Privacy Policy
This Privacy Policy explains how sesame collects, uses, discloses, and safeguards personal information for visitors and players who access or use sesame-ca.com. It applies to website visitors, registered account holders, and recipients of our communications. By using our services, you acknowledge this Policy. Effective date: October 31, 2025.
Who We Are
Observe: Identify the data controller and contact channels. Expand: Include registration/licensing details and a contact point for privacy matters. Reflect: Provide precise yet non-invented facts only.
- Operator: Sesame Online EOOD, a single-owner limited liability company registered in Bulgaria (EIK/UIC: 205723651).
 - Licensing: Licensed for online gambling operations by the National Revenue Agency (NRA) of Bulgaria (see public NRA registers).
 - Registered office/legal address: The company is registered in Bulgaria. The full registered address will be provided upon verified request for privacy or legal purposes.
 - Websites: Official: https://sesame-ca.com. Legacy (reference): https://sesame.bg.
 - Privacy contact (Data Protection Team): [email protected]; Tel: +359 2 493 0008 (BG). Please write "Privacy request" in the subject line.
 
What Personal Data We Collect
Observe: List data categories. Expand: Cover operational, technical, and compliance data. Reflect: Clarify optional vs. required data.
- Identity and contact: full name, date of birth, address, nationality, e-mail, phone, document identifiers collected for KYC/AML (e.g., ID/passport details, proof of address), and account credentials.
 - Account and behavioral data: registration details, session history, game/betting history, deposits/withdrawals, responsible gambling settings, interactions (clickstream, features used), preferences.
 - Payment and financial: payment method details (tokenized where possible), transaction records, payout details, chargeback information.
 - Technical data: IP address, device and browser data, OS/version, language, screen resolution, time zone, cookie IDs, advertising IDs, log files, security event logs.
 - Communications: customer support chats, e-mails, calls (where applicable), marketing preferences and consents.
 - Cookies and similar tech: session and persistent cookies, SDKs, pixels, and local storage for functionality, analytics, personalization, and advertising (see "Cookies & Tracking Technologies").
 
Legal Basis for Processing
Observe: Identify lawful grounds. Expand: Align with Canadian laws (PIPEDA/CASL) and cross-border standards (GDPR, where applicable). Reflect: Map grounds to typical processing.
- Consent: We obtain express or implied consent under PIPEDA for collection, use, and disclosure where required, and express opt-in consent under Canada's Anti-Spam Legislation (CASL) for commercial electronic messages.
 - Contract necessity: Processing needed to create and operate your account, verify identity, process payments and payouts, provide customer support, and deliver games and features you request.
 - Legitimate interests / appropriate purposes: Fraud prevention, security, service analytics, service improvement, and personalization, implemented with safeguards and proportionality. For individuals in the EEA/UK, we rely on legitimate interests under GDPR where appropriate.
 - Legal obligations: Compliance with KYC/AML/CTF requirements, sanctions screening, recordkeeping, tax and regulatory reporting, dispute management, and requests from competent authorities.
 
Purpose of Processing
Observe: State concrete purposes. Expand: Include service, compliance, security, analytics, and marketing. Reflect: Tie purposes to user benefit and risk controls.
- Service delivery: Account registration and management, identity verification, enabling gameplay and transactions, customer support, responsible gambling tools.
 - Compliance and risk: AML/KYC checks, sanctions screening, transaction monitoring, auditing, and regulatory reporting.
 - Security: Detecting and preventing fraud, abuse, cheating, multi-accounting, and cyber threats; ensuring platform integrity.
 - Analytics and improvement: Usage measurement, performance monitoring, A/B testing, product development.
 - Personalization and marketing: Tailoring content, recommendations, and offers; sending marketing communications where you have consent (you may withdraw at any time).
 
Disclosure & Sharing
Observe: Identify categories of recipients. Expand: Include legal, operational, and optional disclosures. Reflect: Add safeguards and conditions.
- Payment and banking partners: card processors, payment gateways, banks, payout providers (to process deposits/withdrawals and verify transactions).
 - Verification and risk vendors: identity/KYC providers, sanctions/PEP screening, fraud detection, cybersecurity services.
 - Technology and operations: hosting/cloud, content delivery networks, analytics platforms, CRM/helpdesk tools, communication service providers.
 - Affiliates and group entities: For centralized operations, anti-fraud, compliance, and customer support-only as necessary and under contractual safeguards.
 - Marketing and advertising partners: only where permitted by law and your consent; includes ad networks and measurement partners.
 - Regulators and authorities: courts, law enforcement, tax bodies, gambling regulators and financial intelligence units, when legally required or to protect rights, users, or the platform.
 - Business transactions: In a merger, acquisition, financing, or asset sale, subject to confidentiality and continued protection of personal information.
 
International Transfers
Observe: Identify destinations outside Canada. Expand: Explain safeguards for cross-border flows. Reflect: Address Quebec Law 25 and GDPR alignment.
- Destinations: Your data may be transferred to Bulgaria and other EEA countries (for operations and compliance), and to the United States or other jurisdictions (for cloud/CDN, analytics, communications, or support tools).
 - Safeguards: We use contractual and organizational measures to ensure comparable protection, including data processing agreements, confidentiality controls, access restrictions, and security standards.
 - EEA safeguards: Where GDPR applies, we implement the European Commission's Standard Contractual Clauses (SCCs) or equivalent transfer mechanisms with risk assessments and supplementary measures.
 - Quebec (Law 25): Before communicating personal information outside Quebec, we assess the privacy risks, consider the legal framework of the destination, and apply appropriate contractual measures.
 - U.S. vendors: Where applicable, preference for providers certified under the EU-U.S. Data Privacy Framework or bound by SCCs and additional safeguards.
 
