• Information about interaction with emails and notifications (e.g., opens, clicks)

Payment and Financial Data

• Partial payment card data (limited to what is necessary and in compliance with PCI-DSS; we do not store full card numbers or CVV codes where prohibited)
• E-wallet details, bank account identifiers, or payment service provider identifiers
• Deposit and withdrawal records, including amounts, timestamps, methods used, and account balances
• Transaction histories and related financial information necessary to process payments and comply with AML/CTF obligations

Behavioral and Profile Data

• Game play and betting history (games played, stakes, wins/losses, session duration)
• Bonus and promotion history, bonus abuse risk scoring, and eligibility information
• Responsible gambling data (self-exclusion status, limits set, affordability checks where required)
• Preferences and interests inferred from your usage (e.g., preferred games, language, device)

Marketing and Communication Data

• Marketing preferences (opt-in/opt-out status for email, SMS, push notifications)
• Records of communications with customer support, including chat logs and email correspondence
• Responses to surveys, feedback forms, promotions, and loyalty programs

Cookies and Similar Technologies

• Cookies, web beacons, tracking pixels, SDKs, and similar technologies used to recognize your browser or device, remember your preferences, and understand how you use the Website
• For more detail, please see the "Cookies & Tracking Technologies" section below

Children and Vulnerable Persons

The services available through Smokace on smokace-game.com are intended only for adults who meet the minimum legal gambling age in their jurisdiction (normally 18 or 19 in Canada, depending on the province/territory). We do not knowingly collect personal data from individuals who do not meet the legal age requirements. If we discover that such data has been collected, we will take reasonable steps to delete it.

Legal Basis for Processing

We process your personal data only when we have a valid legal basis to do so. Because our services are accessible globally, we align our practices with international standards such as the EU General Data Protection Regulation ("GDPR"), Canadian privacy legislation (including the Personal Information Protection and Electronic Documents Act - "PIPEDA" - and substantially similar provincial laws), and, where applicable, Mexican law.

• Contractual necessity: We process data that is necessary to enter into and perform our contract with you, including:
  • Creating and managing your player account
  • Providing access to games and related services
  • Processing deposits, bets, withdrawals, and bonus allocations
  • Providing customer support and resolving technical issues
• Compliance with legal obligations: Some processing is required by law, regulations, or licensing conditions, including:
  • Identity verification and age checks (KYC)
  • Anti-money laundering (AML) and counter-terrorist financing (CTF) monitoring and reporting
  • Record-keeping obligations imposed by our Curaçao license or other applicable laws
  • Responding to lawful requests from courts, regulators, and law enforcement
• Legitimate interests: We process data where it is necessary for our legitimate interests, provided these are not overridden by your rights and freedoms. Our legitimate interests include:
  • Securing the Website, preventing fraud and abuse, and maintaining integrity of games
  • Analyzing service performance and user behaviour to improve functionality and user experience
  • Managing business operations, risk, and internal compliance
• Consent: In some cases we rely on your consent, for example:
  • Sending marketing communications by email, SMS, or push notifications where required by law
  • Using non-essential cookies and similar technologies for analytics and advertising
  • Collecting and using certain optional information that is not required for the provision of our services

Where Mexican law applies (e.g., Mexican users accessing smokace-game.com), our processing bases are aligned with the Federal Law on Protection of Personal Data Held by Private Parties and related regulations, and correspond to the GDPR grounds described above.

Purpose of Processing

We process your personal data for the following purposes, to the extent permitted by applicable law:

