Privacy Policy

This Privacy Policy explains how 22 Ricky Casino, operated via the website 22ricky-aussie.com (referred to as "we", "us", "our" or "22 Ricky Casino"), collects, uses, discloses, and protects personal information of players and other visitors to our website. It applies to all users who access or use our services, including browsing, registering an account, depositing or withdrawing funds, or participating in any gambling activities via 22ricky-aussie.com. By using our website, you acknowledge and agree to the practices described in this Privacy Policy. This Privacy Policy is effective as of 1 January 2026 and replaces any previous versions published on our website.

Who We Are

OBSERVE: Identify the legal entities, locations, license, and contact channels responsible for data processing. EXPAND: Clarify controller roles (operator vs. payments processor) and designate a contact for privacy matters. REFLECT: Present clear corporate and contact data so users know who holds their information and how to reach them.

Operator and Corporate Structure

• Data controller (casino operations): Dama N.V., a public limited company incorporated under the laws of Curaçao Registered address: Scharlooweg 39, Willemstad, Curaçao Company registration number: 152125 E-gaming licence: 8048/JAZ2020-013, issued by Antillephone N.V., Curaçao (status: valid, last verified May 2025, assumed valid through 31 December 2026).
• Payments and billing agent: Friolion Limited, a limited liability company incorporated in Cyprus Registration number: HE 419102, Cyprus. Friolion Limited acts as a payments processor and service company for Dama N.V. and may handle your payment-related data.

Contact for Privacy and Data Protection

• Primary contact for privacy matters (Data Protection contact):
  Email: [email protected] (general and privacy enquiries)
  Support email: [email protected] (player account and rights requests)
  Payments email: [email protected] (payment- and billing-related queries).
• Postal contact (operator):
  Dama N.V., Scharlooweg 39, Willemstad, Curaçao.
• We have appointed an internal data protection contact within our compliance department who can be reached via [email protected]. While not an EU-registered DPO, this contact is responsible for coordinating responses to privacy requests and complaints.

Regional compliance note: 22 Ricky Casino offers services to players in Australia on an offshore basis under Curaçao law. Australian-specific regulatory resources, such as the Australian Communications and Media Authority (acma.gov.au) and federal legislation (legislation.gov.au), are referenced for informational purposes but we are not licensed by any Australian regulator.

What Personal Data We Collect

OBSERVE: Identify all categories of information processed in the course of running an online casino. EXPAND: Include account, technical, financial, behavioural, and cookie-related data. REFLECT: Group these into clear categories with practical examples for transparency.

Identity and Contact Data

• Full name, date of birth, gender (where provided).
• Residential address, country of residence, and nationality (as required for KYC/AML checks).
• Email addresses, telephone numbers, and other contact details provided during registration or support interactions.
• Identity verification data: copies or details of identity documents (e.g. passport, driving licence), proof of address (e.g. utility bill, bank statement), and any information you provide to verify source of funds or wealth.

Account and Usage Data

• Username, encrypted password, security questions/answers (if used), and account status.
• Login and logout timestamps, session duration, language and currency settings.
• Communication records with our support team (emails, chat transcripts, internal notes regarding complaints or disputes).

Technical and Log Data

• IP address, approximate geolocation based on IP, device identifiers, device type, operating system, browser type and version.
• Log data on access to our website and services, including pages visited, clicks, referral URLs, time and date of access, errors, and performance metrics.
• Technical identifiers generated by our platform provider (SoftSwiss) for anti-fraud, security, and session management purposes.

Payment and Financial Data

• Deposit and withdrawal records, including method (e.g. PayID/bank transfer, credit card, Neosurf, cryptocurrency), amount, currency, date, and status.
• Limited card or bank data as required for processing payments (for instance, masked card numbers, card type, issuing country). Full card details are typically processed via secure third-party payment providers.
• Cryptocurrency wallet addresses used for deposits and withdrawals.
• Verification data for AML/CTF (Anti-Money Laundering / Counter-Terrorist Financing) purposes, including source of funds, occupation, and related documentation where required by law or our risk policies.

