Privacy Policy

1. Who We Are

WinnipegSpirit ("we", "our", "the Platform") is a free-to-play social entertainment website operated at returnframe.com. We do not facilitate real-money gaming of any kind. All Spirit Coins are fictional play tokens with no monetary value.

2. Data We Collect

Because WinnipegSpirit requires no account registration, we collect minimal data:

• Browser storage (localStorage / cookies): We save your age-verification flag, cookie consent choice, current Spirit Coins balance, and preferred stake level. This data never leaves your device unless you explicitly share it.
• Analytics (optional): If you consent to analytics cookies, we may collect anonymised usage events (pages visited, session duration) via Google Analytics. No personally identifiable information is linked to these events.
• Server logs: Our hosting provider automatically records your IP address and browser type in standard server logs. These are retained for up to 30 days for security and debugging purposes.

3. How We Use Your Data

We use collected data solely to:

• Remember your consent choices and age confirmation across page visits.
• Maintain your Spirit Coins balance during your session.
• Improve the Platform through anonymised analytics (consent required).
• Identify and fix technical errors via server logs.

We do not sell, rent, or trade your data to third parties for marketing purposes.

4. Legal Basis for Processing

Under applicable Canadian privacy law (PIPEDA) and, where relevant, GDPR, our legal bases are:

• Legitimate interest: Server logs and essential cookies necessary to operate the Platform.
• Consent: Analytics and personalisation cookies — you may withdraw consent at any time via the cookie preferences panel.

5. Cookies and Tracking

We use first-party cookies and localStorage for essential functionality. Optional analytics cookies are only placed with your explicit consent. See our full Cookie Policy for a detailed breakdown.

6. Third-Party Services

If analytics consent is granted, data may be processed by Google LLC (Google Analytics 4) in accordance with Google's privacy policy. WinnipegSpirit has no other third-party data-sharing agreements.

The Platform loads the Bootstrap CSS grid library from jsDelivr CDN. jsDelivr may log your IP for security purposes; consult jsDelivr's privacy policy for details.

7. Data Retention

Browser-stored data (localStorage / cookies) persists until you clear your browser storage or the cookie expires (12 months). Server logs are retained for up to 30 days. Anonymised analytics data may be retained for up to 26 months as configured in Google Analytics.

8. Your Rights

You have the right to access, correct, or delete any personal data we hold. Since WinnipegSpirit stores almost all data locally in your own browser, you can exercise these rights directly:

• Clear browser data: Deletes all locally stored Spirit Coins, consent flags, and session data.
• Opt out of analytics: Use the cookie preferences panel (🍪 button) at any time.
• Contact us: Email [email protected] for any server-side data requests.

9. Children's Privacy

WinnipegSpirit is intended for individuals aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a minor has used the Platform, please contact us immediately so we can delete any associated records.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the Platform after changes constitutes acceptance of the updated policy.

11. Contact

For privacy-related enquiries: [email protected]