• Provision of services: To operate the Smokace online casino available through Smokace on smokace-game.com, including:
  • Creating and managing user accounts
  • Enabling deposits, wagers, game play, bonuses, and withdrawals
  • Delivering customer service and technical support
• Regulatory and legal compliance: To comply with AML/CTF, KYC, licensing, tax, and other legal obligations imposed by Curaçao and other applicable jurisdictions.
• Responsible gambling: To monitor play patterns, apply self-exclusion and limits, and take measures to prevent problem gambling in line with responsible gambling standards.
• Service improvement and analytics: To understand how the Website is used, diagnose technical issues, optimize performance, and improve the user interface and product offering, using aggregated and pseudonymised data where possible.
• Fraud prevention and security: To detect and prevent fraud, abuse, bonus misuse, money laundering, account takeovers, and other security risks, and to protect the integrity of our games and systems.
• Marketing and promotions: To send you tailored offers, bonuses, newsletters, and other marketing communications about Smokace products and services, in accordance with your preferences and applicable laws.
• Business management: To manage our business, maintain internal records, conduct audits, and support corporate transactions (e.g., mergers, acquisitions, restructurings), as permitted by law.
• Legal claims and defence: To establish, exercise, or defend legal claims, disputes, or investigations.

Disclosure & Sharing

We do not sell your personal data. However, we may share it with trusted third parties and authorities under strict conditions and safeguards, as described below.

Service Providers and Technical Partners

• IT and hosting providers: Companies that host our servers, provide cloud infrastructure, content delivery networks, or other technical services necessary for operating Smokace on smokace-game.com.
• Game providers: Licensed gaming content suppliers who provide casino games and may require limited data (e.g., player IDs, session data) to deliver games and ensure fairness and security.
• Analytics and performance tools: Providers that help us analyse Website usage, detect technical issues, and improve performance, using aggregated or pseudonymised data where possible.

Payment and Financial Partners

• Banks, payment processors, card schemes, e-wallets, and other payment intermediaries involved in processing your deposits and withdrawals.
• Fraud prevention and AML service providers that we use to verify identity, assess risk, and comply with regulatory obligations.

Affiliates and Group Companies

• Companies that are part of the same corporate group as Altacore N.V., or its successors, for purposes consistent with this Policy (e.g., internal reporting, consolidated risk management, or support services), subject to appropriate confidentiality and data protection safeguards.

Regulators, Authorities, and Law Enforcement

• Gaming regulators and licensing authorities, including the Curaçao regulator (through Antillephone N.V.), where required to demonstrate compliance.
• Law enforcement agencies, courts, tax authorities, and other governmental bodies in Canada, Curaçao, or other jurisdictions, where we are legally obliged to do so or where disclosure is necessary to protect our rights or the rights of others.

Advertising and Marketing Partners

• Marketing agencies, email and SMS providers, and advertising networks that assist us in delivering marketing communications and personalized promotions, subject to your consent where required.
• Partners who place third-party cookies or similar technologies on our Website for analytics or advertising purposes, in accordance with the "Cookies & Tracking Technologies" section and applicable laws.

Corporate Transactions

• In connection with any merger, sale of assets, restructuring, financing, or acquisition of all or a portion of our business, your personal data may be transferred as part of the transaction, subject to contractual obligations to continue to protect it in accordance with this Policy.

Disclosures with Your Consent

• In addition to the above, we may share your personal data with third parties when you provide your explicit consent or request, for example by participating in a co-branded promotion or tournament run jointly with a partner.

International Transfers

Because Altacore N.V. is established in Curaçao and uses global service providers, your personal data may be transferred to and processed in countries other than the one where you reside, including:

• Curaçao (operator location and core gaming infrastructure)
• Member States of the European Economic Area (EEA) and/or the United Kingdom
• Canada and the United States
• Other countries where our key suppliers (e.g., hosting, game providers, payment processors) are located

These countries may have data protection laws that differ from those of your jurisdiction (e.g., Canada or Mexico). When we transfer personal data internationally, we implement appropriate safeguards, which may include:

• Standard Contractual Clauses (SCCs) or equivalent contractual mechanisms approved under the GDPR for transfers from the EEA/UK
• Contractual clauses and policies ensuring levels of protection comparable to those required under PIPEDA and Mexican law for cross-border transfers
• Technical measures such as encryption and access controls to protect data during transit and at rest
• Due diligence and ongoing monitoring of our service providers' security and privacy practices

Where applicable, we may also rely on adequacy decisions or frameworks recognized by relevant authorities as providing an adequate level of protection. Further details about specific transfer mechanisms can be obtained by contacting us using the details in the "Who We Are" or "Complaints & Contacts" sections.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements. Retention periods may vary depending on the category of data and applicable law, but we generally apply the following guidelines:

