Privacy Policy
This policy explains how Hollycorn N.V., trading as Neospin Casino ("we", "us", "our"), collects, uses, discloses and protects personal information about Australian users of neospin.io and related domains. It is aligned with the Australian Privacy Principles (APP) under the Privacy Act 1988 (Cth).
Effective date: as shown in the footer.
1. Scope and Definitions
1.1 This policy applies to all users in Australia who access our services. "Personal information" has the meaning given in section 6 of the Privacy Act 1988.
1.2 Where you interact with third-party services linked from our platform (game studios, payment providers), their own privacy notices apply to that interaction.
2. Information We Collect
2.1 Account data: name, date of birth, residential address, email, mobile number, account password (hashed).
2.2 Identity verification (KYC) data: government ID, proof of address, proof of source of funds where required by AML rules.
2.3 Financial data: payment method identifiers, transaction history, AU$ balances. Full card numbers are processed by PCI DSS-certified providers and not stored on our systems.
2.4 Behavioural data: game sessions, wagering history, bonus activity, device and IP, browser fingerprint elements used for fraud and RG monitoring.
2.5 Support data: chat transcripts, email correspondence, attached documents.
3. Purposes and Legal Bases
3.1 We use personal information to: (a) provide the services and process transactions; (b) verify identity, age and source of funds; (c) detect fraud, money-laundering and bonus abuse; (d) comply with our licence obligations and applicable law; (e) deliver responsible gambling tools and interventions; (f) communicate service updates; (g) deliver promotional content where you have opted in.
3.2 Lawful bases under APP 3 include performance of contract, compliance with legal obligations and consent (for marketing and non-essential cookies).
4. Disclosure to Third Parties
4.1 We disclose personal information to: payment processors, KYC/AML providers, game studios for fraud and game-fault investigation, cloud hosting and analytics providers, our regulator (Curaçao GCB) and law enforcement on lawful request.
4.2 We do not sell personal information.
5. Cross-Border Data Transfers
5.1 Personal information may be processed outside Australia, including in the European Union, the United Kingdom and Curaçao.
5.2 In line with APP 8, we take reasonable steps to ensure overseas recipients handle personal information consistently with the APPs, through contractual safeguards or equivalent legal frameworks.
6. Security Measures
6.1 Data in transit is protected by TLS 1.3. Sensitive data at rest is protected by AES-256 encryption.
6.2 Access to personal information inside Hollycorn N.V. is role-based and logged. Production access requires multi-factor authentication.
6.3 We run regular vulnerability scans and engage independent penetration testers at least annually.
7. Retention
7.1 KYC and transaction records are retained for seven years after account closure to satisfy AML record-keeping obligations.
7.2 Marketing data is retained until you withdraw consent or the data becomes inactive for 24 months, whichever is sooner.
7.3 Behavioural and support logs are retained for up to 36 months for fraud and dispute resolution.
8. Your APP Rights
8.1 You may request: access to personal information we hold (APP 12), correction of inaccurate data (APP 13), and a copy of this policy.
8.2 Submit requests to [email protected]. We respond within 30 days. Identity verification may be required before we release information.
9. Cookies and Analytics
9.1 We use first-party session cookies essential to authentication and security.
9.2 Analytics and marketing cookies require your consent through our cookie banner. You can withdraw consent at any time via the Cookie Preferences link in the footer.
10. Children
10.1 Our services are restricted to persons aged 18 or over. We do not knowingly collect data from minors. Suspected underage accounts are closed and balances reviewed under our AML policy.
11. Changes
11.1 We may update this policy. Material changes are notified by email and a banner on the platform 14 days before they take effect.
12. Contact and OAIC Complaints
12.1 Privacy queries: [email protected].
12.2 If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by phoning 1300 363 992.