Privacy Policy

1. Introduction

clytharosjourney Limited ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our social casino entertainment platform (the "Platform").

This Privacy Policy complies with the General Data Protection Regulation (GDPR) and the New Zealand Privacy Act 2020. By using our Platform, you consent to the data practices described in this policy.

We are the data controller responsible for your personal information. If you have any questions about this Privacy Policy or our data practices, please contact us at privacy@clytharosjourney.com.

2. Information We Collect

2.1 Personal Data

We may collect the following personal information that you voluntarily provide to us:

• Account Information: Name, email address, username, password, date of birth (to verify 18+ age requirement)
• Contact Information: Email address, phone number (if provided)
• Profile Information: Profile picture, preferences, settings
• Communication Data: Your communications with us, including support requests and feedback

2.2 Usage Data

We automatically collect certain information when you use the Platform:

• Device Information: IP address, browser type, operating system, device identifiers
• Log Data: Access times, pages viewed, features used, clicks, and interactions
• Gaming Activity: Games played, virtual currency activity, progress, achievements (all for entertainment purposes only)
• Location Data: General geographic location based on IP address

2.3 Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities. For detailed information about our use of cookies, please see our Cookie Policy.

3. How We Use Your Information

We use the collected information for the following purposes:

• Provide Services: To operate and maintain the Platform, create and manage your account, and deliver entertainment services
• Age Verification: To verify that users are 18 years of age or older as required by law
• Improve Platform: To understand how users interact with the Platform and improve features, functionality, and user experience
• Communication: To send you updates, newsletters, promotional materials, and respond to your inquiries (with your consent where required)
• Safety and Security: To detect, prevent, and address technical issues, fraud, and violations of our Terms and Conditions
• Legal Compliance: To comply with legal obligations, including the NZ Gambling Act 2003 and Privacy Act 2020
• Analytics: To analyze usage patterns, generate statistics, and understand user behavior for entertainment optimization
• Personalization: To personalize your experience and provide content tailored to your preferences

4. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for the performance of our contract with you (Terms and Conditions)
• Legal Obligation: Processing is necessary to comply with legal obligations, such as age verification requirements
• Legitimate Interests: Processing is necessary for our legitimate interests, such as improving our services, security, and fraud prevention, provided these interests do not override your rights

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in operating the Platform, including:

• Cloud Hosting Services: For secure data storage and Platform infrastructure
• Analytics Providers: Such as Google Analytics, to understand Platform usage and improve services
• Customer Support Tools: To provide efficient support and respond to inquiries
• Email Services: To send communications and updates
• Security Services: To protect against fraud and ensure Platform security

These third parties are contractually obligated to use your information only for the purposes we specify and to protect your data.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, such as:

• Complying with legal obligations or court orders
• Protecting our rights, property, or safety
• Investigating potential violations of our Terms and Conditions
• Preventing fraud or illegal activities

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and ensure your data remains protected.

5.4 No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

6. Data Storage and Security

6.1 Security Measures

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure server infrastructure with regular security updates
• Access controls and authentication procedures
• Regular security audits and monitoring
• Employee training on data protection and security

6.2 Data Security Limitations

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

6.3 Your Responsibility

You are responsible for maintaining the confidentiality of your account credentials. Please use a strong password and do not share your account information with others.

7. Your Rights

Under GDPR and the NZ Privacy Act 2020, you have the following rights regarding your personal data:

7.1 Right to Access

You have the right to request access to the personal information we hold about you and receive a copy of that information.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information.

7.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.

7.4 Right to Object

You have the right to object to the processing of your personal information for direct marketing purposes or based on legitimate interests.

7.5 Right to Data Portability

You have the right to request that we transfer your personal data to another organization or directly to you in a structured, commonly used, and machine-readable format.

7.6 Right to Restrict Processing

You have the right to request restriction of processing of your personal information under certain circumstances.

7.7 Right to Withdraw Consent

Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time.

7.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at privacy@clytharosjourney.com. We will respond to your request within 30 days. You may also have the right to lodge a complaint with your local data protection authority.

8. Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience on the Platform. Cookies help us understand how you use the Platform, remember your preferences, and provide personalized content.

You can control cookie settings through your browser preferences. However, disabling certain cookies may affect the functionality of the Platform.

For comprehensive information about the cookies we use, their purposes, and how to manage them, please refer to our Cookie Policy.

9. Children's Privacy

The Platform is strictly for users aged 18 years and older. We do not knowingly collect personal information from individuals under 18 years of age.

If we discover that we have inadvertently collected personal information from someone under 18, we will delete that information immediately.

If you are a parent or guardian and believe that your child under 18 has provided us with personal information, please contact us at privacy@clytharosjourney.com so we can take appropriate action.

10. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction.

When we transfer personal data internationally, we ensure appropriate safeguards are in place to protect your information in accordance with GDPR and NZ Privacy Act 2020 requirements, including:

• Standard contractual clauses approved by the European Commission
• Ensuring recipients are located in countries with adequate data protection levels
• Implementing additional security measures as necessary

11. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

• Account Data: Retained while your account is active and for a reasonable period afterward to comply with legal obligations
• Usage Data: Typically retained for up to 2 years for analytics and improvement purposes
• Communication Records: Retained for up to 3 years for customer service and legal compliance
• Legal Requirements: Some data may be retained longer to comply with legal, accounting, or regulatory requirements

When personal information is no longer needed, we will securely delete or anonymize it.

12. Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy on the Platform with a new "Last Updated" date
• Sending you an email notification (if you have provided your email address)
• Displaying a prominent notice on the Platform

Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

13. Contact for Privacy Matters

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

clytharosjourney Limited
Data Protection Officer
Social Gaming Entertainment Platform
Privacy Email: privacy@clytharosjourney.com
General Support: support@clytharosjourney.com

We are committed to working with you to obtain a fair resolution of any privacy concerns.