Privacy Policy

This Privacy Policy explains how personal information is collected, used, disclosed, and protected when you visit or use hellspin-aussie.com in connection with the brand Hell Spin (Hell Spin) (the "Website"). It applies to all visitors to the Website and to players who use the gambling services offered through the Website. By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective from 1 January 2025 and is intended to remain in force, with updates as required, at least through 2026.

Who We Are

OBSERVE: The operator and related entities must be clearly identified for transparency and legal accountability.

EXPAND: The Website is operated offshore by a Curaçao-licensed company with a related Cyprus payment entity, targeting users in Australia without maintaining a local Australian office.

REFLECT: We therefore specify the operator, registration details, and primary contact channels below.

The Website hellspin-aussie.com, associated with the brand name Hell Spin and the project Hell Spin, is owned and operated by:

Operator: TechOptions Group B.V., a private limited liability company (B.V.) incorporated under the laws of Curaçao.
Registration number: 153194
Registered legal and headquarters address: Dr. H. Fergusonweg 1, Willemstad, Curaçao
Gambling licence: Sub-licence under Master Licence 8048/JAZ (reference: 8048/JAZ2017-067) issued via Antillephone N.V. and overseen by the Curaçao Gaming Control Board. Status treated as active through at least 2026, subject to regulator decisions.

For certain payment processing and related services, the operator may use:

Payment agent / payment processor: TechOptions (CY) GROUP LTD
Jurisdiction: Cyprus
Registration number: HE 410365

The operator does not maintain a registered office in Australia; services are provided from offshore jurisdictions and may be subject to enforcement or blocking measures by Australian authorities, including the Australian Communications and Media Authority (ACMA).

Data Protection Contact

Data Protection Contact / Department: Data Protection Officer (DPO), TechOptions Group B.V.
E-mail: [email protected] (please state "Privacy request" in the subject line).
Postal contact for privacy matters: Data Protection Officer, TechOptions Group B.V., Dr. H. Fergusonweg 1, Willemstad, Curaçao.

This contact point is responsible for handling questions, requests, and complaints relating to privacy and personal data in connection with hellspin-aussie.com and the Hell Spin project.

What Personal Data We Collect

OBSERVE: Operating an online casino requires collection of identification, contact, technical, financial, and behavioural data.

EXPAND: Additional information such as cookies, device identifiers, and logs are processed for security, regulatory, and optimisation purposes.

REFLECT: We categorise the data we collect to provide transparency and facilitate the exercise of your privacy rights.

Identification and Contact Data

Full name, date of birth, and gender (where provided).
Residential address, country of residence, and postcode (if applicable).
Contact details such as e-mail address and telephone number.
Identity verification information, such as copies or data from passports, ID cards, driving licences, utility bills, or bank statements (KYC documentation).

Account and Usage Data

Username, account ID, passwords (stored in encrypted form), security questions and answers.
Account settings, preferences, and communication choices.
Support correspondence, complaints, and other interactions with our customer support team.

Technical and Log Data

IP address, approximate location derived from IP, device identifiers, browser type and version, operating system, language settings.
Log files recording access dates and times, pages viewed, clickstream data, session duration, and referral URLs.
Information collected through cookies, web beacons, pixels, and similar technologies (see "Cookies & Tracking Technologies" below).

Payment and Financial Data

Payment method details (e.g., partial card numbers masked where appropriate, card type, expiry date, issuing bank, and country).
E-wallet identifiers, bank account details, or other payment instrument identifiers used to make deposits or withdrawals.
Transaction records, including deposits, withdrawals, chargebacks, refunds, and bonus credits.
Payment verification information collected by us or our payment processors as part of anti-fraud and anti-money laundering (AML) checks.

Behavioural and Gambling Data

Game play history, including games played, time spent, stakes, wins, losses, and bonus use.
Betting patterns, frequency of play, average wager size, and risk indicators.
Responsible gambling data, including self-exclusion status, deposit or loss limits, reality checks, and related settings.
Interaction data related to promotions, tournaments, and loyalty or VIP programmes.

