Privacy Policy

Just-casino-new-zealand ("we", "us", "our") provides this Privacy Policy to explain how we collect, use, disclose, and protect your personal information when you interact with the just-nz.com website. This Policy applies to all players and visitors from New Zealand who access or use our online casino services. The effective date of this Policy is 6 November 2025.

Who We Are

OBSERVE: Identify the operator's full legal details and key contact points for data protection.

EXPAND: Ensure the section includes official company registration, licensing, and dedicated Data Protection Officer (DPO) contact for privacy matters.

REFLECT: Present a comprehensive and accessible overview for user confidence and regulatory transparency.

• Operator: just-casino-new-zealand is operated by Dama N.V., a company registered in Curaçao (registration number: 160603), with its legal address at Scharlooweg 39, Willemstad, Curaçao.
• Gaming Licence: Dama N.V. holds Curaçao Gaming Control Board (GCB) licence number OGL/2025/164/0246, valid provisionally through 2025, authorizing online gambling and casino operations for just-nz.com.
• Contact for Privacy Matters: For all privacy-related queries, you may contact our Data Protection Officer at support@just-nz.com. Please specify "Privacy Inquiry" in the subject line for prompt attention.

Regional Compliance Note: All operations for users in New Zealand are regulated under Curaçao law, with adherence to New Zealand privacy standards and gambling requirements.

What Personal Data We Collect

OBSERVE: Define all categories of data processed for casino operations, regulatory obligations, and user experience.

EXPAND: Incorporate both direct and indirect data, including technical and behavioral tracking, for a complete compliance profile.

REFLECT: Provide a transparent, user-focused breakdown for informed consent and legal clarity.

• Personal Identity Data: Full name, date of birth, address, email address, phone number, identification documents (for KYC/AML compliance).
• Account and Transaction Data: Account credentials, payment/banking details, deposit and withdrawal records, betting and game history.
• Technical Data: IP address, device information, browser type, operating system, log files, access times, and referring URLs.
• Behavioral Data: On-site actions (page visits, clicks, session duration), interaction with marketing communications, responsible gambling activity.
• Cookies and Tracking Technologies: Session and persistent cookies, third-party analytics, advertising tags, device identifiers.

Regional Compliance Note: Collection and processing are limited to purposes permitted under New Zealand and Curaçao regulations, with user consent where required.

Legal Basis for Processing

OBSERVE: Detail the lawful grounds for all data processing activities per applicable law.

EXPAND: Address explicit consent, contract necessity, legal obligations, and legitimate interests, referencing regulatory requirements.

REFLECT: Ensure users understand both mandatory and optional processing, supporting their rights and informed participation.

1. User Consent: Processing based on your explicit consent for activities such as marketing communications and optional services. Consent can be withdrawn at any time.
2. Contractual Necessity: Data required to establish, manage, and fulfill your account and gaming transactions, including deposits, withdrawals, and participation in casino activities.
3. Legal Obligations: Compliance with Know Your Customer (KYC), Anti-Money Laundering (AML), tax reporting, and other statutory duties under Curaçao and New Zealand law.
4. Legitimate Interests: Processing for fraud prevention, security, service improvement, analytics, and the protection of our business and users, provided such interests do not override your fundamental rights.

Regional Compliance Note: Where New Zealand law or international standards require, you will be informed of the legal basis for each processing operation.

Purpose of Processing

OBSERVE: Specify why each category of personal data is processed.

EXPAND: Link purposes to legal, operational, and user experience needs.

REFLECT: Ensure every purpose is transparent and justified for regulatory review and user understanding.

• Account Creation and Management: To register, authenticate, and maintain your just-nz.com account.
• Service Provision: To enable gameplay, process transactions, and provide customer support.
• Compliance and Security: To conduct KYC/AML verification, monitor transactions, and prevent fraud or abuse.
• Analytics and Service Improvement: To analyze user activity, enhance platform functionality, and optimize user experience.
• Marketing and Promotions: To send promotional offers, newsletters, and updates (where consent has been given).

