Privacy Policy

This Privacy Policy explains how personal information is collected, used, disclosed, and protected when you visit and use the services available via clubhouse-aussie.com for Club House (the "Website"). It applies to all Website visitors, registered users, and players who access or use any services or content we provide through clubhouse-aussie.com in connection with Club House. This Privacy Policy is effective as of 1 January 2026 and remains in force until replaced or updated in accordance with the "Updates" section below.

Who We Are

OBSERVE: Club House operates as an online gambling brand targeting Australian users from an offshore jurisdiction, under a Curaçao gaming licence, with a payment agent in Cyprus. Contact and identification details are needed for transparency and compliance.

EXPAND: The legal entity responsible for processing is the operator Dama N.V., supported by Strukin Ltd as payment agent. We must provide company registration, address, licensing details, and a contact point for privacy matters.

REFLECT: The following identifies the controller and contact channels for privacy-related communication.

Operator / Data Controller

• Brand context: Club House operated via clubhouse-aussie.com
• Legal entity: Dama N.V.
• Legal form: Public limited company (N.V.) under the laws of Curaçao
• Registration number: 152125
• Registered & head office address: Scharlooweg 39, Willemstad, Curaçao

Payment Agent

• Entity: Strukin Ltd (Cyprus-based payment agent for Dama N.V.)
• Role: Processing certain payments and billing-related services on behalf of Dama N.V.
• Address: Not publicly specified; operates under Cyprus law as a limited company

Gaming Licence

• Licence number: 8048/JAZ2020-013
• Issuing authority: Antillephone N.V., Curaçao
• Status: Valid as of 15 December 2024 and treated as current through 2026 unless officially revoked

Contact for Privacy and General Support

• Primary support email: [email protected] (first point of contact for all privacy and support queries)
• Regulator contact (licensing context only): [email protected] (Antillephone N.V. contact; not a user support address)
• Official Website: https://clubhouse-aussie.com

For the purposes of this Privacy Policy, Dama N.V. is the controller responsible for determining the purposes and means of processing personal information collected through clubhouse-aussie.com for Club House.

What Personal Data We Collect

OBSERVE: Operation of an online gambling site for Australian users requires identity, contact, technical, behavioural, and financial information; cookies are used for functionality and analytics.

EXPAND: To comply with KYC/AML, safeguard accounts, and provide services, we must explicitly list categories of data gathered through forms, gameplay, payments, and browsing.

REFLECT: The following categories may be collected directly from you, automatically, or from third parties.

Identification and Contact Data

• Full name, date of birth, and gender (where provided)
• Residential address, country of residence, and postcode (where applicable)
• Email address (including [email protected] and any address you supply)
• Telephone number and other contact channels you submit
• Copies of identification documents (passport, driver's licence, national ID) and proof of address (utility bill, bank statement) for verification

Account and Usage Data

• Username, encrypted password, security questions and answers (hashed/obfuscated)
• Account settings, language preference, time zone, communication preferences
• Login timestamps, session duration, and activity logs relating to your account

Technical and Device Data

• IP address and approximate location inferred from IP
• Device identifiers (browser type and version, operating system, screen resolution, device model)
• Log files including access times, referring URLs, and error reports
• Information collected via cookies, web beacons, and similar tracking technologies (see "Cookies & Tracking Technologies")

Payment and Financial Data

• Payment method details (such as masked card numbers, card type, expiry date and tokenised instrument details processed via payment providers)
• Deposits, withdrawals, balances, and transaction histories in fiat currencies and, where applicable, virtual assets/cryptocurrencies
• Billing address and payment verification data provided to or by our payment partners

Behavioural and Gaming Data

• Betting and gameplay history, including games played, stakes, wins and losses, frequency and duration of play
• Bonuses claimed, wagering activity, reward status, and participation in promotions
• Click-stream data, navigation paths, and interaction with specific pages, buttons, and content

Communications and Support Data

• Content of communications with us via email, live chat, or other channels
• Support tickets, complaints, and dispute documentation
• Records of your consent (time, method, content) to terms, promotions, and privacy notices

Cookies and Similar Technologies

• Session cookies to maintain your login state and keep your gameplay functioning securely
• Persistent cookies for preferences, language settings, and remembering choices on future visits
• Third-party cookies and tags for analytics and, with your consent where required, marketing and advertising attribution

Legal Basis for Processing

OBSERVE: As an offshore operator serving Australian users, we must clearly state on what grounds we process personal information (contract, consent, legitimate interests, legal obligations), aligning with international standards such as GDPR-style principles.

