Privacy Policy

This Privacy Policy explains how the Australian-facing version of Syndicate Casino available at syndicatebet-au.com ("Syndicate Casino", "we", "us", "our") collects, uses, stores, shares and protects your personal information when you visit our websites or use our casino services.

This Policy applies to all visitors to our websites and all registered players who access our services via syndicatebet-au.com and related mirror domains referenced on that site. By using our services, you acknowledge that your data will be processed by an offshore operator located in Curaçao and Cyprus, and that Australian governmental recourse may be limited.

This Privacy Policy is designed to align with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), as well as international standards such as the EU General Data Protection Regulation (GDPR) and relevant Mexican data protection laws, where they apply to you based on your residence.

This version of the Privacy Policy is effective from 1 February 2026 and remains in force until replaced or updated in accordance with the "Updates" section below.

Who We Are

Operator and legal entity

• Brand name: Syndicate Casino (Australian-facing version: Syndicate Casino)
• Operating website for Australian players: https://syndicatebet-au.com
• Global primary domain: https://syndicate.casino (may be subject to ACMA blocking for Australian users)

Operating company

• Legal name: Dama N.V.
• Legal form: Public limited company (N.V.) under the laws of Curaçao
• Registration number: 152125
• Registered & head office address: Scharlooweg 39, Willemstad, Curaçao

Payment processing subsidiary

• Entity: Friolion Limited
• Role: Payment processing subsidiary for Dama N.V.
• Address: Leandrou, 12A, 3086 Limassol, Cyprus

Gaming licence

• Licence number: 8048/JAZ2020-013
• Licence holder: Dama N.V.
• Licensing jurisdiction: Curaçao, under Antillephone N.V. master licence (see validator.antillephone.com)
• Status: Treated as active through at least 31 December 2026 based on 2025 verification.

Important Australian note: We operate offshore and do not hold an Australian licence under the Interactive Gambling Act 2001. Our websites may be subject to blocking or enforcement actions by the Australian Communications and Media Authority (ACMA). This does not generally affect the processing of your personal information, but it limits Australian regulatory oversight and remedies.

Data Protection contact

• Responsible function: Data Protection Officer / Data Protection Team of Dama N.V.
• Email (primary, including privacy queries): [email protected]
• Email (general information / legal notices): [email protected]
• When writing about privacy, please include "Privacy" or "Data Protection" in the subject line so that your request is routed to the appropriate team.

What Personal Data We Collect

We collect and process only the data necessary to operate Syndicate Casino, comply with legal obligations and improve our services. Depending on how you interact with us, we may collect the following categories of data:

Identification and contact data

• Full name, date of birth, gender (where provided)
• Residential address, nationality, billing address
• Email address(es) and phone number(s)
• Copies of identity documents (e.g. passport, driver licence, national ID) and proof of address documents for KYC/AML checks

Account and gameplay data

• Username, password (stored in hashed form), account ID
• Registration date, verification status, communication preferences
• Betting and gaming history, wins and losses, bonuses claimed, loyalty points and tournament participation
• Interactions with our support team (emails, chats, complaint records)

Payment and financial data

• Payment method details (e.g. partial card details, masked IBAN or account details, e-wallet identifiers)
• Cryptocurrency wallet addresses, transaction hashes and related blockchain metadata when you use crypto payments
• Deposit and withdrawal records, currency, amounts, timestamps and payment provider used
• Fraud risk scores and chargeback records, where applicable

Technical and usage data

• IP address, approximate geolocation derived from IP (country, region, city)
• Device identifiers, browser type and version, operating system, language settings
• Log files, including access times, requested pages, error logs and session identifiers
• Clickstream data, pages viewed, links clicked, time spent, navigation paths

Behavioral and marketing data

• Preferences regarding games, bet sizes, payment methods and promotions
• History of marketing communications sent and opened (emails, SMS, push notifications)
• Participation in surveys, feedback, reviews and competitions
• Segmentation data and internal profiles used for responsible gambling monitoring and targeted offers

