Privacy Policy

This Privacy Policy explains how Neo Spin Casino, operated via the website https://neospinbet-au.com, collects, uses, discloses, stores and protects personal information of players and website visitors located in Australia. It applies to all use of our website, registration and use of gaming accounts, participation in promotions, and any other interaction with our services. By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective as of 1 January 2026 and supersedes any earlier versions published on our sites or related mirror domains targeting Australian users.

Who We Are

OBSERVE: Users must know who is responsible for their data and how to contact them. EXPAND: We identify the operating and processing entities and provide practical contact points. REFLECT: This enables transparency and supports the exercise of privacy rights.

The online casino service marketed as Neo Spin Casino and made available via https://neospinbet-au.com (and certain related mirror domains such as neospin.com, neospin1.com and neospin-au.com) is operated under the gaming licence of:

• Operator (licence holder): Hollycorn N.V. (a company incorporated under the laws of Curaçao)
• Parent company: Hollycorn N.V.
• Payment processing subsidiary: Libergos Limited, Cyprus (acting as a payment processing agent for certain transactions)
• Gaming licence: Antillephone N.V. sub-licence number 8048/JAZ2019-015, issued in Curaçao, valid and assumed active through 2026.

Because some corporate registration details and physical addresses are not specified in the materials provided to us, certain corporate and address information is not listed here. This does not limit your rights; you can always request additional corporate identity details through our support channels, and we will provide the most recent information available.

Contact for Privacy Matters

• Data Protection Contact / Data Protection Department:
  E-mail: [email protected]
  Purpose: handling privacy questions, data subject requests, complaints and incident notices.
• Website: https://neospinbet-au.com

Any references in this Privacy Policy to "Neo Spin Casino", "Neo Spin Casino", "we", "us" or "our" refer collectively to Hollycorn N.V. as the controller of your personal information in connection with the operation of neospinbet-au.com for Australian-facing services.

What Personal Data We Collect

OBSERVE: Operation of an online casino requires multiple categories of data for account management, payments, security and compliance. EXPAND: We group data into logical categories to clarify how each type is used. REFLECT: This categorisation supports transparency and facilitates rights management.

1. Identification and Contact Data

• Full name, date of birth, gender (where provided)
• Residential address, country of residence
• E-mail address (including the address linked to your account)
• Telephone number (mobile and/or landline, when provided)
• Identity document details (such as passport, driver's licence, national ID, utility bills, bank statements) used for verification, KYC and anti-money laundering checks.

2. Account and Gameplay Data

• Username, password (stored in hashed form), security questions or authentication factors
• Account registration and status information (e.g., account creation date, verification status, responsible gambling limits)
• Betting and gaming history: game sessions, stakes, wins/losses, jackpot participation, bonuses claimed, wagering progress, tournaments and leaderboard participation
• Interactions with customer support (including chat logs, complaint records, e-mail correspondence).

3. Technical and Usage Data

• IP address, approximate geolocation derived from IP, device identifiers
• Device information (device type, operating system, browser type and version, language settings)
• Log data (access dates/times, pages viewed, clickstream data, URL paths, error logs)
• Session identifiers and similar technical identifiers required to maintain secure sessions and prevent fraud.

4. Payment and Financial Data

• Payment method type (e.g., bank card, e-wallet, voucher, cryptocurrency wallet)
• Limited card or account details as necessary for payment processing (typically tokenised or partially masked)
• Deposit and withdrawal histories, currency, transaction identifiers, payment provider references
• Billing information and financial verification documents for AML/KYC purposes.

5. Behavioural and Marketing Data

• Information about how you use our casino: game preferences, time spent, frequency of visits, click paths
• Participation in promotions, loyalty programs, VIP status and reward history
• Marketing communication preferences (opt-in/opt-out records, channels, languages)
• Responses to marketing campaigns and surveys, including open and click rates.

6. Cookies and Similar Technologies

• HTTP cookies and HTML5 local storage used to maintain your session and choices
• Analytics identifiers (for example, identifiers used by analytics tools to understand website performance)
• Advertising and affiliate tracking identifiers where you access our services through affiliate links or campaigns.

Where local law treats specific types of data (e.g., government-issued ID numbers or certain financial information) as sensitive, we apply additional technical and organisational protections to those categories.

