Privacy Policy

1. Introduction

This Privacy Policy describes how Tower Gaming N.V. ("we", "us", "our"), operating Aqua Spins Casino at aquaspins.bet, collects, processes and protects the personal data of individuals who use our Platform. We are committed to handling your personal data with respect, transparency and appropriate security.

2. What Data We Collect

We collect the following categories of personal data:

Account data: name, date of birth, email address, country of residence, chosen currency and password (hashed).
Identity and verification data: copies of government-issued ID, proof of address and payment method documentation submitted for KYC purposes.
Transaction data: deposit and withdrawal records, payment method details (card numbers are not stored in full - we use tokenisation via our payment processor), cryptocurrency wallet addresses and transaction hashes.
Play data: game history, session durations, bet amounts, win and loss records. This data is used for account management, responsible gambling monitoring and dispute resolution.
Technical data: IP address, browser type, device identifiers, operating system, referral URL and cookies.
Support communications: content of live chat sessions and emails exchanged with our support team.

3. How We Use Your Data

We process your personal data for the following purposes:

Providing and maintaining your account and casino services (contractual necessity)
Processing deposits and withdrawals (contractual necessity)
Verifying your identity and age to comply with our licensing obligations (legal obligation)
Preventing fraud, money laundering and other financial crime (legal obligation)
Monitoring for responsible gambling indicators and applying intervention tools (legitimate interest and legal obligation)
Sending transactional communications - account confirmations, withdrawal receipts, bonus credits (contractual necessity)
Sending promotional communications - bonus offers, tournament invitations, newsletter (consent - you may withdraw at any time)
Improving our Platform - analytics, A/B testing, performance monitoring (legitimate interest)

4. Cookies

Aqua Spins Casino uses cookies and similar tracking technologies to operate the Platform and understand how it is used. Strictly necessary cookies (session management, security) cannot be disabled. Analytics and marketing cookies are set only with your consent, which you provide via our cookie banner on first visit. You can withdraw consent at any time by adjusting your browser settings or via the cookie management tool in our footer.

5. Data Sharing

We share your personal data only where necessary:

Payment processors: to handle deposit and withdrawal transactions.
KYC service providers: to verify identity documents electronically.
Game software providers: game providers may receive anonymised session data for game performance monitoring - no personal identifiers are shared.
Regulatory and legal authorities: we disclose data as required by our Curacao licence obligations, court orders or law enforcement requests.
Analytics providers: aggregated, anonymised usage data may be shared with analytics platforms.

We do not sell, rent or trade your personal data to third parties for their own marketing purposes.

6. Data Retention

Account data is retained for the lifetime of your account plus 5 years following account closure, as required by our anti-money laundering compliance obligations. KYC documents are retained for a minimum of 5 years post-account closure. You may request deletion of optional data categories (marketing preferences, analytics profiles) at any time.

7. Your Data Rights

Subject to applicable law, you have the following rights regarding your personal data:

Access: request a copy of the data we hold about you.
Rectification: request correction of inaccurate data.
Erasure: request deletion of data we are not legally obliged to retain.
Portability: receive your data in a structured, machine-readable format.
Objection: object to processing based on legitimate interest, including direct marketing.
Withdrawal of consent: withdraw consent for marketing communications at any time via the unsubscribe link in any email or by contacting support.

To exercise any of these rights, email [email protected] with the subject line "Data Rights Request" and include your account email address for verification.

8. Security

We use 256-bit SSL encryption on all connections to the Platform. Player data is stored on access-controlled servers. Internal access to personal data is limited to staff with a legitimate business need. We conduct regular security assessments and maintain an incident response procedure. In the event of a data breach that creates a risk to your rights, we will notify you and the relevant authority within the timeframe required by applicable law.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material updates will be communicated by email to your registered address. The version date in the header of this document reflects the most recent revision. Your continued use of the Platform after notification of changes constitutes acceptance of the revised Policy.

10. Contact

For any privacy-related queries or to exercise your data rights, contact us at [email protected]. Please include "Privacy" in your email subject line.

11. International Data Transfers

Aqua Spins Casino may transfer your personal data to third-party processors located outside the European Economic Area (EEA) as part of our payment processing, KYC verification and analytics operations. Where we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission or equivalent adequacy decisions. You may request details of the specific safeguards applicable to any international transfer by contacting us at [email protected].

12. Children and Minors

Aqua Spins Casino does not knowingly collect personal data from individuals under the age of 18. If you become aware that a minor has provided us with personal data without parental consent, please contact us immediately at [email protected]. We will take steps to delete the relevant data and close the associated account promptly upon verification.

13. Third-Party Links

Our website may contain links to third-party websites - including responsible gambling organisations such as GamCare, BeGambleAware and Gambling Therapy. This Privacy Policy applies only to the Aqua Spins Casino Platform. We are not responsible for the privacy practices of any linked third-party websites and encourage you to review their individual privacy policies.

14. Automated Decision-Making

Aqua Spins Casino uses automated processes to monitor for fraud indicators and responsible gambling signals. These processes may result in automated restriction of your account (for example, a temporary deposit freeze if multiple failed payment attempts are detected in rapid succession). Where an automated decision has a significant impact on your access to our services, you have the right to request human review of that decision. Contact [email protected] to exercise this right.