Privacy Policy
Who We Are
OBSERVE: The operator must be clearly identified, together with its registration and contact details, so that users know who controls their data and how to reach them.
EXPAND: Based on the provided data, the online casino services promoted via Playamo on playamowin-au.com are operated offshore by a Curacao-licensed company. We must also provide a specific contact point for privacy matters.
REFLECT: We therefore specify the legal entity, address, licence information, and a dedicated privacy contact channel.
The services referred to on Playamo and offered via the domain playamowin-au.com are operated by:
- Operator (Data Controller for most activities): Dama N.V.
- Legal form: Public limited company (N.V.) incorporated under the laws of Curacao
- Registration number: 152125
- Registered and legal address: Scharlooweg 39, Willemstad, Curacao
- Gaming licence: 8048/JAZ2020-013 issued to Dama N.V. by Antillephone N.V., authorised by the Government of Curacao, for the provision of online casino and gambling services (validity currently extended to 31 December 2026, subject to regulator decisions)
For all questions, requests or complaints relating to this Privacy Policy or to your personal data, you may contact our data protection contact point:
- Data Protection Contact / Data Protection Department: Dama N.V. - Data Protection
- Email (primary for privacy matters): [email protected]
- Alternative contact (support-related data queries): [email protected]
- Website: https://playamowin-au.com
- Postal address for written requests: Dama N.V., Data Protection Department, Scharlooweg 39, Willemstad, Curacao
At present, Dama N.V. has not appointed a formal Data Protection Officer under EU GDPR; however, the Data Protection Department performs equivalent functions for purposes of handling privacy-related questions and rights requests.
What Personal Data We Collect
OBSERVE: We must explain the categories of data we collect so that individuals understand what information is processed.
EXPAND: For an online casino targeted at Australian users from offshore, this includes account data, KYC and AML data, technical data, behavioural data, and cookies/trackers.
REFLECT: We categorise the information, explain its content, and identify typical sources.
Account and Identification Data
- Basic registration data: full name, username, password, email address, country of residence, date of birth, and preferred currency.
- Contact data: telephone number (where provided), postal address (if requested for verification or payout), and communication preferences.
- Verification / KYC data: copies or details of identity documents (e.g. passport, driver's licence, national ID), proof of address (utility bills, bank statements), source-of-funds or source-of-wealth documentation, and any additional information requested under anti-money laundering (AML) or counter-terrorism financing (CTF) requirements.
Technical and Usage Data
- Technical identifiers: IP address, device identifiers, browser type and version, operating system, screen resolution, language settings, and similar technical data.
- Access and log data: pages visited, referring/exit pages, access dates and times, session duration, login/logout timestamps, error logs, and crash data.
- Device and network data: information about the network you use to access the site (e.g. ISP, approximate location inferred from IP), as well as device model and settings.
Payment and Financial Data
- Payment transaction data: payment method, partial card details or other masked identifiers (where applicable), payment account identifiers (e.g. e-wallet ID), deposits, withdrawals, balances, bonuses used, and transaction history.
- Fraud and risk data: chargeback records, flagged transactions, abnormal patterns, and other indicators generated by internal or third-party risk tools.
- We generally do not store full card numbers or CVV codes on our own systems; these are processed by PCI-DSS compliant payment providers where applicable.
Behavioural and Profile Data
- Gaming and betting data: game preferences, duration and frequency of play, bet sizes, wins and losses, bonus usage, tournament participation, and VIP level.
- Interaction data: clicks, navigation paths, in-game behaviour, and interactions with marketing communications (email opens, link clicks, unsubscribes).
- Responsible gambling data: self-exclusion requests, deposit limits, time-out periods, reality checks, and communications with our responsible gambling team.
- Profile inferences: internal segmentation (for example, by risk level, player value, or product preference) used for responsible gambling interventions, risk management, and tailored offers where lawful.
Communication Data
- Customer support records: emails, chat transcripts, and internal notes resulting from interactions with support via [email protected] or other channels.
