Privacy Policy

This Privacy Policy describes how playfina at playfinaz.com collects, uses, discloses, and protects your personal data when you access or use our services. It applies to all players and visitors of playfinaz.com and explains your legal rights under Australian law. Effective date: 1 January 2025. Last reviewed: 15 June 2025.

Who We Are

OBSERVE: playfina operates playfinaz.com under Curaçao law, serving clients in Australia and globally.
EXPAND: The company is Dama N.V., with all relevant registration, licensing, and contact information below.
REFLECT: This ensures identification requirements and accountability under AU and international statutes.

Legal Entity: Dama N.V., registered in Curaçao (Company number: 152125)
Legal Address and Headquarters: Scharlooweg 39, Willemstad, Curaçao
License: Online Gambling License No. OGL/2023/174/0082, issued by Curaçao Gaming Control Board (valid through 2025)
Regional Operations: Australia (service offered to clients in AU), Cyprus (payment processing by Strukin Ltd., as needed)
Primary Contact (Data Protection): Lucas Bennett, Data Protection Representative
Email: [email protected]

Regional Compliance Note: playfina's operations meet AU data protection requirements for digital gambling services, including clear point-of-contact for privacy matters.

What Personal Data We Collect

OBSERVE: Data is obtained directly from you, your devices, and authorized providers.
EXPAND: Capture extends to various data categories required for gaming operation, AML/KYC, technical optimization, and regulatory reporting.
REFLECT: This holistic list meets AU privacy norms and Curaçao licensing demands.

Personal Identity Data: Full name, date of birth, residential address, email address, phone number, identification documents as required for KYC.
Technical and Device Data: IP address, device type, operating system, browser type, time zone, usage logs, language preference, location data (where permitted).
Payment and Financial Data: Credit/debit card details, bank account details, transaction history, crypto wallet information (if used), and payment processor references.
Behavioral Data: Gaming activity (bet amount, wins/losses, game preferences, frequency), visit and clickstream data, support queries.
Cookies and Similar Technologies: Session identifiers, persistent cookies, web beacons, analytics tags, third-party ad cookies (as set out in Cookies section below).

Legal Disclaimer: Supplying certain data is a condition of use and required for compliance with Australian regulatory obligations (including age and identity verification).

Legal Basis for Processing

OBSERVE: Australian Privacy Act and relevant international frameworks require lawful grounds.
EXPAND: Multiple bases are engaged depending on user interaction and regulatory obligations.
REFLECT: Detailed enumeration of all legal grounds sustains lawful and transparent processing.

User Consent: Where required, your consent is sought before processing activities involving optional or marketing data. You may withdraw consent for non-essential processing at any time.
Contract Fulfilment: Processing is necessary for the performance of our contract to provide casino and gaming services, manage accounts, and process payments/withdrawals.
Legal Obligations: We process personal data to comply with anti-money laundering (AML), Know Your Customer (KYC), taxation, and lawful regulatory requests-including AU reporting regimes.
Legitimate Interests: We process data to protect playfina and users against fraud, maintain security, improve our platform, ensure compliance, and analyze service performance. Legitimate interests are always balanced against your privacy rights as required by AU law.

Protective Clause: playfina never relies on legitimate interest for processing that overrides your fundamental rights and freedoms under Australian law.

Purpose of Processing

OBSERVE: Identifies all functional, legal, and commercial objectives for data processing.
EXPAND: Purposes reflect mandatory regulatory, contractual, and operational needs.
REFLECT: Ensures detailed transparency in line with AU privacy policy standards.

Provision of Casino Services: Account registration, user authentication, processing deposits/withdrawals, providing access to games and bonuses, and customer support.
Compliance Operations: AML/KYC checks, responsible gambling monitoring, legal reporting, and age/identity verification.
Improvement & Personalization: Service optimization, technical troubleshooting, user experience customization, product development, and security enhancements.
Marketing Communications: Sending promotional offers, newsletters, and event updates (with user consent; opt-out always provided).
Data Analytics: Aggregating data for performance metrics, business analysis, and market research (using de-identified data where possible).
Fraud Prevention & Risk Management: Detecting and preventing suspicious activity, safeguarding accounts, and ensuring the integrity of platform operations.

Limitations: playfina does not sell or rent your personal data; all processing strictly adheres to stated purposes and AU privacy regulation.

Disclosure & Sharing

OBSERVE: Details all potential recipients of your data.
EXPAND: Disclosure limited to service providers, regulatory authorities, and legally permitted partners.
REFLECT: Demonstrates accountable, controlled data sharing under AU/Curaçao frameworks.

Payment Processing Partners: Banks, credit institutions, Strukin Ltd. (Cyprus) for regional payments, and licensed cryptocurrency processors as required to complete transactions.
Technical Service Providers: iGaming platform vendors, cloud hosts, analytics providers, IT support (under strict confidentiality agreements).
Regulatory Authorities: Disclosure to Curaçao Gaming Control Board, AU authorities, and law enforcement agencies strictly as required by law.
Business Partners and Affiliates: Selected affiliates for marketing or user referral purposes (with documented user consent; opt-out maintained).
Advertising Networks: Certain data (cookies, device IDs) may be shared with trusted advertising partners with your explicit consent.
Legal/Corporate Events: Data may be disclosed in mergers, transfers, or disposals, conditional on adequate privacy safeguards.

Protective Clause: All third-party processors are bound by data protection agreements consistent with AU privacy requirements, including offshore partners.

International Transfers

OBSERVE: Personal data may be transferred outside Australia (e.g., Curaçao, Cyprus, other EEA/approved jurisdictions).
EXPAND: All cross-border transfers subject to protective measures.
REFLECT: Aligns with AU cross-border data flow rules under APP 8 and international best practice.

