Privacy Policy
This privacy policy is designed to inform players and website visitors of skycrown.games about how their personal information is collected, used, stored, and protected. Proper privacy practices are essential to ensure compliance with Australian law and industry standards, and to maintain user trust and regulatory approval. This policy applies to all individuals interacting with skycrown.games and takes effect on 1 January 2025.
Who We Are
OBSERVE: We present the operator's formal details, secure legal identification, and compliant contact points.
EXPAND: Legal registration supports jurisdictional accountability; providing Data Protection Officer (DPO) contact ensures user rights under privacy law.
REFLECT: This section clearly establishes the legal entity operating skycrown.games and how to reach the responsible contact for personal data queries.
- Operator Legal Identity: skycrown.games is owned and operated by Hollycorn N.V., a company registered in Curaçao (Company Registration Number: 144359), with the registered office at Scharlooweg 39, Willemstad, Curaçao.
- Gaming Licence: Licensed and regulated by the Curaçao Gaming Control Board (Licence No. OGL/2023/176/0095, valid until 2025).
- Data Protection Contact: For privacy or data protection inquiries, contact our Data Protection Department at [email protected]. For support matters, email [email protected].
What Personal Data We Collect
OBSERVE: We catalogue the full range of data categories needed for operation and compliance.
EXPAND: Including all user and technical data required by industry practices and AU law (e.g. Anti-Money Laundering, KYC).
REFLECT: Comprehensive transparency on data collection is ensured for legal validity and informed consent.
- Personal Identification Data: Full name, date of birth, e-mail address, phone number, physical address, account registration data.
- Technical Data: IP address, device identifiers, browser type, log files, access times, geolocation data as permitted.
- Payment and Financial Data: Payment card details, transaction history, withdrawal and deposit records, billing data.
- Behavioral and Usage Data: Betting and gaming history, navigation paths, site interaction (clicks, session duration), responsible gambling activity logs.
- Cookies & Tracking Data: Information from first-party and third-party cookies, analytics tags, tracking pixels, and similar online identifiers.
Legal Basis for Processing
OBSERVE: Specify the lawful grounds supporting all data use on skycrown.games.
EXPAND: Ensure coverage of all reasons required by Australian privacy law and gambling sector common standards.
REFLECT: Explicit legal justification supports user rights and regulatory defence.
- User Consent: We rely on your explicit consent for processing certain information, such as for marketing communications, cookies, and some optional services. Consent is collected via website forms and can be withdrawn at any time.
- Contractual Necessity: To provide casino services (account creation, identity verification, deposits, withdrawals, gameplay, and customer support), processing of your data is required to execute and perform our contract with you.
- Legitimate Interests: We process essential data to detect and prevent fraud or abuse, to maintain technical security, and to improve and personalise our website and gaming services. Legitimate interest assessments are undertaken to ensure user rights are safeguarded.
- Compliance with Legal Obligations: As an AU-facing operator, and under Curaçao licence terms, we must comply with anti-money laundering (AML), Know Your Customer (KYC), taxation, regulatory reporting, and other statutory duties. Processing is mandatory for these purposes.
Regional Compliance Note: This alignment ensures full compliance with relevant Australian privacy principles (APPs), gaming regulations, and international legal standards.
Purpose of Processing
OBSERVE: List every operational reason for data processing by skycrown.games.
EXPAND: Identify implicit purposes (e.g., regulatory audits, risk management).
REFLECT: All declared purposes are legally and practically necessary for casino operation.
- Account Registration & Management: Creating, verifying, and managing player accounts on skycrown.games.
- Casino Service Delivery: Enabling and supporting gameplay, transactions, payouts, and responsible gambling measures.
- Service Improvement & Analytics: Analysing website and game performance, usage trends, site optimisation, and product development.
- Marketing Communications: Sending promotional offers and communications in accordance with your preferences (always with consent and opt-out ability).
- Fraud Prevention & Security: Monitoring, investigating, and preventing fraudulent or suspicious activity, and ensuring system security and regulatory compliance.
