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Privacy Policy

Neospin.games is committed to protecting your privacy and ensuring the security of your personal information when you use our online gaming services. This Privacy Policy explains how we collect, use, share, and protect your personal data. It applies to all players and website visitors accessing neospin.games from Australia and is effective as of 1 January 2025.

Who We Are

OBSERVE: The legal entity operating neospin.games is Hollycorn N.V., registered in Curaçao with registration number 144359, holding Online Gaming License OGL/2023/176/0095 granted by the Curaçao Gaming Control Board and valid until 31 December 2025. Our registered and business address is Scharlooweg 39, Willemstad, Curaçao. For privacy and data protection matters, please contact our Data Protection team via [email protected] or [email protected].

  • Legal entity: Hollycorn N.V., Scharlooweg 39, Willemstad, Curaçao (Registration No. 144359)
  • License: OGL/2023/176/0095, Curaçao Gaming Control Board, valid to 31 December 2025
  • Contact for privacy matters: [email protected]

What Personal Data We Collect

OBSERVE: We collect information directly from you and via technology to provide and improve our services. EXPAND: Data collected depends on your interactions with our site and regulatory requirements. REFLECT: Collection ensures compliance with Australian, international, and anti-fraud regulations.

  • Personal identification data: Full name, date of birth, residential address, email address, phone number, identification documents (as needed for verification/KYC).
  • Technical data: IP address, device identifiers, browser type, operating system, access times, source URLs, log information, and device geolocation (where permitted).
  • Payment and transactional data: Payment card or e-wallet details, transaction history, account balances, withdrawal and deposit records.
  • Behavior and usage data: Game selections, betting history, navigation clicks, session duration, user preferences.
  • Cookies and similar technologies: Session cookies, persistent cookies, third-party analytics and marketing cookies (details in 'Cookies & Tracking Technologies').

Legal Basis for Processing

OBSERVE: Processing of personal data is governed by Australian Privacy Principles, gambling regulations, and industry best practice. EXPAND: Legislative obligations require explicit grounds for data use. REFLECT: Each data processing activity is lawfully justified and monitored for ongoing compliance.

  1. User consent: We collect and process data with your explicit agreement for account registration, marketing communications, and optional features. You may withdraw consent at any time for non-mandatory processing.
  2. Contractual necessity: Processing is necessary to execute our agreement with you, including facilitating gaming activities, executing payments, and providing customer support.
  3. Legal obligations: We process data to meet statutory requirements, including Know-Your-Customer (KYC), Anti-Money Laundering (AML) checks, tax compliance, and mandatory recordkeeping as required by both Curaçao and Australian regulation.
  4. Legitimate interests: Data is processed to ensure platform integrity, prevent fraudulent activity, maintain IT security, and analyse service usage for technical enhancement, provided such processing does not override your rights and interests.

Regional Compliance Note: All processing conforms to the Australian Privacy Act 1988 (Cth) and Interactive Gambling Act 2001, including registration, retention, and consent management obligations.

Purpose of Processing

OBSERVE: Personal data is used exclusively for the legitimate conduct of gaming operations and compliance. EXPAND: We clearly define each processing purpose to ensure transparent information handling. REFLECT: Purposes are regularly reviewed for legal adequacy and proportionality.

  • Service provision: Registering user accounts, verifying identities, enabling gameplay, processing deposits and withdrawals, and providing customer support via [email protected].
  • Service improvement: Monitoring site performance, personalising user experience, and enhancing platform features based on analytics insights.
  • Marketing and communication: Sending promotional emails and notifications, subject to your consent, including newsletters and bonus offers.
  • Compliance and fraud prevention: Detecting and investigating suspicious or unlawful activity, fulfilling KYC/AML requirements, and reporting to licensing or regulatory authorities as required.
  • Analytics: Analysing user behaviour, site usage, and transactional patterns for risk management, business operations, and legal auditing.

Disclosure & Sharing

OBSERVE: Data may be shared with third parties in limited, regulated circumstances. EXPAND: Transfers are subject to contractual and legal safeguards. REFLECT: We maintain strict controls to protect your privacy and only disclose information for clearly specified purposes.

  1. Payment partners and financial institutions: Data necessary for processing your payments, refunds, verifications, and chargebacks.
  2. Service providers and contractors: IT service providers, analytics providers, game developers, and affiliates that act on our behalf under strict confidentiality obligations.
  3. Regulatory authorities: Compliance with requests, audit, reporting, and investigations required by Curaçao or Australian authorities, or as required by law.
  4. Marketing and advertising partners: With your consent, selected partners may access specific data for the purposes of direct marketing or targeted advertising.
  5. Corporate transactions: In the event of mergers, acquisitions, or other business restructuring, user data may be transferred, but only as strictly permitted by law.

Protective clause: All third parties are contractually required to process your data in accordance with privacy, security, and legal requirements equivalent to those described in this Policy.

International Transfers

OBSERVE: Your information may be transferred and processed outside Australia, most commonly to Curaçao, where our headquarters and primary data processors are located. EXPAND: Such transfers are required for effective service provision. REFLECT: We implement robust contractual protections to safeguard your data abroad.

  • Destinations: Curaçao (headquarters), European Economic Area (via technical partners), and other countries as required for support or technical operations.
  • Protection measures: All data transfers are governed by appropriate legal mechanisms, including Standard Contractual Clauses (SCCs), inter-company agreements, and ongoing due diligence of third-party processors to ensure data protection commensurate with Australian standards.
  • Notification clause: Users will be informed if data is transferred to any jurisdiction with materially different privacy frameworks or if the scope of processing materially changes.

