Privacy Policy

Account Registration Data

When you register at Casinonic, we collect:

• Identity Information: Full name, username, email address, date of birth, gender;
• Contact Details: Residential address, phone number, preferred communication methods;
• Verification Documents: Government-issued ID, proof of address, financial documentation.

Financial Information

For deposits and withdrawals, we process:

• Payment Details: Bank account information, payment card details, e-wallet credentials;
• Transaction History: Deposit and withdrawal records, payment method preferences;
• Financial Verification: Source of funds documentation, wealth verification when required.

Gaming and Usage Data

During your gaming sessions, we automatically collect:

• Gameplay Statistics: Games played, session duration, betting patterns, win/loss records;
• Technical Information: IP address, device type, browser information, operating system;
• Website Interaction: Pages visited, click patterns, feature usage, login/logout times.

Communication Records

We maintain records of:

• Support Communications: Live chat transcripts, email correspondence, phone call recordings;
• Marketing Preferences: Consent for promotional materials, communication channel preferences.

Responsible Gaming Information

To promote safe gambling, we collect:

• Self-Assessment Data: Responsible gaming questionnaire responses;
• Behavioral Patterns: Gaming frequency, spending patterns, risk indicators;
• Account Limits: Self-imposed limits on deposits, losses, or session time.

Service Delivery

Primary Uses:

• Account creation and management;
• Processing deposits and withdrawals;
• Providing gaming services and customer support;
• Ensuring fair play and game integrity.

Legal and Regulatory Compliance

Required by Law:

• Anti-Money Laundering (AML): Identity verification, transaction monitoring, suspicious activity reporting;
• Know Your Customer (KYC): Age verification, identity confirmation, source of funds validation;
• Responsible Gaming: Problem gambling detection, self-exclusion enforcement;
• Regulatory Reporting: Compliance with gaming authority requirements.

Business Operations

Legitimate Business Interests:

• Fraud Prevention: Account security, bonus abuse detection, transaction monitoring;
• Risk Management: Player profiling, credit assessments, security threat analysis;
• Service Improvement: Website optimization, game recommendations, user experience enhancement.

Marketing Communications

With Your Consent:

• Promotional offers and Casinonic bonuses;
• New game announcements;
• Company news and updates;
• Partner promotions (from trusted gaming providers).

Opt-Out Options: You can withdraw marketing consent at any time through your account settings or by contacting support.

Data Analytics and Profiling

We use automated systems to:

• Risk Assessment: Evaluate account security and compliance risks;
• Personalization: Customize gaming experience and recommendations;
• Business Intelligence: Generate statistical insights (using anonymized data).

Human Oversight: All significant automated decisions are reviewed by our staff before implementation.

Within Our Corporate Group

We may share your information with other Dama N.V. entities for:

• Consolidated customer support;
• Fraud and bonus abuse prevention;
• Regulatory compliance across all brands;
• Cross-platform promotional offers (with your consent).

Essential Service Providers

Game Providers: Username and IP address shared to deliver gaming content
Payment Processors: Financial information necessary for deposit/withdrawal processing
Verification Services: Identity documents for KYC/AML compliance
Communication Platforms: Contact details for customer support and marketing

Regulatory and Legal Authorities

We may disclose information when:

• Required by law or court order;
• Requested by gaming regulatory authorities;
• Necessary for AML/counter-terrorism compliance;
• To protect our legal rights or public safety.

Marketing Partners

With your explicit consent, we may share contact information with:

• Email marketing service providers;
• SMS communication platforms;
• Direct mail distribution services;
• Telemarketing agencies (for promotional calls).

Data Protection Standards: All third parties must meet strict security requirements and process data only according to our instructions.

Active Accounts

While your account remains active, we retain all necessary data to provide services and ensure compliance.

Closed Accounts

After account closure, retention periods vary by data type:

Financial Records: 5 years minimum (required by AML regulations)
Identity Documents: 5 years after account closure
Transaction History: 5 years for regulatory compliance
Communication Records: 3 years for legal protection
Marketing Data: Deleted immediately unless required for legal purposes
Technical Logs: 1 year for security and fraud prevention

Legal Requirements: Some data must be retained longer to comply with gaming licenses, tax obligations, or legal proceedings.

