Privacy Policy

Who we are

• Operator: Hollycorn N.V., Curaçao (reg. 144359).

• License: Curaçao GCB OGL/2023/176/0095.

• Role: Data Controller.

• DPO contact: [email protected].

Scope & acceptance

• This Policy + T&Cs + Cookie Policy apply.

• Using the site means you accept this Policy.

• Policy may change; check updates.

• Service is 18+ only.

What data is collected

• Identity: name, DOB, gender, username, IDs.

• Contact: address, email, phone, other channels.

• Financial: bank/card details, source of funds/wealth.

• Transactions: deposits, withdrawals, wagering.

• Gameplay/Usage: games played, sessions, bonuses, limits.

• Technical: IP, device, browser, time zone, cookies.

• Comms: email, chat, call records.

• Profile/Analytics: preferences, activity metrics.

• Special categories (when provided/required): RG-related health hints; racial/ethnic data in documents.

Why it’s used (main purposes)

• Run the account and deliver gaming services.

• KYC, AML, fraud and risk checks; closed-loop payments.

• Responsible gaming monitoring and scoring.

• Service ops: troubleshooting, testing, stats.

• Security and abuse prevention (incl. VPN/proxy checks).

• Product messages and marketing (with consent or legitimate interest).

• Legal duties and license compliance.

• Site personalization and ads based on usage.

Legal bases

• Contract: to provide the service.

• Legal obligation: AML/RG, record-keeping, payments.

• Legitimate interest: security, analytics, service improvement.

• Consent: marketing to partners/other brands; some personalization.

Marketing choices

• You may opt out in account settings or via [email protected] / live chat.

• The brand may contact you unless you opt out.

Sharing data

• Group companies for AML/RG/fraud and, with consent, cross-brand marketing.

• Staff under NDA on a need-to-know basis.

• Game providers (e.g., NetEnt) for gameplay delivery.

• Payment providers for deposits/withdrawals.

• Marketing vendors (email/SMS/call/direct mail) if permitted.

• Regulators/law enforcement when required.

• KYC/AML vendors, age/ID checks, sanctions/PEP tools.

• Advisors (legal/consulting) under agreements.

• Corporate changes: data may transfer on merger/sale.

International transfers

• Data may go outside the EU/EEA.

• Safeguards used (e.g., EU SCCs).

• Service use implies acceptance of such transfers.

Retention

• Keep data only as needed for purposes and law.

• Due to AML rules, core records are kept at least 5 years after last transaction or account closure.

• Some data may be anonymized for insights.

Your rights

• Access, copy, and portability (limits apply).

• Rectification (with proof).

• Erasure (where no legal basis to keep).

• Restriction and objection (legitimate-interest cases).

• Withdraw consent at any time (future use).

• Complain to a supervisory authority.

Responses & contacts

• Typical reply time: within one month; longer for complex cases (you’ll be told).

• If no reply within 10 days, contact via another channel.

• Support: [email protected]

• DPO: [email protected]

Security

• Technical and organizational measures in place.

• Access limited to authorized roles.

• Account protected by password and optional 2FA.

• You must keep credentials private.

Minors

• No data is knowingly collected from persons under 18.

• Underage accounts are blocked.