- Feedback and surveys: information you provide in reviews, complaint forms, satisfaction surveys, or other feedback mechanisms.
Cookies and Similar Technologies
- Cookies: small text files stored on your device to keep you logged in, remember your preferences, and measure site performance.
- Tracking technologies: web beacons, pixels, SDKs, tags, and similar technologies embedded in our websites, emails, and applications.
- Third-party analytics and advertising tools: tools such as analytics platforms that collect aggregated statistical data about site usage and conversion performance.
Legal Basis for Processing
OBSERVE: We must identify and explain the legal grounds for processing personal data under widely accepted standards (e.g. GDPR-style principles), while acknowledging that we operate from Curacao and target Australian players in a grey-market environment.
EXPAND: We rely on contract, consent, legitimate interests, and legal obligations (including AML/CTF and licensing requirements in our home jurisdiction). We also need to transparently highlight limitations on Australian regulatory protection given ACMA's position.
REFLECT: We summarise each legal basis, indicate typical examples, and clarify that different bases may apply simultaneously.
Contractual Necessity
- We process your personal data where it is necessary to enter into, perform, or administer a contract with you, including:
- creating and managing your player account;
- processing deposits, wagers, bonuses, and withdrawals;
- providing access to games and related functionality;
- verifying your eligibility to use our services, including age and residency checks;
- communicating with you about your account, transactions, and service-related updates.
Compliance with Legal and Regulatory Obligations
- We process certain data because we are legally required to do so under the laws and regulations applicable to Dama N.V. and its licence, including:
- anti-money laundering and counter-terrorism financing regulations;
- customer identification (KYC) and ongoing monitoring;
- record-keeping obligations imposed by our Curacao gaming licence and other applicable rules;
- responding to lawful requests from competent authorities, courts, or regulators with jurisdiction over us.
- Regional compliance note: For Australian residents, our services are considered offshore and generally unauthorised under the Interactive Gambling Act 2001. You may not benefit from the same level of regulatory protection or dispute recourse as with locally licensed services.
Legitimate Interests
- We process certain data where it is necessary for our legitimate interests or those of third parties, and these are not overridden by your rights and interests. These interests include:
- ensuring the security and integrity of our platforms and games;
- preventing, detecting, and investigating fraud, abuse, or technical issues;
- performing analytics, statistics, and reporting to improve our services and user experience;
- personalising content and limited marketing of similar products to existing customers, within applicable legal limits;
- protecting our legal rights, including the establishment, exercise, or defence of legal claims.
Consent
- We rely on your consent for specific processing activities where required by applicable law, such as:
- sending certain types of direct marketing communications (e.g. emails or SMS about new bonuses or promotions) to non-customers or where consent is otherwise required;
- using non-essential cookies or similar technologies for advertising and advanced analytics, where feasible consent mechanisms are implemented;
- processing special categories of data, if ever collected, in such cases strictly in line with applicable law and your explicit consent.
- You may withdraw your consent at any time, as described under "Your Rights", without affecting the lawfulness of processing based on consent before its withdrawal.
Vital Interests and Public Interest
- In rare cases, we may process data to protect your vital interests or those of another person (for example, where we reasonably believe there is a serious and imminent risk of harm) or to perform a task in the public interest when authorised by law.
Purpose of Processing
OBSERVE: We must clearly state why data is processed.
EXPAND: For an online casino, purposes include service provision, security, responsible gambling, marketing, analytics, and regulatory compliance.
REFLECT: We link purposes to data types and legal bases in an understandable way.
Provision and Administration of Casino Services
- Creating, verifying, and managing your account and profile on playamowin-au.com.
- Providing access to Playamo games and services referenced by Playamo.
- Processing deposits, bets, wins, losses, withdrawals, bonuses, and loyalty programme activities.
- Providing customer support and handling technical or account-related queries.
Regulatory, AML/CTF and Legal Compliance
- Conducting KYC checks, affordability assessments and ongoing due diligence.
- Monitoring transactions and behaviour for suspicious or prohibited activity.
- Maintaining statutory records required under our Curacao licence or other applicable obligations.
