1. Introduction

This Privacy Policy explains how the Casino ("we," "us," "our") collects, uses, discloses, and safeguards personal data in connection with your use of our website and services, in line with applicable data protection law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the General Data Protection Regulation (GDPR).

The Website is intended only for individuals aged 18 and over. Personal data is not knowingly collected from anyone under that age; if we discover that we have done so inadvertently, we will take appropriate steps to address it in line with applicable law.

2. Who We Are

The Website is owned and operated by Novatrix SRL, incorporated under the laws of Costa Rica, registration number 3-102-893958, registered in Province 03 of Cartago, County 07 of Oreamuno, Potrero Cerrado, North Side of Manuel Ávila Camacho School, Costa Rica. As the entity that determines how and why your data is processed, we act as the Data Controller.

A Data Protection Officer (DPO) is designated to oversee compliance with this Policy and to handle questions, rights requests, or complaints relating to personal data, reachable through the Casino's designated privacy contact channel.

3. Personal Data We Process

We process the following categories of data to deliver our services, meet legal obligations, and maintain a safe gaming environment:

• Identity Data: full name, username, date of birth, gender, nationality, and identification numbers.
• Contact Details: residential address and proof of address, email address, phone number, and other means of communication you provide.
• Financial Data: bank account and payment card details, and documentation confirming the source of funds or wealth.
• Transaction Data: details of your deposits, withdrawals, and other financial activity.
• Gaming Data: the games you play, login and logout times, wagering activity, bonuses claimed, and your history of responsible gaming measures.
• Technical Data: IP address and location data, login information, browser type and version, time zone, operating system, and platform.
• Marketing and Communication Data: your marketing preferences and communications with us.

We may also process any other data you provide during your interactions with us.

4. Why We Process Your Data

• Service Delivery: managing your account, processing transactions, verifying identity, and responding to enquiries, on the basis that this is necessary to perform our contract with you.
• Legal Compliance: meeting anti-money laundering (AML), Know-Your-Customer (KYC), responsible gaming, and regulatory reporting obligations, on the basis of legal obligation.
• Fraud Prevention and Risk Management: detecting and preventing fraud, bonus abuse, and unauthorised activity, on the basis of our legitimate interest in protecting the business and our players.
• Marketing and Personalisation: sending promotional communications and personalised offers, based on your consent and/or our legitimate interest.
• Analytics and Improvement: understanding website usage, resolving technical issues, and improving the user experience, based on legitimate interest.
• AI-Assisted Customer Communication: using third-party conversational AI tools to support and streamline customer messaging, based on legitimate interest.
• Security: monitoring and strengthening platform security, based on legitimate interest and legal obligation.

5. Where Your Data Comes From

We collect personal data directly from you when you register, play, or communicate with us; from identity, age, and address verification providers; from the financial institutions and payment providers that process your transactions; from anti-money-laundering and politically-exposed-person databases; from regulatory authorities and responsible gaming registers; and, in pseudonymous form, from affiliate, advertising, and analytics partners.

6. Who We Share Your Data With

Personal data may be shared with:

• Group companies, for fraud prevention, bonus abuse, AML, and responsible gaming purposes, and, with your consent, for marketing about other products within the group.
• Game providers, who may need limited data such as your username or IP address to deliver games on our platform.
• Payment providers, to process your transactions.
• Marketing partners, where you have consented to receive promotional communications.
• Regulatory authorities, where required by law; we will challenge requests that appear unreasonable or overly broad.
• Communication software providers, including conversational AI providers acting as data processors, to support customer service and messaging.
• AML and KYC verification tools, to meet our compliance obligations.
• Any party involved in a business transfer, such as a merger or acquisition, with notice given to you in advance where reasonably possible.
• Our own advisors and data processors, such as lawyers and consultants, under appropriate data processing agreements.

Third parties are required to process your data lawfully, securely, and only for the purpose for which it was shared; we do not permit them to use it for their own separate purposes, and we limit what is shared to what each purpose requires.

7. International Data Transfers

Where personal data is transferred outside the European Economic Area, appropriate safeguards are applied, such as Standard Contractual Clauses approved by the European Commission, or transfers to jurisdictions recognised as offering an adequate level of data protection.

8. How Long We Keep Your Data

Data is retained only as long as necessary for the purpose it was collected for, taking into account applicable legal requirements, the nature of the data, and the risks associated with retaining or disposing of it. Anti-money laundering rules require personal data to be kept for a minimum of five years following account closure, and erasure requests cannot be honoured before that period ends. Anonymised data may be retained beyond this point for service improvement and marketing analysis, without any automated decision-making involved.

9. Your Rights

By using our services, you consent to the collection, use, and disclosure of your personal data as set out in this Policy. Subject to applicable law, including GDPR and PIPEDA, you have the right to withdraw consent, to access, correct, or request deletion of your data, to restrict or object to processing, to request data portability, to opt out of marketing, and to lodge a complaint with a data protection authority if you believe your rights have been infringed.

10. Automated Decision-Making

We do not generally rely on fully automated decision-making. Where this is used in specific circumstances, you will be informed separately where the law requires it.

11. Data Security

Reasonable technical, physical, and administrative safeguards are maintained to protect your data against loss, theft, or unauthorised access, and information is exchanged over secure connections. Access is limited to those who need it for legitimate business purposes. Your account is protected by a unique login and password, and two-factor authentication is available for additional security; keeping your login details confidential is your responsibility.

12. Changes to This Policy

This Policy may be updated as technology and legal requirements evolve. We encourage you to review it periodically.

13. Contact

Questions about this Policy, or requests relating to your personal data, can be directed to our Data Protection Officer through the Casino's designated privacy contact channel.