Cookies and similar technologies

• Session cookies necessary to maintain your login and betting session
• Persistent cookies to remember preferences (language, region, cookie choices)
• Analytics cookies for website performance and usage statistics
• Advertising and affiliate tracking cookies (subject to your consent where required)
• Similar technologies such as pixels, tags and local storage used by us or authorised partners

Legal Basis for Processing

Because our players may reside in different jurisdictions, we rely on a combination of legal bases depending on the context and the applicable law (including the Australian Privacy Act, GDPR in the EU/EEA/UK, and relevant Mexican privacy law where applicable):

• Performance of a contract
  We process your data where necessary to enter into and perform our agreement with you, including:
  • Creating and managing your player account
  • Processing deposits, bets, game outcomes and withdrawals
  • Providing customer support and resolving technical issues
  • Managing loyalty programs, tournaments and promotions you participate in
• Compliance with legal and regulatory obligations
  We are required by the laws and regulations of Curaçao and other applicable jurisdictions to:
  • Perform identity verification (KYC), age checks and source-of-funds assessments
  • Monitor transactions to prevent money laundering, terrorism financing and fraud (AML/CFT)
  • Keep appropriate accounting and transactional records
  • Cooperate with law enforcement, courts, regulators (including overseas regulators such as ACMA where applicable) and tax authorities
• Legitimate interests
  We process data where it is necessary for our legitimate interests and those of our users, provided that your rights and freedoms are not overridden, including:
  • Securing our platforms and preventing abuse, fraud and cheating
  • Improving our services, games, user interfaces and technical performance
  • Protecting the integrity of our gambling operations and enforcing our Terms and Conditions
  • Carrying out internal analytics, reporting and business planning
• Consent
  For certain purposes we rely on your explicit or implied consent, for example:
  • Sending direct marketing communications by email, SMS or push notifications where required by law
  • Using non-essential cookies and similar technologies for analytics and advertising
  • Processing certain sensitive data (such as health-related information you choose to disclose to us in the context of responsible gambling)
  You may withdraw your consent at any time (see "Your Rights"). This will not affect the lawfulness of processing based on consent before its withdrawal.

Purpose of Processing

We process your personal data only for specified, explicit and legitimate purposes. These include:

• Providing and operating our casino services
  • Registering and maintaining your account at syndicatebet-au.com
  • Enabling deposits, bets, games, jackpots and withdrawals
  • Providing multi-currency and crypto payment options through Dama N.V. and Friolion Limited
• Customer support and account administration
  • Handling your queries, complaints and feedback via email and other channels
  • Assisting with account recovery, verification and self-exclusion
  • Notifying you of important changes to our services or policies
• Legal, regulatory and risk management purposes
  • Conducting KYC and AML/CFT checks and transaction monitoring
  • Detecting and preventing fraud, chargebacks, bonus abuse and collusion
  • Complying with applicable laws, regulations, court orders and regulatory requests
• Service improvement and analytics
  • Measuring performance and usability of our websites and games
  • Developing new features and optimizing existing ones
  • Aggregating and anonymising data for statistical and business insights
• Marketing and personalisation
  • Sending promotional offers and bonuses, subject to your preferences and applicable law
  • Customising content, game suggestions and promotions based on your profile
  • Managing affiliate relationships and tracking attribution
• Responsible gambling
  • Monitoring patterns of play that may indicate harmful gambling behaviour
  • Applying limits, cooling-off periods or self-exclusion where requested or required
  • Communicating with you about responsible gambling tools and resources

Disclosure & Sharing

We treat your personal data as confidential and only share it when necessary, subject to appropriate safeguards. We may disclose your data to the following categories of recipients:

• Group companies and affiliates
  • Dama N.V. and its affiliated entities involved in operating Syndicate Casino
  • Friolion Limited and other payment or operational subsidiaries acting on our behalf
• Payment service providers and banks
  • Banks, card schemes and financial institutions processing your deposits and withdrawals
  • Crypto payment processors and exchanges facilitating cryptocurrency transactions
  • E-wallet providers and other alternative payment methods
• Service providers (processors)
  • IT hosting, cloud storage and security providers
  • Customer support tools, CRM systems, KYC/AML verification services and risk scoring providers
  • Email and SMS delivery services, analytics and error monitoring tools
  These third parties process data strictly under our instructions and are contractually obliged to protect your information.
• Regulators, law enforcement and dispute bodies
  • Regulators and authorities in Curaçao and other applicable jurisdictions
  • Australian regulators (including ACMA or other authorities) where we are legally obliged to cooperate
  • Civil courts, arbitrators and dispute resolution bodies when necessary to defend or exercise legal claims
• Advertising and affiliate partners
  • Affiliate networks and partners to measure campaign performance and prevent fraud
  • Advertising partners using cookies or similar technologies for targeted advertising, only where this is permitted by law and, where required, based on your consent
• Corporate transactions
  • Prospective buyers, investors or partners and their advisers in connection with a merger, acquisition, restructuring or sale of business assets
  • In such cases, data sharing will be limited to what is necessary and subject to confidentiality obligations

We do not sell your personal data to third parties for their independent marketing purposes.

International Transfers

Because Syndicate Casino is operated by an offshore company and uses a global infrastructure, your personal data may be transferred to and processed in countries outside your country of residence, including:

• Curaçao - where Dama N.V. is registered and where core gambling operations are managed.
• Cyprus - where Friolion Limited provides payment processing and support services.
• European Economic Area (EEA) and United Kingdom - where some of our hosting, analytics or support providers may be located.
• Other countries - where our carefully selected service providers maintain servers or support centres (including, where applicable, the United States or other third countries).

Some of these countries may have privacy laws that are different from those in your jurisdiction and may not be recognised as providing an "adequate" level of protection (for example, under the GDPR or Mexican law). Where required by applicable law, we implement appropriate safeguards to protect your personal data, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent contractual clauses under UK law
• Contractual obligations requiring recipients to implement robust technical and organisational security measures
• Data minimisation, pseudonymisation and encryption where appropriate

For Australian residents, we take reasonable steps to ensure that overseas recipients do not breach the Australian Privacy Principles (APPs) in relation to your information, although some differences in legal protections may still exist due to the offshore nature of our operations.

Data Retention

We retain your personal data only for as long as necessary for the purposes described in this Policy, or as required by law. Because gambling, financial and anti-money-laundering rules often require extended retention, we apply the following general periods (subject to local legal requirements):

• Account and identification data (KYC)
  • Typically retained for 5 to 7 years after your account is closed or your last transaction, whichever is later, to meet AML/CFT and regulatory obligations and to defend legal claims.
• Transaction and payment records
  • Retained for at least 7 years from the date of the relevant transaction, in line with accounting and anti-fraud requirements.
• Gameplay, bonus and loyalty data
  • Retained for the life of the account and for up to 5 years after closure, subject to AML/regulatory requirements.
• Marketing and communications data
  • Retained for as long as you remain opted-in and for up to 2 years after your last interaction with us, unless you withdraw consent earlier.
• Technical logs and security data
  • Typically kept for 1 to 2 years, unless a longer period is necessary to investigate incidents or fulfil legal obligations.
• Cookies
  • Session cookies expire when you close your browser.
  • Persistent cookies remain on your device for the period indicated in our cookie banner or cookie settings (generally from a few days up to 24 months), unless you delete them sooner.

When data is no longer required, we will securely delete or anonymise it, unless we are legally required or permitted to retain it for a longer period. If you exercise your right to erasure, we may still need to retain certain data where lawfully justified (for example, to comply with AML rules or enforce our Terms).