Behavioural and Gambling Activity Data

• Betting and gaming history, including games played, time spent, stakes, wins and losses, bonus usage, jackpot participation, and tournament activity.
• Transaction patterns, risk scores, bonus eligibility, and responsible gambling indicators (e.g. self-exclusion status, limits set, behavioural markers of harm).
• Clickstream data such as navigation paths and interaction with promotional offers, banners, and emails (e.g. open rates, click rates).

Cookies and Similar Technologies

• Cookies, web beacons, pixels, and similar technologies (see "Cookies & Tracking Technologies" section below).
• Information recorded by such technologies may include session identifiers, authentication tokens, preference settings, analytics identifiers, and advertising identifiers.

Special Categories of Data

We do not intentionally collect special categories of personal data (such as health information, political opinions, or religious beliefs). However, responsible gambling interactions (e.g. information you voluntarily share about gambling-related harm) may indirectly reveal sensitive information. Such data is handled with heightened confidentiality and used only for responsible gambling and compliance purposes.

Legal Basis for Processing

OBSERVE: Identify primary legal grounds under data protection principles (consent, contract, legitimate interest, legal obligation). EXPAND: Map these grounds to concrete processing activities (gaming operations, payments, AML). REFLECT: Explain how these bases apply to offshore gambling services offered to Australian players, with reference to international standards such as GDPR as a benchmark.

Contractual Necessity

• We process your personal data to enter into and perform a contract with you when you register and use an account at 22 Ricky Casino via 22ricky-aussie.com.
• This includes:
  • Creating and managing your player account.
  • Verifying your eligibility to use our services (e.g. age verification).
  • Processing deposits and withdrawals, including payment-related security checks.
  • Providing access to casino games and related features.
  • Providing customer support and managing complaints or disputes.

Compliance with Legal and Regulatory Obligations

• As a Curaçao-licensed operator (Dama N.V.), we are subject to local regulations, our licence conditions and obligations relating to AML/CTF, fraud prevention, and responsible gambling.
• We process identity, transactional, and behavioural data to:
  • Conduct KYC (Know Your Customer) checks.
  • Monitor transactions and gambling activity for suspicious or unlawful behaviour.
  • Prevent money laundering, terrorist financing, and other financial crimes.
  • Comply with record-keeping and reporting obligations, including audits by our licensing authority or other competent bodies.

Legitimate Interests

• We process certain data where we have a legitimate business interest, provided that such processing is not overridden by your rights and interests. These interests include:
  • Ensuring the security and integrity of our platform (fraud detection, account security, incident investigation).
  • Improving our services, website performance, and user experience (analytics, troubleshooting, product development).
  • Enforcing our Terms and Conditions, including withdrawal limits, bonus rules, and anti-abuse measures.
  • Defending our legal rights and handling legal claims or regulatory enquiries.

Consent

• In certain cases, we rely on your consent to process your personal data. This includes:
  • Sending you direct marketing communications (email, SMS, push notifications) about promotions, bonuses, and new products, where required by applicable law.
  • Using certain non-essential cookies and tracking technologies for personalised advertising or advanced analytics.
• You may withdraw your consent at any time (see "Your Rights" and "Cookies & Tracking Technologies" sections). Withdrawal will not affect the lawfulness of processing before withdrawal, but may affect certain features (e.g. receiving marketing or personalised offers).

Regional compliance note: While our primary regulatory framework is Curaçao law, we align our practices with international data protection standards (including principles found in the EU GDPR) as a benchmark. For players located in other jurisdictions, including Australia or Mexico, our processing is primarily grounded in contract and legitimate interests, supplemented by consent where required for marketing or cookies.

Purpose of Processing

OBSERVE: Identify why each category of data is needed. EXPAND: Associate purposes with concrete operations (gaming, payments, compliance, marketing). REFLECT: Provide clear and exhaustive, yet concise, descriptions to allow users to understand how their data is used.

Provision of Casino and Related Services

• Creating, managing, and operating your account at 22 Ricky Casino.
• Enabling you to deposit funds (e.g. via PayID/bank transfer, credit card, Neosurf, cryptocurrency) and withdraw winnings, subject to applicable limits and verification.
• Providing access to casino games, tournaments, and promotions, including technical support, bug fixing, and service maintenance.