Regional Compliance Note: Processing for marketing uses is always subject to explicit user consent under NZ privacy expectations.

Disclosure & Sharing

OBSERVE: Identify recipients of user data and the circumstances for such disclosures.

EXPAND: Include required sharing with regulators, payment providers, affiliates, and advertising networks, emphasizing user control and safeguards.

REFLECT: Provide users with clarity on third-party relationships and legal protections.

1. Payment Processors & Financial Partners: Data shared for the secure processing of deposits and withdrawals, subject to strict confidentiality agreements.
2. Service Providers: Third-party vendors who provide IT, analytics, marketing, and customer support services, bound by data processing agreements.
3. Regulatory & Law Enforcement Authorities: Data disclosed when required to comply with legal obligations, licensing conditions, or official requests from the Curaçao GCB or New Zealand regulators.
4. Affiliates & Advertising Partners: Data may be shared with affiliates and advertising networks only where you have provided explicit consent (e.g., for targeted promotional communications).

Regional Compliance Note: No data is sold. All sharing arrangements comply with NZ privacy laws and international best practices.

International Transfers

OBSERVE: Address cross-border data movement due to hosting, operations, or external service providers.

EXPAND: Explain legal mechanisms and safeguards (e.g., Standard Contractual Clauses, adequacy decisions) used to protect user data during international transfers.

REFLECT: Reassure users that their data receives equivalent protection, regardless of storage or processing location.

• Data Hosting & Processing: Personal data may be transferred to and processed in countries outside New Zealand, including Curaçao and other jurisdictions where our IT infrastructure and service providers are located.
• Protection Measures: All international transfers are governed by robust contractual clauses, with additional technical and organizational safeguards as required by law.
• User Rights: You retain all data protection rights regardless of your data's geographic location, and may request further information regarding specific transfer mechanisms by contacting support@just-nz.com.

Regional Compliance Note: Where required, just-casino-new-zealand ensures compliance with both Curaçao and NZ data export requirements.

Data Retention

OBSERVE: Specify how long each type of data is kept and the criteria for deletion or anonymization.

EXPAND: Address legal retention obligations (e.g., anti-money laundering), user-initiated deletions, and end-of-purpose triggers.

REFLECT: Balance legal requirements with user privacy expectations and operational needs.

1. Personal & Account Data: Retained for the duration of your account and up to 5 years after account closure or the end of the business relationship, in accordance with AML and regulatory requirements.
2. Transactional Data: Maintained for at least 5 years post-transaction, as mandated by applicable law.
3. Cookies & Analytics Data: Stored for up to 2 years from collection or as specified in your cookie preferences.
4. Deletion Criteria: Data is deleted or anonymized upon user request (where permitted), expiration of legal retention periods, or when the purpose for processing is fulfilled.

Regional Compliance Note: Retention periods align with NZ legal standards and Curaçao regulatory requirements for gambling operators.

Your Rights

OBSERVE: Articulate user rights under applicable privacy laws including GDPR-alignment for completeness, adapted for NZ.

EXPAND: Provide clear instructions and guarantee cost-free, timely responses for user requests.

REFLECT: Empower users with actionable controls and robust legal protections.

• Access: You can request a copy of your personal data held by just-casino-new-zealand at any time.
• Rectification: You have the right to correct inaccurate or incomplete personal information.
• Erasure: You can request deletion of your data, subject to legal and regulatory restrictions (e.g., ongoing AML obligations).
• Restriction: You may request the limitation of processing under certain circumstances (e.g., while contesting accuracy).
• Objection: You may object to processing for direct marketing or based on legitimate interests.
• Data Portability: You are entitled to receive your personal data in a commonly used, machine-readable format, and to have it transmitted to another controller upon request.
• Withdrawal of Consent: You may withdraw your consent for marketing communications or other consent-based processing at any time, without affecting prior lawful processing.
• Exercising Rights: Requests must be submitted by email to support@just-nz.com with verified identity. We will respond within 30 days, free of charge, unless requests are manifestly unfounded or excessive.