Your Rights

Your rights depend on your place of residence and the applicable law (for example, the Australian Privacy Act, GDPR for EU/EEA/UK residents, and Mexican data protection laws). Regardless, we aim to respect the following rights for all players, subject to legal limitations:

• Right of access
  • You can request confirmation whether we process your personal data and obtain a copy of your data, together with information about how we use it.
• Right to rectification (correction)
  • You can ask us to correct inaccurate or incomplete personal data. In many cases you can update certain details directly in your account profile.
• Right to erasure ("right to be forgotten")
  • You can request deletion of your personal data where it is no longer necessary, where you have withdrawn consent (if consent was the basis), or where processing is unlawful.
  • We may not be able to erase data that we must keep for legal, regulatory, anti-fraud or AML reasons.
• Right to restriction of processing
  • You can ask us to temporarily restrict processing in certain cases (for example, while we verify the accuracy of data or assess an objection).
• Right to object
  • You can object to processing based on our legitimate interests, including profiling, on grounds relating to your particular situation.
  • You always have the right to object to direct marketing and profiling related to such marketing.
• Right to data portability (GDPR/Mexican/EU/UK residents, where applicable)
  • You may request certain personal data in a structured, commonly used and machine-readable format and ask us to transmit it to another controller where technically feasible.
• Right to withdraw consent
  • Where processing is based on your consent, you may withdraw it at any time (for example, by changing your marketing preferences or cookie choices).
  • Withdrawal does not affect prior lawful processing.
• Rights under Australian Privacy Act
  • Australian residents also have rights to access and correction under the Australian Privacy Principles, and to complain to the Office of the Australian Information Commissioner (see "Complaints & Contacts").
• Rights under Mexican privacy law
  • México-based users may have ARCO rights (Acceso, Rectificación, Cancelación y Oposición) under the Federal Law on Protection of Personal Data Held by Private Parties and may contact the relevant Mexican data protection authority (INAI) if unsatisfied.

How to exercise your rights

1. Submit a request: Contact us at [email protected] or [email protected], clearly stating that your message concerns a "Data Subject Request" or "Privacy Request".
2. Provide necessary information: Include your full name, username, registered email, country of residence, and a clear description of the right you wish to exercise.
3. Verification: To protect your privacy, we may ask you to provide additional information or documentation to verify your identity before acting on your request.
4. Response time: We aim to respond within 30 days of receiving a complete request. If your request is complex or we receive multiple requests, we may extend this period, but we will inform you and explain the reason.
5. Fees: We generally handle requests free of charge. However, where permitted by law, we may charge a reasonable fee or refuse to act on manifestly unfounded or excessive requests.

Cookies & Tracking Technologies

We use cookies and similar technologies to ensure the proper operation of our websites, enhance your user experience, perform analytics and deliver relevant marketing. Cookies are small text files placed on your device when you visit our websites.

Types of cookies we use

• Strictly necessary (session) cookies
  • Essential for the operation of the site and your player account (e.g. keeping you logged in, processing bets, maintaining security).
  • Without these cookies, the site or certain features may not function properly.
• Functional (persistent) cookies
  • Remember your preferences (language, region, display settings, cookie choices).
  • Help us provide a more personalised and consistent experience.
• Analytics and performance cookies
  • Collect aggregated information about how visitors use our sites (pages visited, errors encountered, time spent).
  • Used to improve site performance and usability; typically set by us or by trusted analytics providers.
• Advertising and affiliate cookies
  • Track your interaction with our ads and affiliate links, so that we can measure campaign effectiveness and prevent fraud.
  • In some cases, may be used to deliver more relevant advertising, subject to your consent where required by law.

Managing cookies

• Browser settings: Most browsers allow you to block or delete cookies through their settings. However, blocking essential cookies may impact your ability to log in or place bets.
• On-site tools: Where available, you can manage non-essential cookies via our cookie banner or internal settings panel on syndicatebet-au.com.
• Third-party opt-out: For some third-party analytics or advertising cookies, you may also opt out directly via the provider's own tools.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. While no system can be guaranteed 100% secure, we continually improve our defences and follow industry best practices.

