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Privacy Policy

This privacy policy explains how personal information is handled when you use libertyslotz.com ("the Website"), operated for the benefit of Australian players and visitors. It establishes our commitments to privacy in accordance with Australian law, including the Privacy Act 1988 (Cth), and applies to all players and website visitors. Effective date: 1 January 2025.

Who We Are

OBSERVE: Review operator's legal identity, contact channels, and privacy responsibility as per required transparency under AU law (APP 1 & 5). EXPAND: Infer need for Data Protection Officer (DPO) and clarity of brand-to-site linkage. REFLECT: Provide verifiable company details and DPO contact for all privacy matters.

  • Operator Legal Name: Liberty Slots Operations Pty Ltd
  • Registered Address: Level 18, 101 Collins Street, Melbourne VIC 3000, Australia
  • Australian Business Number (ABN): 12 345 678 901
  • Contact for Privacy Enquiries/Data Protection Officer (DPO): [email protected]; postal: Data Protection, Liberty Slots Operations Pty Ltd, Level 18, 101 Collins St, Melbourne VIC 3000, Australia

What Personal Data We Collect

OBSERVE: Identify AU-relevant data categories as per Privacy Principle 3. EXPAND: Clarify necessity for operational, legal, and marketing purposes. REFLECT: Comprehensive enumeration of information types gathered about users and their activity on libertyslotz.com.

  • Personal Identification Data: Full name, date of birth, residential address, email address, phone number, government-issued identification documents (for verification/KYC).
  • Technical Data: IP address, device information (browser, OS), geolocation data, log data (timestamps, session IDs), connection metadata.
  • Payment and Financial Data: Bank account details, credit/debit card numbers (tokenised via PCI DSS-compliant processors), withdrawal details, transaction history.
  • Behavioral and Usage Data: Betting and game history, deposit and withdrawal activity, clicks, navigation pathways, player preferences, interactions with promotions.
  • Cookies and Tracking Data: Session cookies, persistent cookies, third-party advertising and analytics cookies, pixel tags, local storage objects.

Legal Basis for Processing

OBSERVE: Align processing grounds with APPs and implied contractual/legitimate interests. EXPAND: Account for explicit consent and legal duties imposed on gambling operators. REFLECT: Set out each applicable legal basis with cross-reference to statutory obligations and protective user clauses.

  • User Consent: Personal data processing for marketing and communications will always require the user's explicit consent, which may be withdrawn at any time via account settings or direct requests.
  • Contractual Necessity: We process personal and payment data to confirm eligibility, create accounts, facilitate gaming activities, and provide services as agreed under the User Terms (including payments, rewards, and account management).
  • Legal Obligations (including KYC/AML): Regulatory requirements necessitate verification of identity, anti-money laundering (AML) screening, fraud monitoring, and mandatory record-keeping for up to 5 years after account closure or the last transaction in accordance with applicable Australian gambling law and anti-money laundering legislation.
  • Legitimate Interests: Data is processed to improve services, ensure IT security, prevent fraud, and undertake internal analytics, ensuring such interests do not override users' fundamental data protection rights.

Regional Compliance Note: Where express consent is required by law, processing will not occur without such consent. Certain data retention periods are mandated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

Purpose of Processing

OBSERVE: Map all main business activities reliant on user data. EXPAND: Note additional purposes enabled by technology (personalisation, risk management, lawful marketing). REFLECT: Explain to users why each type of data may be used on libertyslotz.com.

  • Account and Service Provision: To enable account creation, access to games, payment processing, withdrawals, customer support, and technical operations.
  • Service Enhancement and Personalisation: To enhance gaming experience, troubleshoot technical issues, analyse user preferences, and develop new features.
  • Marketing and Communications: With explicit user consent, to provide promotional materials, newsletters, and targeted offers specific to user interests.
  • Legal Compliance and Reporting: To fulfil obligations for anti-fraud, AML, regulatory checks, and resolve disputes as required by Australian law and industry standards.
  • Analytics and Risk Management: To compile aggregate statistics, detect suspicious activity, manage system performance, and implement safeguards against unauthorised access or abuse.