Marketing and Communication Data

Marketing preferences (e.g., consent to receive e-mails, SMS, or on-site notifications).
Records of e-mails and messages sent to you, including open and click rates where permitted.
Participation in surveys, polls, feedback requests, or research initiatives.

Cookies and Similar Technologies

Session cookies that enable core functionality during your visit.
Persistent cookies that remember your preferences or login status across sessions.
Third-party cookies and similar tracking technologies for analytics and, where permitted, advertising.

We may combine personal information from different categories and sources (including third-party verification services and payment processors) to comply with legal obligations, enhance security, and improve the services of Hell Spin provided via hellspin-aussie.com.

Legal Basis for Processing

OBSERVE: As an offshore operator serving users in multiple jurisdictions, we rely on several legal bases for processing personal data.

EXPAND: These include performance of a contract, compliance with legal obligations (such as gambling, AML, and accounting laws), legitimate interests, and your consent for specific activities.

REFLECT: Understanding these bases helps you assess our processing and, where applicable, exercise your right to object or withdraw consent.

Performance of a Contract

We process your personal data where it is necessary to enter into and perform a contract with you. This includes:

Registering and managing your player account.
Providing access to casino games and related services offered on hellspin-aussie.com.
Processing deposits, bets, withdrawals, and bonus credits.
Providing customer support and handling your requests.
Notifying you about changes to our terms and conditions or technical issues directly affecting your account.

Compliance with Legal Obligations

We are required to process certain personal data to comply with applicable laws and regulations, which may include Curaçao gambling regulations, AML/CTF (anti-money laundering and counter-terrorist financing) rules, and other mandatory reporting obligations. This processing may involve:

Verifying your identity, age, and place of residence (KYC checks).
Monitoring and recording transactions for AML/CTF and fraud prevention purposes.
Retaining records for tax, accounting, and regulatory audit requirements for legally mandated periods.
Responding to lawful requests from regulators, law enforcement bodies, courts, or other public authorities.

Legitimate Interests

We may process your personal data where necessary for our legitimate interests, provided that these interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include:

Ensuring the security and integrity of our systems, games, and services.
Preventing, detecting, and investigating fraud, misuse, or other unlawful activities.
Conducting analytics to understand how our services are used, to improve functionality, performance, and user experience.
Protecting our legal rights, defending against claims, and enforcing our terms and conditions.
Managing business administration, risk management, and internal reporting.

Where required by law, and where our legitimate interests are not sufficient, we will seek your consent before processing data for specific purposes, such as certain types of marketing or profiling.

Consent

In some circumstances we rely on your consent as the legal basis for processing, particularly for:

Sending direct marketing communications by e-mail, SMS, push notifications, or similar channels where consent is required.
Using certain cookies and tracking technologies that are not strictly necessary for operation of the Website.
Processing sensitive categories of data (if any) where applicable law mandates explicit consent.

You may withdraw your consent at any time using the mechanisms described in this Privacy Policy. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

Purpose of Processing

OBSERVE: Each processing activity must be linked to a specific, legitimate purpose.

EXPAND: Operating Hell Spin through hellspin-aussie.com involves operational, compliance, security, marketing, and analytic purposes.

REFLECT: We outline the main purposes to provide clarity and align with applicable privacy standards.

Provision of Gambling and Related Services

To create, verify, and manage your player account.
To enable you to deposit funds, place bets, participate in games, and request withdrawals.
To manage bonuses, loyalty programmes, tournaments, and other promotional features.
To provide customer service and technical support.

Regulatory Compliance and Responsible Gambling

To comply with age verification, KYC, AML/CTF, and other legal obligations.
To monitor gameplay and transactions for signs of problem gambling, fraud, or suspicious activity.
To administer self-exclusion mechanisms, deposit/loss limits, and reality checks where available.
To maintain records required by regulators or other competent authorities.

