LAST UPDATED: January 1, 2026

This Privacy Policy describes the manner in which TS Programs Ltd. and its affiliates (collectively, "The High Roller Club", “we”, “our”, “us”) use information in operating our business, our websites, our mobile and other software applications (each, an “app”), and any other online services that displays or provides an authorized link to this Privacy Policy (collectively, our “Services”).
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES.

We reserve the right to update this Privacy Policy at any time to reflect changes in our privacy practices without prior notice to you. When the Privacy Policy is updated, we will update the date at the top of this page to indicate the date last updated, and the revised version will be effective as of the published effective date and will be posted on each of the websites owned or controlled by us. If we make what we regard to be significant changes to this Privacy Policy, we will provide appropriate notice to you.
Please check this Privacy Policy periodically for changes. Your continued use of our Services following the posting of changes to the Privacy Policy will mean you agree to be bound by such changes. We will also update the Privacy Policy and our privacy practices to comply with federal and provincial privacy legislation as they each may apply.

Your privacy is important to us. Although our ability to provide certain service requires that we collect Personal Information about our users, we take measures to ensure the privacy and confidentiality of that information. We are committed to undertaking reasonable measures to protect the privacy, accuracy, reliability and security of all of the Personal Information that is provided to us and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Please read the following description of our policies and practices regarding your Personal Information.

A. Personal Information
We will only use personally identifiable information about you in accordance with this Privacy Policy. Personally identifiable information is information about you that can be attributed to you, and may include but is not limited to, your name, mailing address, e-mail address, phone number, date of birth, payment information, age, and/or gender, and will be referred to as “Personal Information” in this Privacy Policy. We do not collect sensitive Personal Information, such as racial or ethnic origin or health or medical data through our Services. Personal Information does not include the name, title or business address or telephone number of an employee of an organization.
Our Services have various features and services. All of these features and services are available to all those that have registered with our Services.

B. Collection, Use and Disclosure Practices
Wherever possible, we will identify the purposes for which Personal Information is collected at or before the time the Personal Information is collected. We may use Personal Information for the purpose for which it was provided and for certain other activities, which are reasonably ancillary to such purpose.
We may request Personal Information from you such as name, home address, telephone number, e-mail address, age, income, interests and gender for purposes such as newsletter registration, contests, and participation in other interactive online activities, as well as to enable us to market various goods and services to you.
We may use Personal Information to better understand your needs and preferences; to provide you with information about future events; to recommend particular products and services; and to market goods and services offered by Tokyo Smoke  brand initiatives, and affiliated programs operated by TS Programs Ltd.
We may share information with current or future affiliates, including parent and subsidiary companies, joint venture partners, and organizations under common control.
If you have provided express consent, we may share your Personal Information with select marketing partners whose privacy practices align with this Privacy Policy.
We may engage third-party service providers to assist with operations such as fulfillment, analytics, and communications. These providers are required to adhere to the terms of this Privacy Policy.

C. Cookies, Analytics, and Tracking Technologies
Our Services may use cookies and similar technologies to improve functionality, customize content, and analyze site usage. You may adjust your browser settings to manage cookie preferences; however, doing so may affect Service functionality.
We may use Google Analytics to help analyze usage of our Services. Information generated by cookies may be transmitted to and stored by Google on servers outside of Canada, including the United States, in accordance with Google’s privacy practices.

D. Limiting Collection
We limit the collection of Personal Information to that which is necessary for identified purposes. Certain technical information such as IP address, device type, or usage data may be collected automatically and used in aggregated, anonymized form.

E. Limiting Use, Disclosure, and Retention
We do not use or disclose Personal Information for purposes other than those for which it was collected, except with consent or as required by law. Personal Information is retained only as long as necessary to fulfill its intended purpose or legal obligations.

F. Security Safeguards
Access to Personal Information is restricted to authorized employees and service providers. We employ reasonable physical, technical, and organizational safeguards to protect Personal Information. While we take strong measures, no system can be guaranteed to be completely secure.

G. Access and Correction
You may request access to, or correction of, your Personal Information by contacting us. Certain legal limitations may apply.

H. Children’s Privacy
Our Services are not intended for individuals under the age of 13. We do not knowingly collect Personal Information from children under 13.

I. Third-Party Links
Our Services may contain links to third-party websites. We are not responsible for the privacy practices of those sites.

J. Governing Law

This Privacy Policy is governed by the laws of the Province of Ontario and the applicable laws of Canada.

K. Contact Us

If you have questions about this Privacy Policy or your Personal Information, please contact us at thehighrollerclub@tyosmoke.ca.