Regional Compliance Note: Rights are provided at a level equivalent to GDPR, in line with New Zealand privacy law and international gaming industry standards.

Cookies & Tracking Technologies

OBSERVE: Enumerate tracking technologies and their usage in casino operations.

EXPAND: Provide management and opt-out instructions for user empowerment.

REFLECT: Ensure compliance with NZ cookie law and international best practices.

1. Session Cookies: Temporary cookies essential for website functionality and secure user sessions. Deleted when you close your browser.
2. Persistent Cookies: Remain on your device for a specified period to remember preferences and enhance user experience.
3. Third-Party Cookies: Used for analytics (e.g., Google Analytics), advertising, and affiliate tracking, subject to your consent.
4. Management: You may manage or disable cookies via your browser settings or the cookie management panel on just-nz.com. Note that disabling certain cookies may affect functionality.

Regional Compliance Note: Cookie usage aligns with New Zealand digital privacy regulations, and consent banners are provided where required.

Data Security

OBSERVE: List all technical and organizational security measures deployed by just-casino-new-zealand on just-nz.com.

EXPAND: Emphasize compliance with international standards and incident response protocols.

REFLECT: Build user trust through transparency and legal assurance.

• Encryption: All personal data is protected using TLS 1.2+ encryption in transit and advanced encryption standards at rest.
• Access Controls: Strict authentication and authorization procedures, including multi-factor authentication for sensitive operations.
• Staff Training: Regular training for staff on data protection and secure handling of personal information.
• Security Audits: Periodic audits and vulnerability assessments to identify and remediate risks, with reference to ISO/IEC 27001 and SOC 2 standards where applicable.
• Incident Response: Established procedures for breach detection, reporting, and mitigation, including notification to affected users and authorities within legally mandated timeframes.

Regional Compliance Note: Security practices are designed to meet or exceed both Curaçao and NZ regulatory expectations for online gambling operators.

Complaints & Contacts

OBSERVE: Provide all channels for complaint submission and data protection queries.

EXPAND: Detail step-by-step escalation procedures and relevant supervisory authorities.

REFLECT: Foster user confidence in dispute resolution and regulatory oversight.

1. Contacting Us: For any concerns or complaints regarding privacy, email support@just-nz.com (subject: "Privacy Complaint").
2. Complaint Procedure: Upon receipt of your complaint, we will acknowledge it within 5 business days, investigate thoroughly, and provide a formal response within 30 days.
3. Escalation: If you are dissatisfied with our response, you may escalate your complaint to the Curaçao Gaming Control Board (www.gamingcontrolcuracao.org) or, if you are a New Zealand resident, to the Office of the Privacy Commissioner (www.privacy.org.nz, phone: +64 4 474 7590).

Regional Compliance Note: All complaints are handled in accordance with NZ and Curaçao data protection and gambling dispute resolution requirements.

Updates

OBSERVE: Describe user notification and change management procedures for privacy policy updates.

EXPAND: Ensure users are given adequate notice and actionable options for material changes.

REFLECT: Maintain transparency and regulatory compliance through effective communication.

• Advance Notice: Material changes to this Privacy Policy will be notified at least 30 days in advance via email (if provided), website banners, and account dashboard alerts.
• User Options: If you disagree with the changes, you may object or close your just-nz.com account before the new terms take effect.
• Version Control: The current version of this Policy is always available at just-nz.com/privacy-policy. Last updated: 6 November 2025.
• Changelog: All material revisions are summarized at the end of the Policy for transparency.

Regional Compliance Note: Update and notification procedures comply with all applicable NZ and Curaçao legal requirements for privacy policy changes.