Disclosure & Sharing
OBSERVE: Identify every category of third party or public authority with whom data may be shared.
EXPAND: Ensure risk-based access, consent for marketing partners, and audit trails for regulatory bodies.
REFLECT: Data disclosures occur solely as permitted or required under law and contract.
- Payment Processors & Banking Partners: Your payment data is shared securely with vetted payment service providers to process deposits, withdrawals, and financial transactions as necessary for account operations.
- Service Providers & IT Contractors: Data may be processed by cloud hosting, technical support, analytics, or software development contractors, strictly limited by agreement to necessary purposes only.
- Regulatory and Law Enforcement Authorities: We may disclose data to AU authorities or under the requirements of our licensing body (Curaçao Gaming Control Board) for investigations, audits, legal processes, or regulatory submission.
- Affiliates & Advertising Networks: Information may be shared with affiliates and marketing networks exclusively with your explicit consent, for the delivery of tailored promotions or advertisements.
- Corporate Transactions: In the event of mergers, acquisitions, or asset transfers, your data may be shared with counterparties provided confidentiality and regulatory compliance are maintained.
International Transfers
OBSERVE: Clarify all relevant data flows outside Australia and organisational controls.
EXPAND: Ensure robust safeguard mechanisms and transparent user notice under GDPR-equivalent and Australian obligations.
REFLECT: Data safety and legal adequacy are central to all international transfers performed by skycrown.games.
- Countries of Transfer: Personal data may be transmitted to Curaçao (primary processing location), the European Economic Area (EEA), and other jurisdictions where our service providers operate.
- Protection Mechanisms: All international transfers are governed by legally binding agreements incorporating Standard Contractual Clauses (SCCs), ensuring data continues to enjoy comparable protection as required under the Australian Privacy Act and international norms.
- Third-Party Controls: Contractors are required to implement robust security measures and comply with all relevant data privacy legislation.
Regional Compliance Note: These transfer protections fulfil obligations under the Australian Privacy Principles (cross-border disclosures), ensuring adequate safeguarding of Australian users' information.
Data Retention
OBSERVE: Define retention schedules per data type.
EXPAND: Include regulatory retention mandates and scenarios allowing earlier lawful deletion.
REFLECT: Data is not stored longer than allowed by law or necessary for business and regulatory purposes.
- Personal Identification and KYC Data: Retained for the active lifetime of the player account and for a period of no more than 5 years after account closure, as required for anti-money laundering, legal, and fraud-prevention audits.
- Gaming and Transaction Data: Kept for 5 years following the last transaction, in accordance with regulatory recordkeeping obligations.
- Marketing Preferences and Consents: Stored until withdrawal of consent or deletion of account, whichever occurs sooner.
- Cookies and Tracking Data: Retained per type (see Cookies & Tracking), typically from session end up to a maximum of 2 years for analytics or advertising purposes.
- Deletion Criteria: Data is promptly deleted when no longer necessary for stated purposes, upon expiration of regulatory periods, or upon verified and lawful user request, except when retention is required by law or ongoing dispute resolution.
Regional Compliance Note: Retention terms are consistent with the Australian Privacy Act (as amended) and regulatory recordkeeping guidelines for the gambling sector as valid till 2025.
Your Rights
OBSERVE: Ensure clarity and accessibility of all recognised user rights.
EXPAND: Provide actionable instructions, cover all privacy rights under AU law and international best practices.
REFLECT: Rights are central to user control; we facilitate all requests promptly and lawfully.
- Right of Access: You may request confirmation of whether your data is processed and obtain a full copy of your personal information held by skycrown.games.
- Right to Correction: You may request rectification of inaccurate or incomplete personal data at any time.
- Right to Erasure (Deletion): You may request deletion of your data where it is no longer required for its original purpose or when consent is withdrawn, subject to legal retention obligations.
- Right to Restrict Processing: You may request temporary restriction of processing in cases such as contesting data accuracy or objecting to certain uses.
