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Privacy Policy

This privacy policy explains how winward-casino-new-zealand, operating exclusively via winward-nz.com, collects, uses, discloses, and protects personal information of players and website visitors in accordance with applicable New Zealand privacy laws and industry standards. It applies to all users of our services and website as of the effective date: 6 November 2025.

Who We Are

OBSERVE: winward-casino-new-zealand is operated by Blacknote Entertainment Group Limited, acting solely in connection with winward-nz.com for New Zealand clients. EXPAND: Due to publicly unverifiable registration and licensing details (see below), this privacy policy is based on best available corporate information. REFLECT: All personal data processing is managed through our online presence.

  • Legal entity: Blacknote Entertainment Group Limited
  • Website: winward-nz.com
  • Parent company: Blacknote Entertainment Group Limited
  • Subsidiaries: Casino Moons, Thebes Casino, 7Reels Casino, Rich Casino
  • Legal address: Not specified (pending official disclosure)
  • Company registration number: Not specified
  • Game licenses: Curaçao (unverifiable, likely expired or invalid); Costa Rica (not a recognized gaming license)
  • Contact (Data Protection):
  • Data Protection Officer (DPO): Contactable via the emails above; specific DPO not named (pending assignment)

Regional Compliance Note: All data processing is conducted in accordance with the New Zealand Privacy Act 2020 and relevant international standards.

What Personal Data We Collect

OBSERVE: winward-casino-new-zealand collects data necessary to provide, secure, and improve its online gaming services. EXPAND: Data categories cover personal, technical, payment, and behavioral information, as well as cookies and similar technologies. REFLECT: Collection is limited to data required for legitimate casino operations and compliance.

  • Personal Data: Full name, date of birth, email address, phone number, mailing address (if provided), account credentials.
  • Technical Data: IP address, device identifiers, browser type, operating system, access times, server logs.
  • Payment Data: Bank account details, payment card numbers (partially masked), transaction records, withdrawal and deposit history.
  • Behavioral Data: Betting and gaming history, account activity, transaction patterns, website navigation, clickstream data.
  • Cookies & Tracking: Session cookies, persistent cookies, third-party cookies, web beacons, analytics tags, advertising trackers.
  • KYC/AML Documentation: Identity verification documents, proof of address, source of funds (where legally required).

Legal Basis for Processing

OBSERVE: Processing of personal data by winward-casino-new-zealand is strictly regulated under NZ Privacy Act 2020 and aligned with international standards. EXPAND: Multiple legal grounds are applied, depending on the nature and context of processing. REFLECT: Our processing is always based on at least one lawful basis as outlined below.

  1. User Consent: Personal data may be processed where explicit consent is provided (e.g., for marketing communications, optional surveys). Users may withdraw consent at any time.
  2. Contractual Necessity: Processing is required for the performance of a contract, including account registration, provision of gaming services, processing of payments and withdrawals, and customer support.
  3. Legitimate Interests: Data may be processed to prevent fraud and abuse, improve website functionality, carry out analytics, and protect the security of our systems, provided these interests do not override user rights.
  4. Legal Obligations: Compliance with applicable laws and regulations, including anti-money laundering (AML), know-your-customer (KYC) requirements, and reporting to regulatory authorities.

Regional Compliance Note: Where required, processing is also aligned with GDPR principles to ensure cross-border adequacy for NZ users.

Purpose of Processing

OBSERVE: Data is processed to provide, maintain, and enhance winward-casino-new-zealand services via winward-nz.com. EXPAND: Purposes include operational, legal, and marketing functions. REFLECT: All processing is limited to legitimate business purposes.

  • Service Provision: Account creation, identity verification, enabling deposits and withdrawals, delivering gaming services.
  • Customer Support: Responding to inquiries, resolving complaints, providing technical support.
  • Service Improvement: Analyzing user behavior to optimize website functionality and user experience.
  • Marketing & Promotions: Sending offers, newsletters, and targeted advertisements (with user consent).
  • Analytics: Statistical analysis, trend monitoring, business intelligence.
  • Fraud & Risk Management: Monitoring for suspicious activity, enforcing account security, complying with AML/KYC regulations.
  • Legal Compliance: Fulfilling regulatory reporting requirements and cooperating with lawful investigations.

