Privacy Policy

This Privacy Policy explains how Asino Casino, operated as part of the Asino Casino brand on the AU-facing website https://asinobet-au.com ("Site", "Service"), collects, uses, discloses, and protects your personal information. It applies to players, prospective players, and any other visitors who access or interact with the Site, including through registration, gameplay, payments, customer support, and marketing communications.

By using the Site, creating an account, or otherwise providing personal information, you acknowledge that you have read and understood this Privacy Policy and agree to its terms, together with our Terms and Conditions. If you do not agree, you should not use the Site.

This Privacy Policy is effective from 1 January 2026 and is intended to align with applicable data protection standards, including the Australian Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs), the EU General Data Protection Regulation ("GDPR"), and, where relevant, the Mexican Federal Law on Protection of Personal Data Held by Private Parties ("LFPDPPP").

Who We Are

OBSERVE: The Site targets players in Australia but is operated offshore under an international gambling licence. Your data is handled primarily by the licensed operator and its payment and service partners.

Operator and Data Controller
The online casino services promoted under Asino Casino on https://asinobet-au.com are operated by:

• Hollycorn N.V., a company incorporated under the laws of Curaçao
• Registration number: 144359
• Registered address: Scharlooweg 39, Willemstad, Curaçao
• Gaming licence: 8048/JAZ2019-015, issued by Antillephone N.V. under the authority of the Government of Curaçao

For the purposes of data protection laws (including GDPR where applicable), Hollycorn N.V. is the primary "data controller" responsible for determining how your personal data is processed in connection with the Site.

Payment Processing Subsidiary
Certain payment processing and related services may be provided by:

• Libergos Limited, a company registered in Cyprus
• Registration number: ΗΕ 371971
• Registered office: Cyprus (exact street address as indicated in payment documentation)

Libergos Limited acts as a processor or joint controller in respect of payment-related personal data, depending on the specific transaction and contractual arrangements.

Data Protection Contact / DPO
We have appointed a data protection contact function (the "DPO") to oversee privacy matters:

• Data Protection Officer (DPO)
  Email: [email protected]
  Postal: Data Protection Officer, Hollycorn N.V., Scharlooweg 39, Willemstad, Curaçao
• You may also contact us via the support channels (live chat or contact form) available on https://asinobet-au.com, clearly marking your request as "Privacy / Data Protection".

REFLECT: All references in this Privacy Policy to "we", "us", "our" and "Asino Casino" should be understood as referring to Hollycorn N.V. (and, where relevant, Libergos Limited) in connection with the Site at https://asinobet-au.com.

What Personal Data We Collect

OBSERVE: To provide secure online casino services and comply with legal obligations, we must collect various categories of information. We aim to limit collection to what is necessary for clearly defined purposes.

Identity and Contact Data

• Full name, date of birth, gender (where provided)
• Residential address, country of residence
• Email address, username, and any other identifiers you provide
• Copies or details of identification documents (e.g., passport, ID card, driving licence) and proof of address documents for KYC/AML checks

Account, Gameplay and Behavioural Data

• Account registration details, account status, verification status
• Game session data: games played, stakes, wins/losses, time spent, bet histories
• Bonuses claimed, wagering progress, promotions participation
• Responsible gambling settings (limits, self-exclusion, cooling-off periods)
• In-site navigation, clicks, pages viewed, interaction with messages and banners

Technical and Log Data

• IP address, approximate location derived from IP
• Device identifiers, browser type and version, operating system, screen resolution, language settings
• Log files recording access times, login attempts, security events, and errors

Payment and Financial Data

• Payment method details (e.g., masked card numbers, e-wallet identifiers, bank account references, crypto wallet addresses), as required to process deposits and withdrawals
• Transaction histories, payment confirmations, chargeback records, payout details
• Anti-fraud risk scores and checks related to payments

Communications and Support Data

• Content of messages exchanged through live chat, email, and support tickets
• Call or chat logs where applicable, including timestamps and operators involved
• Complaints, feedback, survey responses, and other communications

Cookies and Similar Technologies

• Cookies, web beacons, pixels, tags, SDKs, and local storage used to remember your preferences, authenticate you, track performance, and personalise content
• Online identifiers associated with these technologies, which may link to your account and behavioural data

EXPAND & REFLECT: We may also receive information about you from third-party verification services, payment providers, affiliates, and marketing partners (e.g., to confirm your identity, detect fraud, or measure campaign performance) where this is lawful. All such data is treated as personal data and handled in line with this Privacy Policy.

