Privacy & Cookie Notice

Our Privacy Promise

Here at Christchurch Casino we take your privacy seriously, and we want you to feel confident in how your data is used.

This notice describes how and why we collect, use, and protect your personal data and we would love it if you read the full version. But if you are short on time, you can find a shorter explanation below:

• We collect and process your data mainly to provide you with our services and to meet legal and/or regulatory requirements.
• As an example, if you want to open an account and play with us, we would need some personal details like your name, date of birth and contact information.
• We also need to check your age and your identification to make sure you are old enough to play with us. We do this by processing your personal data for verification checks and, if required, asking you to provide a copy of your ID and address.
• We are committed to helping you play responsibly and giving you the best and safest experience possible.

1. Introduction

Your privacy matters to us. This Privacy and Cookie Notice (the Notice) explains how we handle your personal data when you visit our Website, what your privacy rights are, and how we stay compliant with data protection laws.

We may update this Notice from time to time, especially if the law changes or we improve our services. Any updates will take effect as soon as we post them on the website, and we will let you know if there are any significant changes that you should be aware of.

This Notice forms part of our general “Terms of Use” and should be read together with our General Terms and Conditions and any other Terms of Use available on our Website.

To keep your account running smoothly, it is important that the personal information you have provided is accurate and up to date. If you have any questions or if anything changes, please reach out to us and we will help you.

2. Who is Responsible for Your Data

ChristchurchCasino.com is a brand owned by ChristchurchCasino.com Limited (CCC) and operated by Two Islands Enterprise Limited (TIEL). Both of these companies are what is known as joint data controllers - that means they both have a say in how your personal data is used.

• CCC looks after your data in relation to marketing services;
• TIEL handles your data when it comes to the provision of the services you use

If the joint provision of services comes to an end by termination, CCC will become the sole data controller of your personal data.

If you ever have any questions or concerns about how your data is handled, first reach out to our appointed Data Protection Officer (DPO) via email at privacy@christchurchcasino.com.

In the case that you are still not happy with how your concern is being handled, then you also have the right to contact our Lead Supervisory Authority, which is the Office of the Information and Data Protection Commissioner (IDPC) that governs our company in relation to data protection issues. IDPC: https://idpc.org.mt/file-a-complaint/.

3. Information we collect about you

At Christchurch Casino we only collect Personal data that is relevant to your experience with us. This means any information that can identify you directly, for example your name or address, or indirectly, like your device ID and IP address.

Here is a list of Personal data that we might collect;

• Identity Data: Your full name, date of birth, gender and marital status
• Contact Data: Email address, phone number, billing address - plus any other information you share when registering or using our Website (including registering an account, subscribing to promotions, posting material or requesting further services)
• Correspondence Data: Information you share with us when contacting our Customer Support, entering a competition, or reporting a problem. We may also record phone calls for training and quality control purposes to allow for speedy query resolution.
• Financial Data: Information related to your bank account details or information relating to your financial position - the last being for the purpose of responsible gaming checks.
• Transaction Data: Details about payments made to and from you including game transactions and service purchases made from us.
• Technical Data: Your IP address, browser type including plug-ins and version, device, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website.
• Profile Data: Your username, password, account activity and transactional history.
• Usage Data: Information on how you browse and use our Website.
• Marketing and Communications Data: Your opt-in preferences for receiving emails, promotions, and other communications — as set in your account settings.
• Aggregated Data: We also collect, use and share anonymous data, such as statistical information or demographic data. This data does not identify you personally, directly or indirectly.
• Sensitive Data: In rare cases, we may need to collect special categories of personal data (like health details or criminal records), but only when it’s absolutely necessary for legal or regulatory obligations or when you have provided it voluntarily.

4. If you do not Provide Personal Data

Sometimes we need to collect certain personal data by law, to be able to offer you our continued services properly. If you choose not to give us the requested information — we may not be able to open or maintain your account and in these cases, we may have to close your account. We will always notify you of any changes or requests.

5. How we collect your Data

We collect your personal data in a few different ways - some of it comes directly from you, and some of it we gather automatically or receive from trusted third parties:

Direct Interactions: We collect personal data when you;

• Register an account;
• Play games or place bets;
• Enter a promotion, survey or competition;
• Ask for support or send feedback;
• Choose to receive marketing messages

Automated Interactions: Data, such as IP address or browsing behaviour, may be automatically collected when you interact with our Website through;

• Cookies and other tracking technologies; (link to cookie section nr 17)
• Server logs;

Third Parties or Public Sources: We may also receive Personal data about you from third party sources such as;

• Age and Identity verification providers;
• Financial institutions or credit reference agencies;
• Public Sources, where relevant;
• Services like Bank ID, Google Sign-In, Trustly or similar (to help speed up the sign-up process)

Data received from third parties are used to supplement the personal data that we hold about you for the purposes of prevention or detection of crime, or for responsible gambling purposes.

