Privacy Policy

This privacy policy explains how clubhousecasino, accessible exclusively via clubhouse-casino.games, collects, uses, retains, and protects personal information of players and website visitors in accordance with Australian (AU) privacy laws and best practices for the online gambling industry. This policy applies to all users of our website and services. Effective Date: 01 January 2025.

Who We Are

OBSERVE: Identifying the legal operator and its contact structures is fundamental for transparency and regulatory adherence under AU and Curaçao law.

EXPAND: The corporate identity combines Curaçao incorporation with AU market targeting, requiring precise operator details, registration, and clear data protection contact channels.

REFLECT: The following information ensures all users and regulators can identify, verify, and contact the data controller for any privacy concerns regarding clubhousecasino at clubhouse-casino.games:

Legal Entity Name: Dama N.V.
Legal Form: Public limited liability company (N.V.)
Registration Number: 152125
Registered Address: Scharlooweg 39, Willemstad, Curaçao
Gaming License: OGL/2023/174/0082 (Curaçao Gaming Control Board, valid through 2025)
Data Protection Officer (DPO): Contactable via [email protected]
Official Website: clubhouse-casino.games

What Personal Data We Collect

OBSERVE: Data collection is structured around service provision, security, payments, and compliance. AU law and industry standards require clarity and minimization.

EXPAND: Data types span personal, technical, behavioral, and transaction information to facilitate lawful operation, fraud monitoring, and customer experience improvement.

REFLECT: clubhousecasino (clubhouse-casino.games) collects the following categories of personal data:

Personal Data: Full name, date of birth, residential address, email address, phone number, government-issued identification, proof of address, and relevant KYC documents.
Technical Data: IP address, device information (type, OS, browser), geolocation, device identifiers, access times, and activity logs.
Payment Data: Credit or debit card details, e-wallet and other payment method information, transaction history, and withdrawal/payment records.
Behavioral Data: Account activity, betting and gaming history, clickstream data, site navigation patterns, and preferences.
Cookies & Similar Technologies: Session cookies, persistent cookies, analytics cookies, advertising cookies, and device/browser tracking technologies; see "Cookies & Tracking Technologies" below.

Legal Basis for Processing

OBSERVE: AU Privacy Act and anti-money laundering (AML) regulations require explicit legal bases for processing personal data in gambling operations.

EXPAND: Each processing activity is linked to a clearly defined legal justification, aligning with AU law and global industry practices.

REFLECT: clubhousecasino (at clubhouse-casino.games) only processes your personal information on the following legal grounds:

User Consent: We obtain your consent for optional data uses, such as marketing and cookies.
Contract Fulfillment: We process data to establish, manage, and operate your account, process transactions, and provide gaming services.
Legitimate Interests: We use your information to maintain service security, detect fraud, analyze usage, and improve our offerings, only where these interests do not override your rights.
Legal Obligations: Compliance with laws and regulatory obligations, including KYC procedures, AML/CTF requirements, and mandatory reporting to relevant authorities.

Regional Compliance Note: All data processing aligns with AU privacy law and AML best practices effective through 2025.

Purpose of Processing

OBSERVE: The specific purposes for data processing center on core casino operations and legal obligations.

EXPAND: Each purpose is defined to ensure minimum necessary data use, uphold user trust, and support AU regulatory mandates.

REFLECT: Data collected via clubhouse-casino.games is processed for the following explicit purposes:

Service Provision: Creating and managing user accounts, processing deposits and withdrawals, and delivering gaming services.
Legal & Compliance: Conducting KYC/AML verifications, meeting reporting requirements, and monitoring for fraudulent or prohibited activity.
Customer Support: Handling feedback, account inquiries, and dispute resolution.
Improvement & Analytics: Analyzing website and player behaviors to enhance user experience, optimize features, and develop new offerings.
Marketing (with Consent): Sending promotional communications, offers, and service updates via email or allowable channels.
Security & Prevention: Protecting against unauthorized access, abuse, fraud, and cyber threats within the AU regulatory context.

Disclosure & Sharing

OBSERVE: Data sharing must be justified, documented, and limited to necessary partners, in line with AU privacy principles and gambling regulations.

EXPAND: Transparency in third-party data sharing builds user trust and supports legal defensibility in case of investigations or audits.

REFLECT: clubhousecasino (through clubhouse-casino.games) may disclose personal data under strict conditions as follows:

Payment Partners: Financial institutions and processors for handling deposits, withdrawals, and verification, subject to secure processing agreements.
Service Providers: Technical support, cloud hosting, analytics, marketing, and anti-fraud solution providers, bound by confidentiality and data processing contracts.
Regulators & Authorities: Competent authorities in Curaçao or AU, including gaming and financial regulators, in accordance with license OGL/2023/174/0082 and AU compliance.
Affiliates: Trusted affiliates only where necessary, with user consent and transparent terms.
Advertising Networks: Third parties for targeted advertising, only where explicit consent is provided.
Corporate Transactions: In connection with business transfers, mergers, acquisitions, or re-organizations as permitted by law and subject to protective covenants.

International Transfers

OBSERVE: As clubhousecasino is operated from Curaçao targeting AU users, cross-border data flows must meet AU "adequacy" and protection standards.

EXPAND: Use of technical, legal, and contractual safeguards for any international processing is necessary to mitigate data transfer risks.