Compliance, Security, and Fraud Prevention

• Conducting identity and age verification, KYC, and AML/CTF assessments.
• Monitoring gameplay and transaction patterns to detect fraud, abuse of bonuses, collusion, or prohibited activities.
• Preventing unauthorised access to accounts, securing our systems and infrastructure, and responding to security incidents.
• Meeting record-keeping, audit, and reporting requirements imposed by our licence and applicable laws.

Service Improvement and Analytics

• Analysing how users interact with our website, games, and features to improve usability, reliability, and performance.
• Aggregating and anonymising data to produce internal statistics and business intelligence (e.g. game popularity, market trends), which no longer identify individual players.
• Testing new functionalities, optimising game offerings, and tailoring the platform for the Australian market (e.g. offering PayID or specific game providers).

Marketing and Personalisation

• Sending promotional communications about bonuses, tournaments, loyalty programs, and special offers, where permitted by law and subject to your preferences.
• Segmenting users and personalising offers based on your account history, preferences, and gameplay behaviour, where allowed.
• Using cookies and similar technologies for remarketing and measuring the effectiveness of our campaigns (subject to consent where required).

Customer Support and Dispute Resolution

• Responding to your inquiries, requests, and complaints via email or other support channels.
• Investigating and resolving disputes, chargebacks, responsible gambling concerns, or suspected breaches of our Terms and Conditions.
• Maintaining records of support interactions for quality assurance, training, and evidentiary purposes.

Disclosure & Sharing

OBSERVE: Identify all third parties who may receive personal data. EXPAND: Categorise them (payments, infrastructure, regulators, affiliates) and clarify conditions for sharing. REFLECT: Explain safeguards, limitations, and offshore nature of some recipients.

Payment Service Providers and Financial Institutions

• We share necessary payment and identity data with:
  • Banks and financial institutions processing PayID/bank transfers or card payments.
  • Neosurf and other voucher/alternative payment providers.
  • Cryptocurrency processors and wallet service providers, where used.
• These partners process your data as independent controllers or processors, under their own legal and regulatory obligations.

Technical and Infrastructure Providers

• Our core platform is provided by SoftSwiss (or a related technology provider), which processes data necessary to operate the casino games, wallet, and user interface.
• We use hosting, cloud, security, and analytics services (e.g. SSL/Cloudflare, logging and monitoring tools) that may process your IP address and technical data to ensure availability, performance, and security.

Regulators, Authorities, and Dispute Bodies

• We may disclose your data to:
  • Our licensing authority and related bodies in Curaçao (e.g. Antillephone N.V.) for audits, complaints, and compliance checks.
  • Law enforcement agencies, courts, or government authorities where required by applicable law, court order, or legal process.
  • Fraud prevention agencies and other operators, where permitted, to combat fraud, money laundering, or integrity breaches.

Affiliates, Marketing, and Advertising Partners

• We may share limited data (usually pseudonymised or aggregated) with:
  • Affiliate partners who refer players to 22ricky-aussie.com, for tracking and commission calculation.
  • Marketing and advertising networks for campaign optimisation and attribution.
• Where required by law, we only engage in personalised marketing or advertising with your consent.

Group Companies and Corporate Transactions

• We may share data within the Dama N.V. group of companies, including Friolion Limited (payments) and other related entities, for operational, compliance, and administrative purposes.
• In case of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred to the relevant third parties, subject to appropriate confidentiality and data protection safeguards.

Other Disclosures

• We may share your data where you have explicitly requested or consented to such sharing.
• We may share anonymised or aggregated information that does not identify individuals for statistical, research, or marketing purposes.

International Transfers

OBSERVE: Identify cross-border data flows (Curaçao, Cyprus, other providers). EXPAND: Explain risks and safeguards in absence of local Australian or EU licences. REFLECT: Provide transparency on how we aim to protect data in a multi-jurisdictional environment.