- Cooperating with competent authorities when legally required.
Security, Fraud Prevention and Risk Management
- Protecting our systems, players, and business from fraud, money laundering, hacking, abuse, and other security threats.
- Using internal and third-party tools to detect and prevent multi-accounting, bonus abuse, and other breaches of our Terms and Conditions.
- Enforcing our Terms and Conditions and investigating suspected violations.
Service Improvement and Analytics
- Analysing usage patterns to understand how players interact with our website, games, and promotions.
- Testing and developing new features, interfaces, and services.
- Monitoring performance, fixing bugs, and improving overall user experience.
- Producing aggregated, anonymised or de-identified statistics for internal reporting.
Marketing and Personalisation
- Sending marketing communications about our products and services, such as bonuses, tournaments, and new games, in accordance with your preferences and applicable law.
- Segmenting players based on behaviour and preferences to show relevant offers, where legally permissible.
- Running affiliate and advertising campaigns and measuring their effectiveness.
Responsible Gambling
- Monitoring play patterns and limits to detect potential problem gambling behaviour.
- Implementing tools such as self-exclusion, time-outs, reality checks, and deposit limits.
- Recording interactions and interventions related to responsible gambling obligations.
Disclosure & Sharing
OBSERVE: We must indicate who receives data and in which circumstances.
EXPAND: Typical recipients include payment processors, game providers, IT vendors, affiliates and regulators, as well as where we operate cross-border and under offshore gambling regulation.
REFLECT: We explain categories, not only specific names, and clarify safeguards and responsibilities.
Service Providers and Processors
- Payment service providers: Banks, card schemes, e-wallets, payment gateways, and other financial institutions that process deposits, withdrawals, and refunds.
- Game and software providers: Third-party studios and platform providers that supply games, RNG systems, and associated services, often acting as processors or independent controllers.
- IT and infrastructure providers: Hosting providers, cloud infrastructure, content delivery networks, and security service providers.
- Analytics and anti-fraud tools: Vendors providing fraud detection, identity verification, risk scoring, and analytics services.
Affiliates and Marketing Partners
- We may share limited data with marketing and affiliate partners for:
- attribution and measurement of marketing campaigns related to playamowin-au.com;
- fraud detection and prevention (e.g. affiliate abuse);
- serving or measuring advertisements, where permitted and, where required, based on your consent.
Group Companies and Business Transfers
- We may share personal data with other entities within our wider corporate group (where applicable) for:
- centralised compliance, risk management, and IT security;
- group-level analytics and business management;
- intra-group services or support functions.
- In the event of a merger, acquisition, reorganisation, or sale of assets, personal data may be transferred as part of the transaction, subject to confidentiality and applicable legal requirements.
Regulators, Authorities, and Legal Recipients
- We may disclose your data to:
- licensing bodies, gaming regulators, and financial intelligence units with jurisdiction over our operations;
- law enforcement agencies, courts, or other authorities where we are legally required to do so or where disclosure is necessary to protect our rights or the rights of others;
- professional advisers (e.g. lawyers, auditors) subject to confidentiality obligations.
- Regional note: Australian authorities, such as the Australian Communications and Media Authority (ACMA), may classify our services as prohibited offshore gambling services. While we do not actively disclose player data to Australian regulators except where compelled by law with jurisdiction over us, players should understand that no Australian regulator directly supervises our processing activities.
With Your Consent or at Your Direction
- We may share information with third parties when you explicitly consent to or request such sharing, for example when participating in joint promotions or tournaments operated with partners.
International Transfers
OBSERVE: Data is necessarily moved across borders, especially from Australia to Curacao and other locations.
EXPAND: We must state where data may go, including non-EEA/UK locations, and what safeguards we seek to apply, while noting differences and limitations.
REFLECT: We provide a transparent description of international transfers and safeguards aligned with widely recognised standards.