Legal Basis for Processing

OBSERVE: Because we serve users in multiple jurisdictions, including Australia, the EU/EEA and Mexico, our processing activities must be justified under several legal frameworks. The underlying principles are transparency, necessity, and proportionality.

Contractual Necessity

• We process personal data that is necessary to:
  • Register and administer your player account
  • Provide access to games and related services
  • Process deposits, bets, and withdrawals
  • Provide customer support and communicate about your account
• Under GDPR, this corresponds to Article 6(1)(b) (performance of a contract). Under the Australian Privacy Act, this aligns with APPs regarding collection and use reasonably necessary for our functions or activities.

Compliance with Legal Obligations

• We must comply with applicable anti-money-laundering (AML), counter-terrorist financing (CTF), fraud prevention, tax, gambling and accounting laws in Curaçao and other relevant jurisdictions.
• This requires identity verification, transaction monitoring, record-keeping, reporting to competent authorities, and sanctions screening.
• Under GDPR, this corresponds to Article 6(1)(c) (legal obligation). Under Mexican LFPDPPP and Australian law, it reflects mandatory legal and regulatory obligations imposed on us.

Legitimate Interests

• We rely on legitimate interests where processing is necessary and proportionate, for example to:
  • Protect our business, systems, and users against fraud, abuse, and security threats
  • Improve the Site, games, and user experience through analytics and statistics
  • Enforce our Terms and Conditions and protect legal rights
  • Carry out limited direct marketing consistent with your preferences and legal requirements
• We balance these interests against your rights and expectations, implementing safeguards such as pseudonymisation, access controls, and opt-out options.

Consent

• We obtain your consent where required by law, including for:
  • Non-essential cookies and similar tracking technologies
  • Direct marketing communications (email, SMS, push notifications) where consent is required
  • Processing of certain sensitive data or cross-border transfers where consent is the appropriate legal basis
• You may withdraw your consent at any time, without affecting the lawfulness of processing prior to withdrawal.

REFLECT: In some situations, more than one legal basis may apply. We will always ensure that at least one valid ground exists before collecting or using your personal data.

Purpose of Processing

OBSERVE: We process your personal data only for specified, explicit and legitimate purposes. We do not use it in ways incompatible with these purposes.

Service Provision and Account Management

• Creating, verifying, and managing your player account
• Providing access to casino games and related features
• Processing deposits, bets, withdrawals, and bonus credits
• Providing customer support and handling inquiries or complaints

Compliance, Risk Management and Fraud Prevention

• Carrying out KYC/AML/CTF checks and ongoing monitoring
• Detecting, investigating, and preventing fraud, abuse, collusion, chargebacks, and suspicious behaviour
• Complying with regulatory and licence obligations (e.g., Curacao licensing requirements, financial reporting)
• Maintaining records required by law and for dispute resolution

Improvement, Analytics and Personalisation

• Analysing usage patterns to improve game offerings, performance, and user experience
• Testing and developing new features, promotions, and security measures
• Personalising content, recommendations, and bonuses consistent with your profile and preferences

Marketing and Communications

• Sending service-related notifications (e.g., account changes, security alerts, transaction confirmations)
• Sending marketing communications about promotions, bonuses, and new features, where permitted by law and your preferences
• Measuring and optimising marketing campaigns, including affiliate performance

Responsible Gambling and Player Protection

• Monitoring behaviour to support responsible gambling initiatives
• Implementing self-exclusion, limits, and other protective tools
• Complying with legal and licensing responsibilities related to player protection

REFLECT: Where we need to use your data for a new purpose that is not compatible with the original purposes, we will inform you and, where required, seek your consent.

Disclosure & Sharing

OBSERVE: We share personal data only with parties who require it for legitimate purposes connected to operating the Site, complying with the law, or protecting our rights and users.