Technical measures

• Encryption in transit: Data transmitted between your browser and our servers is protected using TLS (Transport Layer Security) version 1.2 or higher.
• Encryption at rest: Where appropriate, sensitive data (such as passwords and certain financial details) are stored in encrypted or hashed form.
• Access controls: Access to personal data is restricted to authorised personnel who require it for their duties, using role-based access control and logging.
• Network and infrastructure security: Firewalls, intrusion detection/prevention systems, anti-malware solutions and regular patch management help protect our infrastructure.
• Backup and recovery: Regular backups and tested recovery procedures help ensure continuity and data integrity.

Organisational measures

• Policies and training: Staff who handle personal data receive training on data protection, confidentiality and security, and are bound by contractual confidentiality obligations.
• Vendor due diligence: We carefully select service providers and require them to implement appropriate security standards. We review their practices periodically.
• Risk assessments and audits: We conduct internal reviews and, where applicable, external assessments of our security controls. Our approach is aligned with widely recognised standards such as ISO 27001 and SOC 2, although this does not imply formal certification unless expressly stated on our site.
• Incident response: We maintain procedures to detect, respond to and investigate potential data breaches or security incidents. Where required by law, we will notify you and relevant authorities of a qualifying breach without undue delay.

Complaints & Contacts

If you have questions, concerns or complaints about how we handle your personal data, or if you wish to exercise your rights, you can use the following contact channels:

Contacting us

• Email (primary for support and privacy): [email protected]
• Email (general information / legal notices): [email protected]
• Website: https://syndicatebet-au.com
• When writing, please clearly describe your issue and indicate that it relates to "Privacy" or "Data Protection".

Internal complaint procedure

1. Step 1 - Contact support: Raise your concern with our support team via email. Most issues can be resolved quickly at this level.
2. Step 2 - Escalation to Data Protection Officer / Team: If you are not satisfied with the initial response, ask for your matter to be escalated to our Data Protection Officer or Data Protection Team. They will review your complaint in detail.
3. Step 3 - Our response: We aim to respond to privacy-related complaints within 30 days. If we need more time due to complexity, we will inform you of the delay and provide an estimated timeframe.

External supervisory authorities

If you believe that we have not handled your complaint appropriately, or you wish to seek further guidance, you may have the right to contact a supervisory authority, depending on your place of residence:

• Australia - Office of the Australian Information Commissioner (OAIC)
  • Website: https://www.oaic.gov.au
  • Phone (Australia): 1300 363 992
  • Online complaint forms are available on the OAIC website.
• European Union / EEA / UK - Data Protection Authorities
  • You may contact your local data protection authority. Contact details are available via the European Data Protection Board (EDPB) website: https://edpb.europa.eu.
• Mexico - National Institute for Transparency, Access to Information and Personal Data Protection (INAI)
  • Website: https://home.inai.org.mx
  • INAI provides guidance and complaint mechanisms for individuals whose data is processed under Mexican law.

Because Syndicate Casino is operated by an offshore entity, local enforcement options may be limited. Nevertheless, we encourage you to contact us first so we can address your concerns directly.

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements or other factors. When we make material changes, we will take appropriate steps to inform you.

How we will notify you

• Publishing the updated Privacy Policy on syndicatebet-au.com, with a revised "Last updated" date.
• Displaying banners or notices on our website or within your account dashboard.
• Sending email notifications to the email address associated with your account, particularly where changes are significant or where required by law.

Effective date and advance notice

• Unless otherwise stated, updates take effect when the revised Policy is posted on our website.
• For changes that materially affect your rights or our use of your data (for example, new processing purposes or new categories of recipients), we will provide at least 30 days' advance notice, where reasonably possible.
• If you do not agree with the updated Policy, you may close your account and stop using our services before the changes take effect. Continued use after the effective date will constitute your acceptance of the updated Policy.

Version control:
Current version: Privacy Policy for Syndicate Casino (syndicatebet-au.com)
Last updated: February 2026

Previous versions of this Privacy Policy may be made available upon request to help you understand how our practices have evolved over time.