- Your personal data may be transferred to and processed in countries outside your country of residence, including but not limited to:
- Curacao (primary operational and regulatory jurisdiction of Dama N.V.);
- European Economic Area (EEA) member states, the United Kingdom, and Switzerland (for certain service providers and infrastructure hosting);
- other countries where our key service providers, payment providers, game studios or support teams are located (for example, in North America or Asia).
- When we transfer personal data internationally, we aim to ensure an adequate level of protection by:
- using contractual safeguards such as standard contractual clauses or equivalent data transfer agreements where required under EU/UK-style data protection frameworks;
- imposing strict contractual obligations on recipients, including confidentiality, data security, and data protection commitments;
- conducting risk assessments concerning the country of destination and the nature of the processing.
- Some countries to which we transfer data may not offer the same level of data protection as your home jurisdiction. By using our services and providing your personal data, you acknowledge that such transfers may occur, subject to the safeguards described above and your rights under applicable law.
Data Retention
OBSERVE: We need to set out how long data is kept.
EXPAND: Retention must balance legal requirements (such as AML record-keeping) with data minimisation, and include clear examples and deletion criteria.
REFLECT: We define indicative periods and criteria for different categories.
- General principle: We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including for satisfying legal, regulatory, accounting, or reporting requirements, resolving disputes, and enforcing our agreements.
Indicative Retention Periods
- Account and identification data: normally kept for the duration of your account and up to five (5) years after account closure or your last activity, whichever is later, unless a longer period is required by law or necessary for the establishment, exercise, or defence of legal claims.
- KYC/AML documentation: retained for at least five (5) years after the end of the business relationship or from the date of the last transaction, in line with common AML/CTF obligations and our licensing conditions, potentially extended up to the end of 2026 or longer if legally required.
- Payment and transaction data: generally kept for five (5) to seven (7) years to comply with financial and audit requirements.
- Technical logs and security data: normally kept for up to two (2) years from collection, unless linked to specific investigations, security incidents, or legal matters requiring longer retention.
- Marketing data: kept for as long as you remain subscribed and for up to two (2) years after your last interaction with our marketing communications, unless you withdraw consent earlier.
- Responsible gambling data: kept at least for the duration of any self-exclusion or similar measure and for a subsequent period of five (5) years to ensure we do not inadvertently reactivate excluded accounts.
Deletion and Anonymisation
- When personal data is no longer needed for the purposes for which it was collected and no longer required to be retained under applicable law or for legitimate business needs, we will:
- securely delete or destroy it; or
- anonymise or irreversibly de-identify it so that it can no longer be associated with an identifiable individual.
- Where you have requested erasure, we will comply where permitted by law and where retention is not required for legal or legitimate reasons, as further described in "Your Rights".
Your Rights
OBSERVE: Users require a clear explanation of their rights over their personal data.
EXPAND: We align our approach with well-recognised privacy regimes such as the EU General Data Protection Regulation (GDPR) and comparable rights under other frameworks. The prompt refers to Mexican law, but for Australian users in a grey-market context we instead emphasise GDPR-style rights as our internal standard while acknowledging that local law and regulator oversight may differ and that Mexican data regulations do not directly apply here.
REFLECT: We describe each right, its limits, and how to exercise it, together with response times and cost conditions.
Overview of Rights
Subject to applicable law, you may have the following rights in relation to your personal data:
- Right of access: to obtain confirmation as to whether we process your personal data and to receive a copy of such data, together with information about the processing.
- Right to rectification: to request correction of inaccurate data and completion of incomplete data.
- Right to erasure ("right to be forgotten"): to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal ground applies), or where processing is unlawful, subject to legal and regulatory retention obligations.
- Right to restriction of processing: to request that we limit the processing of your data in certain circumstances, for example while we verify its accuracy or handle an objection.
- Right to object: to object to processing based on our legitimate interests, including profiling, and to object at any time to the use of your data for direct marketing.
- Right to data portability: to receive personal data you provided to us in a structured, commonly used and machine-readable format and to request its transmission to another controller where technically feasible and where the legal basis is consent or contract.
- Right to withdraw consent: where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting prior lawful processing.