• Account and identification data: Kept for the duration of your active account and typically for up to five (5) years after account closure, unless a longer period is required by law (e.g., AML/CTF regulations) or necessary for ongoing disputes.
• KYC and AML records: Copies of identification documents, verification results, and AML monitoring records are retained for at least five (5) years after the end of the business relationship or after the date of the last transaction, or for any longer period mandated by applicable regulations.
• Payment and financial data: Transaction records, invoices, and accounting documents are typically retained for five (5) to seven (7) years, depending on legal and tax requirements.
• Technical logs and security data: Server logs, access logs, and security-related data are generally stored for up to two (2) years, unless a longer period is necessary for security investigations or legal proceedings.
• Marketing data: Information related to marketing preferences and communication history is kept for as long as you remain subscribed to marketing communications and for a reasonable period thereafter to document compliance with your preferences. If you withdraw consent, we will stop using your data for marketing and keep minimal records to honour your opt-out.
• Cookies and tracking data: Storage periods vary by cookie type. Session cookies are deleted when you close your browser; persistent cookies are kept for a longer period (typically from a few days up to 24 months), as described in our cookie settings or banner.

When personal data is no longer needed, we will take reasonable steps to irreversibly anonymise or securely delete it. Where full deletion is not feasible (for example, in backup archives), we will isolate the data and protect it from further processing until deletion is possible.

Your Rights

Depending on your place of residence (for example, Canada, the European Economic Area, the United Kingdom, or Mexico) and subject to legal limitations, you have certain rights regarding your personal data. We aim to apply high, harmonised standards across Smokace on smokace-game.com that are consistent with PIPEDA, GDPR, and relevant Mexican privacy laws.

Key Rights (Access, Correction, Deletion, Restriction, Objection, Portability)

• Right of access: You may request confirmation of whether we process your personal data and obtain a copy of that data, together with information about how we process it.
• Right to rectification/correction: You may request that we correct or update inaccurate or incomplete personal data. In some cases, you can update your information directly in your account settings.
• Right to erasure ("right to be forgotten" / cancellation): You may request that we delete your personal data where:
  • It is no longer necessary for the purposes for which it was collected, or
  • You have withdrawn consent (where processing was based on consent), or
  • You have successfully objected to the processing, or
  • Deletion is required under applicable law.
  We may retain certain data where required by law (e.g., AML/CTF, tax, or regulatory obligations) or where needed to establish, exercise, or defend legal claims.
• Right to restriction of processing: You may request that we restrict processing of your personal data in certain circumstances (for example, while we verify its accuracy or assess an objection).
• Right to object: You may object to:
  • Processing based on our legitimate interests, on grounds relating to your particular situation
  • Processing for direct marketing purposes, including profiling related to direct marketing. If you object to marketing, we will stop processing your data for this purpose.
• Right to data portability: Where technically feasible and legally required (for example, under GDPR), you may request that we provide your personal data in a structured, commonly used, and machine-readable format, or that we transmit it to another controller.
• Right to withdraw consent: Where we rely on your consent (e.g., for marketing communications or non-essential cookies), you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Rights Under Canadian and Mexican Law

• Canadian law (PIPEDA and substantially similar provincial laws): As a Canadian resident, you have rights to access and correct personal information held about you and to challenge our compliance with these laws. We will respond to your access or correction request within 30 days, subject to permitted extensions, and generally free of charge, except where a reasonable fee is allowed by law for excessive or repetitive requests.
• Mexican law (LFPDPPP - ARCO rights): Where Mexican privacy law applies, you have ARCO rights:
  • Acceso: Access your personal data and information regarding its processing
  • Rectificación: Request correction of inaccurate or incomplete data
  • Cancelación: Request cancellation of data when inappropriate or unnecessary, subject to legal retention obligations
  • Oposición: Object to processing for specific purposes
  These rights are implemented through processes broadly aligned with the GDPR and PIPEDA standards described above.