Legal Basis for Processing

OBSERVE: Online casinos must rely on clearly defined legal grounds to process data. EXPAND: We align our practices with widely recognised principles similar to the GDPR and applicable privacy frameworks, while noting Australian privacy expectations. REFLECT: This ensures that each data use can be justified and, where relevant, consent can be withdrawn.

1. Performance of a Contract

We process your personal data where it is necessary to enter into and perform our agreement with you, including to:

• Create, verify and manage your player account on neospinbet-au.com
• Provide access to our games and related services
• Process deposits, bets, wins, withdrawals and bonuses
• Provide customer support and handle your requests or complaints
• Enforce our Terms and Conditions and Bonus Terms as published on neospin.com, as applicable to your account.

2. Compliance with Legal and Regulatory Obligations

We process personal data to comply with obligations arising from:

• Anti-money laundering (AML) and counter-terrorist financing (CTF) regulations applicable to our licensed operations
• Know Your Customer (KYC) and age verification requirements to prevent underage gambling
• Record-keeping, reporting and cooperation obligations towards our licensing authority in Curaçao and other competent regulators or authorities
• Legal obligations to respond to lawful requests by law enforcement, courts or regulators in relevant jurisdictions.

3. Legitimate Interests

We may process your data where this is necessary for our legitimate interests, provided that these interests are not overridden by your rights and freedoms. These interests include:

• Ensuring the security and integrity of our systems, games and accounts
• Detecting, investigating and preventing fraud, abuse, cheating, money laundering or other unlawful or irregular activities
• Performing analytics to improve our website, games, user experience and business operations
• Defending and exercising legal claims or handling disputes
• Managing affiliate relationships and verifying traffic sources, in a privacy-conscious manner.

4. Consent

We rely on your consent where required by applicable law, in particular for:

• Sending direct electronic marketing communications (e.g., email, SMS, push notifications) about our own products, promotions and offers, where local rules require an opt-in
• Using certain non-essential cookies or similar technologies for personalised advertising or detailed behavioural analytics
• Processing particular types of optional information you choose to provide (for example, participation in certain surveys).

You may withdraw your consent at any time using the mechanisms described in this Privacy Policy. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Purpose of Processing

OBSERVE: Understanding why data is processed is key for informed choice. EXPAND: We connect each main casino function with its data uses. REFLECT: This clarification helps players predict and control how their data is used.

1. Provision of Casino Services

• To register and manage your player account on neospinbet-au.com
• To verify your age, identity and eligibility to participate in real-money gambling
• To process deposits, bets, wins, withdrawals and bonus redemptions
• To provide our casino games and related functionalities across desktop and mobile devices
• To provide multi-language support and communicate with you regarding account operations, security alerts and service-related messages.

2. Service Improvement, Personalisation and Analytics

• To monitor website performance, stability and security
• To analyse aggregated gameplay and traffic data in order to improve game offering, UX design, promotions and customer journeys
• To personalise content, recommendations and offers based on your activity and preferences, where permitted
• To gather feedback through surveys and support interactions.

3. Marketing and Promotions

• To send you promotional communications about our games, tournaments, bonuses and loyalty programs, subject to your preferences and applicable consent requirements
• To manage VIP and loyalty schemes, including tailored rewards and account management
• To measure the effectiveness of marketing campaigns and affiliate partnerships.

4. Security, Fraud Prevention and Legal Compliance

• To protect your account, detect unauthorised logins and secure payments
• To detect collusion, bonus abuse, multi-accounting, payment fraud and other prohibited conduct
• To comply with AML/CTF, KYC and other legal obligations
• To respond to legal requests, enforce our Terms and Conditions, and handle disputes or complaints.

Disclosure & Sharing

OBSERVE: Running an online casino requires cooperation with third-party service providers and authorities. EXPAND: We identify the main categories of recipients and conditions under which data is shared. REFLECT: This transparency allows users to understand which parties may access their information.

1. Group Companies and Operational Partners

• Hollycorn N.V. and group entities: Internal processing for account management, risk management, compliance and customer service.
• Libergos Limited (Cyprus): Payment processing, reconciliation and financial operations for deposits and withdrawals on behalf of the operator.

2. Payment Service Providers and Banks

• Banks, card schemes, e-wallet providers, voucher and cryptocurrency payment processors which execute your deposit and withdrawal instructions
• These providers receive only the information necessary to perform the relevant payment service and to comply with their own regulatory obligations.