How to Exercise Your Rights
- Submit a request: You can exercise your rights by contacting our Data Protection Department via [email protected] or, for support-related issues, [email protected]. Please specify which right you wish to exercise and provide enough information for us to verify your identity and locate your data.
- Identity verification: For security reasons, we may ask you to provide information or documentation to verify your identity before acting on your request. This helps protect your data from unauthorised access or changes.
- Response time: We aim to respond to your request without undue delay and in any event within 30 days of receipt of a complete request. Where requests are complex or numerous, we may extend this by up to an additional 30 days, in which case we will inform you of the extension and reasons.
- Fees: We will handle your request free of charge, unless it is manifestly unfounded or excessive (for example, repeated requests). In such cases, we may charge a reasonable fee or refuse to act on the request, as permitted by law.
- Limitations: Your rights may be subject to legal restrictions and exemptions. For example, we may refuse erasure or restriction where data must be retained for AML/CTF, regulatory or legal claim purposes, or where disclosure would adversely affect the rights and freedoms of others.
While Australian privacy and gambling laws may not provide you with the same regulatory oversight in relation to an offshore operator such as Dama N.V., we voluntarily apply the above rights framework as a matter of policy, in line with internationally recognised data protection principles.
Cookies & Tracking Technologies
OBSERVE: Cookies underpin the technical operation of the website and marketing.
EXPAND: We must distinguish types and provide basic instructions on how to manage them.
REFLECT: We give an accessible explanation with clear categories.
Types of Cookies We Use
- Session cookies: temporary cookies that are stored on your device only for the duration of your browsing session and are deleted when you close your browser. They are used to maintain your login state, security tokens, and basic navigation.
- Persistent cookies: remain on your device for a longer period or until you delete them. They allow us to remember your preferences (such as language or region), recognise you as a returning visitor, and tailor content.
- First-party cookies: set directly by playamowin-au.com to provide core functions of the website and remember your settings.
- Third-party cookies: set by external providers such as analytics services or advertising networks to measure site usage, conversions, and, where allowed, to deliver more relevant marketing.
Purposes of Cookies and Similar Technologies
- Strictly necessary / functional: enable essential site functionality such as logging in, account management, transaction processing, and security. These cannot be disabled through our systems without materially affecting service use.
- Performance and analytics: help us understand how visitors use the site, which pages are most popular, and how campaigns perform. This information is usually aggregated.
- Advertising and marketing: used by us or our partners to deliver, measure, and optimise marketing campaigns related to our services, subject to your consent where required.
Managing Cookies
- You can manage or disable cookies through your browser settings. The method varies by browser, but typically you can:
- view which cookies are stored on your device;
- delete existing cookies;
- block all or specific types of cookies;
- set preferences for certain websites.
- Disabling strictly necessary cookies may prevent some parts of the website or our services from functioning properly.
- Where a cookie or tracking consent mechanism is available on playamowin-au.com, you may use it to adjust your preferences for non-essential cookies.
Data Security
OBSERVE: We hold sensitive financial and identification data that must be protected.
EXPAND: We must outline technical and organisational measures, including encryption, access controls, training, and incident response, referencing recognised security practices.
REFLECT: We describe measures in clear categories and emphasise that no system is perfectly secure, while committing to reasonable protection.
Technical Measures
- Encryption in transit: Data transmitted between your browser and our servers is protected by industry-standard Transport Layer Security (TLS 1.2 or higher), helping to prevent interception.
- Encryption at rest: Sensitive data fields are encrypted or otherwise protected at rest using modern cryptographic methods, in line with our security policies and, where relevant, those of our platform and payment partners.
- Access controls: Access to systems containing personal data is limited to authorised personnel and service accounts based on the principle of least privilege and is protected by authentication measures, including, where appropriate, multi-factor authentication.
- Network and application security: We use firewalls, intrusion detection or prevention systems, and other tools to monitor for suspicious activity and protect against unauthorised access.
Organisational Measures
- Policies and procedures: Internal information security and data protection policies govern the handling of personal data.