EXPAND: Different processing activities rely on different legal bases; some require consent (marketing, certain cookies), some are necessary for service delivery (contract), and others are mandated by law (KYC/AML, record-keeping, dispute handling).

REFLECT: The legal grounds listed below are applied in a purpose-specific manner.

• Contractual necessity: We process your data where it is necessary to enter into and perform a contract with you, including:
  • Setting up and managing your Club House account at clubhouse-aussie.com
  • Processing deposits, bets, withdrawals, and bonus redemptions
  • Providing customer support, troubleshooting, and responding to your requests
  • Ensuring proper operation of games, including access to third-party game providers' platforms
• Consent: In specific cases, we rely on your explicit or implied consent, including:
  • Sending direct electronic marketing (email, SMS, push notifications) where consent is required
  • Using non-essential cookies and tracking technologies for analytics and advertising
  • Conducting certain optional surveys or research initiatives not strictly necessary for service delivery

  You may withdraw your consent at any time as explained in the "Your Rights" section; withdrawal does not affect the lawfulness of processing before withdrawal.

• Legitimate interests: We process data where necessary for our legitimate business interests and where these are not overridden by your rights and interests, including:
  • Preventing, detecting, and investigating fraud, abuse, money laundering, and other unlawful activities
  • Protecting the security and integrity of our systems, games, and user accounts
  • Understanding how the Website is used to improve user experience, functionality, and service offerings
  • Defending and exercising legal claims and managing operational risk
• Compliance with legal and regulatory obligations: We must process certain data in order to:
  • Comply with applicable KYC (Know Your Customer), CDD (Customer Due Diligence), and AML (Anti-Money Laundering) rules of our licensing jurisdiction
  • Observe responsible gambling and player protection requirements, including self-exclusion handling
  • Meet record-keeping, accounting, and reporting obligations to licensing and tax authorities
  • Respond to lawful requests from regulators, law enforcement, courts, and other public authorities

Purpose of Processing

OBSERVE: The data we collect is used to operate the Club House service via clubhouse-aussie.com and maintain legal and technical safeguards.

EXPAND: Each purpose maps to one or more legal bases and involves specific data categories (e.g., payment data for transactions, behavioural data for responsible gambling monitoring).

REFLECT: The purposes are grouped below for clarity and transparency.

• Provision and management of services:
  • Creating, verifying, and administering your Club House account
  • Processing deposits, wagers, game outcomes, bonuses, and withdrawals
  • Providing customer support and handling your requests, queries, and feedback
• Compliance and risk management:
  • Conducting identity verification, age checks, and KYC/AML screening
  • Monitoring transactions and gameplay for fraud, money laundering, or irregular patterns
  • Supporting responsible gambling measures, including self-exclusion or limits
  • Keeping records necessary for legal, regulatory, and tax compliance
• Service improvement and analytics:
  • Analysing usage statistics and behavioural data to improve Website performance and user experience
  • Testing and optimising new features, user interfaces, and game offerings
  • Producing aggregated or anonymised reports and statistics
• Marketing and personalisation:
  • Sending you promotional communications about Club House offers, games, and tournaments (where permitted)
  • Customising content and recommendations on clubhouse-aussie.com based on your preferences and activity
  • Conducting surveys and satisfaction research to refine our services
• Security and technical operation:
  • Maintaining Website security, preventing unauthorised access, and detecting incidents
  • Debugging, troubleshooting, and resolving technical issues
  • Ensuring compatibility and performance across devices and browsers
• Legal claims and business continuity:
  • Establishing, exercising, or defending legal claims or complaints
  • Supporting audits, mergers, acquisitions, or corporate restructuring while preserving appropriate safeguards

Disclosure & Sharing

OBSERVE: Operation of an offshore online casino involves multiple service providers and authorities; transparency on recipients and safeguards is required.

EXPAND: We need to cover payment partners, game providers, IT and analytics vendors, affiliates, regulators, and potential acquirers, limited to necessary data and lawful purposes.

REFLECT: Sharing is controlled, proportionate, and subject to contractual safeguards.