Disclosure & Sharing

OBSERVE: winward-casino-new-zealand safeguards personal data and only shares it where legally required or operationally necessary. EXPAND: Disclosures are made to trusted third parties under strict contractual obligations. REFLECT: No data is sold to third parties for commercial gain.

  • Payment Partners: Banks, payment processors, and financial institutions for processing deposits, withdrawals, and anti-fraud checks.
  • Service Providers: IT support, hosting providers, analytics platforms, customer communication services.
  • Regulators & Authorities: Government regulators, law enforcement agencies, and other authorities where required by law or to protect legal rights.
  • Affiliates: Subsidiaries and business partners within Blacknote Entertainment Group Limited for operational efficiency, subject to confidentiality agreements.
  • Advertising Networks: Third-party advertising partners, only with user consent, for promotional and retargeting purposes.

Protective Clause: All third parties are contractually bound to protect user data and use it solely for specified, lawful purposes.

International Transfers

OBSERVE: Personal data may be transferred and processed in countries outside New Zealand, including within the operational jurisdictions of Blacknote Entertainment Group Limited. EXPAND: Main processing locations may include Curaçao, Costa Rica, and other countries where our service providers are based. REFLECT: We implement robust safeguards to ensure data remains protected in accordance with NZ and international standards.

  1. Countries/Regions: Data may be transferred to and processed in Curaçao, Costa Rica, EU/EEA countries, and other locations as required for service provision.
  2. Protection Measures:
    • Standard contractual clauses (SCCs) approved by the New Zealand Privacy Commissioner (or equivalent safeguards) are used where appropriate.
    • Third-party processors are required to comply with strict data protection standards, including ISO 27001 or comparable certifications where available.
    • Data transfers are only conducted where adequate protection of user privacy can be ensured.

Regional Compliance Note: Where data is transferred internationally, we ensure compliance with both NZ Privacy Act 2020 and relevant international frameworks.

Data Retention

OBSERVE: winward-casino-new-zealand retains personal data only as long as necessary for the purposes outlined in this policy and to meet legal requirements. EXPAND: Retention periods are reviewed regularly and data is securely deleted or anonymized when no longer required. REFLECT: Users may request deletion or restriction in accordance with legal limitations.

  • Personal Data: Retained for up to 5 years following account closure to comply with AML, KYC, and regulatory obligations, unless a longer period is required by law.
  • Payment Data: Retained for 7 years for financial auditing and anti-fraud purposes.
  • KYC/AML Documentation: Retained for at least 5 years post-transaction or account closure, in line with applicable laws.
  • Cookies & Technical Data: Session cookies are deleted upon browser closure; persistent cookies and analytics data retained for up to 2 years.
  • Deletion Criteria: Data is deleted or anonymized upon (a) user request (except where legally prohibited), (b) expiration of retention period, or (c) when processing purpose has been fulfilled.

Protective Clause: Data subject to ongoing legal proceedings or investigations may be retained until resolution.

Your Rights

OBSERVE: winward-casino-new-zealand upholds all user rights under the NZ Privacy Act 2020, with reference to GDPR principles and Mexican privacy law where applicable. EXPAND: The following rights are available to all data subjects, with free-of-charge exercise and clear procedures. REFLECT: All requests are addressed within 30 days of receipt.

  1. Right of Access: Obtain confirmation of whether your data is being processed and request a copy of your personal data.
  2. Right to Rectification: Request correction of inaccurate or incomplete personal data.
  3. Right to Erasure: Request deletion of personal data where processing is no longer necessary, or upon withdrawal of consent (subject to legal retention obligations).
  4. Right to Restrict Processing: Request restriction of processing in certain circumstances (e.g., contesting accuracy, objection to processing).
  5. Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
  6. Right to Data Portability: Request to receive your personal data in a structured, machine-readable format.
  7. Right to Withdraw Consent: Withdraw consent for marketing or other optional processing at any time without affecting the lawfulness of prior processing.
  8. Procedures:
    • Submit requests via the contact details in the "Complaints & Contacts" section.
    • All requests are processed within 30 days; complex requests may be extended by up to 60 days with notice.
    • No fee is charged for exercising these rights, except where requests are manifestly unfounded or excessive.