Anonymized Analytics: We may retain anonymized statistical data indefinitely for business intelligence purposes.

Right of Access

What: Request copies of all personal data we hold about you
How: Contact our DPO via email or support ticket
Timeline: Response within 30 days
Cost: Free (additional copies may incur reasonable fees)

Right to Rectification

What: Correct inaccurate or incomplete information
Requirements: You may need to provide supporting documentation
Limitations: Cannot change information required for regulatory compliance

Right to Erasure (“Right to be Forgotten”)

What: Request deletion of your personal data
Limitations: Cannot delete data required by legal obligations (e.g., 5-year AML retention)
Timeline: Immediate deletion where legally permissible

Right to Data Portability

What: Receive your data in a structured, machine-readable format
Scope: Data provided with consent or for contract performance
Format: Common file formats (CSV, JSON, PDF)

Right to Object

Grounds: Object to processing based on legitimate interests
Marketing: Automatic opt-out from all promotional communications
Profiling: Challenge automated decision-making

Right to Restrict Processing

Scenarios:

• Disputing data accuracy;
• Processing is unlawful but deletion is not desired;
• Data needed for legal claims;
• Pending objection assessment.

Right to Withdraw Consent

Marketing Communications: Instant opt-out via account settings
Optional Services: Withdraw consent for non-essential features
Note: Cannot withdraw consent for data required by legal obligations

Right to Complain

Supervisory Authorities: File complaints with your local data protection authority
Internal Complaints: Contact our DPO for grievance resolution

Technical Safeguards

Encryption: All sensitive data encrypted in transit and at rest using industry-standard protocols
Access Controls: Multi-factor authentication, role-based access, regular access reviews
Network Security: Firewalls, intrusion detection, secure communication channels
Data Backups: Regular backups with encryption and offsite storage

Organizational Measures

Staff Training: Regular data protection training for all employees
Confidentiality Agreements: All staff sign comprehensive NDAs
Incident Response: Established procedures for data breach detection and response
Regular Audits: Third-party security assessments and penetration testing

Account Security

Your Responsibilities:

• Use strong, unique passwords;
• Enable two-factor authentication when available;
• Never share account credentials;
• Report suspicious activity immediately;
• Keep contact information current.

Breach Notification

In the unlikely event of a data breach:

• Regulatory Notification: Within 72 hours to supervisory authorities;
• Customer Notification: Within 30 days if high risk to your rights;
• Remedial Actions: Immediate steps to contain and resolve the breach.

Current Practices

Limited Use: We generally avoid fully automated decisions affecting your rights
Human Oversight: Significant automated decisions are reviewed by qualified staff
Transparency: When automated decisions are used, we provide explanation of the logic involved

Automated Systems in Use

Fraud Detection: Algorithmic assessment of suspicious transactions (reviewed by analysts)
Responsible Gaming: Automated flagging of concerning gambling patterns (reviewed by specialists)
Bonus Eligibility: Algorithmic assessment of promotional offer eligibility
Risk Scoring: Automated risk assessment for AML purposes

Your Rights Regarding Automated Decisions

• Request human review of automated decisions;
• Express your perspective on automated assessments;
• Challenge automated decisions that significantly affect you.

Sensitive Information

We may occasionally process sensitive data categories:

Health-Related Data: Information related to gambling addiction or self-exclusion requests
Ethnic Origin: May be apparent from identity documents (not actively collected)

Enhanced Protections

• Explicit consent obtained when required;
• Restricted access to authorized personnel only;
• Enhanced security measures applied;
• Regular review of necessity and proportionality.

Notification of Changes

Significant Updates: Email notification to all active users
Minor Changes: Website notice and updated policy date
Legal Requirements: Immediate implementation with appropriate user notice

Your Continued Consent

Continued use of our services after a policy update constitutes acceptance of the revised terms and conditions.

Version Control

We maintain records of all policy versions to ensure transparency and compliance.

Applicable Law

This Privacy Policy is governed by the laws of Curaçao and applicable European Union data protection regulations.

Dispute Resolution

Primary Contact: Data Protection Officer ([email protected])
Escalation: Curaçao Gaming Control Board
EU Residents: Local supervisory authority in your country of residence