How to Exercise Your Rights

1. Submit a request: You may exercise your rights by contacting us using the details in the "Who We Are" or "Complaints & Contacts" sections. Clearly state:
   • Your full name and account ID (if applicable)
   • The right(s) you wish to exercise
   • Any relevant details that will help us locate your data (e.g., time period, specific services)
2. Identity verification: For security reasons, we may need to verify your identity before acting on your request. This may involve asking for additional information or documentation.
3. Response time: We aim to respond to all valid requests within 30 days of receipt. If we need more time due to complexity or volume, we will inform you of the extension and the reasons for it, in accordance with applicable law.
4. Fees: We generally handle requests free of charge. However, where permitted by law, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, excessive, or repetitive. We will inform you in advance if a fee will be charged.
5. Limitations: Your rights may be subject to certain legal restrictions (for example, where disclosure would reveal personal data of another person, where legal privilege applies, or where retaining data is required by law). If we decline your request in whole or in part, we will explain the reasons, unless we are legally prevented from doing so.

Cookies & Tracking Technologies

We use cookies and similar technologies on Smokace on smokace-game.com to ensure the proper functioning of the Website, enhance your experience, and support analytics and marketing activities, in accordance with applicable law.

Types of Cookies We Use

• Strictly necessary (functional) cookies: These cookies are essential for the operation of the Website and for enabling basic functions such as navigation, secure login, and access to protected areas. They cannot be switched off in our systems and are usually set in response to your actions.
• Preference cookies: These remember your choices (e.g., language, region, display settings) to provide a more personalized experience.
• Analytics and performance cookies: These help us understand how visitors use the Website, which pages are most popular, and how users move around the site, so that we can improve its performance and usability. We typically use aggregated or pseudonymised data for these purposes.
• Advertising and targeting cookies: These may be set by us or third-party partners to build a profile of your interests and show you relevant advertisements on our Website or other websites. They work by uniquely identifying your browser and internet device.

Third-Party Cookies

Some cookies on Smokace may be set by third parties, such as analytics providers, advertising networks, or game providers. These third parties may use the data collected via their cookies in accordance with their own privacy policies.

Managing Cookies

• You can manage your cookie preferences through:
  • The cookie banner or internal privacy/cookie settings panel available on the Website (where provided); and
  • Your browser settings, which typically allow you to block or delete cookies from specific sites or all websites.
• If you disable certain cookies, parts of the Website may not function properly, and some features (such as automatic login or remembering preferences) may be unavailable.
• For more information about cookies, including how to see what cookies have been set and how to manage or delete them, consult your browser's help section or independent resources such as allaboutcookies.org.

Data Security

We take the security of your personal data seriously and implement appropriate technical and organizational measures designed to protect it against unauthorized access, loss, misuse, alteration, or destruction.

Technical Measures

• Encryption in transit: Data transmitted between your browser and smokace-game.com is protected using Transport Layer Security (TLS) version 1.2 or higher, where supported by your browser and device.
• Encryption at rest: Sensitive data, including certain financial and authentication information, is stored using industry-standard encryption methods and access controls.
• Access controls: Access to personal data is restricted to authorized personnel and service providers who require it for legitimate business purposes and are subject to confidentiality obligations.
• Network and system security: We employ firewalls, intrusion detection and prevention systems, anti-malware tools, and other security technologies to safeguard our infrastructure.
• Secure development practices: Systems and applications are developed and maintained following security-by-design and security-by-default principles, including regular patching and updates.

Organizational Measures

• Policies and training: We maintain internal policies and procedures relating to data protection and information security, and we provide regular training to staff who handle personal data.
• Vendor management: Our service providers are carefully selected and required to implement appropriate security measures. Data processing agreements and confidentiality obligations are in place where required.
• Audits and testing: We perform periodic security assessments, audits, and, where appropriate, penetration testing to evaluate the effectiveness of our controls.
• Incident response: We maintain incident response procedures to detect, respond to, and remediate security incidents. Where required by law, we will notify you and/or relevant authorities of personal data breaches without undue delay.

