Privacy Policy

1. Introduction

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

This Privacy Policy complies with the New Zealand Privacy Act 2020 and the European Union General Data Protection Regulation (GDPR) where applicable.

By using the Platform, you consent to the data practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide to Us

When you register for an account or use certain features, we may collect:

• Account Information: Email address, password (encrypted), and optionally a username or display name
• Profile Information: Any additional information you choose to provide in your profile
• Communication Data: Information you provide when you contact us, including your name, email, and message content
• Preferences: Your communication preferences and settings

2.2 Information Collected Automatically

When you access the Platform, we automatically collect certain information:

• Device Information: Device type, operating system, browser type and version, unique device identifiers
• Usage Data: Pages visited, time spent on pages, links clicked, gameplay activity, features used
• Log Data: IP address, access times, referring website addresses
• Cookies and Similar Technologies: We use cookies and similar tracking technologies. See our Cookie Policy for details

2.3 Virtual Currency and Gameplay Data

• Virtual coin balances and transaction history (all virtual, no real money)
• Game play history, progress, and achievements
• Social features usage (friends, leaderboards, etc.)

2.4 Information We Do NOT Collect

We do NOT collect:

• Payment or financial information (no real money transactions)
• Sensitive personal information (race, ethnicity, political opinions, religious beliefs, health data)
• Real gambling data (as this is not a gambling platform)

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Provide and Maintain the Platform

• Create and manage your account
• Provide access to games and features
• Track virtual currency and game progress
• Enable social features and interactions

3.2 Improve and Personalize Your Experience

• Analyze usage patterns to improve the Platform
• Develop new features and games
• Personalize content and recommendations
• Troubleshoot technical issues

3.3 Communication

• Respond to your inquiries and support requests
• Send important updates about the Platform (with your consent)
• Send promotional communications about new features or bonuses (only if you opt-in)

3.4 Safety and Security

• Monitor and prevent fraudulent activity
• Enforce our Terms and Conditions
• Protect against security threats
• Ensure compliance with legal obligations

3.5 Legal Compliance

• Comply with applicable laws and regulations
• Respond to legal requests and prevent harm
• Verify age requirements (18+ platform)

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area, our legal basis for processing personal information includes:

• Consent: You have given consent for processing for specific purposes (e.g., marketing communications)
• Contractual Necessity: Processing is necessary to provide the Platform services
• Legal Obligation: Processing is required to comply with legal obligations
• Legitimate Interests: Processing is necessary for our legitimate interests (e.g., improving the Platform, preventing fraud)

5. How We Share Your Information

5.1 We Do NOT Sell Your Personal Information

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

5.2 Service Providers

We may share information with trusted third-party service providers who assist us in:

• Website hosting and maintenance
• Data analytics and platform improvement
• Customer support services
• Email communication services

These service providers are contractually obligated to protect your information and use it only for the services they provide to us.

5.3 Game Providers

Some games are provided by third-party software providers. Minimal necessary information may be shared to enable gameplay.

5.4 Legal Requirements

We may disclose your information if required by law or in response to:

• Legal processes (court orders, subpoenas)
• Government or regulatory requests
• Protection of our rights, property, or safety
• Investigation of fraud or security issues

5.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

6. Data Security

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

• Encryption of data in transit (SSL/TLS)
• Secure password storage (hashed and salted)
• Regular security assessments and updates
• Access controls and authentication
• Monitoring for suspicious activity

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

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide the Platform services
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Maintain security and prevent fraud

When you delete your account, we will delete or anonymize your personal information within a reasonable timeframe, except where we are required to retain it by law.

8. Your Privacy Rights

Under the New Zealand Privacy Act 2020 and GDPR (for EU residents), you have the following rights:

8.1 Right to Access

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

8.2 Right to Correction

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

8.3 Right to Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations).

8.4 Right to Restrict Processing

You have the right to request restriction of processing in certain circumstances.

8.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format.

8.6 Right to Object

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

8.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time.

8.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at support@deynoraxspectra.com with the subject line "Privacy Rights Request". We will respond within the timeframes required by applicable law (generally 30 days).

9. Children's Privacy

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

If we become aware that we have collected personal information from someone under 18, we will take steps to delete that information promptly.

If you believe we have collected information from a child under 18, please contact us immediately.

10. International Data Transfers

Your information may be transferred to and processed in countries other than New Zealand. We ensure that such transfers comply with applicable data protection laws and that appropriate safeguards are in place.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on the Platform. For detailed information about our use of cookies, please see our Cookie Policy.

12. Third-Party Links

The Platform may contain links to third-party websites (such as responsible gaming resources). This Privacy Policy does not apply to those external sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

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

• Posting the updated Privacy Policy on the Platform
• Updating the "Last Updated" date
• Sending you an email notification (if you have an account)

Your continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

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

deynorax spectra Limited
Privacy Officer
New Zealand

Email: support@deynoraxspectra.com
Subject Line: Privacy Inquiry

15. Regulatory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with:

• New Zealand: Office of the Privacy Commissioner (www.privacy.org.nz)
• EU Residents: Your local data protection authority