Disclosure & Sharing

OBSERVE: Identify mandatory/optional recipients for data disclosure. EXPAND: Highlight consent-based sharing and regulatory requirements. REFLECT: Clearly stipulate recipient categories and user safeguards.

  • Payment Partners and Financial Institutions: Data is shared securely with licensed payment processors and banks for transaction execution and verification.
  • Service Providers: Third-party technical suppliers (hosting, anti-fraud screening, IT support), under strict confidentiality and data processing agreements compliant with Australian and international standards.
  • Regulatory and Law Enforcement Authorities: Where necessary to comply with legal obligations (including AU regulatory requests, court orders, law enforcement investigations).
  • Affiliates and Marketing Networks: With user consent, personal data (non-sensitive) may be shared for advertising, customer referral, and promotional purposes, always in accordance with the Privacy Act 1988 and the Australian Privacy Principles.
  • Corporate Transactions: In the case of a merger, acquisition, or restructuring, user data may be transferred as an asset or for due diligence, but always under strict confidentiality obligations.

We do not sell or commercially disclose your personal information without your explicit consent.

International Transfers

OBSERVE: Recognise cross-border transfer triggers and jurisdictional restraints under APP 8. EXPAND: Identify recipients outside Australia and relevant protections. REFLECT: Inform users of safeguards in place when overseas data handling occurs.

  • Data Transfers Outside Australia: Some service providers, data processors, or cloud storage platforms used by libertyslotz.com may be located in, or process data in, countries such as the United States, the European Union, or Singapore.
  • Safeguards: Any such transfers are conducted in compliance with the Australian Privacy Principles, using standard contractual clauses, binding corporate rules, or equivalently robust contractual and technical protections to maintain data security and user rights.

Regional Compliance Note: No international transfer occurs unless the receiving party affords protection substantially similar to the Australian regime or user-specific informed consent has been obtained.

Data Retention

OBSERVE: Document mandatory and practical retention periods for all data types. EXPAND: Note user-triggered deletion procedures and fixed statutory minimums (e.g., 5 years for KYC/AML records). REFLECT: Disclose periods and methods for data review and disposal.

  • Personal Identification and Verification Data: Retained for at least 5 years following account closure or last transaction, as required by law, after which it is securely deleted or anonymised unless a longer retention is required for ongoing dispute resolution or regulatory obligations.
  • Payment and Transaction Data: Similarly retained for minimum 5 years for audit, tax, and compliance purposes.
  • Behavioral and Technical Data: Retained for a period necessary to fulfil the purposes outlined above, typically no longer than 2 years after account closure, unless otherwise mandated.
  • User-Initiated Deletion: Account closure or specific deletion requests will trigger data removal processes, except for any data we must retain under statutory or contractual requirements.

Data is deleted or permanently de-identified in accordance with regulatory guidance and internal policy at the expiration of the maximum retention period or upon user request, subject to legal exceptions.

Your Rights

OBSERVE: Ensure users' rights per the Australian Privacy Principles (APP 12 and 13) and general best practices are fully disclosed. EXPAND: Include procedural explanation for exercising rights. REFLECT: Clearly enumerate user data rights and how to exercise each with libertyslotz.com.

  1. Right to Access: Request access to all personal data held about you in a digital, printable format.
  2. Right to Correction: Request correction or completion of inaccurate, outdated, incomplete, or misleading personal data.
  3. Right to Erasure ("Right to Be Forgotten"): Request deletion of your data where legally permissible, subject to retention obligations for legal or regulatory compliance.
  4. Right to Restrict Processing: Request the limitation of how your data is used in situations where you contest its accuracy or object to processing.
  5. Right to Object: Object to the processing or use of your personal data for direct marketing purposes at any time.
  6. Right to Data Portability: Where feasible, receive your data in a portable, machine-readable format and have it transferred to another provider at your direction.
  7. Right to Withdraw Consent: Withdraw consent for marketing communications or non-essential data processing at any time via account settings or by contacting our DPO.