While we strive to protect your personal data using measures aligned with internationally recognized standards (such as ISO/IEC 27001 and SOC 2 principles), no system can be completely secure. You are responsible for keeping your account credentials confidential and for using strong, unique passwords. If you suspect any unauthorized access to your account, please contact us immediately.

Complaints & Contacts

If you have questions, concerns, or complaints about how we handle your personal data on Smokace, we encourage you to contact us first so that we can seek to resolve the issue amicably.

Internal Contact Channels

1. Customer support: For general queries and minor concerns, please contact our customer support team via the support options available on https://smokace-game.com (e.g., live chat or helpdesk).
2. Data protection contact (DPO/data protection team): For privacy-specific questions or to exercise your data protection rights:
   • Postal address: Data Protection Officer, Altacore N.V., Dr. Henri Martinus, Willemstad, Curaçao
   • Email:
   • Online forms: Use any dedicated privacy or contact forms accessible on smokace-game.com, clearly indicating that your request concerns privacy/data protection.

Complaint Handling Procedure

1. Submission: Send your complaint or request in writing, providing sufficient detail to understand the issue and identify your account (if applicable).
2. Acknowledgement: We will acknowledge receipt of your complaint, typically within a reasonable time after receiving it.
3. Investigation: We will investigate the matter, which may include reviewing our systems and consulting relevant internal teams or third-party providers.
4. Response: We will provide a substantive response within 30 days, unless a longer period is allowed by law due to complexity or volume. If we require more time, we will inform you of the extension and explain why.
5. Escalation: If you are not satisfied with our response, you may request further review internally or escalate your complaint to the relevant supervisory authority, as described below.

Supervisory Authorities

If you are not satisfied with how we address your complaint, you have the right to contact a data protection authority or privacy regulator in your jurisdiction.

• Canada - Office of the Privacy Commissioner of Canada (OPC)
  • Website: https://www.priv.gc.ca
  • Telephone (toll-free in Canada): +1 800 282 1376
  • Mailing address and additional contact details are available on the OPC website.
• Provincial privacy regulators (where applicable): If you reside in a Canadian province or territory with its own private sector privacy regulator (e.g., Alberta, British Columbia, Quebec), you may also contact the relevant provincial authority. Contact details are available on their respective official websites.
• Mexico - National Institute for Transparency, Access to Information and Personal Data Protection (INAI)
  • Website: https://www.inai.org.mx
  • Contact details and complaint procedures (for ARCO rights and other issues) are available on the INAI website.
• European Union / EEA / UK - Data Protection Authorities:
  • If GDPR or UK GDPR applies to you, you have the right to lodge a complaint with your local data protection authority in the EU/EEA or with the UK Information Commissioner's Office (ICO).
  • A current list of EU/EEA data protection authorities and their contact details is available at: https://edpb.europa.eu/about-edpb/board/members_en

We encourage you to contact us first before approaching a regulator, so that we can attempt to resolve your concerns directly.

Updates

We may modify or update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will update the "Last updated" date, and, where appropriate, provide additional notice.

Notification of Changes

• Minor changes: For non-material updates (e.g., clarifications, formatting, or minor adjustments), we may simply update the Policy on smokace-game.com, with the revised version taking effect when posted.
• Material changes: For changes that materially affect your rights or how we process your data (for example, new processing purposes, new categories of data, or changes in international transfers), we will:
  • Provide clear notice on the Website, such as banners or pop-up notifications; and/or
  • Notify you directly via email or in-account messaging (where available).

Advance Notice and Your Choices

• Where required by law or where we reasonably consider it appropriate, we will provide you with at least 30 days' notice before material changes take effect.
• During this notice period, you may review the updated Policy and decide whether to continue using the services. If you do not agree with the changes, you may choose to close your account and stop using Smokace on smokace-game.com.
• Continued use of the Website after the effective date of an updated Policy will constitute your acceptance of the updated terms, to the extent permitted by applicable law.

Last updated: February 2026

For historical versions or a summary of material changes affecting Smokace, you may contact us using the details provided in the "Complaints & Contacts" section.