Countries and Regions Involved

• Your personal data may be processed and stored in:
  • Curaçao - where Dama N.V. is incorporated and licensed.
  • Cyprus - where Friolion Limited operates as a payments agent.
  • Other countries - where our hosting providers, technical vendors, or partners maintain infrastructure (these may include EU member states or other jurisdictions).

Protection Measures

• We implement technical and organisational measures to protect your data during transfers, including:
  • Use of encryption (e.g. TLS/SSL) for data in transit.
  • Access controls, authentication, and logging on our systems.
  • Contractual safeguards with processors and service providers to require appropriate data protection standards.
• Where feasible, and particularly in relations with providers subject to GDPR or similar frameworks, we use standard contractual clauses or equivalent legal mechanisms as a basis for transfers.

Regional compliance note: By using 22ricky-aussie.com, you acknowledge that your data may be transferred to, stored, and processed in countries outside your jurisdiction, including Curaçao and Cyprus, which may have different data protection laws than those in Australia, the EU, or Mexico. We will take reasonable steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Data Retention

OBSERVE: Identify retention needs based on legal, contractual, and operational requirements. EXPAND: Provide indicative periods for key categories. REFLECT: Combine fixed periods with criteria-based retention (e.g. limitation periods, AML rules).

General Retention Principles

• We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including:
  • servicing your account and providing access to our games; and
  • meeting legal, accounting, and regulatory requirements.
• We also consider factors such as applicable limitation periods for legal claims, AML/CTF rules, and our legitimate interests in maintaining certain records.

Indicative Retention Periods

• Account and identity data: Normally retained for the duration of your account and for up to 5 - 7 years after account closure to comply with AML, regulatory, and tax-related requirements, and to handle potential disputes.
• Transaction and payment data: Retained for at least 5 - 7 years after the relevant transaction, in line with financial record-keeping obligations.
• Gambling and behavioural data: Retained for the duration of your account and generally for up to 5 years after closure, subject to longer retention where required for AML, dispute resolution, or regulatory investigations.
• Marketing data and preferences: Retained until you withdraw your consent or object, or after a defined inactivity period (for example, 2 years of no activity), unless we need to retain limited information to record your opt-out choice.
• Support and complaint records: Retained for up to 5 years after resolution of the issue, or longer if needed for legal defence or regulatory purposes.

Deletion and Anonymisation

• When we no longer need personal data for the specified purposes, we will:
  • securely delete or destroy it; or
  • irreversibly anonymise it so it can no longer be associated with you.
• We may retain anonymised data indefinitely for statistical and analytical purposes.

Your Rights

OBSERVE: Identify standard data subject rights (access, rectification, erasure, restriction, objection, portability, consent withdrawal). EXPAND: Align with GDPR-style rights and provide procedures and timeframes. REFLECT: Offer a clear, practical path for exercising rights, including free-of-charge guarantees and external recourse.

Overview of Your Rights

• Right of access: You can request confirmation whether we process your personal data and obtain a copy of such data, together with information about the processing.
• Right to rectification: You can request correction of inaccurate or incomplete personal data. You may also be able to update certain details directly in your account.
• Right to erasure ("right to be forgotten"): You can request deletion of your personal data where:
  • the data is no longer necessary for the purposes for which it was collected;
  • you have withdrawn consent (where processing was based on consent); or
  • you object to processing and there are no overriding legitimate grounds.
  This right is subject to our legal obligations (e.g. AML rules may require continued retention).
• Right to restriction of processing: You can request that we suspend processing in certain circumstances, for example while we verify the accuracy of data or assess an objection.
• Right to object: You can object to:
  • processing based on our legitimate interests, on grounds relating to your particular situation; and
  • processing for direct marketing, in which case we will stop such processing.
• Right to data portability: Where technically feasible and required under applicable law, you can request a copy of certain personal data in a structured, commonly used and machine-readable format, and have it transmitted to another controller.
• Right to withdraw consent: Where we rely on your consent (e.g. for marketing or non-essential cookies), you may withdraw it at any time. This will not affect prior lawful processing.