Countries/Regions of Transfer: Curaçao (headquarters), Cyprus (payment processing by Strukin Ltd.), EEA member states (where necessary) and jurisdictions with established data protection equivalence.
Safeguards: Standard Contractual Clauses (SCCs), intra-group DPA, and technical security standards applied to all international transfers.
User Rights: Where required by AU or EU law, you may request further details of such safeguards at any time.
Exclusions: playfina does not transfer your data to jurisdictions lacking minimum legal safeguards as specified under AU privacy regulations.

Obligation: playfina monitors international transfer arrangements for compliance with Australian and Curaçao law.

Data Retention

OBSERVE: Retention policies specific to each data category and justified under law.
EXPAND: Criteria determined by contract, regulation, industry standards.
REFLECT: Supports right to erasure and minimizes unnecessary data storage.

Personal Account Data: Retained for the duration of your account plus five (5) years after closure or final transaction, consistent with AU Anti-Money Laundering and Curaçao requirements.
KYC and AML Documentation: Held for a minimum of five (5) years after account closure, or longer if mandated by legal or regulatory proceedings.
Payment and Transaction Data: Retained no more than five (5) years after last transaction for audit and anti-fraud:
- Users may request deletion where legally permissible.
Behavioral and Log Data: Stored for up to three (3) years for analytics and platform improvement; anonymized data may be kept longer for statistical purposes.
Marketing Data: Retained until you withdraw consent or unsubscribe from marketing communications.

Deletion Criteria: Data is deleted or anonymized upon account closure, user request (as legally permissible), fulfillment of processing purpose, or through scheduled review at maximum retention threshold.

Your Rights

OBSERVE: Comprehensive enumeration of all actionable rights under AU and relevant international law.
EXPAND: Each right described with practical implications and contact pathway.
REFLECT: Ensures full transparency, accessibility, and fulfillment mechanisms.

Right of Access: You may request confirmation whether we process your personal data, and receive a copy of relevant information in a commonly used format.
Right to Rectification: You may require correction of inaccurate or incomplete personal data.
Right to Erasure ("Right to be Forgotten"): You may request erasure of your personal data where processing is no longer required, legal deadlines have expired, or upon withdrawal of consent (subject to legal data retention obligations).
Right to Restrict Processing: You may ask us to suspend processing of specific data under certain circumstances (e.g. pending a correction).
Right to Object: You may object to specific processing (e.g. direct marketing) at any time.
Right to Data Portability: You may request to receive your personal data in a machine-readable format for transfer to another provider.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time, without effect on processing prior to withdrawal.

Exercise of Rights: Please contact our Data Protection Representative at [email protected] for assistance. We will respond in accordance with AU law.

Cookies & Tracking Technologies

OBSERVE: playfina at playfinaz.com uses cookies and similar technologies for essential operations, analytics, and advertising.
EXPAND: The table below details the types and purposes of cookies used.
REFLECT: Ensures clear information and user control, as required by AU law and best practice.

Type	Purpose	Examples
Session Cookies	Essential for login, user authentication, maintaining session security	User login state, session preference
Persistent Cookies	Remember user choices, device settings, and language across visits	Language, site preferences
Third-Party Cookies	Analytics, advertising, and affiliate tracking by trusted partners	Google Analytics, advertising networks

Cookie Management: You can manage, block, or delete cookies through your browser settings or, where available, the internal cookie preference panel on playfinaz.com.
User Consent: Non-essential cookies are set only with your prior informed consent.
Opt-Out Information: Please consult our Cookies Policy for additional details and opt-out mechanisms.

Data Security

OBSERVE: Security obligations cover technical, physical, and organizational measures.
EXPAND: Aligns with AU cyber security recommendations for gambling platforms.
REFLECT: Demonstrates robust, ongoing commitment to personal data safety.

Encryption & Secure Transmission: All data in transit is protected via SSL/TLS; sensitive data is encrypted at rest.
Access Controls: Personal data access strictly limited to authorized personnel subject to confidentiality obligations.
Network & System Protections: Firewall usage, DDoS mitigation, intrusion detection technologies, and regular vulnerability scanning.
Audits & Compliance: Periodic technical and organizational reviews of data processing activities; compliance monitoring with AU and Curaçao requirements.
Employee Training: Staff receive regular training on data protection principles, cyber security, and incident response.

Protective Clause: While playfina implements state-of-the-art measures, no system can guarantee absolute security; users are encouraged to use strong passwords and monitor account activity.

Complaints & Contacts

OBSERVE: Clear and direct access to complaint procedures and contact methods.
EXPAND: Outlines pathways for data issue resolution and escalation.
REFLECT: Satisfies AU privacy complaint handling requirements.

Data Protection Inquiries: Email all queries, requests, or concerns to Lucas Bennett (Data Protection Representative) at [email protected].
Complaint Handling: Upon receipt of a complaint, playfina investigates and aims to respond within thirty (30) days. If dissatisfied with our response, you may escalate to the Office of the Australian Information Commissioner (www.oaic.gov.au).

Instructions: Please provide specific details and supporting documentation for prompt handling.

Updates

OBSERVE: playfina maintains this Privacy Policy as a living document.
EXPAND: Users will be notified of significant changes by email or on-site notices.
REFLECT: Ensures ongoing compliance with AU and international regulatory environments through 2025.

Notification Method: Changes will be communicated via email (if subscribed) and published promptly on playfinaz.com.
Review Cycle: Policy reviewed semi-annually or as required by changes in law or business operations.
Latest Revision: 15 June 2025. Next scheduled review: January 2025.

Your Responsibility: Users are encouraged to periodically review this Privacy Policy for updates.