3. Technical and Business Service Providers

• IT hosting providers, data centres and cloud services
• Game providers and software platforms required to deliver casino content
• Customer support tools, communication platforms and CRM systems
• Analytics services used to understand website performance and usage patterns
• Security, fraud prevention and identity verification providers supporting KYC, AML and risk management.

4. Affiliates and Advertising Networks

• Affiliates who refer players to neospinbet-au.com may receive limited data (such as aggregated performance metrics or anonymised identifiers) to verify commissions.
• Advertising networks or tools may receive cookie identifiers or similar data to provide, measure or limit online advertising, where permitted by applicable law and your cookie/marketing preferences.

5. Regulatory and Public Authorities

• Gaming regulators (including our licensing authority in Curaçao) to demonstrate compliance with licence conditions, AML/CTF requirements and fair gaming rules
• Law enforcement agencies, courts and other governmental bodies where disclosure is required by law, regulation, legal process or to protect our rights, property or safety or that of others.

6. Corporate Transactions

• In connection with a proposed or actual merger, acquisition, reorganisation, sale of assets, or similar corporate transaction involving Hollycorn N.V., personal data may be disclosed to professional advisers and potential counterparties under appropriate confidentiality obligations.

We do not sell your personal information as understood under many data protection regimes. We require all third parties who process personal data on our behalf to implement appropriate security measures and to process personal data only according to our documented instructions and applicable law.

International Transfers

OBSERVE: Our operations and infrastructure are cross-border by nature. EXPAND: We must explain where data may go and which safeguards apply. REFLECT: These measures are intended to maintain an adequate level of protection regardless of the data's location.

1. Locations of Processing

• Your data may be processed in, or transferred to, countries outside your location, including but not limited to Curaçao, Cyprus, member states of the European Economic Area (EEA), and other jurisdictions where our hosting providers, game providers or service partners are located.
• Access from Australia to our services implies that your data may be routed through and stored on servers in such locations.

2. Safeguards for International Transfers

• Where we transfer personal data to service providers or partners in countries that may not provide the same level of data protection as your home jurisdiction, we take steps to ensure that appropriate safeguards are in place.
• These may include:
  • Contractual protections such as standard data protection clauses or equivalent data transfer agreements requiring high standards of privacy and security;
  • Technical measures, including strong encryption in transit and at rest, strict access controls and data minimisation;
  • Organisational measures, such as internal policies, training and access limitations based on role and necessity.

By using our services, you acknowledge that your personal data may be transferred and processed outside of Australia as described, subject to the safeguards outlined in this Privacy Policy.

Data Retention

OBSERVE: We must keep data only as long as needed for defined purposes and legal obligations. EXPAND: Different categories have different retention needs, especially for AML and dispute handling. REFLECT: We define typical periods and explain criteria for deletion or anonymisation.

1. General Retention Principles

• We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, regulatory reporting or dispute-resolution requirements.
• When personal data is no longer required, we will securely delete or irreversibly anonymise it, unless we are legally required to continue storing it.

2. Typical Retention Periods

• Account and identification data: Generally kept for the duration of your active account and typically for up to 5 - 7 years after account closure, to comply with AML/CTF, KYC and record-keeping obligations and to handle potential disputes.
• Payment and transaction records: Typically retained for 5 - 7 years from the date of the relevant transaction, in line with financial regulations and tax or audit requirements.
• Gameplay and betting history: Generally retained for the duration of your active account and up to 5 years after closure for security, fraud prevention, responsible gambling analysis and dispute resolution.
• Marketing data: Retained until you withdraw your consent or object to marketing, after which your data will be placed on a suppression list to ensure that we respect your preferences.
• Technical logs: Stored for periods typically ranging from several months up to 2 years, depending on their importance for security, troubleshooting and legal compliance.

3. Criteria for Deletion or Anonymisation

• Expiration of legal retention periods applicable to gambling, AML or financial records
• Resolution of disputes, investigations or regulatory inquiries that require data retention
• Your request for deletion, where processing is based on consent or where no overriding legal grounds exist to continue processing.

Your Rights

OBSERVE: Players must be able to control and review their personal data. EXPAND: We align our practices with widely recognised data protection frameworks, including rights comparable to those under the GDPR, while acknowledging local requirements. REFLECT: We provide clear procedures, timeframes and cost-free guarantees.