How to Exercise Your Rights

1. Submit a request: Send an email to [email protected] or [email protected] clearly stating:
   • your full name and registered email address;
   • your country of residence; and
   • the specific right(s) you wish to exercise and any relevant details.
2. Verification: For security, we may ask you to verify your identity (e.g. by confirming account information or providing identification documents) before acting on your request.
3. Response time: We will respond without undue delay and, in principle, within 30 days of receiving a complete request. For complex or multiple requests, this period may be extended by a further 30 days, in which case we will inform you of the extension and reasons.
4. Fees: We will handle your request free of charge. However, where requests are manifestly unfounded or excessive (for example, repetitive), we may charge a reasonable fee or refuse to act on the request, where permitted by applicable law.

Note on jurisdiction: Our rights framework is aligned with GDPR-style principles and, where relevant, with other privacy frameworks. For players in Mexico or the EU/EEA, you may also have additional or slightly different rights under your local data protection laws. Regardless of your location, we will make reasonable efforts to honour your rights in line with this Policy, subject to applicable legal obligations (for example, AML retention requirements).

Cookies & Tracking Technologies

OBSERVE: Identify categories of cookies and their uses. EXPAND: Distinguish necessary from analytics/advertising cookies and management options. REFLECT: Provide concise guidance on how users can control cookies via browser and internal tools.

Types of Cookies We Use

• Session cookies: Temporary cookies that are stored only for the duration of your browsing session and are deleted when you close your browser. They are essential for:
  • keeping you logged in as you navigate the site;
  • managing your game sessions; and
  • ensuring secure operation of the website.
• Persistent cookies: Cookies that remain on your device for a specified period or until you delete them. They help us:
  • remember your language and other preferences;
  • store basic account-related settings; and
  • improve usability and performance over time.
• Third-party cookies: Cookies set by service providers such as analytics platforms or advertising networks. These may collect information about your use of our site and other websites to:
  • provide aggregated statistics and performance metrics;
  • help us optimise our marketing campaigns; and
  • enable limited remarketing or advertising, subject to legal requirements and your preferences.

Purposes of Cookies

• Strictly necessary / functional: Required for the operation of the site and provision of core services (authentication, security, load balancing).
• Analytics and performance: Used to understand how visitors use the site (e.g. page views, game popularity, error logs) and to improve layout, navigation, and content.
• Advertising and personalisation: Used to tailor promotional content, measure campaign effectiveness, and, where applicable, deliver more relevant offers. These cookies are usually optional and may require your consent, depending on your jurisdiction.

Managing Cookies

• You can manage or disable cookies through your browser settings. The method varies by browser, but typically you can:
  • block all cookies;
  • block cookies from specific websites; or
  • delete cookies when you close your browser.
  Note that blocking or deleting cookies may impact the functionality of 22ricky-aussie.com, including the ability to remain logged in or access certain games.
• Where available, we may offer an internal cookie or privacy preferences panel on the website allowing you to adjust non-essential cookies and marketing preferences.

Data Security

OBSERVE: Identify key security controls (encryption, access control, audits). EXPAND: Set out organisational, technical, and procedural safeguards. REFLECT: Acknowledge residual risks while demonstrating adherence to industry best practices.

Technical and Organisational Measures

• Encryption in transit: We use TLS 1.2+ and SSL certificates (including 128-bit SSL via providers such as Cloudflare) to encrypt data transmitted between your device and our servers.
• Encryption and protection at rest: We employ industry-standard security measures to protect stored data, including access controls, network segmentation, and secure backups. Where feasible, sensitive data is encrypted or pseudonymised.
• Access control and authentication: Personal data is accessible only to authorised personnel who require access for their job functions (e.g. support, payments, compliance). Access is controlled through authentication, role-based permissions, and logging.
• Multi-factor and credential security: Administrative and critical systems are protected through additional security mechanisms (e.g. multi-factor authentication) where appropriate. Passwords are stored using cryptographic hashing.
• Security monitoring and audits: We conduct regular internal reviews, vulnerability assessments, and monitoring activities to detect potential issues, suspected abuse, or attacks.
• Staff training: Employees involved in processing personal data receive training on confidentiality, data protection, and information security, with periodic refreshers.
• Incident response: We maintain procedures for identifying, investigating, and responding to security incidents. Where a data breach poses a significant risk to your rights and freedoms, we will notify you and, where required, relevant authorities, in line with applicable laws.