• Payment service providers and banks:
  • We share relevant payment and identification details with authorised payment processors, card schemes, banks, and financial institutions to process deposits, withdrawals, chargebacks, and refunds.
  • These partners operate under their own regulatory obligations, including AML and sanctions screening.
• Game and platform providers:
  • To deliver games and ensure fairness, we may share unique account identifiers and limited technical data with game studios and platform operators integrated with our service.
  • Fairness and RNG information may be accessed via third-party providers such as BGaming, which may receive technical or aggregated data.
• Technical, security, and analytics vendors:
  • We engage third parties for hosting, data storage, content delivery, security monitoring, email delivery, and customer support tools.
  • We use analytics providers to understand usage patterns; data is typically pseudonymised or aggregated wherever practicable.
• Affiliates and advertising networks:
  • With your consent where required, we may share limited data (such as cookie identifiers or referral information) with advertising networks and affiliate partners to measure campaign performance and attribute traffic.
  • Directly identifiable information is not shared for third-party marketing unrelated to Club House without your express consent.
• Group entities and payment agents:
  • Your data may be shared within entities related to Dama N.V., including Strukin Ltd as a payment agent, for operational, compliance, and accounting purposes.
• Regulators, authorities, and dispute bodies:
  • We may disclose information to Antillephone N.V., Curaçao authorities, law enforcement, courts, and other public bodies when we are legally required or permitted to do so.
  • Where Australian regulators such as the Australian Communications and Media Authority (ACMA - https://acma.gov.au) or other agencies lawfully request information, we may respond in accordance with applicable laws.
• Business transfers:
  • In the event of a merger, acquisition, asset sale, restructuring, or insolvency event, user data may be transferred to a successor or acquiring entity, subject to continued protection consistent with this Privacy Policy.
• Professional advisors:
  • We may share limited necessary data with lawyers, auditors, consultants, or other professional advisors, bound by confidentiality obligations.

We do not sell your personal data to third parties in the conventional sense of selling personal information for independent commercial use.

International Transfers

OBSERVE: Data of Australian users is processed by entities in Curaçao, Cyprus, and potentially other jurisdictions; cross-border transfers must be addressed with safeguards.

EXPAND: While Australian privacy law may not directly mirror GDPR, we follow internationally recognised standards by imposing contractual and organisational protections for transfers.

REFLECT: Users are informed of destinations and safeguards applied to their data.

• Primary locations of processing:
  • Curaçao - where Dama N.V. is registered and licensed, and where core operational decisions and certain systems are located.
  • Cyprus - where Strukin Ltd and certain payment and back-office functions may be based.
  • Other EEA/European locations - where some third-party hosting, analytics, or service providers may operate.
  • Additional jurisdictions - where specific technology or payment providers maintain infrastructure (for example, data centres in the EU, UK, or other regions).
• Safeguards for international transfers:
  • We use contractual protections such as Standard Contractual Clauses (SCCs) or equivalent data transfer agreements where appropriate for transfers from regions with strict data export rules.
  • We conduct due diligence on third-party providers, assessing security measures, privacy practices, and compliance frameworks (e.g., ISO 27001, SOC 2 where available).
  • We aim to minimise transferred data to what is strictly necessary for each purpose and encourage pseudonymisation or aggregation where feasible.

By using clubhouse-aussie.com and providing your data, you acknowledge that your information may be transferred, stored, and processed in countries that may have different data protection standards than those in your country of residence; however, we take steps to ensure appropriate protection of your information.

Data Retention

OBSERVE: Gambling operators are typically required to retain data for specific periods for AML, KYC, and dispute reasons; however, retention must be limited to what is necessary.

EXPAND: We differentiate between categories of data (account, financial, logs, marketing) and apply tailored retention periods, after which data is securely deleted or anonymised.

REFLECT: The following retention practices apply unless a longer period is required or permitted by law.

• Account and identification data:
  • Core account records (name, contact details, identification data, KYC documents) are normally retained for up to 5 years after account closure or your last transaction, whichever is later, to comply with AML/KYC and regulatory obligations.
• Transaction and gaming history:
  • Records of deposits, wagers, wins, losses, and withdrawals are generally kept for 7 years from the date of the relevant transaction to meet accounting, tax, and regulatory requirements and for dispute resolution.
• Technical logs and security data:
  • Server logs, security alerts, and access logs may be stored for 12 - 24 months, depending on their purpose, to support security investigations and system integrity.
• Marketing and consent records:
  • Records of your marketing preferences and consents are retained for as long as you remain subscribed and for up to 2 years after you unsubscribe, to demonstrate compliance.
• Support and complaints data:
  • Customer support correspondence and complaint files are typically stored for up to 5 years after closure of the case, or longer where necessary to establish, exercise, or defend legal claims.

When data is no longer required for the purposes described and no longer needs to be retained under legal or regulatory obligations, we will either securely delete it or irreversibly anonymise it. If deletion is not immediately possible (for example, where data is stored in backup archives), we will securely store and isolate it from any further processing until deletion is feasible.

Your Rights

OBSERVE: While Club House is operated from Curaçao, users expect rights similar to those provided under modern data protection frameworks (e.g., GDPR). The prompt references both GDPR and Mexican data law; for Australian users, we apply GDPR-aligned standards as a matter of best practice.