REFLECT: Personal data may be transferred and processed in Curaçao, EU/EEA, Australia, or other countries where essential service providers are located. All such transfers are subject to:

Standard Contractual Clauses (SCCs): We implement SCCs approved by the European Commission or equivalent contractual protections for non-AU transfers.
Technical Safeguards: Encryption in transit and at rest, controlled access, and secure protocols.
Legal Compliance: Ensuring all third parties handle your data only as authorized, consistent with AU law and our licensing requirements through at least 2025.

Regional Compliance Note: All cross-border transfers are conducted with a commitment to AU privacy standards for gaming operations.

Data Retention

OBSERVE: AU law stipulates retention limits for different data, emphasizing minimal retention post account activity unless longer is mandated by statutory or AML obligations.

EXPAND: Retention schedules are defined for personal, transactional, and support data with delineated deletion procedures.

REFLECT: clubhousecasino's (clubhouse-casino.games) retention policy is as follows:

Personal and Account Data: Retained during the active account period and for up to 5 years after account closure, or as required to comply with legal and AML/CTF obligations through 2025.
Payment and Transaction Data: Retained for periods mandated by financial regulations, typically 5 years.
Behavioral and Analytics Data: Retained for service improvement for up to 2 years unless required longer by law.
Cookies and Technical Data: Retention periods vary by cookie type; see "Cookies & Tracking Technologies" below.

Data may be deleted upon verified user request, expiry of the retention period, or if the original processing purpose no longer applies. When deletion is not technically feasible, data will be securely anonymized where possible.

Regional Compliance Note: Retention aligned with AU AML/CTF Act through at least 2025.

Your Rights

OBSERVE: The Privacy Act 1988 (Cth) and AU OAIC principles grant users specific, actionable rights regarding their data.

EXPAND: Mechanisms for exercising these rights must be accessible, and all requests must be processed promptly in compliance with AU law.

REFLECT: As a user of clubhousecasino (via clubhouse-casino.games), you are entitled to:

Access: Request and receive a copy of the personal information we hold about you.
Correction: Request correction of any inaccurate or incomplete personal information.
Deletion: Request erasure of your data, subject to regulatory or lawful retention requirements.
Restriction: Request restriction or suppression of processing in certain circumstances.
Objection: Object to processing for particular purposes, including direct marketing.
Data Portability: Request to receive your data in a portable format or have it transmitted to another controller where technically feasible.
Marketing Opt-Out: Withdraw your consent for direct marketing communications at any time via provided unsubscribe methods or by contacting [email protected].

All rights requests will be acknowledged and actioned in accordance with AU statutory timelines.

Cookies & Tracking Technologies

OBSERVE: AU law and industry best practice require cookie transparency and user control options, especially with marketing or analytics uses.

EXPAND: Clear categorization and opt-out mechanisms are mandatory to maintain compliance and user trust.

REFLECT: clubhousecasino (via clubhouse-casino.games) uses the following cookies and tracking technologies:

Session Cookies: Enable basic site operation and user authentication for the duration of a browsing session.
Persistent Cookies: Remember login details, preferences, and language choice for enhanced user experience over multiple sessions.
Third-Party Cookies: Analytics cookies (e.g., Google Analytics) for site performance tracking; advertising cookies for personalized marketing, always based on explicit consent.

You can manage or disable cookies through your browser settings or, where available, via our website's internal cookie management panel. Disabling certain cookies may affect service functionality.

Regional Compliance Note: All cookie operations comply with AU regulatory guidance as of 2025.

Data Security

OBSERVE: AU privacy law and the gambling sector require robust technical and organizational measures to safeguard personal information.

EXPAND: Security covers data at rest, in transit, employee access, and breach detection/response as core pillars of risk management.

REFLECT: clubhousecasino (as operated through clubhouse-casino.games) implements the following comprehensive security measures:

Secure Transmission: SSL/TLS encryption is applied to all data exchanges between users and our servers, ensuring confidentiality and integrity.
Encryption at Rest: Sensitive data, including payment and identification documents, is encrypted using industry-standard algorithms when stored.
Access Restrictions: User data access is limited to authorized personnel based on role and necessity, with regular access audits.
Security Audits: Regular technical and organizational security audits are conducted to assess, test, and enhance our systems.
Staff Training: All employees with access to personal data undergo mandatory privacy and security training to comply with AU casino data handling expectations.

These measures are reviewed and upgraded regularly to address evolving threats and comply with prevailing AU security standards through 2025.

Complaints & Contacts

OBSERVE: AU law mandates clear, accessible complaint procedures and DPO contact channels for user privacy concerns.

EXPAND: Effective complaint escalation procedures and multi-channel access promote accountability and user empowerment.

REFLECT: For questions, requests, or complaints about your personal data at clubhousecasino (accessible via clubhouse-casino.games), you may:

Email our DPO/Data Protection Team: [email protected]
Alternative Contacts: [email protected]

All privacy-related communications are acknowledged within five business days and responded to in compliance with AU regulatory timelines. If you are dissatisfied with our resolution, you may raise your concerns directly with the Office of the Australian Information Commissioner (OAIC).

Updates

OBSERVE: Ongoing compliance requires that privacy policies are kept current and users are notified of substantive changes.

EXPAND: Advance notice and easy access to revised versions promote transparency and user trust.

REFLECT: clubhousecasino (as accessed at clubhouse-casino.games) will update this privacy policy as required by changes in law, industry standards, or service modifications. Users will be notified of significant updates via our website, with the revised policy always available at clubhouse-casino.games.

Date of Last Revision: 01 January 2025