Regional Compliance Note: Transfers are compliant with Australian Privacy Principle 8 and subject to ongoing assessment to maintain data security equivalence.

Data Retention

OBSERVE: Retention periods are defined by regulatory obligations, business needs, and user requests. EXPAND: Retention minimizes unnecessary data storage. REFLECT: We securely delete or anonymise data when processing purposes expire or are lawfully contested.

  1. Personal account data: Retained for the lifetime of your neospin.games account and up to five (5) years after account closure or last transaction, to meet KYC/AML and audit requirements as per Australian and Curaçao regulations.
  2. Financial and transactional data: Stored for at least five (5) years after relevant transaction or account closure in accordance with anti-money laundering law, after which data is securely destroyed or anonymized.
  3. Cookie and analytics data: Retained for up to two (2) years from collection or until manually deleted by the user.
  4. Deletion requests: Personal data may be deleted upon your verified request except where further retention is required by law or for legitimate dispute resolution.

Protective clause: Data will not be retained longer than necessary for the purposes identified or required by law. Deletion will occur securely using industry-standard data sanitisation methods.

Your Rights

OBSERVE: Under Australian law and international best practice, users are granted actionable privacy rights. EXPAND: We provide mechanisms to enable you to exercise your rights efficiently. REFLECT: Responsive procedures are in place for all user privacy requests.

  • Access: Obtain confirmation as to whether your personal data is processed and to receive a copy thereof.
  • Correction: Request rectification of inaccurate or incomplete information held about you.
  • Erasure ("Right to be Forgotten"): Request deletion of personal information unless retention is necessary for compliance or dispute resolution.
  • Restriction: Request limitation of processing under certain circumstances (e.g. while a dispute is assessed).
  • Objection: Object to the processing of your data for direct marketing or on grounds relating to your situation, except where legally required.
  • Portability: Request your data in a structured, commonly used, and machine-readable format for transmission to another service provider where technically feasible.
  • Withdrawal of consent: At any time, you may withdraw your consent for optional data processing such as marketing communications.

Exercise of rights: You may exercise these rights by contacting [email protected]. Verification of your identity may be required to prevent unauthorized access.

Cookies & Tracking Technologies

OBSERVE: Neospin.games uses cookies and related technologies to enhance your experience and optimise site performance. EXPAND: Use of cookies is governed by privacy and consumer protection laws in Australia. REFLECT: Cookie usage is clearly disclosed, and management tools are provided for user control.

  • Session cookies: Temporary files that enable site navigation and authenticate user sessions, automatically deleted after you close your browser.
  • Persistent cookies: Retained on your device to remember preferences, facilitate login, and enable faster access on return visits. Typically expire after up to 2 years unless manually deleted.
  • Third-party cookies: Deployed by analytics and marketing partners (e.g., Google Analytics) to collect anonymised behavioral data and to tailor advertising campaigns. These may be subject to additional privacy requirements.
  • Cookie management: You may manage or disable cookies by adjusting your browser settings or opting out via our internal privacy panel where available. Please note that some site functions may be limited if certain cookies are disabled.

Regional Compliance Note: Consent is obtained for non-essential cookies in accordance with the Australian Privacy Principles and online tracking guidelines.

Data Security

OBSERVE: Neospin.games employs industry-standard security practices to protect your data against unauthorized access, loss, or misuse. EXPAND: Security systems are regularly audited and updated to anticipate evolving threats. REFLECT: Employees and contractors undergo privacy and regulatory training to maintain compliance reliability.

  • Encryption: All personal and financial data are encrypted using SSL/TLS protocols during transmission. Sensitive information at rest is stored with robust encryption technologies.
  • Access controls: Only authorized personnel with a legitimate business need may access your data, and all access is securely logged and regularly reviewed.
  • Physical and logical security: Data centres are protected by layered physical access controls, firewalls, anti-malware systems, and redundancy protocols.
  • Ongoing audits: Regular third-party and internal assessments are performed to identify and remediate any vulnerabilities.
  • Staff training: All staff receive mandatory data protection and privacy training, including obligations under the Australian Privacy Act and relevant gambling regulation.

Complaints & Contacts

OBSERVE: For concerns about your privacy, neospin.games provides accessible contact channels. EXPAND: Complaint mechanisms comply with Australian dispute resolution standards. REFLECT: We commit to transparent and responsive handling of all inquiries.

  1. Submitting a complaint: Email our Data Protection team at [email protected] with your concern or question. Please provide sufficient detail to enable a thorough investigation.
  2. Resolution procedure: We will acknowledge your complaint within 3 business days and seek to resolve all issues within 30 days or as required by law. If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC) or applicable data protection authorities.

Updates

OBSERVE: This Policy may be updated to reflect changes in law, technology, or our business practices. EXPAND: Updates will be published on neospin.games. REFLECT: Significant amendments will be communicated via email or in-site notifications when required.

  • Notification of changes: Users will be notified of material Policy amendments by prominent website notice and, where legally required, via email.
  • Effective date: This Privacy Policy is effective as of 1 January 2025 and was last updated on 1 January 2025.

Regional Compliance Note: All users are encouraged to review this page periodically to ensure continued awareness of their rights and neospin.games' privacy practices.