Service Providers and Processors

• Payment processors and financial institutions (including Libergos Limited and other third-party payment gateways, banks, card schemes, and crypto service providers) for processing deposits, withdrawals, and chargebacks
• Identity verification, KYC/AML, and fraud-prevention providers
• IT infrastructure, hosting, security, and support providers
• Customer support tools, CRM systems, and communication platforms
• Analytics and business intelligence providers, subject to appropriate safeguards

Group Companies and Business Partners

• Other entities within the Hollycorn N.V. group, strictly for internal administrative, compliance, or support purposes
• Affiliate and marketing partners, to reconcile referrals, measure campaign performance, and honour affiliate agreements

Regulators, Authorities and Dispute Bodies

• Regulatory authorities and licensing bodies in Curaçao or other relevant jurisdictions, as required by licensing and AML/CTF obligations
• Law enforcement agencies, courts, and external advisers (legal, financial, compliance) where necessary for defending legal claims, investigating suspected unlawful activity, or complying with legal obligations
• Alternative dispute resolution bodies or regulators where you lodge a complaint relating to our services

Advertising Networks and Third-Party Marketing

• Subject to your consent and applicable law, we may share limited identifiers (such as cookie IDs or hashed email addresses) with advertising networks and marketing platforms to deliver or measure targeted advertising related to our services.

REFLECT: We do not sell your personal data to third parties for their independent marketing purposes. Whenever we share data, we seek to ensure that the recipient provides adequate safeguards and processes the data only in accordance with our instructions and applicable law.

International Transfers

OBSERVE: Asino Casino operates internationally. This means your personal data may be transferred to and processed in countries outside your own, including countries that may have different or less protective data protection laws than those in your home jurisdiction.

Where Your Data May Be Processed

• Curaçao - where Hollycorn N.V. is registered and licensed
• Cyprus - where Libergos Limited provides payment services
• EU/EEA member states - where some of our service providers or group entities may be located
• Other countries (including, potentially, the United States or other jurisdictions) where third-party service providers (e.g., hosting, analytics, messaging, or security vendors) operate

Safeguards for Cross-Border Transfers

• We implement contractual and technical safeguards to protect your data, such as:
  • Standard Contractual Clauses (SCCs) approved by the European Commission for transfers of personal data from the EEA/UK
  • Data processing agreements with recipients defining security measures, confidentiality, and limited purposes
  • Encryption, access controls, and minimisation of data shared with third parties
• For Mexican and Australian users, we take reasonable steps to ensure that overseas recipients do not breach applicable privacy principles and that data is handled consistently with this Privacy Policy.

REFLECT: By using the Site, you understand that your data may be processed in Curaçao, Cyprus, and other countries. Where required by law, we will obtain your explicit consent before undertaking certain international transfers.

Data Retention

OBSERVE: We retain personal data only for as long as needed for the purposes described in this Privacy Policy, or as required by law and regulatory obligations (including AML/CTF record-keeping).

Retention Periods

• Account and Identification Data: For the lifetime of your account and generally up to 5 years after account closure, to comply with AML/CTF, gambling, and accounting obligations and to handle potential disputes.
• Payment and Transaction Data: Typically 5 - 7 years from the date of the relevant transaction, in line with financial and tax record-keeping requirements.
• KYC/Verification Documents: Generally up to 5 years after the end of the business relationship or your last transaction, unless a longer period is required by law or necessary in connection with investigations or legal claims.
• Gameplay and Behavioural Data: For the duration of your account and a limited period thereafter (usually up to 5 years), to support responsible gambling, resolve disputes, and perform legitimate analytics.
• Support Communications: Typically 3 - 5 years after closure of the relevant ticket or complaint.
• Cookies and Online Identifiers: Retained in accordance with the cookie lifespan (session or persistent) described in our cookies section and your browser settings, generally from a few minutes up to 2 years.

Deletion, Anonymisation and Archiving

• When data is no longer required, we will:
  • Securely delete or irreversibly anonymise it; or
  • Archive it in a restricted-access environment where retention is necessary for legal or regulatory reasons only.
• Where you exercise your rights to deletion or objection, we will act in accordance with applicable law, subject to our obligations to retain certain records.