1. Overview of Your Rights

• Right of access: You can request confirmation whether we process your personal data and obtain a copy, together with information about how we use it.
• Right to rectification: You can request correction of inaccurate or incomplete personal data held about you.
• Right to erasure ("right to be forgotten"): You can ask us to delete your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent and no other legal ground exists, or where processing is unlawful. We may retain certain data where legally required (for example, AML/CTF or financial reporting obligations).
• Right to restriction of processing: You can request that we limit processing of your data (for example, while we verify its accuracy or assess an objection).
• Right to object: You may object at any time to processing based on legitimate interests, particularly where related to direct marketing. If you object to marketing, we will stop using your personal data for that purpose.
• Right to data portability: Where technically feasible and applicable, you can request to receive certain personal data you have provided to us in a structured, commonly used and machine-readable format and to have us transmit it to another controller where the processing is based on consent or contract and carried out by automated means.
• Right to withdraw consent: Where processing is based on your consent, you can withdraw it at any time, without affecting prior lawful processing.

2. Exercising Your Rights

1. Submission of request: Send your request by e-mail to [email protected]. Clearly state your identity, the right you wish to exercise and any relevant account details (such as username and registered e-mail address).
2. Verification: For your protection, we may need to verify your identity before acting on your request. We may ask you to provide additional information or documentation consistent with our KYC and security procedures.
3. Response timeframe: We aim to respond to all valid requests within 30 days of receipt. Where a request is particularly complex or numerous, we may extend this period by a further 30 days, and we will notify you of any such extension and the reasons for it.
4. Cost: We will handle your requests free of charge, unless they are manifestly unfounded or excessive (for example, repeated requests). In such cases, we may charge a reasonable fee or refuse to act on the request, in line with applicable law.
5. Limitations: Some rights may be restricted where necessary to protect the rights and freedoms of others, maintain the confidentiality of security measures, or comply with overriding legal obligations (such as AML/CTF requirements or regulatory retention duties).

Nothing in this Privacy Policy limits any rights you may have under applicable privacy or data protection laws in your jurisdiction, including rights analogous to those under the GDPR or similar international frameworks.

Cookies & Tracking Technologies

OBSERVE: Cookies are essential for secure sessions and improved user experience. EXPAND: We distinguish between types and uses of cookies and offer control options. REFLECT: This allows players to make informed choices about tracking while understanding potential impacts on service quality.

1. Types of Cookies We Use

• Session cookies: Temporary cookies that exist only for the duration of your browsing session and are deleted when you close your browser. They help us maintain your logged-in state and keep your session secure.
• Persistent cookies: Cookies stored on your device for a defined period or until deleted. They remember your preferences (such as language, cookie choices) and help us recognise you on return visits.
• First-party cookies: Cookies set directly by neospinbet-au.com for essential, functional, and limited analytics purposes.
• Third-party cookies: Cookies set by external services, such as analytics providers or advertising and affiliate partners, where used. These help us understand traffic sources, campaign performance and, where permitted, may be used for tailored advertising.

2. Purposes of Cookies

• Strictly necessary / functional: Required for the website to function, including log-in, account management, security features and enabling core game functions. These cookies cannot be switched off in our systems.
• Performance / analytics: Used to collect aggregated information about how visitors use our website (e.g., which pages are visited most often, error messages). This helps us improve performance and usability.
• Advertising and affiliate tracking: Used, where permitted, to deliver more relevant advertising and track referrals from affiliate partners. They may help limit the number of times you see a particular advertisement and measure the effectiveness of campaigns.

3. Managing and Disabling Cookies

• You can manage or disable cookies through your browser settings. Most browsers allow you to:
  • View which cookies are stored on your device
  • Delete cookies
  • Block cookies from all or selected websites
  • Set preferences for certain types of cookies.
• Our website may also provide an internal cookie preference panel or banner where you can manage your non-essential cookie settings, when this functionality is available.
• Please note that blocking or deleting certain cookies, especially strictly necessary cookies, may impair your ability to log in, place bets or use some features of neospinbet-au.com.

Data Security

OBSERVE: Online gambling involves sensitive financial and identification data, requiring robust protection. EXPAND: We implement layered technical, organisational and procedural security measures. REFLECT: While no system is perfectly secure, these measures are designed to reduce risk to an acceptable level and to respond swiftly to incidents.