- Right to Object: You may object to processing for direct marketing or based on legitimate interests.
- Right to Data Portability: You are entitled to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller, where technically feasible.
- Right to Withdraw Consent: You may withdraw your marketing consent at any time via account settings or by contacting [email protected].
Request Procedure: Submit requests by contacting our data protection team at [email protected]. We respond within legally mandated timeframes, subject to identification and applicable exemptions.
Cookies & Tracking Technologies
OBSERVE: Inform users about all cookies used, their functions, and control mechanisms.
EXPAND: Clarify cookie categories and third-party involvement to meet AU and global standards.
REFLECT: User transparency and consent underpin lawful online tracking.
-
Types of Cookies:
- Session Cookies: Temporary cookies deleted upon browser closure, used to maintain secure logins and gameplay sessions.
- Persistent Cookies: Remain on your device up to 2 years, supporting user preferences and faster site access.
- Third-Party Cookies: Set by analytics and advertising partners, assisting in performance assessment and serving tailored ads (only with explicit consent).
-
Purposes:
- Functional: Enabling critical site functions, recognizing returning users, and saving preferences.
- Analytics: Understanding how visitors use skycrown.games to inform service improvements.
- Advertising: Supporting targeted marketing in line with user consent and legal requirements.
- Managing Cookies: You can manage cookie preferences via your web browser's settings to block or erase cookies or via the internal control panel (where available on skycrown.games). Rejecting some cookies may impact your site experience.
Regional Compliance Note: Cookie usage and management options are compliant with the Australian Privacy Act and OAIC guidance concerning online tracking and consent requirements valid through 2025.
Data Security
OBSERVE: Specify every technical and organisational measure in place.
EXPAND: Include external audit, staff training, and compliance monitoring.
REFLECT: Security controls are appropriate to casino risk and sensitive data involved.
- SSL/TLS Encryption: All traffic, registration, and payment processes on skycrown.games are secured via strong SSL/TLS encryption, ensuring confidentiality and integrity.
- Data at Rest Encryption: Sensitive data is encrypted when stored in our systems or in secure third-party hosting.
- Access Restrictions: Access to personal data is tightly controlled, limited to authorised employees, and based on role necessity. Additional authentication is enforced for sensitive functions.
- Organisational Policies: All staff undergo regular data privacy and security training. Internal policies and procedures are reviewed for ongoing legal compliance with AU standards.
- Security Audits: Regular technical and operational audits are conducted to identify and proactively address vulnerabilities.
- Incident Response: A documented breach response protocol enables rapid containment, investigation, and notification compliant with mandatory Australian Notifiable Data Breaches (NDB) requirements.
Complaints & Contacts
OBSERVE: Include clear instructions for raising concerns and formal complaint processes.
EXPAND: Support user rights with direct and documented communications.
REFLECT: Effective redressal protects users and demonstrates regulatory good faith.
- Privacy Enquiries: Direct all privacy or data protection questions to our Data Protection Department at [email protected]. General or support queries may be sent to [email protected].
- Complaint Procedure: Complaints should be submitted in writing by email. We investigate all complaints and will respond with a resolution or explanation within 30 days, in line with Australian privacy legislation.
- Regulatory Referral: If you remain dissatisfied after our response, you may escalate your complaint by contacting the Office of the Australian Information Commissioner (www.oaic.gov.au) or an equivalent supervisory authority.
Updates
OBSERVE: Set forth clear update mechanisms and notification standards.
EXPAND: Include both proactive and retroactive notice as required under AU law.
REFLECT: Transparency protects users and ensures continued compliance.
- Policy Changes: We may amend this privacy policy at any time, particularly to reflect legal developments or service changes. Substantial changes will be communicated by notice on skycrown.games and, where material, by email prior to their effective date.
- Effective Date: This policy is effective as of 1 January 2025. The most recent revision date will be displayed at the top of the policy.
For ongoing reference, please periodically review this page for the most up-to-date information regarding our privacy practices.