REFLECT: Retention periods may differ depending on your jurisdiction and specific regulatory obligations. We regularly review our retention schedules to ensure ongoing compliance and necessity.

Your Rights

OBSERVE: Depending on where you are located (including Australia, the EU/EEA, the UK and Mexico), you may have specific rights regarding your personal data. We respect and endeavour to facilitate these rights in a consistent, transparent manner.

GDPR Rights (EU/EEA/UK Users)

• Right of Access: To obtain confirmation of whether we process your data and receive a copy of that data.
• Right to Rectification: To have inaccurate or incomplete data corrected.
• Right to Erasure ("Right to be Forgotten"): To request deletion of your data where there is no overriding legal basis for retention.
• Right to Restriction: To limit processing in certain circumstances (e.g., while we verify accuracy or handle an objection).
• Right to Data Portability: To receive certain data in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible.
• Right to Object: To object to processing based on legitimate interests or direct marketing (including profiling).
• Rights Relating to Automated Decision-Making: To request human review of decisions that are based solely on automated processing and have legal or similarly significant effects on you.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

Mexican ARCO Rights (Mexico Users)

• Under the Mexican LFPDPPP you may, where applicable, exercise:
  • Access: To know what personal data we hold and how it is used.
  • Rectification: To request correction of inaccurate or incomplete data.
  • Cancellation: To request that data be deleted when you consider it is not being used appropriately or is no longer necessary.
  • Opposition: To object to certain processing for legitimate reasons.

Australian and Other Rights

• Under the Australian Privacy Act and APPs, you generally have rights to:
  • Request access to personal information we hold about you
  • Request correction of personal information you believe is inaccurate, out-of-date, incomplete, or misleading
• We may ask you to verify your identity before responding to such requests.

How to Exercise Your Rights

1. Submit a Request: Send an email to [email protected] or contact us via the "Privacy / Data Protection" option in our support channels, specifying:
   • The right(s) you wish to exercise
   • Relevant details (e.g., timeframe, type of data, account ID)
2. Verification: We may request additional information to confirm your identity and ensure that we do not disclose data to unauthorised persons.
3. Response Time: We aim to respond within 30 days of receiving a complete request. If we need more time due to complexity or volume, we will inform you of the extension and reasons.
4. Fees: Requests are handled free of charge. However, where permitted by law, we may charge a reasonable fee or decline to act on manifestly unfounded or excessive requests (e.g., repeated requests).

REFLECT: In some cases, legal or regulatory requirements (such as AML/CTF obligations) may limit or delay our ability to fully comply with your request. Where this occurs, we will explain the reasons unless prohibited by law.

Cookies & Tracking Technologies

OBSERVE: Cookies and similar technologies help us provide a secure, reliable and personalised experience. Some are necessary for the Site to function, while others are used for analytics or marketing.

Types of Cookies We Use

• Strictly Necessary Cookies (Session & Persistent): Required for core functions such as login, security, and transaction processing. The Site cannot function properly without these cookies.
• Functional Cookies: Remember your preferences (e.g., language, region, saved credentials where permitted) to enhance usability.
• Analytics/Performance Cookies: Help us understand how visitors interact with the Site, which pages are most popular, and how services perform. We use this data to improve features and performance.
• Advertising/Marketing Cookies: Used (where permitted) to deliver relevant offers, measure campaign effectiveness, and limit the number of times you see certain promotions.
• Security and Anti-Fraud Cookies: Assist in detecting malicious activity and protecting user accounts.

Managing Cookies

• You can manage or disable cookies through:
  • Your browser settings (e.g., blocking or deleting cookies)
  • Cookie preferences or banners available on the Site, where implemented
• Disabling strictly necessary cookies may impact core functionality and your ability to use certain features (e.g., login, placing bets).
• Opting out of analytics or advertising cookies may reduce the personalisation of your experience but will not prevent you from using the Site.

REFLECT: For more detailed information about specific cookies and their lifespans, please refer to any cookie management interface or documentation available on https://asinobet-au.com.

Data Security

OBSERVE: We recognise the sensitivity of personal and financial information processed in connection with online gambling. We implement administrative, technical, and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction.