Data Retention
Observe: State durations. Expand: Reflect regulatory and operational needs. Reflect: Define deletion criteria.
- Account and identity data: Kept for the life of the account and generally up to 5 years after closure to address legal, regulatory, and anti-fraud obligations.
 - KYC/AML records: Typically retained for 5 years from the date of last transaction or account closure, subject to applicable law.
 - Payment and transaction records: 5-7 years for auditing, tax, accounting, and AML purposes.
 - Technical logs and security events: 12-24 months, unless needed longer for investigations or legal purposes.
 - Marketing data: Until consent is withdrawn or after 24 months of inactivity, whichever occurs first.
 - Cookies: Session cookies expire on logout/close; persistent cookies typically 3-24 months (see Cookie settings).
 - Deletion criteria: Expiry of retention period, withdrawal of consent where applicable, successful objection, or when purposes end and no legal obligation requires further retention.
 
Your Rights
Observe: Outline rights under Canadian law; align with GDPR and Mexican frameworks. Expand: Provide procedures and timelines. Reflect: Ensure clarity and free-of-charge assurance.
- Canada (PIPEDA and provincial laws): Access your personal information; request corrections; withdraw consent (subject to legal/contractual limits); request information about our policies and practices; challenge compliance. Quebec Law 25 adds rights related to automated decision-making explanations and data portability in certain cases.
 - GDPR alignment (EEA/UK residents): Rights to access, rectification, erasure, restriction, portability, objection (including to profiling/marketing), and to not be subject to solely automated decisions producing legal effects, subject to exceptions.
 - Mexico (LFPDPPP): ARCO rights-Access, Rectification, Cancellation, and Opposition-plus withdrawal of consent and limitation of use/disclosure, subject to legal exceptions.
 - How to exercise: Submit a request to [email protected] or via your account. We may require identity verification. Indicate the right(s) you wish to exercise and relevant details to locate your data.
 - Timelines and fees: We aim to respond within 30 days. Requests are free of charge unless manifestly unfounded or excessive, in which case a reasonable fee or refusal (with reasons) may apply.
 - Marketing withdrawals: Use the "unsubscribe" link in emails or adjust preferences in your account. Withdrawing marketing consent does not affect service messages.
 
Cookies & Tracking Technologies
Observe: Classify cookies. Expand: State purposes and controls. Reflect: Provide practical management options.
- Types: 
    
- Session cookies: essential, expire when you close your browser.
 - Persistent cookies: remain for a set period for preferences, analytics, or advertising.
 - Third-party cookies/SDKs/pixels: analytics, anti-fraud, and advertising partners.
 
 - Purposes: 
    
- Functional: login, security, load balancing, preferences.
 - Analytics: usage metrics, performance, diagnostics.
 - Advertising/personalization: tailored offers and measurement (with consent where required).
 
 - Controls: Manage via your browser settings and the "Cookie Settings" link in our site footer (where available). Blocking certain cookies may impact functionality.
 
Data Security
Observe: Describe safeguards. Expand: Cover technical, organizational, and vendor measures. Reflect: Avoid over-claiming certifications.
- Encryption: TLS 1.2+ for data in transit; industry-standard encryption (e.g., AES-256) for data at rest where applicable.
 - Access controls: Role-based access, least-privilege, MFA for administrative access, network segmentation, key management.
 - Secure development: SDLC with code reviews, dependency scanning, and vulnerability management; change control and segregation of environments.
 - Monitoring and testing: Logging and alerting, periodic penetration tests, regular security assessments and audits.
 - Staff and process: Background checks where lawful, confidentiality agreements, and recurring security/privacy training.
 - Standards: Controls aligned with recognized frameworks (e.g., ISO/IEC 27001). We require key vendors to maintain appropriate certifications such as SOC 2 or ISO 27001 where relevant.
 - Incidents: We maintain incident response procedures and will notify affected individuals and regulators as required by applicable law.
 
Complaints & Contacts
Observe: Provide clear channels and escalation. Expand: Include Canadian, EU, and Mexican authorities. Reflect: Set expectations and timelines.
Contact sesame
- Data Protection Team (primary): [email protected]; Tel: +359 2 493 0008.
 - Online: Use on-site support/live chat when available at sesame-ca.com.
 - Postal: If you require postal submission, contact us by email to obtain the current address and reference "Privacy request."
 
Complaint procedure
- Submit your concern to us with details and any supporting information.
 - We acknowledge receipt and investigate. We strive to respond within 30 days.
 - If unresolved, you may escalate to a supervisory authority (see below).
 
Supervisory authorities
- Canada (OPC): Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, QC K1A 1H3; Tel: 1-800-282-1376; priv.gc.ca.
 - EU (if GDPR applies): You may contact your local authority or our EU regulator. Bulgaria: Commission for Personal Data Protection (CPDP), 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria; Tel: +359 2 915 3580; cpdp.bg. EU authority list: edpb.europa.eu.
 - Mexico (LFPDPPP): Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI); inai.org.mx.
 
Updates
Observe: Describe how we notify changes. Expand: Provide timing, method, and options. Reflect: Track versioning for transparency.
- Notification methods: We will post updates on this page and, for material changes, provide additional notice via e-mail, account notifications, and/or a prominent site banner.
 - Advance notice: For material changes that reduce your rights or expand processing purposes, we will provide at least 30 days' advance notice where legally required.
 - User options: You may review changes, adjust preferences, withdraw marketing consent, or close your account if you do not agree with the updated terms.
 - Version control: Last updated: October 2025. Material changes since the prior version: clarified international transfer safeguards; added Quebec Law 25 references; expanded ARCO rights alignment.