Service Improvement and Analytics

To analyse usage patterns and preferences, helping us improve the design, content, and functionality of the Website.
To conduct statistical and aggregated analysis of betting and game performance (with data typically anonymised or pseudonymised where feasible).
To test, develop, and improve systems, algorithms, and security measures.

Marketing and Personalisation

To send you promotional communications about Hell Spin products, services, and special offers, where permitted by law and in line with your preferences.
To personalise content, bonuses, and recommendations based on your account activity and preferences.
To conduct surveys, competitions, and feedback campaigns aiming to enhance our services.

Security and Fraud Prevention

To authenticate users and prevent unauthorised access to accounts.
To detect and prevent fraud, abuse, collusion, bonus misuse, money laundering, and other prohibited or unlawful activities.
To implement and monitor security measures, including log analysis and incident response.

Business Operations

To manage internal administration, accounting, and reporting.
To conduct audits and due diligence processes.
To handle disputes, enforcement of our contractual rights, and management of legal claims.

Disclosure & Sharing

OBSERVE: Operation of an online casino requires collaboration with third-party providers and may involve disclosures to regulators and authorities.

EXPAND: We differentiate between categories of recipients and explain the conditions under which data may be shared.

REFLECT: This promotes transparency and helps you understand how and why your information might leave our direct control.

Group Companies and Payment Agents

We may share your personal data with TechOptions (CY) GROUP LTD and other related entities acting as payment agents, processors, or service providers, strictly as necessary for payment processing, risk checks, and financial reconciliation.

Payment Service Providers and Banks

Banks, card schemes, e-wallet providers, and other payment institutions that process deposits and withdrawals on our behalf.
These partners receive data necessary to perform the transaction, conduct security checks, and comply with their own legal obligations.

Service Providers and Technical Partners

Gaming software providers, platform providers, and RNG (Random Number Generator) testing laboratories (for example, entities that may be listed on institutional registries such as eCOGRA or iTech Labs, although no specific certification for TechOptions Group B.V. is assumed unless explicitly stated by those organisations).
IT infrastructure providers, hosting providers, content delivery networks, and cyber-security service providers.
Customer support platforms, communication tools, and marketing or analytics providers.

Regulators and Public Authorities

Gambling regulators, such as the Curaçao Gaming Control Board and associated licence holders.
Law enforcement agencies, courts, tax authorities, and other governmental bodies where required by law or where we reasonably believe disclosure is necessary to protect our rights, your safety, or the safety of others.
Australian authorities, including the Australian Communications and Media Authority (ACMA), if required under applicable law or enforcement action (for example, in relation to blocking or investigation of offshore gambling services).

Affiliates and Advertising Partners

Affiliate partners who refer players to hellspin-aussie.com, receiving limited data necessary for attribution and commission calculation (typically aggregated or pseudonymised where possible).
Advertising networks and marketing partners, only where local laws permit such sharing and where you have provided any required consent.

Corporate Transactions

In the event of a merger, acquisition, sale of assets, restructuring, or insolvency, your personal data may be transferred to another entity as part of the transaction, subject to appropriate confidentiality and data protection safeguards.

In all cases, we require third parties to process personal data only for specified purposes, in accordance with our instructions and applicable law, and to implement suitable security measures.

International Transfers

OBSERVE: Data processing involves cross-border transfers between Curaçao, Cyprus, and potentially other jurisdictions.

EXPAND: While Australia has its own privacy and gambling enforcement regimes, data may be stored or processed in countries with different levels of protection.

REFLECT: We implement contractual and organisational safeguards to protect your information, recognising that no transfer mechanism is flawless.

Your personal data may be transferred to and processed in:

Curaçao - where TechOptions Group B.V. is incorporated and operates its primary infrastructure or administrative functions.
Cyprus - where TechOptions (CY) GROUP LTD and some payment or support services may be located.
Other countries in the European Economic Area (EEA) or outside the EEA where certain service providers (e.g., hosting, analytics, payment, or game providers) are located.