1. Technical Security Measures

• Encryption in transit: Data transmitted between your browser and our servers is protected using industry-standard encryption protocols (TLS 1.2 or higher), helping to prevent interception or tampering.
• Encryption at rest: Sensitive data, including certain financial and identification information, is stored using encryption or tokenisation, with keys managed under strict controls.
• Access controls: Access to personal data is restricted according to the principle of least privilege, and granted only to authorised staff or service providers who need it for their role.
• Network and infrastructure security: Use of firewalls, intrusion detection and prevention systems, log monitoring and other security tools to defend against attacks and unauthorised access.

2. Organisational and Procedural Measures

• Internal policies and training: Staff involved in processing personal data receive training on data protection, security practices and confidentiality obligations. Policies define how data is handled throughout its lifecycle.
• Authentication and account protection: We encourage strong passwords and may implement additional authentication mechanisms (e.g., multi-factor authentication) where available, particularly for access to sensitive account features.
• Vendor due diligence: Service providers with access to personal data are assessed for their security posture and contractually required to maintain appropriate safeguards.
• Security reviews and testing: Our systems are periodically reviewed and may be subject to vulnerability assessments or penetration tests to identify and remediate weaknesses.

3. Incident Response

• We maintain procedures to detect, respond to and investigate suspected personal data breaches or security incidents.
• In the event of a breach that is likely to result in a significant risk to your rights and freedoms, we will take appropriate steps to mitigate harm and, where required by applicable law, notify you and relevant authorities without undue delay.

While we take appropriate steps to protect your personal data, you are also responsible for keeping your account credentials confidential and for choosing a strong, unique password. We recommend that you log out after using shared devices and promptly notify us if you suspect any unauthorised access to your account.

Complaints & Contacts

OBSERVE: Users require clear channels to raise questions and complaints. EXPAND: We set out the steps from internal handling to escalation to supervisory bodies. REFLECT: This structured process supports trust and accountability.

1. Contact Channels

• E-mail (primary): [email protected] - for all privacy-related queries, rights requests and complaints.
• Website: https://neospinbet-au.com - where additional contact options or forms may be made available from time to time.

2. Internal Complaint Procedure

1. Submission: Send a detailed description of your concern, including relevant dates, account information and copies of any supporting documents, to [email protected].
2. Acknowledgement: We will acknowledge receipt of your complaint as soon as reasonably practicable, usually within 5 business days.
3. Investigation: Your complaint will be reviewed by the appropriate team or responsible person within our data protection or compliance function.
4. Response: We aim to provide a substantive response within 30 days of receiving your complaint. If we are unable to respond within this period due to complexity or the need for additional information, we will inform you of the delay and provide an estimated timeframe.
5. Further steps: If you are not satisfied with our response, you may seek recourse with relevant supervisory or regulatory authorities in your jurisdiction, as described below.

3. Escalation to Supervisory Authorities

If you believe that we have not adequately addressed your privacy concerns or processed your personal data in compliance with applicable law, you may have the right to lodge a complaint with an appropriate data protection or privacy authority. The relevant authority will depend on your country of residence and the applicable legal framework. Contact information for local authorities is typically available on their official websites.

This is in addition to any other rights or remedies available to you under applicable law.

Updates

OBSERVE: Privacy practices evolve over time with legal and operational changes. EXPAND: We commit to transparent versioning and notification. REFLECT: This allows users to reassess their relationship with the service whenever material changes occur.

1. Changes to This Privacy Policy

• We may update or revise this Privacy Policy from time to time to reflect changes in our services, technology, legal or regulatory requirements, or for other operational reasons.
• Each version of the Privacy Policy will be identified by an effective date and, where appropriate, a version number.

2. Notification of Material Changes

• When we make material changes that significantly affect how we process your personal data or your rights, we will provide you with prior notice through one or more of the following channels:
  • E-mail sent to the address registered to your account on neospinbet-au.com
  • Prominent notification or banner on our website or in the account dashboard
  • In-product or in-account message presented on your next login.
• Where feasible and required by applicable law, we will provide at least 30 days' advance notice before material changes take effect, giving you the opportunity to review them.

3. Your Options Following Updates

• If you continue to use our services after the effective date of the updated Privacy Policy, your continued use will constitute acknowledgment of the updated terms.
• If you do not agree with the changes, you may:
  • Adjust your privacy or marketing preferences through available tools or by contacting us; and/or
  • Request closure of your account and, where applicable, exercise your data protection rights as described above.

Last updated: January 2026