To exercise your rights, contact our Data Protection Officer at [email protected]. We respond to all valid requests within 30 days, in accordance with the Australian Privacy Principles.

Cookies & Tracking Technologies

OBSERVE: Identify cookie types, legal rationale, and user management options as per Privacy Act and ACCC guidelines. EXPAND: Disclose data collected by cookies and explain user opt-out procedures. REFLECT: Provide a clear summary of tracking methods on libertyslotz.com and control over them.

  1. Session Cookies: Temporary cookies necessary for website operation and player authentication; deleted when you close your browser.
  2. Persistent Cookies: Remain on your device to remember preferences, enable faster login, and facilitate personalisation; lifespan does not exceed 12 months.
  3. Third-Party Cookies: Set by analytics providers (e.g., Google Analytics), payment partners, and advertising networks (with user consent), used for performance measurement and targeted advertising.
  • Cookie Management: You can control or delete cookies at any time using your browser's privacy settings, and/or the in-site cookie preference panel. Disabling certain cookies may limit website functionality.
  • Do Not Track: libertyslotz.com respects your 'Do Not Track' browser settings where technically feasible, and will not use unnecessary cookies unless consent is granted.

Data Security

OBSERVE: Systematise technical/organisational safeguards per AU security standards (APP 11). EXPAND: Highlight multi-layered security strategy and third-party risk mitigation. REFLECT: Document the specific measures in place for user assurance.

  • Encryption and SSL: All data transmitted between the user and libertyslotz.com is secured via industry-standard SSL/TLS encryption. Sensitive data (including banking details) is encrypted at rest and in transit.
  • Access Controls: Strict internal access policies limit data access to authorised personnel only, using role-based access and authentication.
  • Regular Audits and Security Testing: We conduct routine vulnerability assessments, penetration testing, and compliance audits to ensure ongoing protection of all systems and data.
  • Staff Training: All employees accessing personal data undergo regular data protection and cyber security training in line with current best practices.
  • Incident Management: In the event of a data breach, affected users and the Office of the Australian Information Commissioner (OAIC) will be notified in accordance with the Notifiable Data Breaches (NDB) scheme.

Regional Compliance Note: All security measures align with the requirements of the Australian Privacy Principles and industry-specific regulations governing gambling operators.

Complaints & Contacts

OBSERVE: Ensure user support and statutory complaints mechanisms are transparent. EXPAND: Clarify escalation process, OAIC referral, and DPO communication. REFLECT: Outline steps for raising and resolving privacy issues regarding libertyslotz.com.

  1. Internal Resolution: If you have questions, requests or complaints regarding your privacy or the handling of your personal data by libertyslotz.com, please contact our Data Protection Officer at [email protected] or via the feedback form at https://libertyslotz.com/contact.
  2. Response Commitment: We commit to acknowledging all written privacy complaints within 5 business days and aim to resolve all issues within 30 days. Outcomes will be provided in writing.
  3. Escalation to Regulator: If you are not satisfied with our response, you may lodge a complaint directly with the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au).

Updates

OBSERVE: Ensure users receive timely notice of material policy changes. EXPAND: Add commitments to visible communication channels and change log maintenance. REFLECT: Make clear to users how to stay informed about privacy updates on libertyslotz.com.

  • Notification of Changes: Any material changes to this privacy policy will be posted on the Website's privacy page, and for material modifications, users will be notified via email or in-site notification before the changes become effective.
  • Effective Date and Revision History: The current version is effective as of 1 January 2025. The date of each update will be shown at the top of this policy page for user reference.