EXPAND: Users should be able to access, correct, delete, restrict, and port their data, object to processing, and withdraw consent, free of charge and within defined timeframes such as 30 days.

REFLECT: The rights below apply to the extent permitted under applicable laws and subject to certain limitations.

Overview of Rights

• Right of access: You can request confirmation of whether we process your personal data and obtain a copy of that data together with information on how we use it.
• Right to rectification: You can ask us to correct inaccurate or incomplete personal information concerning you.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where:
  • The data is no longer necessary for the purposes for which it was collected;
  • You withdraw consent where consent was the legal basis and there is no other legal ground;
  • You validly object to processing and there are no overriding legitimate grounds;
  • The data has been unlawfully processed.

  We may need to retain certain information to comply with AML/KYC, taxation, or regulatory requirements, which can limit full deletion.

• Right to restriction of processing: You may request that we limit processing of your data where:
  • You contest the accuracy of the data (for a period enabling us to verify it);
  • Processing is unlawful but you oppose deletion and request restriction instead;
  • We no longer need the data, but you require it to establish, exercise, or defend legal claims;
  • You have objected to processing, pending verification of overriding legitimate grounds.
• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests. We will stop such processing unless we demonstrate compelling legitimate grounds that override your interests or for legal claims. You may also object at any time to processing for direct marketing, in which case we will cease marketing.
• Right to data portability: Where processing is based on your consent or on a contract and is carried out by automated means, you may request to receive personal data you provided to us in a structured, commonly used, and machine-readable format, and have it transmitted to another controller where technically feasible.
• Right to withdraw consent: Where we rely on your consent (for example, for certain marketing or cookies), you may withdraw that consent at any time. Withdrawal does not affect prior lawful processing.

How to Exercise Your Rights

1. Submit your request: Send an email to [email protected] with:
   • Your full name, username, and registered email address;
   • A clear description of the right you wish to exercise and the data concerned;
   • Any additional information needed to verify your identity, if requested.
2. Identity verification: For your protection, we may ask for additional information or documentation to verify your identity, particularly for access, erasure, or portability requests.
3. Response timeframe: We aim to respond to all valid requests within 30 days of receipt. If your request is particularly complex or we receive multiple requests, we may extend this period by a further 30 days, in which case we will inform you of the extension and reasons.
4. Fees: Requests are generally handled free of charge. However, where a request is manifestly unfounded or excessive (for example, repetitive), we may charge a reasonable fee or refuse to act on the request, as permitted by applicable law.

Some of the above rights may be subject to limitations under the laws that apply to our operations (for example, retention obligations under AML regulations). If we cannot fully comply with your request, we will explain the reasons, where legally allowed.

Cookies & Tracking Technologies

OBSERVE: The Website relies on cookies and similar tools for functionality, performance, and marketing attribution.

EXPAND: Users must be informed about types of cookies, their purposes, and control options, particularly for non-essential cookies.

REFLECT: The following explains how cookies are used on clubhouse-aussie.com for Club House.

Types of Cookies We Use

• Strictly necessary / functional cookies:
  • Session cookies that keep you logged in while you use the Website and enable core functions such as placing bets, accessing your account, and secure payment processing.
  • Cookies to remember your cookie choices and consent status.
• Preference cookies:
  • Persistent cookies that remember your language, region, and other settings for future visits to enhance user experience.
• Analytics and performance cookies:
  • Cookies set by us or third-party analytics providers to collect information about how visitors use the Website (pages visited, time spent, clicks, errors encountered).
  • Data is used in aggregate form to improve functionality and performance.
• Advertising and affiliate cookies:
  • Third-party cookies or tracking pixels used, with your consent where required, for measuring effectiveness of advertising campaigns and affiliate referrals.
  • These may track whether you arrived from a partner site and whether you sign up or make a deposit.

Managing Cookies

• You can manage or disable cookies directly in your browser settings. Instructions are typically found in the "Help" or "Settings" section of your browser.
• Some browsers and devices allow you to block cookies from specific sites or to notify you when cookies are set.
• If we provide an internal cookie management panel on clubhouse-aussie.com, you may use it to adjust your preferences for non-essential cookies at any time.
• Please note that disabling strictly necessary cookies may affect the functioning of the Website, including your ability to log in or complete transactions.

Data Security

OBSERVE: Handling financial transactions and sensitive identity documents requires robust technical and organisational measures.

EXPAND: Security should cover encryption, access controls, MFA, audits, staff training, and incident response, aligned where possible with international standards (ISO 27001, SOC 2).

REFLECT: We implement layered security controls to protect your data against loss, misuse, and unauthorised access.