Reference: NZ Privacy Act 2020; GDPR (EU 2016/679); Mexican Federal Law on Protection of Personal Data Held by Private Parties (where applicable).

Cookies & Tracking Technologies

OBSERVE: winward-casino-new-zealand uses cookies and similar technologies to enhance user experience on winward-nz.com. EXPAND: Users are informed about the types, purposes, and management of cookies. REFLECT: Consent is obtained where required; users retain control over cookie preferences.

  • Session Cookies: Enable essential website functionality; expire when browser is closed.
  • Persistent Cookies: Retain user preferences and login status; expire after a set period (up to 2 years).
  • Third-Party Cookies: Used for analytics, advertising, and social media integration; subject to third-party privacy practices.
  • Purposes: Website functionality, analytics (e.g., Google Analytics), marketing, and user personalization.
  • Management: Cookies can be managed or disabled via browser settings or internal account panels (where available). Blocking cookies may affect website functionality.

Data Security

OBSERVE: winward-casino-new-zealand employs robust technical and organizational measures to protect personal data. EXPAND: Security practices are aligned with international standards and adapted to emerging threats. REFLECT: Continuous improvement and staff training underpin our security posture.

  1. Encryption: All data transmitted over winward-nz.com is protected with TLS 1.2 or higher. Data at rest is also encrypted using industry best practices.
  2. Authentication & Access Controls: Multi-factor authentication for staff access; strict role-based permissions to minimize exposure.
  3. Security Audits: Regular internal and external security assessments, including vulnerability scans and penetration testing.
  4. Incident Response: Documented incident response plan, including immediate notification to affected users and authorities as required.
  5. Employee Training: Ongoing staff education programs on privacy, data protection, and cyber security.
  6. Compliance: Alignment with ISO 27001 and SOC 2 controls where applicable; regular review of security framework.

Protective Clause: While all reasonable measures are taken, users acknowledge that no internet transmission is entirely secure. Any security incidents are managed transparently and in accordance with legal obligations.

Complaints & Contacts

OBSERVE: winward-casino-new-zealand provides multiple channels for privacy-related inquiries and complaints. EXPAND: Clear procedures and escalation pathways are established to ensure user rights are respected. REFLECT: Complaints are addressed promptly and transparently.

  1. Initial Contact: Users should submit privacy-related requests or complaints to:
  2. Complaint Procedure:
    • Submit a written complaint or inquiry with clear details of the issue.
    • All complaints are acknowledged within 5 business days.
    • Substantive responses are provided within 30 days of receipt.
    • If further investigation is required, users will be informed of any delays and interim steps.
  3. Escalation: If not satisfied with the response, users may escalate to:

Free-of-Charge: All complaint procedures are free of charge unless requests are manifestly unfounded or excessive.

Updates

OBSERVE: winward-casino-new-zealand regularly reviews and updates this privacy policy to reflect changes in legal requirements and business practices. EXPAND: Users are notified of material changes in advance and provided with clear options. REFLECT: The most current version is always available on winward-nz.com.

  • Notification Methods: Updates communicated via email notifications, website banners, and account dashboard alerts (where registered).
  • Version Control:
    • Last updated: 6 November 2025
    • Changelog:
      • Material changes to processing purposes, data sharing practices, or user rights will be documented with a summary of amendments.
  • Advance Notice: At least 30 days' advance notice is provided for significant changes, allowing users to object or close their accounts if desired.
  • User Options: Users may contact support to object to changes or request account closure at any time.

Continued use of winward-nz.com after the effective date of any update constitutes acceptance of the revised policy.