When we transfer personal data internationally, we take steps intended to ensure that an adequate level of protection is in place, including:

Using contractual safeguards, such as standard contractual clauses or equivalent instruments, where required by applicable data protection law.
Limiting access to personal data on a need-to-know basis and applying technical measures such as encryption and pseudonymisation.
Conducting risk assessments of key providers and monitoring compliance with agreed data protection and security obligations.

By using hellspin-aussie.com and the services of Hell Spin, you acknowledge that your data may be transferred to and processed in jurisdictions that may have different data protection rules than those in your country, including Australia. Where mandated by local law, we will rely on your explicit consent or other lawful transfer mechanisms.

Data Retention

OBSERVE: Retention periods are driven by legal, regulatory, and operational needs.

EXPAND: Gambling and AML regulations often require keeping records for a minimum number of years after the relationship ends.

REFLECT: We define retention periods by category and explain criteria for deletion or anonymisation.

General Retention Principles

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.
Where possible, we anonymise or aggregate data so that it can no longer be associated with an identifiable individual.

Category-Specific Retention Periods

Account and identification data (KYC): Typically retained for the duration of your account and for up to five (5) years after account closure or your last transaction, whichever is later, to comply with AML/CTF and gambling regulations. In some cases, longer retention may be required by law or necessary for legal claims.
Transactional and gambling history: Retained for at least five (5) years after the relevant transaction or account closure, to support regulatory audits, tax or accounting requirements, and dispute resolution.
Marketing data: Retained for as long as you maintain an active account or until you withdraw consent or object to marketing, after which data may be kept in a suppression list to honour your preferences.
Technical logs and security data: Retained for a period proportionate to security and operational needs, generally between six (6) months and five (5) years depending on the sensitivity of the logs and applicable legal requirements.
Customer support records: Retained for up to five (5) years after the resolution of the related issue, or longer if needed for legal defence or regulatory purposes.

Deletion and Anonymisation

When personal data is no longer necessary for the purposes for which it was collected and no longer required by law, we will securely delete or anonymise it.
Where deletion is technically impossible or would require disproportionate effort, we will implement measures to prevent further processing and restrict access.

Your Rights

OBSERVE: Players and visitors need clear information about their rights regarding personal data.

EXPAND: Although the Website is operated offshore and primarily subject to Curaçao law, we align our practices with key international standards, including principles derived from the EU General Data Protection Regulation (GDPR). The section prompt also references Mexican privacy law; we reference such standards only on a best-efforts, non-jurisdictional basis, as the operator is not established in Mexico.

REFLECT: The rights below are provided subject to applicable law, contractual obligations, and overriding regulatory requirements (for example, AML retention duties).

Access to Your Data

You may request confirmation as to whether we process personal data about you and, if so, receive a copy of that data, together with information about how and why we process it.

Correction (Rectification)

You may request that we correct inaccurate personal data or complete incomplete information. In some cases, we will need supporting documentation (e.g., updated ID or proof of address).

Deletion (Erasure)

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 only legal basis).
- You have successfully objected to processing (see below).
- The data has been processed unlawfully.
We may not be able to delete data where retention is required by law, particularly for AML, gambling, or accounting obligations, or where needed to establish, exercise, or defend legal claims.

Restriction of Processing

You may request that we restrict processing of your data in certain circumstances, for example:
- While we verify the accuracy of your data following a rectification request.
- Where processing is unlawful and you prefer restriction to deletion.
- Where we no longer need the data but you require it for legal claims.
- Pending verification of whether our legitimate interests override your interests following an objection.

Objection to Processing

You may object, on grounds relating to your particular situation, to processing based on our legitimate interests. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests or where processing is necessary for legal claims.
You may object at any time to processing of your personal data for direct marketing purposes. We will then cease such processing without undue delay.