Standards reference: While 22 Ricky Casino is not formally certified under ISO 27001 or SOC 2 as of 2026, our technical and organisational controls are designed with reference to these and other recognised industry standards for online gambling platforms.

Complaints & Contacts

OBSERVE: Identify channels for questions and complaints. EXPAND: Provide a structured complaint-handling process and escalation options. REFLECT: Ensure users know they can escalate to external authorities if they are dissatisfied.

How to Contact Us

• Email (primary): [email protected] - for player-related queries, rights requests, and complaints.
• Email (general/privacy): [email protected] - for general corporate and privacy enquiries.
• Email (payments): [email protected] - for issues related to deposits and withdrawals.
• Postal address: Dama N.V., Scharlooweg 39, Willemstad, Curaçao.

Complaint Procedure

1. Internal complaint: Send a detailed description of your issue to [email protected], including:
   • your full name and registered email address;
   • your username (if applicable);
   • relevant transaction or game details; and
   • a clear explanation of your concern or alleged breach.
2. Acknowledgement: We will acknowledge receipt of your complaint as soon as reasonably possible, typically within 5 business days.
3. Investigation and response: Our team will review your complaint, may request additional information if necessary, and will aim to provide a substantive response within 30 days. Complex cases may require more time; if so, we will keep you informed of progress.
4. Escalation internally: If you are not satisfied with the initial response, you may request that your complaint be escalated to our compliance or management team for a further review.

Escalation to Supervisory or External Authorities

Because 22 Ricky Casino operates under a Curaçao licence, supervisory oversight is primarily exercised by the Curaçao licensing framework (e.g. Antillephone N.V.). You may also seek advice from data protection or consumer authorities in your own country.

• Curaçao / Licensing-related: You can find licence validation information at: https://validator.antillephone.com. Specific complaint channels may be indicated there or in our Terms and Conditions.
• Australia: For information on online gambling regulation and potential consumer protections, you may consult:
  • Australian Communications and Media Authority (ACMA): https://acma.gov.au
  • Australian Government legislation portal: https://legislation.gov.au
  These bodies do not license or directly supervise 22 Ricky Casino but provide regulatory guidance and information.
• EU / EEA or Mexico: If you are located in the EU/EEA or Mexico and believe your data protection rights have been violated, you may have the right to lodge a complaint with your local data protection authority. Contact details can usually be found on your national regulator's website.

We encourage you to always contact us first so that we can attempt to resolve your issue promptly and fairly.

Updates

OBSERVE: Identify need for periodic updates. EXPAND: Clarify notification methods, version control, and advance notice for material changes. REFLECT: Provide transparency on how players will be informed and what options they have.

Changes to This Privacy Policy

• We may update this Privacy Policy from time to time to reflect:
  • changes in our services, technologies, or business practices;
  • changes in applicable laws or regulatory requirements; or
  • feedback from players, regulators, or other stakeholders.
• Each version of the Privacy Policy will be identified by the "Last updated" date indicated below.

Notification of Material Changes

• For material changes that significantly affect your rights or the way we process personal data, we will:
  • provide notice via email to the address linked to your account, where feasible; and/or
  • display a prominent notice or banner on 22ricky-aussie.com; and/or
  • show an alert in your account dashboard on your next login.
• Where reasonably possible and required, we will provide such notice at least 30 days in advance of the effective date of the changes.

Your Options on Policy Changes

• If you do not agree with the updated Privacy Policy, you may:
  • adjust your privacy or marketing preferences (e.g. opt-out from marketing);
  • stop using our services and request account closure; and/or
  • exercise any of your rights described in the "Your Rights" section.
• Your continued use of 22ricky-aussie.com after changes take effect will constitute your acknowledgement of the updated Privacy Policy, subject always to your rights under applicable law.

Last updated: January 2026