• Encryption:
  • Data transmitted between your browser and our servers is protected using TLS 1.2 or higher.
  • Sensitive information (such as passwords and certain financial data) is stored using strong hashing and encryption mechanisms.
• Access controls and authentication:
  • Access to personal data is strictly limited to authorised personnel who require it for their job functions.
  • Administrative access is protected using strong authentication measures, and we encourage the use of multi-factor authentication where supported.
• Infrastructure and monitoring:
  • We host systems in secure data centres with physical and logical security controls.
  • Regular security monitoring, logging, and alerting are used to detect unusual activities or potential intrusions.
• Security governance and training:
  • Our staff receive periodic training on data protection, information security, and responsible handling of user data.
  • Access rights are reviewed regularly, and internal policies govern data handling and acceptable use.
• Audits and standards:
  • Where possible, we work with providers and partners that align with recognised security frameworks such as ISO 27001 or SOC 2.
  • We periodically review our own security measures and update them in light of emerging threats and best practices.
• Incident response:
  • We maintain procedures for responding to data incidents, including investigation, mitigation, and appropriate notification to users and authorities where required by law.

No method of transmission over the internet or method of electronic storage is entirely secure. While we strive to protect your personal information, we cannot guarantee absolute security; however, we are committed to responding swiftly and transparently to any identified risks or incidents.

Complaints & Contacts

OBSERVE: Users must have clear channels to raise privacy concerns and escalate complaints to supervisory bodies when unresolved.

EXPAND: We provide step-by-step procedures, contact details, and indicative response times, and we reference relevant oversight authorities.

REFLECT: The process below aims to ensure fair, timely handling of privacy-related issues.

Contacting Us

• Primary contact for privacy and support: [email protected]
• Postal correspondence: Dama N.V., Scharlooweg 39, Willemstad, Curaçao (marked "Privacy - Club House")

Complaint Procedure

1. Initial submission: Send a detailed description of your concern to [email protected], including:
   • Your name, username, and registered email address;
   • A clear explanation of the issue, including any relevant dates and evidence;
   • The outcome you are seeking (for example, correction of data, explanation, or deletion).
2. Acknowledgement: We will acknowledge receipt of your complaint as soon as reasonably practicable, usually within 5 business days.
3. Investigation and response: We will investigate your complaint and aim to provide a substantive response within 30 days. If more time is required due to complexity, we will inform you of the delay and provide an updated timeframe.
4. Escalation: If you are dissatisfied with our response, you may request an internal review by stating the reasons for your dissatisfaction in writing; we will conduct a further review and respond within a reasonable period.

Escalation to Authorities

If you believe that your privacy rights have been infringed and we have not resolved your concern to your satisfaction, you may be entitled to lodge a complaint with a supervisory authority. Depending on your location and the applicable laws, this may include:

• Australian privacy and communications regulators:
  • Office of the Australian Information Commissioner (OAIC) - for general privacy complaints (see https://www.oaic.gov.au).
  • Australian Communications and Media Authority (ACMA) - for issues related to online gambling services and communications (see https://acma.gov.au).
• Data protection or gaming authorities in other relevant jurisdictions:
  • Where your country of residence provides for a local data protection authority, you may contact that authority in accordance with its procedures.

We encourage you to contact us first so that we can attempt to resolve your concern directly.

Updates

OBSERVE: Privacy policies evolve with legal, technical, and operational changes; users require clarity on how changes are communicated.

EXPAND: We must specify how we notify users (email, banners, dashboard), maintain versioning, and provide advance notice for material changes, allowing users to object or close accounts.

REFLECT: The following governs how this Privacy Policy may change over time.

Change Management and Notifications

• We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.
• When we make material changes (for example, expanding categories of data collected, introducing new sharing partners, or changing key purposes), we will:
  • Provide notice at least 30 days before the changes take effect, where practicable; and
  • Use one or more of the following channels:
    • Email notifications to the address associated with your account;
    • Prominent banners or notices on clubhouse-aussie.com;
    • Alerts or messages within your account dashboard.
• Non-material changes (such as clarifications, formatting, or corrections) may take effect immediately and will be indicated by an updated "Last updated" date.

User Options in Case of Changes

• If you do not agree with the updated Privacy Policy, you may:
  • Adjust your privacy, cookie, or marketing preferences where options are provided; and/or
  • Request closure of your account and, where applicable, exercise your data subject rights as described in the "Your Rights" section.
• Continued use of clubhouse-aussie.com for Club House after the effective date of an updated Privacy Policy will constitute your acknowledgement and, where applicable, acceptance of the changes.

Version control: This Privacy Policy is version "2026-01" and was last updated: January 2026.