In certain cases, and upon your permission, we can use data from third-party services to help speed up the account creation process by collecting Registration and Contact Data.

6. How we use your Data (and Why)

We only use your personal data when we have got a valid reason to do so. Under the data protection laws, these reasons are called “lawful basis”, and they include:

• Contract obligation; where needed to fulfil our contract with you - for example, running your account or processing payments
• Legal or regulatory obligations; for example, verifying your identity or for responsible gambling purposes
• Your consent; where you have given it - for example, marketing messages or push notifications
• Legitimate interests; where these don’t override your rights - for example, improving our services

Below is a breakdown of how we use your personal data, the purpose, and the legal reason behind it:

We also use non-personal information (e.g. general gameplay statistics or analytics) to help us understand trends, measure performance, and prevent fraud. This data does not identify you directly or indirectly and is usually collected by us or through trusted service providers.

Sometimes we work with third-party providers or companies who process data on our behalf, also called Processors. They only ever use your data for the purposes we've outlined above and in line with this Notice.

In certain situations, we may also share data with third parties like Equifax Ltd. to assess financial risk so that we may provide an effective service and comply with responsible gambling obligations. Further information on how Equifax Ltd. holds and uses your personal data can be found here.

7. Sending your Data outside of EU

Because we work with partners and providers around the world, your personal data may sometimes be transferred to countries outside the European Union.

If this happens, we make sure your data stays protected by following the standard contractual clauses pursuant to European Commission Decision 2021/914 of 4 June 2021 available here.

We only work with trusted partners who meet strict data protection standards. In particular, we transfer to and receive from Christchurch Casinos Limited (30 Victoria Street, PO Box 4141, Christchurch, New Zealand) basic identification data of players who are residents of New Zealand and who have been banned or restricted from participating in gambling activities. This information is only shared for the purpose of responsible gambling in order to restrict their access to gambling activities and prevent or lessen any threat to the health of the individual concerned. The recipient of such data does not use such data for any other purpose.

8. Marketing: How we stay in touch

We may use your contact details - like your name, email, phone number or home address - to send you updates, offers and promotions about our services. These might come directly from us or through trusted marketing partners (together the “Marketing Affiliates”):

• ChristchurchCasino.com and our group of companies
• Our White Label Partner, ChristchurchCasino.com Limited and its group of companies
• Other partners and affiliates we work with

We might share your data with these partners (our “Marketing Affiliates”) so they can send you offers they think you'll enjoy. These offers may come via email, SMS, phone, or post.

We will only send you marketing communications that you have given us your consent for. You can unsubscribe at any time — no hard feelings. To do so, go to your Account and update your marketing preferences or follow the link in the relevant communication to unsubscribe. Even if you opt out of marketing, we may still send you important service messages from time to time (like changes to your account or legal updates).

We may also use tools like Google Ads and Facebook Ads to show you relevant promotions. This means we might share certain information with platforms like Facebook to tailor ads you see. You can read more about Facebook Ads here. By using our Website, you consent to Facebook and us using your personal data for advertisement. If you no longer wish to receive such advertisements on Facebook, you can manage your preferences on Facebook in the link set out above.

9. Monitoring, Profiling and Automated Decisions

At Christchurch Casino we use monitoring and profiling tools to help run services responsibly and securely. This includes spotting patterns that could indicate a player is at risk of harm, or detecting suspicious activity that could relate to fraud or money laundering.

9.1. Responsible Gambling Monitoring

We are legally required to keep an eye on your account behaviour to support safer gambling. That means that we are recording and monitoring all transactions you make on your account along with other relevant data to comply with our licensing and regulatory obligations and to help identify potential signs of problem gambling.

We have developed automated rules based on historic data to alert us if such happens - but don’t worry, we don’t make big decisions without a human reviewing the situation. Sometimes, our system might place limits or even temporarily restrict your account if these rules are triggered.

If you’d like to contest a decision or speak to someone, you can contact us at privacy@christchurchcasino.com

9.2. Anti-money laundering

We are also legally required to monitor accounts for suspicious activity — especially where large or irregular transactions are involved. Our systems help flag risk profiles based on transaction behaviour and usage data.

Just like with responsible gaming, any serious decisions here are always reviewed by a real person before action is taken.