Data Portability

Where technically feasible and where the legal basis for processing is your consent or performance of a contract, you may request that we provide you with a copy of your personal data in a structured, commonly used, and machine-readable format, or that we transmit it directly to another controller where technically possible.

Withdrawal of Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing carried out before withdrawal.
Withdrawal of consent may limit or prevent us from providing certain services (for example, personalised offers or specific marketing communications).

Procedures, Timeframes, and Cost

How to exercise your rights: You may exercise your rights by contacting our DPO at [email protected] and clearly stating your request and the right you wish to exercise. For your protection, we may need to verify your identity before responding.
Response timeframe: We aim to respond to all valid requests within one (1) month of receipt. If the request is complex or we receive multiple requests, we may extend this period by up to two (2) additional months, in which case we will inform you of the extension and reasons.
Charges: We generally handle requests free of charge. However, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, excessive, or repetitive, consistent with applicable law.

Nothing in this Privacy Policy is intended to grant rights beyond those provided under applicable law in your jurisdiction, nor to subject TechOptions Group B.V. or Hell Spin to any specific foreign legal regime (such as the laws of Mexico or the European Union) where this is not otherwise required.

Cookies & Tracking Technologies

OBSERVE: Cookies and similar tools are essential to provide and optimise the Website and services.

EXPAND: Different types of cookies serve technical, functional, analytical, and advertising purposes.

REFLECT: We describe the categories of cookies used, their purposes, and your options to manage them.

Types of Cookies We Use

Strictly Necessary / Session Cookies: These cookies are essential for the operation of hellspin-aussie.com, enabling functions such as login, navigation, and secure use of the Website. They are typically deleted when you close your browser.
Functional / Preference Cookies: These cookies remember your preferences (e.g., language, region, saved details) and enhance your experience. They may persist for a defined period after your visit.
Analytics / Performance Cookies: These cookies collect information about how visitors use the Website (e.g., pages visited, session duration, error messages). We use this data in aggregated form to improve functionality and performance.
Advertising and Third-Party Cookies: Where allowed by law and with any necessary consent, we may permit third-party partners (e.g., affiliate networks or advertising providers) to set cookies that track your activity across websites to measure campaign performance and deliver more relevant advertising.

Managing Cookies

You can manage or delete cookies using your browser settings. Instructions are typically available in the "Help" or "Settings" section of your browser.
Most browsers allow you to:
- View which cookies are stored and delete them individually.
- Block third-party cookies or cookies from specific sites.
- Block all cookies or delete all cookies when closing the browser.
Blocking or deleting certain cookies may affect your ability to use some features of hellspin-aussie.com, particularly those requiring login or real-time game functionality.
Where available, you may also manage certain cookie preferences via an on-site cookie banner or internal settings panel.

Data Security

OBSERVE: Security of personal data is critical given the financial and sensitive nature of gambling-related information.

EXPAND: We employ a combination of technical, organisational, and procedural measures to protect data against unauthorised access, alteration, disclosure, or destruction.

REFLECT: While no system is entirely immune to risk, our goal is to maintain a security posture consistent with recognised industry standards.

Technical Measures

Encryption in transit: Communications between your browser and hellspin-aussie.com are protected using Transport Layer Security (TLS) version 1.2 or higher, helping to safeguard data from interception.
Encryption at rest: Sensitive data, including passwords and certain financial information, is stored using strong encryption or hashing mechanisms.
Access controls: Personal data is accessible only to authorised personnel and systems, based on role and need-to-know principles.
Network and application security: We employ firewalls, intrusion detection/prevention systems, and regular patching to protect against vulnerabilities.

Organisational and Procedural Measures

Multi-factor authentication (MFA): Where implemented, MFA and strong authentication practices are used for administrator accounts and other sensitive access points.
Staff training: Employees and contractors with access to personal data receive training on confidentiality obligations, data protection, and security best practices.
Security audits and monitoring: We subject our systems and procedures to periodic reviews, internal audits, and monitoring. External audits may also be carried out by independent experts or as part of regulatory oversight.
Incident response: We maintain procedures to detect, investigate, and respond to suspected data breaches or security incidents. Where required by law, we will notify affected individuals and/or relevant authorities without undue delay.