Technical and Organisational Measures

• Encryption: Data transmitted between your browser and our servers is protected using TLS 1.2+ encryption. Where appropriate, we also encrypt data at rest.
• Access Controls: Access to personal data is restricted to authorised personnel on a need-to-know basis, protected by role-based permissions, strong authentication, and logging.
• Authentication and Session Security: We use secure password practices, session management controls, and may employ multi-factor authentication for internal systems.
• Network Security: Firewalls, intrusion detection/prevention systems, and other security technologies protect our infrastructure.
• Secure Development and Testing: We apply secure coding practices and conduct security testing (including vulnerability assessments and, where appropriate, penetration tests).

Governance, Training and Incident Response

• Policies and Procedures: We maintain internal policies governing data protection, access, retention, and incident management.
• Staff Training: Employees with access to personal data receive training on data protection and security responsibilities.
• Incident Response: We operate procedures for identifying, assessing, and responding to security incidents. Where required by law, we will notify relevant authorities and affected individuals of data breaches without undue delay.
• Standards Alignment: Our controls are designed with reference to recognised frameworks such as ISO/IEC 27001 and SOC 2. While we may not hold formal certification, we strive to maintain comparable levels of security appropriate to the nature and volume of data processed.

REFLECT: No system can guarantee absolute security. However, we continuously review and improve our security posture to address evolving threats and industry best practices.

Complaints & Contacts

OBSERVE: You have the right to raise questions or complaints regarding how we handle your personal data. We encourage you to contact us first so we can attempt to resolve the matter directly.

How to Contact Us

• Data Protection Officer (DPO):
  Email: [email protected]
  Postal: Data Protection Officer, Hollycorn N.V., Scharlooweg 39, Willemstad, Curaçao
• Support Channels:
  You can also reach us via live chat or any contact forms provided on https://asinobet-au.com, indicating that your query concerns "Privacy / Data Protection".

Internal Complaint Procedure

1. Step 1 - Contact Support: Raise your concern with our customer support via live chat or contact form, providing details of the issue.
2. Step 2 - Escalation to DPO: If you are not satisfied with the initial response or your issue is complex, contact the DPO directly at [email protected]. Please include your account details (but not your password) and a clear description of your complaint.
3. Step 3 - Investigation and Response: We will investigate your complaint and aim to respond within 30 days. If we require more time due to complexity, we will inform you of the extension and expected timeframe.

Escalation to Supervisory Authorities

If you believe that your privacy rights have been infringed and you are not satisfied with our response, you may have the right to lodge a complaint with a data protection authority in your jurisdiction, for example:

• Australia: Office of the Australian Information Commissioner (OAIC) - see https://www.oaic.gov.au for contact details and complaint procedures.
• European Union / EEA: Your local data protection authority, whose contact details can be found via the European Data Protection Board at https://edpb.europa.eu.
• Mexico: Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI) - see https://www.inai.org.mx for guidance on ARCO rights and complaints.

REFLECT: We welcome the opportunity to address your concerns directly and encourage you to contact us before approaching a supervisory authority, although you are not obliged to do so.

Updates

OBSERVE: Laws, regulatory guidance and our services may change over time. We may update this Privacy Policy to reflect such changes, to clarify our practices, or to improve transparency.

How We Will Notify You

• We will publish the updated Privacy Policy on https://asinobet-au.com with a new "Last updated" date.
• For material changes that significantly affect your rights or the way we process your data, we will:
  • Provide prominent notice on the Site (e.g., banners or pop-up notifications), and/or
  • Send you an email or account notification, where feasible, at least 30 days before the changes take effect.

Your Choices on Updates

• If you disagree with the updated Privacy Policy, you may:
  • Contact us with your questions or objections; and/or
  • Close your account and cease using the Site before the changes become effective.
• Continued use of the Site after the effective date of the updated policy will constitute your acceptance of the changes, to the extent permitted by law.

REFLECT: This AU-facing Privacy Policy complements the global Asino Casino privacy information available via our main brand website. In the event of any inconsistency for users of https://asinobet-au.com, this document will prevail.

Last updated: 06 November 2026