- Staff training: Staff members with access to personal data receive training on data protection, confidentiality, and security obligations.
- Vendor due diligence: We assess key service providers' security controls and include data protection and security obligations in our contracts.
Monitoring, Audits and Incident Response
- We monitor systems for vulnerabilities and apply security patches and updates in a risk-based manner.
- We periodically review our security controls and may engage independent assessments or audits where appropriate, including reliance on our platform providers' certifications (such as ISO 27001 or SOC 2, where applicable to them).
- We maintain incident response procedures designed to:
- identify and contain security incidents;
- assess the impact on personal data;
- mitigate harm and restore normal operations;
- comply with notification obligations to regulators and affected individuals, where required by applicable law.
While we strive to protect your personal data using appropriate measures, no security system is completely impenetrable. You are also responsible for maintaining the confidentiality of your login credentials and for notifying us immediately if you suspect unauthorised use of your account.
Complaints & Contacts
OBSERVE: Users must know how to raise concerns and with whom.
EXPAND: As an offshore operator, our primary point of recourse is internal; however, we also describe general options to approach data protection authorities in relevant jurisdictions where individuals may reside or whose laws may apply, while noting the specific limitations for Australian players.
REFLECT: We set out a clear complaint path and realistic expectations.
Contacting Us
- Primary privacy contact: [email protected]
- Customer support for account-related issues: [email protected]
- Postal address: Dama N.V., Data Protection Department, Scharlooweg 39, Willemstad, Curacao
Internal Complaint Procedure
- Submission: Send your complaint or query in writing to our Data Protection Department, indicating that it is a "Privacy / Data Protection Complaint". Provide your account details, contact information, and a clear description of the issue.
- Acknowledgement: We aim to acknowledge receipt of your complaint within seven (7) days.
- Investigation: We will investigate your complaint, which may include contacting you for additional information.
- Response: We will provide a substantive response within 30 days of receiving a complete complaint, explaining our findings and any actions we will take. If we cannot meet this timeframe, we will inform you of the delay and the reasons.
- Escalation: If you are not satisfied with our response, you may request that your complaint be escalated internally for further review.
External Recourse and Supervisory Authorities
Because Dama N.V. is established in Curacao and provides services to Australian residents on an offshore basis, you may not have direct access to an Australian gambling or data protection regulator with effective jurisdiction over our operations. However, in certain circumstances (for example, if you are an EU/EEA resident and EU data protection law applies to our processing of your data), you may have the right to lodge a complaint with your local data protection authority.
- If you are located in a jurisdiction that provides a right to complain to a data protection authority, you may contact:
- the authority in the country or region of your habitual residence;
- the authority in the place of your work; or
- the authority in the place where you consider that a violation of data protection law occurred.
We encourage you to first contact us directly so we can attempt to resolve your concerns as efficiently as possible.
Updates
OBSERVE: Privacy policies evolve over time.
EXPAND: We must explain how users will be informed of changes, keep version control, and give notice of material updates.
REFLECT: We define notification methods, timing, and user options.
Changes to This Privacy Policy
- We may update or amend this Privacy Policy from time to time to reflect changes in our practices, technologies, legal or regulatory requirements, or other factors.
- When we make changes, we will revise the "Last updated" date at the end of this Privacy Policy and, where appropriate, provide a summary of material changes.
Notification of Material Changes
- For material changes that significantly affect your rights or the way we process your personal data, we will take additional steps to inform you, which may include:
- sending an email notification to the address associated with your account;
- displaying a prominent notice or banner on playamowin-au.com;
- providing alerts in your account dashboard, where available.
- Where feasible and required, we will provide at least 30 days' advance notice before material changes take effect, so that you have time to review them.
User Options on Policy Changes
- If you do not agree with the updated Privacy Policy, you may:
- adjust your privacy settings (where available);
- withdraw your consent for certain processing activities, where applicable; and/or
- close your account and cease using our services.
- Continued use of our services after the effective date of an updated Privacy Policy will constitute acceptance of the changes, to the extent permitted by applicable law.
Last updated: January 2026