While we endeavour to align our controls with recognised security frameworks (such as principles reflected in ISO 27001 or SOC 2), we do not claim formal certification under any specific standard unless explicitly stated elsewhere on hellspin-aussie.com.

Complaints & Contacts

OBSERVE: Users must have clear channels to raise concerns and complaints about privacy or data protection.

EXPAND: We provide internal escalation paths and outline external supervisory authorities where applicable.

REFLECT: This supports accountability and gives users confidence that issues will be addressed.

Contacting Us

Primary privacy contact (DPO/Data Protection Department): TechOptions Group B.V.
E-mail: [email protected]
Postal address: Data Protection Officer, TechOptions Group B.V., Dr. H. Fergusonweg 1, Willemstad, Curaçao.

Internal Complaint Procedure

Submission: Send your complaint or query, including relevant details and any supporting evidence, to our DPO via e-mail or post.
Acknowledgment: We will acknowledge receipt of your complaint within seven (7) business days where practicable.
Investigation: We will investigate your complaint, which may involve contacting you for further information and reviewing internal records.
Response: We aim to provide a substantive response within thirty (30) days of receiving your complete complaint. For complex matters, we may extend this timeframe, informing you of the extension and reasons.
Escalation: If you are not satisfied with our response, you may request further review within our organisation or seek advice from an external authority or legal adviser.

External Supervisory Authorities

Given that TechOptions Group B.V. is established in Curaçao, the primary regulatory and supervisory bodies are those in that jurisdiction. However, depending on your location, you may have the right to lodge complaints with data protection or communications regulators in your country.

For users in Australia, the following authorities may be relevant:

Australian Communications and Media Authority (ACMA): Responsible for enforcing rules relating to online gambling services and communications. Information on blocked gambling websites and enforcement actions is available at https://acma.gov.au/blocked-gambling-websites.
Office of the Australian Information Commissioner (OAIC): For matters relating to privacy and the handling of personal information in Australia. Contact details are available at https://www.oaic.gov.au.

Nothing in this section should be interpreted as confirming that any particular foreign authority has jurisdiction over TechOptions Group B.V. in all circumstances. However, we will cooperate in good faith with competent authorities in accordance with applicable law.

Updates

OBSERVE: Privacy laws and our operations may evolve over time, necessitating updates to this Privacy Policy.

EXPAND: We outline how we will notify you of changes, maintain version control, and provide you with options if you do not agree with material changes.

REFLECT: Transparent change management enhances trust and ensures that your continued use of hellspin-aussie.com is based on informed understanding.

Changes to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technical developments.
Each version of the Privacy Policy will be identified by the "Last updated" date and, where feasible, a version number.

Last updated: January 2025 (intended to remain valid, with any necessary updates, through at least 2026).

Notification of Material Changes

For non-material changes (e.g., clarifications, minor edits), we may update the Privacy Policy without specific notification, and the revised version will apply from the date it is posted.
For material changes that significantly affect your rights or how we process your personal data, we will:
- Provide notice on hellspin-aussie.com (for example, via a banner or pop-up message); and/or
- Send an e-mail notification to the address associated with your account; and/or
- Display alerts in your account dashboard where applicable.
Unless otherwise required by law, we will provide at least thirty (30) days' advance notice before material changes take effect, giving you the opportunity to review them.

Your Options in Case of Changes

If you continue to use hellspin-aussie.com and the services of Hell Spin after the effective date of the updated Privacy Policy, you will be deemed to have accepted the changes, subject to applicable law.
If you do not agree with the updated Privacy Policy, you may:
- Adjust your privacy or marketing preferences where available; and/or
- Request closure of your account and, where applicable, exercise your rights regarding deletion or restriction of processing, subject to legal retention obligations.