10. Keeping your Data safe

We take security very seriously and use a range of measures to protect you and protect your personal data from being lost, stolen, accessed without permission, or otherwise misused. Some of the steps we take include:

• Encryption of sensitive data using TLS v1.2 or higher
• Secure servers and firewall protection
• Access controls, so only authorised staff can view your data
• Password protection - it’s both our and your responsibility to keep your password safe at all times

When you are using our secure pages (like account or payment areas), the data is encrypted by SSL protocol to ensure it’s safe. You might get a pop-up from your browser when accessing these secure areas for the first time - that is just your browser letting you know your information is protected.

While we do our very best to keep you and your data safe, no online system is 100% immune to risk. That is why it’s important that you always protect yourself when browsing online. For your own safety, please avoid disclosing any sensitive information, like payment card numbers, via emails sent to us. By using our Website, you accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have failed in our obligations under data protection legislation.

11. How long we keep your Data

We only keep your personal data for as long as we need it — either to deliver our services or to meet legal or regulatory requirements. As a general rule, we will keep your data while your account is active, and for up to five years after that. In some cases, we may hold onto certain data for longer if required by law or if there's a valid business reason (such as resolving a dispute or audit purposes). Where we no longer need your data, we will securely delete or anonymise it.

12. Your rights, Our Process

You have the rights over your personal data, and we are here to help you exercise them. Please note, however, that not all rights are absolute. If you would like to make a request, just email us at privacy@christchurchcasino.com.

• Access: You can request a copy of your personal data (also known as “data subject access request”)
• Correction: Ask us to update inaccurate or incomplete data
• Deletion: You can also request that your data be deleted if we no longer have a good reason to keep it (sometimes we may need to retain it for legal reasons)
• Objection: You can object to how we are using your data for our legitimate interests, for example marketing purposes
• Restriction: Ask us to pause how we are using your data in certain situations
• Withdraw consent: You can change your mind at any time on permission requested data, for example marketing purposes
• Contest automated decisions: You can always ask us to review automated decisions that affected you
• Data portability: You can request to transfer your data to another provider

You won’t be charged for making a request - unless it is excessive or clearly unfounded, in which case a small fee may apply. We also reserve the right to refuse to comply with your request if it’s deemed unfounded, in which case we will demonstrate that we have compelling legitimate grounds to refuse your request. We aim to always respond to data request queries within one month, at which point we may request proof of ID to confirm it is really you making the request.

13. Opting out of Communications

We sometimes use your contact details to share things like product updates, promotions, contests or events. You can opt out of receiving these communications at any time either via the link in the communication or via your Account settings.

Even if you opt out of marketing, we may still send you essential service messages about your account, security updates or legal changes - these are part of the service and can’t be turned off.

14. Third-party Sites and Services

This Notice applies to ChristchurchCasino.com only. If you follow a link to another website, app, or service — even if it’s accessible via our platform — please check their privacy policy. We’re not responsible for how they collect or use your data.

15. Corporate changes

If our business structure changes - such as a merger, acquisition, asset sale or restructure - your data may be transferred to a new owner as part of the transaction. If this happens, they will take on the responsibilities outlined in this Notice.

16. Legal disclosures

Sometimes we may be required by law to share your data - for example:

• If we are responding to a court order
• If a regulator or government agency requires it
• If we need to protect our business, other players, or enforce our rights

In these cases, we will always make sure any disclosure is lawful and necessary.

17. Cookies & Pixels Notice

Cookies

Cookies are small text files stored on your device when you visit our Website. They help us remember your preferences, understand how you use our site, and improve your experience.

There are different types of cookies that we use - all equally tasty:

• Essential Cookies: For making sure our Website and it’s applications can function properly and run smoothly
• Analytical Cookies: To help us understand how you use our Website, sometimes with the help of third-party providers such as Google Analytics
• Persistent Cookies: These are saved on your device for a fixed period so that we can remember your last visits and make sure we display the right content based on your previous preferences
• Functional Cookies: To help us personalize your experience
• Session Cookies: Temporarily stored during your visit to help us remember things like your navigation history on our Website

We sometimes work with third-party services that use cookies for things like measuring effectiveness or personalizing offers. You can learn more or manage these cookie preferences at www.aboutads.info/choices.

You can choose to block or delete cookies through your browser settings - just be aware that some of our site features may not work properly without them.

Pixels

We also use tracking pixels (tiny pieces of code) to understand how you interact with our site and advertisements. These pixels help us track visits, measure campaign performance, and tailor advertising through social platforms.

This data is non-personal and often aggregated - but it plays a big role in helping us improve your experience and our services.

By continuing to access and use our Website and services, you consent to the use of cookies and pixels as described in accordance with this Notice.

Date: Last updated on 16th April 2025